Dear Administrator Wheeler: On behalf of the North American Die Casting Association (“NADCA” or “Association”) please accept these comments in response to the Environmental Protection Agency’s (EPA) Notice of Proposed Rulemaking (NPRM) “Increasing Consistency and Transparency in Considering Costs and Benefits in the Clean Air Act Rulemaking Process.” NADCA supports the EPA’s proposal to codify the practice of preparing benefit-cost analyses (BCAs) in the development of future significant Clean Air Act (CAA) regulations.
Under the previous administration, the EPA continuously failed to adequately consider the potential benefits and costs in its analysis of a new rule. Instead the agency pushed through an average of 565 new rules a year using deeply flawed methods, including its reliance on the “societal cost of carbon” calculation when deriving the economic benefit of a new rule. Such calculations not only lacked transparency, they grossly overstated environmental benefits.