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Comments to OMB on Advancing Equity and Supporting Underserved Communities

In his Presidential Memorandum titled Modernizing Regulatory Review, President Biden called on OMB to identify measures to promote racial justice in the regulatory review process. The Memorandum emphasized the significance of cost-benefit analysis, calling on OMB to “propose procedures that take into account the distributional consequences of regulations, including as part of any quantitative or qualitative analysis of the costs and benefits of regulations, to ensure that regulatory initiatives appropriately benefit and do not inappropriately burden disadvantaged, vulnerable, or marginalized communities.”

We submitted comments outlining procedures and methodologies that OMB could apply to account for equity in the regulatory review process, with a focus on environmental injustice.