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WASHINGTON (May 21, 2019) – The American Chemistry Council (ACC) issued the following statement in support of the U.S. Environmental Protection Agency (EPA) memorandum, “Improving Consistency and Transparency in Considering Benefits and Costs in the Rulemaking Process.” ACC previously filed comments with EPA on this issue.

“We welcome EPA’s plan to improve cost-benefit analysis in regulatory decision-making. Efficient and effective rulemaking requires a realistic assessment of economic impacts, and we commend Administrator Wheeler for taking action to clarify, standardize and bring greater transparency to the process. We applaud EPA’s commitment to following sound economic and scientific principles in benefit-cost analysis, and we look forward to its updated ‘Guidelines for Preparing Economic Analyses.’

“ACC has called for an improved regulatory assessment model that reflects cumulative impacts, applies consistent standards in the use of scientific data and sources, and is clear about its approach so that methodologies and effects are well understood. Greater certainty will promote growth and investment in the U.S. chemistry industry and manufacturing sector.

“We endorse the established principle that agencies should regulate only when benefits outweigh costs, as embodied in numerous executive orders over many years. For example, EO 12866 directs EPA to strive to maximize net benefits by requiring full cost-benefit balancing, unless specifically prohibited by statute. The White House Office of Management and Budget (OMB) has provided valuable guidance to agencies, but it is rarely followed.

“Additionally, the use of objective risk assessments that utilize the best available science and a weight of the scientific evidence approach are critical to effective cost-benefit analysis.

“Cost-benefit analysis can help policymakers and the public understand the consequences of proposed regulations on jobs, investment, economic growth and the competitiveness of U.S. manufacturing in global markets. With proper reforms, cost-benefit analysis can continue to fulfill its important role in federal regulatory review.”


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