未来能源研究所-关于废除化石燃料发电机组温室气体排放标准的评论（英）-2025.8_28页_1022kb

Summary of EPA Repeal Analysis Comments

The article comments on the EPA's proposed repeal of greenhouse gas emissions standards for fossil fuel-fired electric generating units, highlighting several key issues:

• Significance Threshold Conflict: The EPA's assertion that the power sector's emissions do not meet significance thresholds—a 3% global share and a $100 million economic impact—is inconsistent with established federal guidelines and previous EPA findings. Economic monetization shows that even low-value estimations exceed the threshold, with potential costs ranging from $19 billion to over $436 billion annually in present value terms.

• Inadequate Economic Analysis: The EPA's benefit-cost analysis excludes or minimizes ancillary costs, such as increased local air pollution leading to premature deaths and health damages, using an outdated approach. The analysis focuses only on avoided compliance costs ($19 billion), ignoring co-benefits and climate damages, which alone outweigh these savings by several folds under various SCC estimates.

• Emissions and Health Impacts: Repealing the standards leads to substantial increases in CO2, SO2, and NOx emissions, causing projected cumulative emissions rises of 1.2-5.8 gigatons by 2050. This results in significant health damages due to increased fine particulate matter and ozone-related illnesses, estimated at $157-$476 billion annually, far exceeding compliance cost savings.

• Electricity Price and Demand Uncertainty: Models show the repeal, combined with the OBBBA, could increase average electricity prices by 2.1-3.3 percent annually, raising household costs by $67-$97 per year. Higher electricity demand projections and reduced renewable deployment under OBBBA exacerbate prices and increase reliance on volatile fossil fuels.

• Overall Net Losses: Comprehensive analysis indicates that the repeal imposes net losses on society, with costs ranging from $128.9 billion to over $855 billion across sensitivities, dwarfing EPA's estimated savings. Even when excluding climate costs, health damages alone surpass avoided compliance costs, making the repeal net costly under all considered scenarios.

The authors recommend conducting accurate benefit-cost analyses that account for full economic and environmental impacts to ensure sound policy outcomes.