PRK for Repeal of Greenhouse Gas (GHG) Emissions Standards for Fossil Fuel-Fired Electric Generating Units

This proposal will impact Tribes for many reasons.  First many of the fossil fuel fired power plants are on or near Indian communities.  By its own recognition, the repeal of these rules will cause an increase in emissions not only of the GHG but other air pollutants such as Particulate Matter, Sulfur Dioxides, Mercury and other Hazardous Air Pollutants (HAPs).  By EPA’s own estimates, included in the Regulatory Impact Analysis, this proposal will result in, a net disbenefits of the proposed rule from 2026 to 2047 to be $ −110 billion at a three percent discount rate, or roughly $ −6.8 billion per year even disregarding the benefits of the reduction in GHG.  This proposal ignores the increase harm from the increase in emissions and because many of these sources are on or near Indian Country. Tribes may disproportionately feel the effects of the anticipated, hundreds of deaths and billions of dollars in public health cost that will result from the emissions increases.

How to Comment on the Rule:

Comments are accepted via https://www.regulations.gov/ or by email: a-and-r-docket@epa.gov, Attn. Docket ID No. EPA-HQ-OAR- EPA-HQ-OAR-2025-0124

Comments are due on August 7, 2025.

  1. NTAA Tribal Template Letter – A template word document that includes NTAA’s comments that can be uses by Tribes to submit to the EPA.
  2. NTAA Fact Sheet – A fact sheet that can be used by Tribes to inform community members and leadership regarding this proposal.