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.