Andrew Wheeler’s Trojan Horse for Clean Air Act Regulation
نویسندگان
چکیده
On December 9, 2020, EPA issued a new rule deceptively titled, Increasing Consistency and Transparency in Considering Benefits Costs the Clean Air Act Rulemaking Process. The has been widely justly criticized for requiring to publish numerical estimates of regulatory benefits that exclude ancillary “co-benefits.” This short essay endorses critique but argues this (and existing literature about rule) misses most important damaging accomplishment rule: if implemented, will add at least forty-two mandatory steps must undertake -- on pain judicial challenge reversal court – cost-benefit analysis all rules under authority Act. Many these are time-consuming burdensome. Some may be impossible complete, due limitations available data science. foreseeable result paralysis by analysis, or litigation. While Biden Administration is taking overturn rule, aptly illustrates toolkit analytical rhetorical techniques which harmful law policy presented as benign.
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ژورنال
عنوان ژورنال: Social Science Research Network
سال: 2021
ISSN: ['1556-5068']
DOI: https://doi.org/10.2139/ssrn.3837654