NACWA Comments on EPA’s Cost Benefit Proposal
NACWA submitted comments on August 13 in response to EPA’s recent advanced notice of proposed rulemaking (APRM),< Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process, that sought public comment on how the Agency should consider costs and benefits and whether the Agency can increase consistency and better improve transparency across all environmental statutes.
NACWA’s comments suggest five overarching considerations—in addition to addressing water affordability across all regulatory activities—that EPA should reflect upon as it works to advance this issue. Against the backdrop of statutory constraints, NACWA’s considerations for the Agency include 1) more consistent definitions and less arbitrary interpretations when it comes to costs and benefits; 2) how increasingly more stringent regulations impact the water sector; 3) inclusion of net environmental benefit into future rulemakings; 4) the complexities of co-benefits and how to address these in rules; and 5) increasing transparency in the administrative record.
Although it is encouraging to see EPA broadly consider costs and benefits and how they play out across environmental regulatory paradigms, it is unclear how EPA would actually move forward and achieve increased consistency or greater transparency without Congressional action to revise existing environmental statutes.
NACWA will continue to engage with EPA on this important issue. Contact Emily Remmel, Director of Regulatory Affairs, with further questions.