As we noted previously, we spent the last several weeks analyzing the impact of the Trump administration’s decriminalization of greenhouse gas emissions from new natural gas and new and existing coal-fired power plants.

Our analysis, which was prepared for the Prime Mover Institute (PMI), spanned 50 pages and detailed how the Trump Administration’s deregulatory agenda would save Americans living in the Midcontinent Independent System Operator (MISO) region $314.6 billion through 2055, with the repeal of Biden and Obama era regulations saving much more across the entire country.

However, the most interesting part of the story isn’t that the rules provide such massive benefits; it’s that the Trump administration might have missed them if not for our analysis.

Today, we describe the process of writing our comments, sharing some main findings, and detailing why the Environmental Protection Agency’s modeling process needs serious reform.

Rolling Back the Regs

On March 12, 2025, EPA Administrator Lee Zeldin announced his agency would undertake 31 deregulatory actions, making it a verifiable Baskin-Robbins of regulatory rollbacks.

This scope was unprecedented in EPA history, and it meant the agency would need to work at a breakneck speed in order to enact all of these priorities in the next three years, so they would not be subject to Congressional Review Act (CRA) repeal should Democrats hold all three branches of government after the 2028 elections.

On June 17th, 2025, the Trump administration published its Proposed Rule, formally entitled the “Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units.” From what legal experts tell us, the actual text of the rules is very strong.

However, the Regulatory Impact Analysis (RIA) used to justify the rules needed some help to supplement the record on the analysis side of the equation and (hopefully) increase the odds that the rules would withstand the inevitable court challenges that will follow its finalization.

The Case of the Missing Benefits

According to the RIA published with the rules, the Trump Administration’s proposed repeal of previous greenhouse gas regulations, which we will refer to as the “Trump Proposal” from now on, would have produced just $19 billion in benefits under a 3 percent discount rate from 2026 through 2047.

The administration did not perform its own analysis of the impact of the Trump Proposal on the power sector, but instead got this number by simply reversing the compliance costs