Energy Innovation’s Mike O’Boyle, Brendan Pierpont, and GridLab Executive Director Ric O’Connell provided a joint declaration in support of litigation concerning whether courts should grant a stay on enforcement of the Environmental Protection Agency’s rules that limit greenhouse gas emissions from existing coal-fired power plants and new gas-fired power plants. The declaration focuses on the impact the rule will have on utilities in the near-term, finding that impacts will be minimal and reconsideration of coal economics will likely benefit consumers. This work reflects Energy Innovation’s research that was also submitted as part of the record before EPA as they were taking public comment on the Rules.