Pursuant to Notice of Proposed Rulemaking, "Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process," 85 Fed. Reg. 37057 (June 19, 2020) ("Proposed Rule"), it is requested the following public comments be considered and the Proposed Rule revised as set forth below. There is over-riding need for a more robust and definitive benefits-cost analysis for all EPA Clean Air Act rulemaking procedures.