The Environmental Protection Agency’s proposed rule, Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process, is unjustified and fails to satisfy its own standards for adequately explaining the need for a new regulation. We submitted comments to EPA and the chartered Science Advisory Board noting that the proposal is unnecessary and explaining how it breaks from best practices for cost-benefit analysis of regulations in several significant ways.
Related Reading
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Statement on EPA’s Package of Power Plant Regulations
Media Resources / April 25, 2024
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Defining “Adequately Demonstrated”: EPA’s Long History of Forward-Looking Standards Under Section 111 of the Clean Air Act
Publications / April 24, 2024
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Comments to OMB on Draft Update of Circular A-4
Project Updates / June 20, 2023
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New Guidance Improves Consideration of Health, Equity, and Environmental Benefits in Regulations
Media Resources / April 6, 2023
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Still Your Grandfather‘s Boiler: Estimating the Effects of the Clean Air Act‘s Grandfathering Provisions: Working paper
Publications / December 13, 2022