On July 1, 2020, EPN members Roy Gamse (on behalf of himself), Vijay Limaye (on behalf of the Natural Resources Defense Council), and Wayne Nastri (on behalf of the South Coast Air Quality Management District) presented testimony on the proposed rulemaking “Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act (CAA) Rulemaking Process” during a virtual public hearing. This proposed rulemaking would have far- reaching negative implications, undermines science, and could encourage unnecessary litigation over future rules. EPA should instead focus on implementing and improving existing economic guidelines and practices to ensure the development of robust, transparent cost-benefit analysis.
Read the testimony of EPN member Roy Gamse, former EPA Deputy Assistant Administrator for Planning and Evaluation and Acting Assistant Administrator for Planning and Management.
Read the testimony of EPN member Vijay Limaye, former Physical Scientist, Air Monitoring and Analysis Section, Air and Radiation Division, EPA Region 5, who spoke on behalf of the Natural Resources Defense Council.
Read the testimony of EPN member Wayne Nastri, former EPA Administrator, Region 9, who spoke on behalf of the South Coast Air Quality Management District.