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Amicus Brief on MATS Rule

Policy Integrity submitted an amicus brief in conjunction with the Tulane Environmental Law Clinic and the Harvard Emmett Environmental Law & Policy Clinic in support of the EPA for a federal court case challenging the agency’s proposed standards to curb mercury and toxic air pollution from power plants. Some industry groups are contesting the EPA’s “National Emission Standards for Hazardous Air Pollutants from Coal and Oil-Fired Electric Utility Steam Generating Units” (otherwise known as the MATS rule) finalized last year.

Our brief evaluated the EPA’s calculations of the MATS rule’s benefits in its regulatory impact analysis. We confirmed that administrative law and best economic practices support the EPA’s methodology for incorporating indirect benefits and assessment of significant unquantifiable benefits, and ultimately the rule is justified by economic analysis showing benefits to far outweigh the costs of compliance.