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EPA finished repealing most of the 2024 power plant carbon rules and, the same day and in the same docket, proposed erasing the rest. One of those is closed to you. The other closes November 2.

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The Federal Register issue dated September 17 carries two EPA documents with one docket number between them. The first is a final rule: it repeals most of the 2024 Carbon Pollution Standards for power plants, takes effect November 16, and the agency says it is not reopening it. The second is a supplemental proposal arguing that the Clean Air Act does not authorize EPA to regulate power plant emissions for climate reasons at all — which would rescind the 2015 findings and repeal every remaining greenhouse gas standard for the source category. Comments on the second close November 2; a virtual hearing is October 1; the last day to register to speak is September 29, and each speaker gets four minutes. EPA puts the compliance cost savings of the finished repeal at $160 billion present value at a 3% discount rate and $95 billion at 7%, and states in the same table that it has not monetized the health and welfare impacts of the emission changes.

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Two documents. One docket number. They were filed on the same day, they are about the same rules, and they are at completely different stages — which means only one of them is still open to anyone outside the agency.

If you read one headline about this, you probably read about the first one. The second one is the one with a deadline on it.

Document one: finished

Partial Repeal of the Carbon Pollution Standards for Fossil Fuel-Fired Electric Generating Units (FR Doc. 2026-19071) is a final rule. Its action line says so in one word: "ACTION: Final rule."

What it does, in its own summary: EPA "is repealing most provisions of the 2024 Carbon Pollution Standards for greenhouse gas (GHG) emissions from fossil fuel- fired electric generating units (EGUs) based on a reevaluation of the best system of emission reduction for the relevant subcategories."

Specifically, three things go:

  • the emission guidelines for existing fossil fuel-fired steam generating units;
  • the carbon-capture-based standards for coal-fired steam units undertaking a large modification;
  • the carbon-capture-based standards for new base load stationary combustion turbines — the Phase 2 standards.

"This final rule is effective on November 16, 2026."

That is the whole public clock on document one. There is no comment period, because the comment period was in 2025. It is done.

Document two: open until November 2

Rescission of the Greenhouse Gas Findings for Fossil Fuel-Fired Power Plants and Repeal of Regulations for Power Plant Greenhouse Gas Emissions Under Clean Air Act Section 111 (FR Doc. 2026-19072) is a supplemental notice of proposed rulemaking, published in the same issue, forty-six pages later, under the same docket ID.

Its argument is not about capture rates or co-firing percentages. It is about authority: "We propose that CAA section 111 does not authorize the EPA to regulate emissions from power plants in response to global climate change concerns."

If finalized, the notice says, that reasoning "would also require rescinding the Administrator's contrary findings and determinations in 2015 and repealing all associated 2015 and 2024 GHG standards for the fossil fuel-fired EGU source category."

The two documents are explicitly fenced off from one another. Document two states: "In a separate action published concurrently with this supplemental notice, the EPA is finalizing the repeal of certain 2024 GHG standards for the fossil fuel-fired EGU source category on distinct legal and technical grounds. We are not reopening that final rule."

What has a date on it:

What When
Comments due November 2, 2026
Paperwork Reduction Act comments to OMB October 19, 2026
Virtual public hearing October 1, 2026
Last day to pre-register to speak September 29, 2026

Each speaker gets four minutes. The notice says so: "Each commenter will have 4 minutes to provide oral testimony." Written comments are not worth less for being written — "Written statements and supporting information submitted during the comment period will be considered with the same weight as oral testimony and supporting information presented at the public hearing."

Registration runs through EPA's greenhouse gas standards page for fossil fuel-fired power plants, or the hearing team at (888) 372-8699. Comments go to regulations.gov under Docket ID No. EPA-HQ-OAR-2025-0124 — the same docket that carries the finished rule.

The money, and what is not in it

EPA puts the savings of the finished repeal like this: over 2026 to 2047, the present value of estimated compliance cost savings for the power sector is "$160 billion using a three percent discount rate and $95 billion using a seven percent discount rate," in 2024 dollars discounted to 2025. Real resource cost savings — the full avoided spend on physical and labor inputs — are put at $280 billion and $180 billion on the same two rates. An economy-wide model (SAGE) puts social cost savings at roughly $310 billion.

Under the table carrying the first pair of numbers, EPA prints its own caveat:

Note: For the reasons the EPA describes in section 4 of the RIA, the Agency has not monetized several impact categories, including the potential health and welfare impacts of changes in emissions. Therefore, this table does not include those impact categories.

So the $160 billion is a savings figure with the health side of the ledger deliberately left blank, and the document says so on the same page.

What EPA says about the emissions it is giving up

The final rule summarizes a comment that the standards being repealed "would reduce CO2 emissions by 1.38 billion metric tons over roughly two decades" — that is a commenter's number, as EPA characterizes it, not EPA's projection.

EPA does not dispute that something is forgone. It writes: "The EPA also recognizes that this action to repeal requirements of the 2024 CPS forgoes the CO2 emission reductions that were projected to be achieved under the 2024 CPS."

Its answer is that the reductions could not count, because the control strategies were disqualified first: 90 percent carbon capture "is not adequately demonstrated," and 40 percent natural gas co-firing is "impermissible generation shifting." On co-pollutants — particulate matter, sulfur dioxide, nitrogen oxides — EPA says that even if it counted them, "the Agency would determine that the costs and energy impacts of the controls should be weighted more heavily than those forgone reductions."

Why the pairing matters

A final rule and a proposal published together look, from outside, like one event. They are not. The final rule has already absorbed everything the public had to say; the proposal has not heard from anyone yet. If you have something to put on the record about whether the Clean Air Act reaches power plant carbon at all, document two is the only one of the two that can still receive it, and it stops receiving on November 2.

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