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. The letter also addressed how the regulation’s disregard of the complex ways in which pollutants interact within and across environmental media would undermine environmental protections and the existing regulatory programs that are essential to public health, protection of ecosystems and wildlife, and local economies. Rescinding the regulation reduces this risk and associated negative environmental health and safety risks that often disproportionately affect children and residents of environmental justice communities.
Read the Clinic’s comments: 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)