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)
On October 31, 2018, the Emmett Clinic filed comments urging the EPA to withdraw the proposed ACE rule because the Regulatory Impact Analysis (RIA) for the proposed rule is deficient and takes steps that artificially and unreasonably skew the cost-benefit analysis to favor the proposed rule. The Clinic submitted the comments on behalf of itself and a number of signatories with backgrounds in economics, public health, and environmental law and policy (including 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).