Clean Water Act Section 316(b) Engagements

Analysis Group and our academic affiliate Professor Robert Stavins have been involved in multiple engagements related to the permitting of cooling water intake and discharge at power plants. Conducted on behalf of individual investor-owned utilities and industry groups, these engagements have included developing original cost-effectiveness and cost-benefit analyses; assessing cost-benefit analyses by regional Environmental Protection Agency (EPA) offices; and commenting on the EPA's nationwide Clean Water Act Section 316(b) Phase II rule making for cooling water intake at existing power plants. Several of our analyses and comments focused on the EPA's estimation of the benefits of reducing cooling water intake at these plants. Subsequent to the submission of our comments, the EPA substantially revised its benefits estimation in the context of both the individual permitting process in which our team was engaged and the EPA's nationwide rule making.