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Abstract

The Article is a case study regarding a rule governing cooling water towers for power plants promulgated pursuant to the Clean Water Act ("CWA"). It analyzes the history of the Office of Information and Regulatory Affairs ("OIRA") within the Office of Management and Budget ("OMB"), and its influence in compelling the Environmental Protection Agency ("EPA") to conduct cost-benefit analysis of all regulations. It argues that the EPA should not receive Chevron deference since it has acted illegally by interpreting the CWA not as a technology-based environmental law, but instead as a cost-benefit law.

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