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Comments to EPA Science Advisory Board on Economic Analysis Guidelines

The Environmental Protection Agency’s chartered Science Advisory Board (SAB) invited the public to comment on its new draft Guidelines for Preparing Economic Analyses. We submitted multiple sets of comments covering different portions of the guidelines.

Our initial comments provided brief responses to the guidelines and urged the SAB to hold additional meetings to allow the public to more fully engage on each important topic. We then submitted comments covering chapters 1-7 and comments covering chapters 9-10 in advance of additional meetings. Our comments note that the new draft guidelines remain the product of thoughtful work grounded in economic literature and offer recommendations for further improvement. We also provided oral comments at the June 9, 2020 meeting of the SAB, where we further emphasized the need to adjust the discount rate schedule for intergenerational benefits and costs.