These comments review a cost-benefit analysis done by the EPA of four regulatory options and discuss the agency’s use of the cost-benefit framework in the regulatory process. They offer more complete estimates of benefits, look more closely at projected electricity market and employment impacts, and identify problems with non-monetizable values that make cost-benefit analysis less useful in this context. In addition, they argue against the EPA’s recommendation of site-specific decisions, which would shift the burden of cost-benefit analysis onto individual states.