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Comments to EPA on Proposed Transport Rule

In April 2022, EPA proposed a Federal Implementation Plan (FIP) to reduce interstate transport of ozone pollution using the Clean Air Act's Good Neighbor Provision. This Proposed FIP would implement a legally sound system to address ozone pollution from both electric generating units (EGUs) and other sources (non-EGUs) and confer hundreds of billions of dollars of net societal benefits. Policy Integrity submitted comments supporting the Proposed FIP, and making a number of recommendations to clarify and strengthen the final rule. In particular, we recommend that EPA select the regulatory alternative that maximizes net benefits and revise and expand its distributional analysis to better reflect the impacts of the Proposed FIP on vulnerable groups.

We also submitted joint comments with a coalition of environmental groups on EPA's use of the social cost of greenhouse gases in the Proposed FIP. Those comments provide additional legal, economic, and policy justifications that can further bolster EPA's adoption of those valuations as a lower bound of projected climate impacts.