Natural Resources Defense Council (NRDC) filed 2 comments on this docket between Nov 23, 2018 and Nov 23, 2018. 23 other organizations filed here. The comment window closed 2812d ago.
The Natural Resources Defense Council (NRDC) submits the enclosed comments on EPAs proposed rule Protection of Stratospheric Ozone: Revisions to the Refrigerant Management Programs Extension to Substitutes, 83 Fed. Reg. 49,332 (Oct. 1, 2018).
Please consider the attached comments on the failure to monetize the value of forgone emission reductions. These comments are submitted jointly by Environmental Defense Fund, Institute for Policy Integrity at New York University School of Law, Natural Resources Defense Council, Sierra Club, and Union of Concerned Scientists. Our organizations may separately submit other comments regarding other aspects of the proposed rescission. We also attach a broader, recent set of comments on the social cost of greenhouse gases. Sincerely, Jason A. Schwartz, Legal Director Institute for Policy Integrity
In 2016 EPA finalized a rule updating the refrigerant management requirements under the Clean Air Act. This action revisits aspects of the 2016 rule’s extension of the refrigerant management requirements to substitutes like hydrofluorocarbons.
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