Prior to the
The OMB also suggested the
"The commenter believes that it would be appropriate for the proposed rule to consider the full range of cost estimates developed by [the
For both queries, the
"Despite NETL's best efforts to accurately estimate costs, it is widely accepted among cost estimation professionals that projections of [nth-of-a-kind] costs for technologies that are still under development are typically lower than the actual costs that are eventually realized," the OMB wrote.
"Nth-of-a-kind" technology refers to future technology, and is often cheaper because "first-of-a-kind" technology hasn't had all the kinks worked out and is less efficient. Think about how expensive cellphones used to be and how accessible they are now.
" 'Next-of-a-kind' costs will not be realized before more demonstration projects proceed," the OMB wrote.
Ten days later, on
The reason for such a clarification to be removed,
"We believe that the text starting with 'despite the application.....' should be deleted because it is conjecture and not factual (and ignores the other side of the story, because it is often shown that projections like this are unnecessarily pessimistic and costs," Culligan said.
Except that the rule won't have an impact on reducing emissions and is more about positioning the U.S. as a supposed leader on global warming initiatives.
That's evidenced by the fact that while the OMB urged the
Prior to the