Dear Administrator Regan:

Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA’s) proposal regarding new source performance standards (NSPS) for greenhouse gas (GHG) emissions from new and reconstructed electric generating units (EGUs).

The Cato Institute is a public policy research organization dedicated to the principles of individual liberty, limited government, free markets, and peace. At Cato, I am the Director of Energy and Environmental Policy Studies, and my research focuses on the economics and reliability of electricity, the role of free markets in improving the availability and affordability of energy and natural resources, and environmental regulations that impact the energy sector.

I commend you for your efforts to better understand the impacts of the EPA’s power plant regulations on grid reliability.

Procedural Background
The EPA issued the original notice of proposed rulemaking (Original NPRM) in this docket on May 23, 2023, with comments due on or before August 8, 2023. The EPA then issued a supplemental notice of proposed rule-making (Supplemental NPRM) published in the Federal Register on November 20, 2023, with comments due on or before December 20, 2023. The Supplemental NPRM solicited comments on (1) reliability issues associated with the Original NPRM and (2) EPA’s Initial Regulatory Flexibility Analysis (IRFA), which EPA undertook after publishing the Original NPRM.