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ITSSD continues battle against Clean Power Plan

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World Coal,

The Institute for Trade, Standards and Sustainable Development (ITSSD) has filed a supplement to its initial comments on the US Environmental Protection Agency’s (EPA) Clean Power Plan (CPP).

The supplementary filing adds new information regarding alleged compliance violations of the Information Quality Act (IQA) peer review requirements by three EPA-developed climate change assessments. These assessments form the basis for the proposed CPP regulation.

Under the IQA and applicable EPA IQA-implementing standards, the EPA is required to ensure that the peer reviews of the three assessments – as well as ten other reports from the National Oceanic and Atmospheric Administration, upon which EPA primarily relied as scientific foundation for said rule – satisfied the “most rigorous” IQA guidelines ensuring that selected peer reviewers are “financially and intellectually independent” and free from institutional as well as individual conflicts of interest.

“Since [the] EPA did not validate that the peer reviews of these thirteen assessments had fully satisfied such applicated IQA standards, [the] EPA is precluded, as a matter of law, from relying on [them] as the scientific foundation […] of the CPP,” the ITSSD concluded in its supplementary filing.

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