By not monetizing the effects of regulatory actions as they pertain to EJ issues, analysts run the risk of presenting information in ways that will cause decisionmakers and the public to overlook important consequences due to 1 This document does not purport to represent the views, if any, of New York University School of Law. [...] Background EPA first published the Technical Guidance for Assessing Environmental Justice in Regulatory Analysis (EJ Technical Guidance) in 2016.3 The purpose of the EJ Technical Guidance was to outline analytic expectations and discuss technical approaches and methods that can be used by EPA analysts to evaluate the environmental justice (EJ) effects of regulatory actions. [...] For the Draft Revised EJ Technical Guidance, EPA states, “[u]pdates to the technical guidance reflect advancements in the state of the science; other new peer-reviewed Agency guidance documents; and new priorities and direction related to the conduct of EJ analysis, including Executive Order 14096.”4 I. [...] According to the principle of diminishing marginal utility, each additional unit of consumption provides incrementally lesser benefits to the recipient, implying that one-dollar worth of consumption has a greater impact on the welfare of a poor person than it does on the welfare of a wealthy person. [...] According to the principle of diminishing marginal utility, each additional unit of consumption provides incrementally lesser benefits to the recipient, implying that one-dollar worth of consumption has a greater impact on the welfare of a poor person than it does on the welfare of a wealthy person.
Authors
- Pages
- 6
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- United States of America
Table of Contents
- Report on the EPAs Draft Technical Guidance for Assessing Environmental Justice in Regulatory Analysis 1
- 1. The SAB should advise EPA to distinguish EJ analyses from analyses that 1
- 2. When conducting quantitative analyses the SAB should advise EPA to encourage 1
- 3. If EPA determines that it cannot conduct a particular analysis or cannot fully 2
- 4. The SAB should advise EPA to consider the EJ implications of its actions or 2
- Background 2
- Technical Guidance for Assessing Environmental Justice in Regulatory Analysis 2
- I. EPA Should Distinguish EJ Analyses From Analyses That Assess Distributional Effects in the Draft Revised EJTG. 2
- II. EPA Should Encourage Analysts to Monetize Effects When Feasible Instead of Presenting Only Quantitative Probability Risks or Volumetric Values 3
- III. EPA Should Instruct Analysts to Document Justifications for Decisions to Not Conduct a Particular Analysis 4
- IV. EPA Should Instruct Analysts to Consider EJ Issues as Early as Possible Rulemaking Process and then Reconsider Iteratively as Part of the Same Process. 5