A Letter.pdf

The Environmental Protection Agency (EPA) published proposed Greenhouse Gas (GHG) Standards and Guidelines for Fossil Fuel-Fired Power Plants, known as the Clean Power Plan 2.0 (CPP2.0) Proposal, in May 2023. The proposal suggests using Carbon Capture Utilization and Storage (CCUS) as a main form of compliance, but concerns have been raised about the lack of CCUS infrastructure and the feasibility of meeting proposed requirements. The CPP2.0 Proposal aims to transform the nation's electric generation, causing utility service to be less reliable and more expensive, and exceeds the limited authority Congress granted EPA under Clean Air Act Section 111. Recent decisions to cancel or delay CO2 pipeline projects have heightened concerns about the integrity of the EPA's rulemaking process. The EPA's analysis has been questioned, including its claim that a CO2 pipeline network can be built from 5,000 miles to 25,000 miles in a short timeframe, and its reliance on misleading data. The proposal's defects, including inaccurate discussions about CO2 pipelines and concerns about the accuracy of the EPA's claims, have led to requests for the EPA to withdraw the CPP2.0 Proposal and provide information about its rule development process.