FACT SHEET
Proposed Affordable Clean Energy Rule -
Comparison of ACE and CPP
CPP	ACE Rule
CO2 emissions The ACE Rule continues downward C02 trend, pushing power sector C02
emissions to around 34% below 2005 levels (similar to CPP).
EPA's policy role
Expansive program to regulate
entire energy sector
Inserted EPA into energy policy
Reshaped the grid and energy
markets
Reasonable program focused on
potential upgrades to coal plants
Keeps EPA focused on
environmental policy
Leaves the market alone and doesn't
pick winners and losers
Coal impacts
Shut down coal
Keeps coal plants open and makes
them more efficient
Reliability and Promoted disinvestment in coal in
energy mix	favor of renewables and natural gas
Promotes investments to make coal
plants cleaner, modern and more
efficient
Relied on fuel switching
No fuel switching
Federal and state
roles
Set a single federal standard and
forced states to adopt it
Lets states set their own standards
that meet federal guideline
consistent with current law
State plans and
deadlines
Included detailed requirements for
state plans
Includes flexible guidelines for states
to evaluate potential for energy
efficiency
Required states to report to EPA up
to 6 times over 15 years, starting 1
year after final rule
States may only need to make 1
submission to EPA, and 3 years after
final rule
New Source	No changes to NSR permitting
Review permitting requirements, deterring energy
efficiency upgrades at coal plants
Targeted updates to NSR so coal
plants can improve efficiency and
modernize
Retained annual test in NSR,
meaning efficiency upgrades would
likely trigger more requirements
Proposes initial hourly trigger for
NSR, meaning efficiency projects
won't trigger additional
requirements
FOR MORE INFORMATION
https://www.epa.gov/stationarv-sources-air-pollution/proposal-affordable-clean-energy-ace-rule

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