NACAA Comments on EPA Cost-Benefit Analysis ANPRM

August 8, 2018 – NACAA submitted comments on EPA’s advance notice of proposed rulemaking (ANPRM), “Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process”.  The ANPRM seeks comment on consistency- and transparency-based concerns related to EPA’s assessment of the costs and benefits of its regulatory actions and also requests suggestions to change how the agency performs such analyses.  NACAA’s letter makes four broad points in response to the ANPRM: 1) a rulemaking to alter the existing cost-benefit analysis framework is unnecessary and could distort future cost-benefit analyses; 2) potential changes to EPA’s cost-benefit framework should prioritize a broader accounting of public health benefits; 3) EPA should not diminish or abandon its consideration of co-benefits; and 4) the ANPRM’s vagueness limits opportunities for stakeholder comment. The ANPRM was published in the Federal Register on June 13, 2018 and is open for public comment through August 13, 2018.  For further information, click here.