Eighteen AGs Filed Comments on EPA Proposal That Would Distort Cost-Benefit Analyses for Clean Air Act Rulemakings
AUGUST 3, 2020
New York Attorney General Letitia James led a coalition of 18 attorneys general in filing comments in response to the Environmental Protection Agency’s (EPA) proposal to establish a one-size-fits-all approach to cost-benefit analyses for Clean Air Act rulemakings. The comments emphasized that the proposal improperly ignores the different approaches prescribed by the statute for its various programs, and is based on a “false premise that uniformity across these disparate provisions is lawful and possible.” The comments also highlighted the proposal’s “impracticable and unlawful” treatment of co-benefits, and its “woefully inadequate” discussion of greenhouse gas emissions and the social cost of carbon—a particularly glaring gap given the EPA’s “demonstrated lack of transparency and consistency” in this area.
- Documents: CommentsPress Release
- Document Type: Comment Letters Press Releases/Statements
- States: California Connecticut Illinois Iowa Maryland Massachusetts Minnesota New Jersey New York North Carolina Oregon Pennsylvania Rhode Island Vermont Virginia Washington Washington, D.C. Wisconsin
- Agencies: Environmental Protection Agency
- Issues: Clean Air & Climate Clean Air Act Climate Environmental Justice Greenhouse Gas Emissions Natural Resources Public Health Public Lands & Wildlife
- Era: Trump Administration
- Action Type: Rulemaking & Other Federal Administrative Proceedings