Guest post by Isaac Orr and Mitch Rolling

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 of the Biden administration’s final greenhouse gas rules and counting those avoided costs as benefits in the Trump Proposal.

Ordinarily, it would seem reasonable to assume that the benefits of reversing a regulation could be determined by reversing the estimated cost of complying with said regulation.

However, this “Reverse Uno” of the costs and benefits of the Biden rules missed the bigger picture: the costs and benefits of the Biden administration’s final regulations were based upon a fatally flawed baseline (the B.S. Biden Baseline scenario discussed last week) that hid 90 percent of the cost of the regulations, as shown in the graph below.

Therefore, it would be impossible for the Trump Administration to accurately quantify the benefits of the Trump Proposal if it accepted the faulty premise of the B.S. Biden Baseline. This is where we stepped in to model the true benefits of the Trump Proposal for PMI.

Calculating the Cost of the Biden Regulations

Calculating the cost of the Biden regulations was straightforward. After digging through the Biden EPA’s spreadsheets to determine how much new power plant capacity the agency expected to be placed into service in the MISO region as a result of its final rules, we calculated the cost of building and operating this new capacity, compared to the current grid, through 2055.

The vast majority of this new capacity consisted of wind, solar, natural gas, and battery storage. We determined that after accounting for fuel savings and other operational savings from rising generation from wind and solar, and accounting for federal subsidies, the MISO grid envisioned by the Biden EPA under its rules would be a net cost increase of $404.1 billion through 2055.

These numbers are large, but they don’t tell the whole story.

The modeled MISO grid in this scenario was woefully unreliable, causing several blackouts when we stress-tested the generation fleet against historical fluctuations in electricity demand and wind and solar capacity factors obtained from the U.S. Energy Information Administration (EIA).

Some of these blackouts would be massive. For example, the largest blackout we observed in our analysis of EPA’s modeled grid reached a maximum capacity shortfall of over 31,000 MW (31 GW) in the 2040 EPA model year using the 2020 historical year, constituting 22.5 percent of the electricity demand on the MISO system at the time of the capacity shortfall.

There is no world where the American public would tolerate such massive and economically devastating blackouts year after year, and no world where the policymakers who enacted these regulations could remain in office. As a result, we determined that the modeled MISO grid in the Biden final rules was too unreliable to be a realistic basis for understanding their financial impact.

To determine the actual cost of these rules, we concluded we would need to calculate the cost of building enough additional wind, solar, battery storage, and natural gas capacity to avoid these blackouts while still meeting the emissions rates established by the Biden EPA’s modeling. We called this the “Avoiding Biden Blackouts” scenario.

Avoiding the Blackouts, Jack

In our Avoiding Biden Blackouts scenario, we increased the amount of installed capacity on the MISO system to prevent blackouts from occurring while also achieving a carbon dioxide emissions rate of 0.8 metric tons per MWh of electricity generated, which is the same emissions rate we determined would occur under the final Biden rules.

We also increased the estimated compound annual growth rate in peak electricity demand to 2 percent, compared to the EPA’s estimates of 1.2 to 1.7 percent, to better reflect the latest estimates for data center demand growth from MISO.[1]

Our modeling found building enough additional wind, solar, battery storage, and natural gas capacity to prevent blackouts would require an extra 196 gigawatts (GW) of additional capacity, compared to the scenario discussed above, consisting of an additional 49.9 GW of wind, 20 GW of solar, 86.3 GW of four-hour battery storage, and 40.5 GW of natural gas, which you can see in the graph below.

Building this extra capacity to reliably meet electricity demand for every hour of the modeled years would cost MISO ratepayers an additional $867.9 billion, compared to the current grid. The costs incurred in the Avoiding Biden Blackouts scenario can be considered the true cost of the Biden administration’s final rules.

The Trump Proposal- Let’s Talk Turkey

Once we established a realistic cost estimate for the Biden regulations, we needed to determine how much MISO ratepayers could save if those regulations were repealed.

To do this, we created an illustrative Trump Proposal scenario that could demonstrate the economic and reliability benefits of continuing to use the existing coal and nuclear plants on the MISO system, and to build new natural gas power plants to reliably meet the rising demand for datacenters that we used in the Avoiding Biden Blackout scenario.

The modeled MISO grid in the Trump Proposal Policy Scenario more closely resembles the existing MISO grid than the other scenarios because the rules are, in large part, intended to preserve the reliable, low-cost power plants that currently keep the lights on in the region and remove impediments to the construction of new natural gas plants to meet rising electricity demand.

Under the Trump Proposal, the total installed capacity on the modeled MISO system grows from 223 GW to 445 GW to meet the growth in demand from 121 GW to 224 GW in 2055. The growth in capacity largely consists of natural gas, solar, wind, and battery storage, with retirements consisting of coal plants and some older natural gas and oil facilities.

Building this additional capacity would cost an additional $307.2 billion through 2055—no small amount— but compared to the Avoiding Biden Blackouts scenario, it would yield $560.7 billion in cost savings through the modeling window.

While much more coal remains on the system in this scenario, there are still 19.5 GW of coal retirements in the Trump Proposal, along with a substantial buildout of wind and solar capacity due to carbon-free electricity mandates in Illinois, Michigan, and Minnesota, and less onerous RPS mandates in other MISO states.

Savings under the Trump Proposal would be even larger if not for these state-level policies. Our modeling indicated meeting the growth in peak demand without building more wind and solar would cost only $66.5 billion through 2055, which means scaling back the Biden regulations could save MISO ratepayers up to $801.4 billion through 2055.

There is no question that the Trump Proposal would eliminate the need to spend hundreds of billions of dollars in new power plant infrastructure, creating a massive benefit for MISO ratepayers. However, determining the total net benefits of the rules required us to also look at the costs of the rules in terms of higher emissions of criteria pollutants and greenhouse gases.

We’ll discuss that part of the analysis in another article.

Conclusion

Determining the savings opportunity presented by the Trump Proposal was a saga requiring us to model the economic and reliability impact of four different scenarios.

In the end, we determined that giving power plant operators the ability to continue to utilize their existing coal, nuclear, and natural gas plants and build reliable capacity to meet rising peak demand forecasts would save MISO customers over half a trillion dollars on their electric bills over the next two and a half decades.

Do these savings outweigh the costs of more emissions? You’ll have to tune in next time to find out. Make sure to subscribe so you get it in your inbox.

Originally posted at the Energy Bad Boys Substack, reposted with permission.

[1] Midcontinent Independent System Operator, “Long-Term Load Forecast,” December 2024, https://cdn.misoenergy.org/MISO%20Long-Term%20Load%20Forecast%20Whitepaper_December%202024667166.pdf.