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We’re leading an all-out national mobilization to defeat the climate crisis.

Join our work today to help us build a thriving and just clean energy future. 

What Are 111(b) and 111(d) Rules? Here’s Why They Are Vital for Cutting Carbon Pollution

The next big opportunity for Biden to cut carbon pollution? EPA standards for power plants under the Clean Air Act. Here’s what the administration should do next on climate.

President Joe Biden talks with EPA Administrator Michael Regan aboard Air Force One on Thursday, February 17, 2022.



On April 25, 2024, EPA finalized the first-ever power plant pollution standards for the existing U.S. coal fleet and newly proposed gas plants, with most covered plants required to cut their pollution by 90 percent by 2032. Together, these rules are estimated to curb over 1.4 billion metric tons of carbon pollution and create $270 billion in climate benefits and $120 billion in public health benefits.

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President Biden has yet to use his most effective tool to combat the climate crisis—EPA standards for power plant carbon pollution. These rules alone could cut as much pollution from the power sector by 2030 as the climate provisions in the Inflation Reduction Act. And if he doesn’t act quickly, he could miss his opportunity to use these critical rules all together. 


What’s next on climate after the Inflation Reduction Act

Joe Biden ran for president on the most ambitious climate platform ever. One of his central campaign promises was to achieve 100 percent carbon pollution-free electricity by 2035. 

Now that he’s signed a historic climate bill, the Inflation Reduction Act, the U.S. is finally making major progress in the fight to defeat the climate crisis. However, with just the Inflation Reduction Act, the U.S. is not on track to hit 100 percent clean electricity by 2035—or the critical interim target of 80 percent clean power by 2030. However, President Biden has the power to get us within striking distance of these targets.

One executive action in particular can get the U.S. nearly all the way to our 2030 target. If EPA sets ambitious pollution standards for power plants, the U.S. would get to 76 percent clean electricity this decade, according to brand new modeling from NRDC and Evergreen. That’s up from only 39 percent clean power today. With a few additional executive actions or state-level policies, President Biden’s clean power targets are within reach.

Here’s what you need to know.


What are the 111(b) and 111(d) rules?

These EPA rules would set carbon pollution standards for new and existing power plants. That means requiring fossil-fueled power plants to directly reduce their emissions. The name comes from the section of the Clean Air Act that gives EPA this authority: sections 111(b) and 111(d).

The 111(b) rule would set New Source Performance Standards for new power plants that run on fossil gas. That means that all gas plants currently proposed could not be built unless they reduce carbon pollution to a certain threshold set by EPA. This rule would reduce the pollution that would come from the roughly 200 gas plants that have been proposed around the country. Because of recent technological innovation, an emissions reduction of 90 percent for new power plants is possible. The 111(b) rule is essential to defusing the climate bomb that these proposed gas plants would otherwise cause.

The 111(d) rule would set Emission Guidelines for existing power plants, requiring states to develop plans for the existing coal and gas plants in their state to meet EPA’s emission limits. This rule would help tackle the 25 percent of U.S. greenhouse gas pollution that currently comes from existing power plants. Because the 111(d) standard would cover existing plants that run on both coal and gas, EPA should issue two separate rules under this section to make sure that both major fossil fuel sources are covered.


Why are these rules key on the path to decarbonization?

The U.S. still has a major fossil fuel problem. While the recent passage of the Inflation Reduction Act will make clean energy cheaper, these clean energy incentives won’t decarbonize the economy on their own. The only way to actually cut pollution from the power sector is to directly reduce the emissions that come from burning fossil fuels. The 111(b) and 111(d) rules would do just that. Both of these rules can and must require substantial carbon pollution reductions. President Biden needs to use all of his available tools to address the climate crisis, and the Section 111 rules are two of the best opportunities.

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Modeling from Evergreen and NRDC’s recent paper, Powering Toward 100 Percent Clean Power, lays out the stakes. The Inflation Reduction Act could reduce power-sector carbon pollution to 66 percent below 2005 levels by 2030. That’s a big improvement, but it’s still short of the 80 percent target that President Biden needs to hit. By setting ambitious 111(b) and 111(d) standards, EPA could get us to a 77 percent emissions reduction this decade, keeping President Biden’s clean power goals within reach.


EPA has the authority—and duty—to regulate carbon pollution

You might be wondering how the Supreme Court plays into all of this. Last summer, the Supreme Court released its decision in West Virginia v. EPA, a case about President Obama’s proposed 111(d) regulation—commonly referred to as the Clean Power Plan. In that decision, the court did not revoke EPA's authority to regulate carbon pollution from power plants under the Clean Air Act—saying only that it can’t set standards based on "generation shifting," or replacing fossil fuels with cleaner generation.

EPA's core authority to regulate carbon pollution from power plants remains intact. In fact, the Inflation Reduction Act recently reinforced this authority by amending the Clean Air Act to explicitly clarify that EPA must regulate carbon pollution under the Act—and that Congress intends EPA to regulate carbon pollution from power plants specifically.


What President Biden and EPA Administrator Regan must do

Now, however, delays from EPA mean President Biden is at risk of failing to use these tools all together. He must go further, faster.

EPA should set new rules that conform to West Virginia’s constraints, by setting standards based on technology that causes individual plants to “operate more cleanly.” This is sometimes called an “inside-the-fenceline” approach, because it focuses on technology that reduces emissions at the power plant itself. These inside-the-fenceline technologies, as mentioned earlier, allow for significant carbon pollution reductions of at least 90 percent. EPA and President Biden must act accordingly.

And, they must do it quickly. EPA delayed the planned release of these two vital rules until summer 2024. President Biden needs to act much faster to ensure that these climate rules are finished during his first term. Without moving faster, court challenges and lengthy notice and comment periods risk leaving these rules unfinished—and President Biden’s campaign promises on climate unfulfilled. He cannot afford to miss this moment.

Fossil fuel plants—and their air pollution—are harming the climate and communities across the country. Without finalizing ambitious 111(b) and 111(d) rules, President Biden will be leaving communities out to dry—and breaking his campaign promise to the American people of 100 percent carbon-free electricity.

Join us in telling President Biden that power plant pollution standards can’t wait. He must use his most effective climate tools, and fast.