Guest Blogger Benjamin Miller: Suggestions to help EPA Successfully Implement Retrospective Reviews

On June 13th, the Environmental Protection Agency (EPA) issued an advanced notice of proposed rulemaking soliciting comments on how to improve the consistency and transparency of the cost benefit analyses that guide EPA’s regulatory decision making. Both are praiseworthy goals, particularly because executive orders issued by the Trump administration last year resulted in cost benefit analysis being used not only for determining the appropriateness of individual regulations, but also for choosing between regulations when deciding which to implement. In its solicitation for comments, EPA has hinted at a key part of the answer: retrospective reviews. Many of the questions on which EPA is seeking feedback are in the weeds of policy analysis, such as how to grapple with the realities of inadequate data, model limitations, and uncertainty about how to weight various factors. As will always be the case, implicit or explicit decisions will be made to address…

Read more detail on Recent Environmental Law posts –

Related news:

This entry was posted in Environmental Law and tagged , , , , , , , , , . Bookmark the permalink.

Leave a Reply