• Kelly Sloan | Public Comments

Cost Benefit Analysis
August 4, 2020

Dear Mr. Wheeler, It is my sincere hope that the Environmental Protection Agency (EPA) will fully adopt the above-referenced rule to require transparency and consistency in the completion of cost-benefit analyses on any future rule promulgated under the auspices of the Clean Air Act.

The purpose of the cost-benefit analyses, which is ostensibly required in the course of the evaluation of a proposed rule, is to do just what the name implies – determine the likely and potential economic harms that the new regulation would impose, weighed against the benefit to society. Too often in the past, and especially during the previous administration, these evaluations have been suborned by purely political considerations; i.e. the benefits of a proposed agency action have been exaggerated, while the costs have been downplayed, minimized, or outright dismissed. This rule would rectify that by providing clear guidance as to what factors ought to be considered, and making those determining factors clear as well to the public.