The North American Association of Food Equipment Manufacturers (NAFEM) submits the following comments to the U.S. Environmental Protection Agency’s (EPA) Notice of Proposed Rulemaking – Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process (85 Fed. Reg. 36,512, June 11, 2020) (the “Proposed Rulemaking”). The Proposed Rulemaking relates to whether EPA should ensure that its regulatory actions and decision-making is based on a consistent and transparent methodology for how costs and benefits are considered in its regulatory process under the Clean Air Act.
The Proposed Rulemaking follows the 2018 Advanced Notice of Proposed Rulemaking – Increasing Consistency and Transparency in Considering Costs and Benefits in Rulemaking Process (83 Fed. Reg. 27,524; June 13, 2018) that reviewed the process generally across EPA. NAFEM submitted comments on this ANPRM to the docket No. EPA-HQOA-2018-0107. NAFEM supports this Proposed Rulemaking for many of the reasons that it explained in detail in those prior comments (attached).