Dear Mr. Wheeler, On behalf of the Colorado Alliance of Mineral and Royalty Owners (CAMRO), I would like to express my strong support for your agency’s proposed rule “Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process”.
Too often in the past, the EPA has been less than transparent when it comes to how it conducts cost-benefit analysis of proposed rules and regulations, including what inputs, assumptions, and datasets are used. As royalty owners who are often directly, or indirectly, impacted by EPA decisions, we believe that the public has a right to know to what extent cost/benefit estimates are uncertain, and what information was included or omitted. Further, we believe that the agency should require cost-benefit analysis be implemented throughout the agency in a uniform, consistent manner, and be applied to all significant new and proposed rules and regulations. This new rule provides for these things.