American Experiment’s Comments on the Environmental Protection Agency’s Carbon Rule

Center of the American Experiment’s Isaac Orr and Mitch Rolling submitted comments on the Environmental Protection Agency (EPA)’s Carbon Rule on August 8, 2023.

Preview:

American Experiment modeled the resource adequacy, reliability, and cost of EPA’s proposed Section 111 rules. We determined that EPA’s modeled MISO grid under the rules would not meet resource adequacy or reliability, and reliably meeting EPA’s emissions targets would cost MISO ratepayers an additional $246 billion compared to EPA’s assumed grid.

EPA is attempting to transform the entire U.S. electric grid using a process that is less rigorous and less transparent than a state integrated resource plan. More time and transparency is needed to thoroughly evaluate the impact of the proposed Section 111 rules in the entire country.

A full copy of the comments can be viewed here.

You can also view American Experiment’s “Analysis of EPA’s Proposed Carbon Rules One-Pager” here.