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Comments to EPA on Rescinding Its “Once In, Always In” Policy

The Environmental Protection Agency (EPA) is proposing to abandon its longstanding “Once In, Always In” policy, in turn allowing “major sources” that reduce emissions below major source thresholds to reclassify as “area sources” subject to less stringent regulation. We submitted comments detailing inadequacies in EPA’s assessment of the rule’s costs and benefits. The agency fails to analyze the rule’s aggregate emissions impacts, conduct its illustrative analyses against an appropriate baseline, account for the possibility of inadequate state enforcement, and monetize the health and environmental effects of emissions changes.