December 28, 2018
On behalf of its members, NAFEM has responded to an advance notice of potential rulemaking from the Environmental Protection Agency (EPA). The agency is seeking to understand how to best consider costs and benefits in the regulatory process. In its comments to the agency, NAFEM stated that:
- A consistent approach to cost-benefit analyses is important not only for EPA rulemaking, but across agencies, especially those that are regulating the same or similar products, processes or industries.
- Transparency is key to help ensure that appropriate cost-benefit reviews are conducted fairly and based on verifiable data. In the past, EPA has significantly underestimated the costs and impact of various regulations. Transparency will help address this concern.
- Retrospective reviews are critical to sound rulemaking. They help the agency better understand challenges businesses face complying with regulations and help the public understand how complex regulatory mandates are becoming.
NAFEM will continue to monitor EPA’s action on this topic.