Comment Letter for 100 Legal Scholars on EPA Supplemental Notice of Proposed Rulemaking—Strengthening Transparency in Regulatory Science

October 9, 2020
Sean Hecht, Julia Stein

On May 18, 2020, Emmett Institute supervising attorney and project director Julia Stein and co-executive director Sean Hecht filed a comment letter to EPA on behalf of 100 U.S. law professors urging the agency to withdraw its revamped “Transparency in Science” rule. As written, the rule would foreclose EPA’s ability to rely on important peer-reviewed scientific studies that inform key environmental protections, like safe drinking water standards and pesticide regulations, where the underlying data supporting those studies are not publicly available. EPA's proposal strikes at the very heart of the agency's mission, in clear contravention of EPA’s authorizing statutes. The letter shows that EPA cannot discharge its legal obligations to consider the best science in the name of protecting public health and the environment if controlled by this rule’s limitations. 

Download the comment letter.

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