• David Hill | Public Comments

Cost Benefit Analysis
August 3, 2020

I am submitting these comments concerning EPA’s notice of proposed rulemaking (NOPR), “Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process,” Docket EPA-HQ-OAR-2020-00044. These comments address four points. They:

  1. support the legal and policy soundness of using benefit-cost analysis in evaluating the legality and appropriateness of significant Clean Air Act rulemakings;
  2. support the NOPR’s proposal that the benefits and co-benefits of a proposed significant Clean Air Act rulemaking be segregated and separately identified;
  3. support the overall regulatory mandate that benefit-cost analysis must be presented “in a manner designed to be objective, comprehensive, reproducible to the extent reasonably possible, and easily understood by the public”; and
  4. encourage EPA to consider how the mandates of the rule can best be put in place and enforced while at the same time not becoming a source of extensive new litigation that results in Clean Air Act requirements becoming even more uncertain and expensive for the regulated community.

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