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Students File Comments on EPA's Clean Power Repeal
Pennsylvania Ag Connection - 02/12/2018

University of Pennsylvania law students from the Environmental Law Project (ELP) have submitted a filing with the Environmental Protection Agency in response to its proposed repeal of the Clean Power Plan.

In the filing, the students argue that the proposed repeal is not supported by scientific evidence, and that the agency's change in course is not supported by a valid justification.

"The rescission of a rule requires the same level of justification as the implementation of a rule in the first instance; just as if it were implementing a new rule, EPA must provide support grounded in scientific evidence for its proposed rescission of the CPP," the students write in their comment. "EPA has failed to do so."

The Environmental Law Project is a pro bono student project that fosters campus discussion of environmental issues and connects interested students to opportunities to explore environmental legal practice. Thirteen students from the ELP worked on the project to draft the comment, which was led by Paul Stephan L'18 and Garrison Todd L'18. The ELP is led by Adeline Rolnick L'18 and Nicholas Bellos L'19.

"ELP's regulatory project provides law students with the distinctive opportunity to earn pro bono hours by participating in the rulemaking process," said Rolnick. "With the support of the Toll Public Interest Center, Professor Coglianese, and our student board members, our volunteers have the opportunity to gain a hands-on administrative law education and to influence important environmental policies."

"For about 10 years now, students involved in ELP have contributed vitally to the development of environmental regulation by filing public interest comments," said Professor Cary Coglianese, an expert on regulation and the Director of the Penn Program on Regulation. "The ELP's 'Notice-and-Comment Project' not only provides Penn Law students a distinctive experiential learning opportunity, but it also affords them meaningful opportunity to make an impact on the development of environmental law."

In terms of this year's comment, Coglianese explained that Penn Law's ELP has picked a major environmental rulemaking. "The Clean Power Plan was the anchor of the U.S. domestic policy with respect to climate change under the Obama Administration," he said.

Although President Trump singled out the Clean Power Plan for revision or repeal in an executive order he issued in early 2017, the EPA still must go through the full notice-and-comment rulemaking process to make changes to the Clean Power Plan. "Even when the direction of the agency is clear, public comments can shape the specifics of how the agency proceeds as well as provide arguments for what will be, in a rulemaking like this, an inevitable round of litigation," Coglianese noted.

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