August 07, 2025

EPA’s Greenhouse Gas Rollbacks Ignore Its Own Findings

ELPC challenges EPA repeal of power plant greenhouse gas emissions standards

By Brian Lynk, Senior Attorney

On August 7, ELPC ramped up its fight against the Trump administration’s dangerous rollbacks of critical air pollution and climate protections. Senior Attorney Brian Lynk and Associate Attorney Callie Sharp submitted formal comments to the U.S. Environmental Protection Agency (EPA), opposing the agency’s proposed repeal of greenhouse gas (GHG) emissions standards for fossil fuel-fired power plants. EPA’s proposal starkly rejects decades of scientific consensus, and its own long-standing findings.

In its proposal, EPA argues that U.S. fossil fuel-fired electricity generation “does not contribute significantly” to harmful GHG pollution, despite U.S. power sector emissions amounting to 3% of global GHG emissions. This claim is scientifically inaccurate and legally indefensible.

Since 2009, the EPA has repeatedly reaffirmed, based on strengthening scientific evidence, that greenhouse gas pollution from power plants poses a threat to public well-being and warrants regulation.

READ THE COMMENTS

The power sector is one of the largest sources of climate pollution in the United States, driving serious harms to public health, the environment, and the economy. In 2023 alone, U.S. domestic power plants emitted more carbon pollution than nearly every country on Earth, resulting in over $290 billion in climate-related damages.

The Midwest is especially vulnerable. Home to many of the nation’s remaining fossil fuel-fired power plants, the region faces outsized risks from local air pollution and broader climate impacts including extreme heat, tornadoes, flooding, and derechos. As such, the Midwest bears a large burden of climate and health consequences, making strong federal protections absolutely critical.

Highlights from ELPC’s Comments to EPA

• The U.S. power sector is a major global polluter: In 2023, fossil fuel-fired power plants in the U.S. emitted 1.4 billion metric tons of CO₂ — more than the total annual GHG emissions of nearly every other country on Earth.
• The economic damages are significant: These emissions caused an estimated $290 billion in climate-related damages — more than the entire GDP of over three-quarters of the world’s countries.
• EPA’s argument is flawed and unlawful: The agency’s claim that power plants do not “contribute significantly” to climate change directly contradicts its own previous findings, disregards overwhelming evidence, and applies a legal standard already rejected by the courts.
• Climate change threatens public health: The 2023 National Climate Assessment links rising temperatures to increases in cardiovascular and respiratory disease, kidney failure, diabetes, and poor pregnancy outcomes. Even small increases in temperature can lead to life-threatening consequences. For every 0.1°C of warming above present levels, about 140 million more people globally will be exposed to dangerous heat.
• EPA has repeatedly affirmed the danger of GHGs: Since its 2009 Endangerment Finding, EPA has repeatedly affirmed that GHGs endanger public health and welfare, that power plants are a major source of these emissions, and that GHG emissions from power plants should be regulated.
• Scientific consensus is stronger than ever: From record-setting global temperatures to accelerating sea level rise, the science is clear and increasingly urgent. EPA itself has acknowledged that no other body of research matches the depth, rigor, or international consensus of the climate science informing its standards.

Brian Lynk,

Senior Attorney

Brian Lynk is a Senior Attorney at ELPC's Washington, DC office, focused on protecting clean air and great places in the Midwest from rollbacks of federal environmental protections.

MORE FROM Brian Lynk