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Comments to EPA on Proposal for Cost-Benefit Analysis and the Clean Air Act

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.