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Comments to EPA on Proposed Rule to Strengthen Power Plant Effluent Guidelines

In March, the Environmental Protection Agency (EPA) proposed to strengthen its power plant effluent guidelines by tightening discharge requirements for flue gas desulfurization wastewater, bottom ash transport water, and combustion residual leachate resulting from steam electricity generation. In our comment letter, we offer several recommendations for EPA to strengthen its consideration of regulatory benefits. 

In our comment letter, we recommend that EPA: 

  • Emphasize the significance of non monetized benefits resulting from enhanced water quality and explain why water quality benefits are more difficult to monetize than air quality benefits;

  • Monetize additional benefit categories for which supporting research is available and qualitatively describe in greater detail any benefit categories that EPA cannot quantify and monetize; and

  • Consider performing additional analysis using the agency’s draft updated estimates for the social cost of greenhouse gases. 

Our comments build off of two reports that the Institute for Policy Integrity published with outside economists, including a report co-authored by economists Dr. David A. Keiser and Dr. Catherine L. Kling.