On August 21, 2018, the Trump administration issued a proposal to replace the Clean Power Plan (CPP), which broadly covered carbon dioxide (CO2) emissions from the entire existing generation fleet, with the Affordable Clean Energy (ACE) rule that features more narrowly-focused guidelines for improving efficiency at existing coal plants. Depending on how states would use their discretion under the proposed rule to set emission standards for specific coal plants, the ACE rule may marginally increase the efficiency of coal plants but will not likely have significant impacts on industry-wide emissions. ACE also changes the New Source Review (NSR) process for plant efficiency projects so that those projects would unlikely be considered a “major modification” that triggers major NSR permitting requirements.

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