EPA lacks accurate cost benefit analysis for its recent proposal lowering the leak rate for commercial and industrial refrigeration equipment. EPA’s own analysis shows regulatory burden outweighs the benefits to industry by millions of dollars per year. The compliance costs associated with the proposal are estimated by EPA to be $63 million per year (in 2014 dollars) while annual operating savings associated with reduced refrigerant use are estimated to be $52 million, leaving a cost-benefit deficit of $11 million annually. While ABA supports a program in which leaking refrigeration equipment must be repaired, EPA’s analysis for this proposal is flawed.
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