On behalf of Morning Star Packing Company, Merit Oil Company, and Norman R. “Skip” Brown (the “California Commenters”), Texas Public Policy Foundation (“TPPF”) hereby submits comments on the Environmental Protection Agency’s (“EPA’s” or the “Agency’s”) proposed amendments to the rule-making titled “Standards of Performance for Greenhouse Gas Emissions from New, Modified, and Reconstructed Stationary Sources: Electric Utility Generating Units (EGUs),” which EPA promulgated by notice dated October 23, 2015 (the “2015 Rule”), which regulate carbon dioxide emissions from new fossil fuel-fired sources under Section 111 of the Clean Air Act (the “Clean Air Act” or the “Act”). See 42 U.S.C. § 7411. The instant comments are made to inform EPA of the significant obstacles to continuing the 2015 Rule, with amendments, as the Agency has proposed in its call for comments. The California Commenters note that some of the same problems that plagued the 2015 Rule remain with the proposal to amend it.
Energy & Environment
Fool Me Twice: Why the Texas Grid is Still Vulnerable to Winter Storms | Part 2: Projecting Winter Outage Risk Through 2030
Part 2: Projecting Winter Outage Risk Through 2030 As Texas approaches the five-year anniversary of Winter Storm Uri, the ERCOT grid faces growing vulnerability to winter power outages. This analysis projects that by 2030, the same type of storm that would cause approximately 12 hours of outages today could result in nearly 24 hours of...
January 29, 2026