cover image: March 25, 2024 Michael S. Regan, Administrator


March 25, 2024 Michael S. Regan, Administrator

25 Mar 2024

2 (“[T]he RIA for this action analyzes the benefits associated with the projected emissions reductions under this proposal to inform the EPA and the public about these projected impacts.”) In reality, the RIA exposes the invalidity of the Agency’s unsupportable speculation regarding health benefits. [...] Specifically, EPA’s use of the BPT method for the LMWC sector was devoid of any of the sector-specific information that proper use of the BPT method requires. [...] EPA has developed tools and models for life cycle analyses that would enable the agency to more comprehensively consider the secondary impacts of the proposed rule, including the risk of facility closure and diversion of MSW to landfills.27 But it has failed to apply these tools and best practices to the present rulemaking. [...] Together, we must listen to science and meet the moment.”43 While much has been said throughout this rulemaking of the environmental justice impacts of the WTE industry, EPA has once again ignored the other side of the ledger, and the well-documented disparity in climate impacts among socio-economic and ethnic groups. [...] 22 FG: 102498371.5 While we understand that the quality of EPA’s estimates depends on the quality of the data available to the Agency, EPA’s refusal to give the communities we represent additional comment time for purposes of supplying the Agency with better cost and feasibility data is not defensible given Agency representatives’ acknowledgement of the need for accurate and reliable data.


Jennifer Sy Lopez

Published in
United States of America

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