Comments on Rescinding the Rule on “Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process,” 86 Fed. Reg 26,406 (Docket ID No. EPA-HQ-OAR-2020-0044)
On June 14, 2021, the Clinic submitted comments on behalf of the Chesapeake Bay Foundation and National Parks Conservation Association supporting EPA’s decision to rescind the Trump-era regulation regarding the use of cost-benefit analyses in Clean Air Act rulemakings. The letter supported EPA’s conclusion that the rulemaking was unnecessary, unresponsive to any real problem and duplicative of existing EPA guidance documents.