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Comments to EPA on Proposed Rescinding of Clean Air Act Benefit-Cost Rule

In May, EPA announced its intention to rescind a 2020 rule entitled "Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process." Policy Integrity submitted comments in support of this decision based on the view that the 2020 rule is unnecessary, unsupported by any evidence of need, and inconsistent with best practices for cost-benefit analysis. We attached joint comments that Policy Integrity submitted during the original rulemaking which made these arguments in addition to demonstrating specifically how the rule broke from cost-benefit best practices by (1) devaluing indirect benefits, (2) subjecting benefit calculations to stricter standards than cost calculations, and (3) raising the bar for evidence of causality in a manner that excludes studies highly significant to EPA’s cost-benefit analysis.