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Comments to EPA on Weakening the Chemical Disaster Rule

In May 2018, EPA proposed to repeal significant portions of the Chemical Disaster Rule, a rule that would have improved safety procedures at chemical plants. In response, we submitted comments highlighting the ways in which this proposed deregulatory action is arbitrary and capricious. We explain how EPA failed to adequately assess the impact of the repeal on the Chemical Disaster Rule’s benefits. We also explain that the agency should update its analysis of the avoided damages of chemical accidents in order to fully assess the repeal’s impact on the benefits of the Chemical Disaster Rule and that the agency should provide a justification for the repeal that does not take credit for EPA’s illegal delay of the Chemical Disaster Rule.