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The Clean Air Task Force criticizes the EPA's Affordable Clean Energy (ACE) rule for repealing the Clean Power Plan (CPP) and replacing it with a system focused on minor heat rate improvements for coal plants. The author contends that this approach ignores the existing trend of shifting toward cleaner energy sources and will lead to increased CO2 emissions and public health risks, including premature deaths. The document asserts that the ACE rule fails to employ the "best system of emission reduction" required by the Clean Air Act and announces plans to challenge the rule in the D.C. Circuit Court of Appeals.

The Clean Air Task Force (CATF) criticizes the EPA's Affordable Clean Energy (ACE) rule, characterizing it as a "life-extension program for coal plants" that replaces the Clean Power Plan. CATF asserts that the ACE rule will increase carbon emissions and cause over 1,600 annual deaths by 2030 compared to the Clean Power Plan, while benefiting the coal industry at the expense of public health and the environment. Consequently, CATF intends to legally challenge the rule.

The Clean Air Task Force (CATF) supports the Clean Energy Standard Act of 2019, which aims for the decarbonization of the U.S. electric power sector by mid-century. The legislation is described as technology-inclusive, supporting carbon capture and storage, nuclear energy, hydroelectric generation, and renewables. It proposes incentives for always-available zero-carbon electricity via a credit multiplier and a new Department of Energy RDD&D program. CATF notes that this federal effort aligns with existing state-level legislation in California, New Mexico, Nevada, and Washington, as well as targets set by major utilities covering 37.9% of US electricity sales.

The document details a transition in U.S. energy policy from renewable portfolio standards to Clean Electricity Standards (CES), which allow for a diverse range of zero-carbon technologies, including nuclear and carbon capture. It provides a comprehensive list of states and utility companies that have enacted or pledged 80-100% carbon-free electricity targets, noting that these commitments collectively cover approximately 38% of U.S. electricity sales and 31% of national utility CO2 emissions.

The Clean Air Task Force supports the Enhancing Fossil Fuel Energy Carbon Technology Act, which proposes four new programs for the research, development, and demonstration of transformational CCUS technologies for industrial sources and coal- and gas-fueled power. The organization argues that such investments are essential for cost reduction and complement the 45Q tax credit.

The Clean Air Task Force supports the USE IT Act as a critical tool for developing a diversified portfolio of low-carbon technologies. The testimony emphasizes that meeting global temperature targets requires not only emission reductions but also negative emissions, which can be achieved through carbon capture utilization and storage (CCUS) and direct air capture (DAC). The author argues that the USE IT Act will catalyze innovation through prize competitions and facilitate the expansion of the US CO2 pipeline network, which currently stands at 4,500 miles but may need to reach 66,000 miles to support large-scale deployment.

Jay Duffy of the Clean Air Task Force testifies that the EPA's proposed increase of the CO2 emission rate for new coal plants to 1,900-2,200 lbs. CO2/MWh-g is unsupported by technology and science. He argues that carbon capture and sequestration (CCS) is more cost-effective and available than in 2015, citing projects like Petra Nova and Boundary Dam and the expanded 45Q tax credit. Duffy claims the proposed weaker standards would allow a single 600 MW plant to emit 1.1 million additional tons of CO2 and 500 additional tons of SO2 annually, offsetting gains from other EPA proposals.

The Clean Air Task Force supports the Green New Deal's goal of net zero greenhouse gas emissions, emphasizing that deep decarbonization requires a diverse portfolio of technologies, including renewables, nuclear power, and carbon capture and storage.

The report finds that the 45Q tax credit could lead to the annual capture and storage of approximately 49 million metric tonnes of CO2 by 2030 in the U.S. power sector, primarily through retrofits on coal and natural gas combined cycle (NGCC) plants. This deployment is found to be complementary to renewable energy growth and could meet two-thirds of the 2030 U.S. power sector goal set by the International Energy Agency (IEA) to limit global temperature rise to 2 degrees Celsius. The analysis emphasizes that the economics of the 45Q credit make enhanced oil recovery (EOR) more favorable than saline storage, necessitating rapid infrastructure development to realize the credit's full potential.

The document argues that Alberta's proposed methane regulations are weaker than federal rules and will fail to meet the province's 2014 pledge to reduce oil and gas emissions by 45% by 2025.

The Clean Air Task Force endorses Xcel Energy's target of zero-carbon electricity by 2050, stating that such goals are necessary to manage climate change and that the power grid must lead the effort to eliminate carbon emissions by mid-century.

The document reports a significant increase in hazardous toxic air pollution and cancer risks in Pennsylvania linked to the oil and gas industry between 2011 and 2014, highlighting the vulnerability of over 1.6 million residents and 300,000 students living near operations.

The report advocates for the development and deployment of zero-carbon hydrogen and ammonia to address sectors that are difficult to electrify. It details production methods such as steam methane reforming with carbon capture and storage (SMR+CCS) and electrolysis, while highlighting the scalability of ammonia due to existing global infrastructure. The document examines applications in heavy-duty transport, marine shipping, and grid-balancing, and calls for coordinated public-private initiatives to manage safety risks and establish supportive policy frameworks.

The author contends that a 100 percent renewable energy pathway to decarbonization is risky because it depends on the simultaneous success of multiple uncertain elements, including wind and solar scaling, transmission grid expansion, seasonal storage, load management, and public funding. Using a probabilistic example, the text illustrates that if five essential elements each have a 90% chance of success, the cumulative probability of success drops to 59%. The document proposes 'de-risking' the energy transition by pursuing multiple independent technology paths in parallel, which mathematically increases the overall likelihood of achieving full decarbonization.

The Clean Air Task Force (CATF) criticizes the EPA's 2019 Renewable Fuel Standard (RFS) for prioritizing corn ethanol and soy biodiesel over cellulosic biofuels. While Congress intended cellulosic biofuels to comprise nearly one-third of the 2019 mandate, they account for only 2%. CATF asserts that the reliance on first-generation biofuels drives deforestation in Southeast Asia and Latin America and calls for Congressional intervention to fix the policy.

The Clean Air Task Force supports a Union of Concerned Scientists report highlighting that existing nuclear plants provide approximately 60 percent of the United States' carbon-free electricity and serve as a foundation for future nuclear expansion using modern technology.

The Clean Air Task Force criticizes the Trump EPA's plan to revise the Mercury and Air Toxics Standards (MATS), asserting that the administration is intentionally ignoring the vast health benefits of the rule—such as 11,000 fewer premature deaths annually—to justify a rollback. The author contends that by limiting the benefit-cost analysis to mercury alone, the EPA is abandoning established regulatory principles to serve the interests of private coal company owners, despite the rule's high cost-effectiveness and the opposition of the utility industry that has already implemented the controls.

The author criticizes the EPA for moving to undermine the Mercury and Air Toxics Standards (MATS), which reduce mercury and other air toxics from coal- and oil-fired power plants. The document highlights that MATS prevents 11,000 premature deaths and 130,000 asthma hospitalizations annually, noting that the EPA is using the benefits of MATS in its modeling to justify other rule rollbacks, such as the ACER rule, while simultaneously seeking to weaken MATS itself.

The author contends that allowing year-round E15 sales is unlawful under the Clean Air Act and would increase the production of environmentally damaging corn ethanol. The document highlights risks to air quality via ozone formation and the failure of the Renewable Fuel Standard to deliver projected advanced biofuel benefits.

The Clean Air Task Force (CATF) condemns the rollback of the BLM Methane Waste Rule, noting that the rule previously reduced annual methane emissions by 175,000-180,000 tons. CATF asserts that the rollback will cost taxpayers millions of dollars due to wasted natural gas and increased air pollution, while threatening the health of tens of thousands of people living near oil and gas wells on public lands.