To: Re: EPA should enhance its presentation and discussion of net benefits.

While the agency appropriately illustrates many benefits of reducing water pollution to wild animals and consequent benefits for humans, it should also recognize additional cascading impacts on both threatened and non-threatened terrestrial animals, based on the links between aquatic and terrestrial ecosystems and the 1 This document does not purport to present the views, if any, of New York Unive. [...] EPA Should Assess Which Option Maximizes Net Benefits, Considering the Differences in Unquantified Benefits Between Different Options EPA compares costs and benefits in its BCA.4 In its main comparison table, EPA shows that monetized costs and benefits increase with regulatory stringency.5 And EPA acknowledges the existence of unquantified “Other Benefits” with a “+” in the “Total Benefits” column. [...] EPA Should Enhance Its Distributional Analysis EPA claims that it “evaluated the distribution of estimated benefits and costs of the proposed regulatory options across the affected population, with consideration of their distribution among communities with environmental justice concerns.”45 In reality, EPA assessed only the distribution of two benefit categories: enhanced drinking water and enhanc. [...] EPA notes that the prior version of Circular A-4 calls for “a separate description of distributional effects (i.e., how both benefits and costs are distributed among sub-populations of particular concern),”56 but the rest of that same sentence makes clear that the purpose of the exercise is “so that decision makers can properly consider them along with the effects on economic efficiency.”57 (Again. [...] EPA Should Apply Its Updated Climate-Damage Estimates in Its Main Analysis EPA valued climate disbenefits using estimates of the social cost of greenhouse gases (SC-GHG) developed by the Interagency Working Group on the Social Cost of Greenhouse Gases (Working Group).62 Although the Working Group’s valuations relied on the best science available at the time of their development, and while EPA robu.