To: Subject: We make the following recommendations to improve the Proposed Rule’s assessment of

These reclassifications became possible under a rule finalized in 2020, which EPA refers to as the Major MACT to Area or MM2A Rule (2020 Rule).3 We make the following recommendations to improve the Proposed Rule’s assessment of costs and benefits: EPA should assess the costs and benefits of the Proposed Rule, and to the extent that the agency relies on any findings in the 2020 Rule’s Regulatory. [...] EPA Should Provide an Assessment of the Costs and Benefits of the Proposed Rule and Provide a Reasoned Explanation for Deviating from Any of Its Conclusions in the 2020 Rule That Were Based on Flawed Assumptions In the Proposed Rule, EPA notes that it has “not prepared a quantitative analysis of the potential costs and benefits associated with this action,”14 but that it has included the regulator. [...] Acknowledging Flaws in the Analyses Underlying the 2020 Rule and Providing a Reasoned Explanation for Taking Different Positions from the 2020 Analyses To the extent that EPA relies on the RIA and technical analyses, (collectively 2020 Analyses) underlying the 2020 Rule, even if only as illustrative of relevant costs and savings affected by the Proposed Rule, EPA must acknowledge the flaws in thes. [...] EPA Should Consider the Effects of Alternatives to the Proposed Rule EPA should not only assess the costs and benefits of the Proposed Rule, but also of its regulatory alternatives. [...] EPA Should Make a Final Conclusion of Whether the Benefits of the Proposed Rule Justify Its Costs Upon updating its assessment of the costs and benefits of the Proposed Rule and its alternatives, as consistent with the recommendations above, EPA should make a final decision regarding adoption of the Proposed Rule or one of its alternatives.