The U.S. Environmental Protection Agency (EPA) has requested public input on regulations that may be appropriate for repeal, replacement, or modification pursuant to President Trump’s deregulatory agenda (as outlined in Executive Orders 13771 and 13777). The Sabin Center has submitted a comment letter urging EPA to preserve existing greenhouse gas emission standards.

In the letter, we explain the necessity of these standards and the fact that they provide important benefits that significantly outweigh their costs. This finding is supported by EPA’s own assessments of rules such as the Clean Power Plan, the New Source Performance Standards for power plants, and the emission standards for motor vehicles – EPA conducted a cost-benefit analysis for each of these rules in which it concluded that the overall economic and public health benefits accruing from the reduction in greenhouse gas emissions and co-pollutants would far outweigh any adverse economic impacts. For example, EPA determined that the implementation of the Clean Power Plan would generate climate and public health benefits worth an estimated $34 to $54 billion annually in 2030, as compared with compliance costs ranging from $5.1 to $8.4 billion. There are also a variety of independent studies which have also found that policies like the Clean Power Plan would deliver substantial net benefits, in some cases exceeding what EPA has predicted, and minimal costs.

We also explain why the EPA lacks authority to solely account for compliance costs when deciding whether to issue, modify, or repeal regulations issued under the Clean Air Act. Specifically, we note that there is no provision in the Clean Air Act that authorizes EPA to ignore public health benefits when making such decisions – to the contrary, the Clean Air Act compels consideration of such benefits, and in some cases, forbids consideration of costs.

EPA is accepting public input on this matter through May 15, 2017. Click here to learn more about the review process and to submit comments.

A copy of the comment letter is available here.

Information about Trump’s deregulatory agenda and its effect on EPA regulations is available here and here.

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