October 31, 2018 – The Clinic submitted comments on EPA\u2019s proposal to repeal the Obama Administration\u2019s Clean Power Plan and replace it with the \u201cAffordable Clean Energy\u201d rule (the \u201cProposal\u201d), which would significantly weaken the regulation of greenhouse gas emissions from existing coal and natural gas fired power plants.\u00a0 The comments focused on fundamental flaws in the Regulatory Impact Analysis (\u201cRIA\u201d) that result in EPA failing to provide an accurate or complete assessment of the Proposal\u2019s impacts on human health or the environment and significantly skewing the calculation of costs and benefits in favor of the Proposal.\u00a0 EPA failed to offer a rational basis for the RIA\u2019s departure from long-standing cost-benefit practices and climate science.<\/p>\n
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.\u00a0 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.<\/p>\n