On August 3, 2020, EPN submitted comments on EPA’s proposal, “Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process,” which specifies how cost-benefit analyses must be prepared for every significant new rule under the Clean Air Act (CAA). EPN finds that these requirements, which duplicate existing guidance for EPA and the entire Executive Branch, are not needed and are not called for in the CAA. They would open the door to litigation for any new regulation on the grounds that EPA has fallen short in complying with it.
Read the comments.