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An Evaluation of the Benefit-Cost Analysis in the 2020 Steam Electric Reconsideration Rule

85 Fed. Reg. 64,650 (Oct. 13, 2020)

In its analysis of the 2020 Steam Electric Reconsideration Rule, the Environmental Protection Agency failed to adequately provide quantitative estimates for numerous harms from steam electric power plants' wastewater streams and drew conclusions about the rule’s impacts that are undermined by a fair assessment of unquantified impacts. Given the significant number of forgone benefits that the agency left unquantified, it is likely that the agency undervalued the harms of the rule by a large amount. Thus, the unquantified forgone benefits would likely undermine EPA's decision to finalize the 2020 Rule. In such a case, it is imperative that the agency rethink its approach. Our report identifies flaws in the 2020 Rule and details changes the agency can make to significantly improve its benefit-cost analysis.