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The summer of 2025 has seen the U.S. Environmental Protection Agency (EPA) implement a significant shift in U.S. federal climate policy envisioned by the Trump Administration.

First, on June 17, 2025, EPA proposed a rule, entitled Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units, which would repeal Obama and Biden era Greenhouse Gas (GHG) emissions standards for fossil fuel-fired power plants. This rule proposed three key determinations:

  • EPA proposes a reinterpretation of Section 111 of the Clean Air Act (CAA) that would require a “significant contribution finding.” As a predicate to regulation, EPA must first find that GHG emissions from fossil fuel-fired power plants contribute significantly to regulated air pollution.
  • EPA proposes to find that fossil fuel-fired power plants do not contribute significantly to the broader aggregation of GHG emissions in the atmosphere.
  • With no “significant contribution finding,” the proposed rule would thereby repeal:
    • The Obama Administration’s 2015 New Source Performance Standards (NSPS) (40 CFR part 60, subpart TTTT) (Adopted as part of Clean Power Plan).
    • The Biden Administration’s 2024 Carbon Pollution Standards (40 CFR part 60, subparts TTTTa and UUUUb).
    • Connect: https://www.squirepattonboggs.com/en/professionals/c/cox-michael
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