int(301) Emmett Clinic Files Comments on EPA’s Proposal to Repeal the Clean Power Plan – Emmett Clinic
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Emmett Clinic Files Comments on EPA’s Proposal to Repeal the Clean Power Plan

Clinic Publications News
October 31, 2018
October 31, 2018 – The Clinic submitted comments on EPA’s proposal to repeal the Obama Administration’s Clean Power Plan and replace it with the “Affordable Clean Energy” rule (the “Proposal”), which would significantly weaken the regulation of greenhouse gas emissions from existing coal and natural gas fired power plants.  The comments focused on fundamental flaws in the Regulatory Impact Analysis (“RIA”) that result in EPA failing to provide an accurate or complete assessment of the Proposal’s impacts on human health or the environment and significantly skewing the calculation of costs and benefits in favor of the Proposal.  EPA failed to offer a rational basis for the RIA’s departure from long-standing cost-benefit practices and climate science.

The Clinic filed these comments on its own behalf and on behalf of professors from Tufts University and Northeastern University and the President and Executive Director of the Woods Hole Research Center.  These signatories are experts in economics, public health, and environmental law and policy, and include lead authors on reports by the Intergovernmental Panel on Climate Change and former senior level advisors in the White House National Science and Technology Council, the White House Office of Science and Technology Policy, and the State Department.

The link to the comments is here: Comments on Proposed Rule: Emission Guidelines for GHG Emissions from Existing Electric Utility Generating Units; Revisions to Emission Guideline Implementing Regulations; Revisions to New Source Review Program (ACE Rule), 83 Fed. Reg. 44,746 (Docket No. EPA-HQ-OAR-2017-0355)