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Comments to EPA on Proposed Particulate Matter Standards for Aircraft Emissions

The Environmental Protection Agency (EPA) recently proposed airplane pollution standards that will have no effect on emissions and require no technological improvements. We filed comments urging EPA to evaluate a full suite of regulatory alternatives, including more stringent standards that would reduce emissions. Rather than simply deferring to an international body’s technology-following standards, we recommend that EPA exercise its broad discretion under the Clean Air Act to consider technology-forcing standards and then presumptively adopt the alternative that maximizes societal net benefits. We also recommend that EPA conduct a distributional analysis to evaluate the impacts of the Proposed Rule and the relative distributional consequences for each regulatory alternative.

These comments were co-written with Clinical Associates Jenna Pearlson and Tanya Shahjanian.