Advocacy Submits Comments on Increasing Consistency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process to EPA
On June 11, 2020 the Environmental Protection Agency (EPA) published a proposed rule titled “Increasing Consistency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process.” This letter constitutes the Office of Advocacy’s (Advocacy) public comments on the proposed rule.
Advocacy generally supports the use of Benefit-Cost Analyses in the development of rules under the Clean Air Act. However, aggregate analyses can mask significant economic impacts on small entities. Advocacy strongly encourages EPA to incorporate elements of its statutory obligations under the Regulatory Flexibility Act into this rule, to directly address the disproportionate impacts that regulatory decisions can have on small entities.
For further information, please contact Dave Rostker with the Office of Advocacy.
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