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Comments to EPA on Proposed Cooling Rules

Policy Integrity submitted comments to the EPA on its proposed rules for cooling water intake structures, required under the Clean Water Act. These rules would affect practices at power plants that mean death for thousands of fish boiled or pinned by screens and intake pipes.

While the proposal is an improvement over the EPA’s last attempt to regulate these structures, our comments find that it could be strengthened by more fully capturing all benefits in the economic analysis. While non-commercial marine life’s existence value and ecosystem services (“non-use benefits”) are difficult to quantify, the EPA should estimate these benefits as fully as possible and select the regulatory option that best maximizes all net benefits.

We also urge EPA to set a reasonable deadline for existing sources to comply with the more stringent standards that new sources are held to. Without this deadline, businesses would be incentivized to continue running old, inefficient, environmentally damaging facilities for fear that an upgrade would trigger costly new compliance burdens. And in delegating authority to state agencies to make many key regulatory decisions, EPA should provide clear instructions so that state determinations are unbiased, based on sound science and economics, consistent, and focused on maximizing net benefits.