This comment letter responds to a request from the Environmental Protection Agency for comments on its June 11 proposed rule “Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process” (hereinafter the “Benefit/Cost” rule). The proposed rule focuses on “processes that [EPA] would be required to undertake in promulgating regulations under the Clean Air Act (CAA) to ensure that information regarding the benefits and costs of regulatory decisions is provided and considered in a consistent and transparent manner.”
My name is Benjamin Zycher. I am a resident scholar at the American Enterprise Institute in Washington, DC, and am the senior energy/environment policy specialist there. I formerly was a senior economist at the RAND Corporation, an adjunct professor of economics at the University of California, Los Angeles (UCLA), and a senior staff economist at the President’s Council of Economic Advisers. I hold a doctorate in economics from UCLA and a master’s degree in public policy from the University of California, Berkeley. The views that I express in this letter are my own and do not purport to represent those of any institution with which I am affiliated.