Mr. Bloomberg and Dr. Smith provided technical comments on behalf of The Fertilizer Institute on the EPA’s proposed amendments to National Emission Standards for Hazardous Air Pollutants (NESHAP) for the phosphoric acid manufacturing and phosphate fertilizer production source categories. The analysis focused on EPA’s proposal to replace the current total fluoride (F) limit with a hydrogen fluoride (HF) limit for phosphate fertilizer production. Using an economic analysis of proposed costs and the absence of any identifiable benefits, Mr. Bloomberg and Dr. Smith demonstrated that EPA’s proposal to test for HF instead of total F clearly fails the benefit-cost test. This means that this regulatory provision will result in an inefficient (i.e., wasteful) reallocation of societal resources and is inconsistent with the objectives of good regulation as summarized in Executive Orders 12866 and 13563.