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The Institute for Policy Integrity asserts that the EPA's authority to set greenhouse gas emission standards for power plants is legally sound because the source category was listed in the 1970s. The document contends that power sector emissions meet any reasonable threshold for 'significant contribution' to air pollution, consistent with the EPA's fifty-year historical practice of assessing pollution contributions.

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  • Under Section 111 of the Clean Air Act, the EPA is only required to determine if a source category contributes significantly to air pollution at the time of its initial listing; it is not required to make a new finding when establishing new performance standards for a category already on the list.
  • The EPA did not need a pollutant-specific significant contribution finding for greenhouse gas emissions from fossil-fuel-fired power plants because the category was listed and the required findings were made in the 1970s.
  • Power sector emissions meet the criteria for 'significant contribution' to climate change based on the EPA's historical approach over the last fifty years, which considers total pollution quantity and the share of nation- or sector-wide emissions.

Cite the original document

APA
Adler, K. W. D. (2025). Significant by Any Measure. Institute for Policy Integrity. https://policyintegrity.org/publications/detail/significant-by-any-measure
Chicago
Adler, Kate Welty, Dena. Significant by Any Measure. Institute for Policy Integrity, 2025. https://policyintegrity.org/publications/detail/significant-by-any-measure.
Wikipedia
{{cite press release |last1=Adler |first1=Kate Welty, Dena |title=Significant by Any Measure |publisher=Institute for Policy Integrity |date=27 May 2025 |url=https://policyintegrity.org/publications/detail/significant-by-any-measure |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{adler2025significant, author = {Adler, Kate Welty, Dena}, title = {{Significant by Any Measure}}, publisher = {Institute for Policy Integrity}, year = {2025}, month = may, url = {https://policyintegrity.org/publications/detail/significant-by-any-measure}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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