Comment on the U.S. Environmental Protection Agency’s Advanced Notice of Proposed Rulemaking on “Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process” (83 Fed. Reg. 27,524 (June 13, 2018)
Responsible public policy should rely on a more rational prioritization of resources that is informed by a meaningful weighing of compliance burdens against the risks in full consideration of the uncertainty associated with those risks. In our attached comments, API supports EPA’s interest in improving the consistency and transparency of its calculation and consideration of regulatory costs and benefits. These economic considerations, which are required in numerous statutes and executive orders, were mandated precisely for the purpose of improving the efficacy of environmental regulation and the allocation of both industry and Agency resources. Efforts to improve the consistency and transparency of these analyses should not, therefore, be viewed as an effort to abandon the Agency’s pursuit of improved environmental outcomes – nor has API ever advocated for such a result. This ANPRM is a critical step toward improved regulatory processes.
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