Power Plant Carbon Standards

Policy Engagement Overview

InfluenceMap's database covers roughly 1,000 companies and 300 industry associations globally, with the most engaged entities scanned on a weekly basis and all entities assessed at least every other quarter. The current state of corporate engagement on this regulation is summarized below. The graph to the right indicates InfluenceMap's capture of corporate positions on the regulation, ranging from strong opposition to strong support. Both this page and the graph were last updated on August 15, 2025.

As cautioned by InfluenceMap’s April 2023 briefing, many of the same utilities that opposed the Obama administration’s Clean Power Plan strongly opposed the Biden administration’s power plant carbon standards. InfluenceMap evidence shows particularly strong opposition from certain utilities and their industry groups, with a notable absence of advocacy from generally positive companies. This positioning has continued into the Trump administration, which has proposed a repeal of “all greenhouse gas (GHG) emissions standards for fossil fuel-fired power plants.”

Engagement on the Trump Administration's Proposed Repeal

InfluenceMap observed the following engagement trends during the Trump Administration’s proposed repeal comment period:

• The utility sector maintained negative positioning on power sector regulation. Edison Electric Institute (EEI) and members including FirstEnergy and PPL Corp advocated for the proposed repeal of the carbon capture compliance pathways, supporting Trump EPA’s proposed finding that they were neither ”adequately demonstrated” nor “achievable.” EEI in particular questioned the legality of the compliance pathway as well as the staggered nature of the carbon standards, and called for the EPA to facilitate the buildout of new gas-fired generation.

• The Midwest Ozone Group (MOG) endorsed the finding that regulation of fossil fuel power plants would not have a “significant” effect on GHG emissions. In its comments, MOG supported the Trump administration’s proposed finding that fossil fuel-fired power plants are not “significant contributors” of GHG emissions. Listed members in MOG’s comments include utilities Ameren, American Electric Power, Berkshire Hathaway, and Duke Energy as well as subsidiaries of FirstEnergy and PPL Corp; oil & gas companies including ExxonMobil and Marathon Petroleum; and industry groups including American Iron and Steel Institute and Steel Manufacturers Association.

• Cross-sector industry groups advocated for deregulation. Several industry associations that continue to demonstrate misaligned positions on climate, including the US Chamber of Commerce and National Association of Manufacturers, advocated for the repeal of the standards.

Responses to the Biden Administration’s Finalized Standards for Existing Coal and New Gas Power Plants

• In April 2024, Advanced Energy United CEO Heather O'Neill stated support for the rules while advocating for utilities to rapidly decarbonize, stating that “instead of looking to build new gas plants or prolong the life of old coal plants, utilities should be taking advantage of the cheaper, cleaner, and more trusty tools in the toolbox.”

• Meanwhile, groups that continue to oppose science-aligned climate policy challenged the legality of the rules, with National Mining Association (NMA) and America’s Power filing a May 2024 joint petition for review and utilities American Electric Power (AEP), Duke Energy, and Vistra Corp filing a petition for review under the ad hoc coalition Electric Generators for a Sensible Transition; this coalition added more members – including Ameren, Evergy, PPL Corporation, Berkshire Hathaway, NRG, and Southern Company – when it filed an August 2024 emergency application for an immediate stay.

Engagement on the Biden Administration’s Existing Gas Plant Rule

Following the decision to separate the carbon standards for existing gas-fired power plants into a separate regulation, the Biden administration’s EPA opened a non-regulatory comment period from March 2024 to May 2024. EEI and major utilities – including American Electric Power, Ameren, Duke, PPL, and Southern -- submitted comments that strongly opposed an ambitious regulation and advocated for flexible compliance pathways.

Engagement on the Biden Administration’s Official Proposal

Positive Advocacy

• Apple and Microsoft lone advocates from Big Tech: In August 2023, Apple submitted positive comments, advocating for the EPA to clearly define “low-GHG hydrogen” as hydrogen produced from new renewable resources. Microsoft signed one of the two joint letters organized by Ceres advocating for the EPA to expand the scope of coverage for affected power plants and move up compliance timelines. Dozens of other companies signed these letters, including Danone, Ikea, Salesforce, Starbucks, Trane Technologies, Unilever, and VF Corp. Alphabet, Amazon, and Meta appeared absent on these proposed rules.

• Support from clean energy industry groups: Industry groups Advanced Energy United and Solar Energy Industries Association supported the ambition of the proposal.

No Public Engagement

• Surprising utility silence: Higher scoring US utilities tracked by InfluenceMap, including Consolidated Edison, Exelon, Pacific Gas & Electric (PG&E), and Public Service Enterprise Group, appeared absent on the proposed rules by not submitting any individual comments. For example, although National Grid, NextEra, and PG&E advocated via the Energy Strategy Coalition – whose comments supported the use of CCS and low-GHG hydrogen while pushing for greater flexibility and other fuels such as renewable natural gas – they have not articulated their individual positions, aside from a May 2023 press release by PG&E in broad support. Similarly, Con Edison participated via the Clean Energy Group’s comments, which advocated for less stringent compliance timelines, while not offering any individual comments of its own.

Opposition

• Main utility trade group spearheaded opposition: In August 2023 comments, EEI strongly opposed the ambition of the regulation and suggested that the EPA was acting beyond its legal boundary in proposing phased standards and the use of carbon capture and storage (CCS) and hydrogen, and emphasized that stringency of the proposed rules could delay the buildout of new fossil gas infrastructure. Several utilities seconded EEI’s negative position in their own comments, including Alliant, Berkshire Hathaway Energy, CMS Energy, Dominion Energy, DTE Energy, Entergy, and FirstEnergy. Subsequently, in December 2023 comments on the supplemental comment period, EEI repeated its concerns with the feasibility of the CCS and hydrogen compliance pathways and called for the EPA to extend compliance timelines and raise emissions thresholds. In February 2024, EEI appeared to link the EPA’s decision to remove the existing gas rule from the proposal with the industry group’s own negative engagement. Ameren, AEP, Duke, PPL Corp, Southern Company, and Xcel, in addition to the those listed above, emphasized the same narrative as EEI, namely that the uses of CCS and hydrogen were not feasible at the proposed timeline and scale. Many of these utilities signed the August 2023 comments submitted by the Class of ‘85 Regulatory Response Group and the Power Generators Air Coalition, both of which pushed back on the proposed rules and suggested that the EPA was acting beyond its legal boundary. (See InfluenceMap’s April 2023 briefing for more details on members of the Class of '85 and PGen). Several utilities maintained their oppositional positions in December 2023 comments submitted to the supplemental comment period, including Ameren, Duke, and Southern Company.

• Opposition from utilities: Ameren, Ameren, AEP, Duke, PPL Corp, Southern Company, and Xcel, in addition to the those listed above, emphasized the same narrative as EEI, namely that the uses of CCS and hydrogen were not feasible at the proposed timeline and scale. Many of these utilities signed the August 2023 comments submitted by the Class of ‘85 Regulatory Response Group and the Power Generators Air Coalition, both of which pushed back on the proposed rules and suggested that the EPA was acting beyond its legal boundary. (See InfluenceMap’s April 2023 briefing for more details on members of the Class of '85 and PGen). Several utilities maintained their oppositional positions in December 2023 comments submitted to the supplemental comment period, including Ameren, Duke, and Southern Company.

• A shift by Edison International: Edison International CEO Pedro Pizarro, who at the time served as the EEI Chair, stated in an August 2023 interview with the Los Angeles Times that “there’s no daylight between Southern California Edison and Edison Electric Institute on this particular topic. I have my Edison hat and my EEI hat on at the same time, because they have the same view.” This statement marked a departure from the utility’s typically more positive engagements (e.g., supporting the Clean Power Plan and the EPA’s right to regulate carbon emissions).

• Constellation disagreed with EEI’s negative position, but still advocated for weaker rules: In an August 2023 press release, CEO Joseph Dominguez stated that he was “disappointed to see many of my peers represented by the Edison Electric Institute and others working to block these very practical measures.” On the other hand, Constellation also strongly advocated against a clear definition of “low-GHG hydrogen” as well as the inclusion of any additionality criteria around the use of hydrogen.

• Strong opposition from trade groups: Many industry groups opposed the proposed rules, including API, America’s Power, Business Roundtable, National Association of Manufacturers, National Federation of Independent Business, and NMA. In August 2023 joint comments, the US Chamber of Commerce, American Fuel & Petrochemical Manufacturers, and American Chemistry Council called for the EPA to withdraw the proposal. America’s Power CEO Michelle Bloodworth directly called for a withdrawal of the rules in a statement at the Federal Energy Regulatory Commission’s November 2023 Reliability Technical Conference.