ERCC Letter to OIRA Administrator Cass Sunstein

November 14, 2011

The Electric Reliability Coordinating Council (ERCC) sent a hard hitting letter to OMB officials reviewing the EPA utility MACT Rule and pointing out in detail the failure of EPA to address concerns with electric reliability, including recent revelations that they deleted important lines of inquiry from the preamble to the rule without making any changes to the rule itself that pertain to reliability.  The letter addresses the data on reliability and concepts like the safety valve.  The letter also unpacks the EPA’s benefits analysis and demonstrates that its sheer cost and inflexibility is likely to make matters worse from a public health perspective.