The Trump administration has released its proposed new rule to replace the Obama administration’s Clean Energy Plan. Entitled the Affordable Clean Energy Rule, the new approach has four tenets for reducing greenhouse gas emissions: 1) that on-site, heat-rate efficiency improvements are the best way to reduce emissions; 2) a list of candidate technologies that states can use to establish performance standards; 3) an update to the permitting program for power plants to encourage efficiency improvements; and 4) adequate time for states to devise their plans to reduce emissions. The new rule is less onerous on power plants, replacing the strict carbon dioxide emissions limits of the Clean Power Plan with encouragements to improve efficiencies at plants. One reaction to the new rule covered by the Financial Times is that it will not help to revive coal firing in the USA – gas and renewables are too competitive – but it will help to slow its decline. In declining more slowly, the Environmental Protection Agency’s own estimates are that there will be an additional 350-1080 deaths as a result of air pollution compared to the Clean Power Plan. Given that the rule gives more control to states and is less prescriptive than the Clean Power Plan (which never came into effect because of a ruling by the Supreme Court), it is unlikely to be stayed by the Supreme Court.