Discipline CAA cost-benefit: targeted pollutant benefits primary; co-benefits separate
Across OAR, Mandate requires consistent transparent cost consideration, appropriate discount rates, focusing benefits on the congressionally targeted pollutant, separately identifying co-benefits, acknowledging quantification uncertainty, updating RACT cost guidance, and obeying CAA §321 employment evaluations.
Mandate
Mandate Ch. 13 (EPA) — OAR cross-cutting reforms: issue rule ensuring consistent transparent consideration of costs; when doing cost-benefit analysis use appropriate discount rates, focus on benefits of reducing pollutant targeted by Congress, identify co-benefits separately, acknowledge uncertainties; review/revise RACT cost guidance; obey CAA §321 continuing evaluations of employment and plant-closure effects; ensure CAA §307(d) procedures observed.
Undo plan
1) Count all meaningful health benefits transparently without double-counting.
2) Publish both targeted-pollutant and co-benefit estimates for public scrutiny.
3) Use OMB Circular A-4 updates carefully with sensitivity analyses.
4) Conduct real §321 employment studies—not ignore or exaggerate.
5) Verify: RIA completeness checklists and retrospective cost audits.