This report presents the emissions and cost results of a series of variant cases run in the FACETS energy system model to assess alternatives to EPA’s proposed repeal of the Carbon Pollution Standards (CPS). FACETS—a detailed, technologically-realistic model of the U.S. energy system—-models individual power plants and their dispatch, retrofit, and retirement options, as well as new builds, under projections for future power demand, fuel prices, technology options, and policies. This modeling showed generally that, although EPA analyzed no scenario other than simply repealing the CPS, alternative approaches such as extending compliance timelines or reducing the stringency of the standards could achieve emission reductions at lower cost than the CPS.
This resource was commissioned by or produced by staff of the Center for Applied Environmental Law and Policy before the organization rebranded as Ridgeline Center for Law and Policy in 2026.