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EPARulemakingEPA-HQ-OA-2018-0107

Improving Consistency and Transparency of Cost Considerations in Rulemaking

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Apr 15, 2022
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closed 2906d ago
Environmental Defense Fund filings
3

Activity

Environmental Defense Fund filed 3 comments on this docket between Jun 22, 2018 and Aug 28, 2018. 68 other organizations filed here. The comment window closed 2906d ago.

What Environmental Defense Fund filed (3)

Aug 28, 2018· Comment submitted by Martha Roberts, Surbhi Sarang, Tomás Carbonell, Environmental Defense Fund (EDF)· EPA-HQ-OA-2018-0107-1851

Please see attached comments of Environmental Defense Fund, Environmental Law & Policy Center, National LGBTQ Task Force, National Parks Conservation Association, Natural Resources Defense Council and Waterkeeper Alliance on Advance Notice of Proposed Rulemaking, Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process, 83 Fed. Reg. 27,524 (June 13, 2018).

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Aug 16, 2018· Comment submitted by Environmental Defense Fund (EDF) et al.· EPA-HQ-OA-2018-0107-0749

Please see supporting attachments to comments of Environmental Defense Fund, Environmental Law & Policy Center, National LGBTQ Task Force, National Parks Conservation Association, Natural Resources Defense Council and Waterkeeper Alliance on Advance Notice of Proposed Rulemaking, Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process, 83 Fed. Reg. 27,524 (June 13, 2018). 1. Kimberly M. Castle and Richard L. Revesz, Environmental Standards, Thresholds, and the Next Battleground of Climate Change Regulations Minnesota Law Review, Vol. 103, 2018, Forthcoming; NYU School of Law, Public Law Research Paper No. 18-22; NYU Law and Economics Research Paper No. 18-12 (Apr. 2018). 2. EDF, Power Companies Declining Estimates of the Compliance Costs of Mercury & Air Toxics Standards (MATS). 3. EPA, The Benefits and Costs of the Clean Air Act from 1990-2020 Summary Report (Mar. 2011). 4. EPA, The Benefits and Costs of the Clean Air Act from 1990-2020 (Apr. 2011). 5. EPA, Summary of Expert Opinions on the Existence of a Threshold in the Concentration-Response Function for PM2.5-related Mortality (June 2010). 6. Joint Comments of Environmental Defense Fund, Institute for Policy Integrity at New York University School of Law, Montana Environmental Information Center, Natural Resources Defense Council, Sierra Club, Union of Concerned Scientists, Western Environmental Law Center, WildEarth Guardians on Comments on Flawed Estimates of the Social Cost of Carbon in the Proposed Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units Docket ID EPA-HQ-OAR-2017-0355 (Apr. 26, 2018). 7. Thomas Stoerk, Gernot Wagner, and Robert E.T. Ward, Recommendations for Improving the Treatment of Risk and Uncertainty in Economic Estimates of Climate Impacts in the Sixth Intergovernmental Panel on Climate Change Assessment Report, 12 Review of Environmental Economics and Policy 371 (Aug. 1, 2018). 8. Interagency Working Group on Social Cost of Carbon, United States Government, Technical Support Document: Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866 (Feb. 2010).

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Jun 22, 2018· Comment submitted by Laura Bloomer and Surbhi Sarang, Environmental Defense Fund (EDF)· EPA-HQ-OA-2018-0107-0018

Please see attached an initial comment from EDF requesting an extension of the comment deadline for Advance Notice of Proposed Rulemaking: Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process, 83 Fed. Reg 27,524 (June 13, 2018).

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Abstract

In an Advanced Notice of Proposed Rulemaking (ANPRM), EPA will solicit comments and recommendations on how it can make regulatory cost considerations more consistent, reliable, and transparent. The ANPRM is expected to illustrate how EPA considered costs in recent rulemakings and pose questions to help identify opportunities for improvement. Based on the comments received and further considerations, EPA may move to develop implementing regulations through the notice-and-comment rulemaking process (NPRM/FRN).

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Co-filers (68)

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