CATF opposes any proposal that is inconsistent with EPA’s use of the best available science for regulatory decisions that impact public health and the environment. We strongly urge EPA to reconsider this proposal, and to take the blanket exclusion option off the table.
The expansion of the rule’s scope and potential implications for regulatory science are very disturbing — especially as this proposal will have retroactive effect. This could undermine the use of foundational research like the Harvard Six Cities and American Cancer Society studies although hundreds of other studies have built upon and reinforced the direct link between pollution exposures and significant public health damages, even premature deaths, including studies based on the publicly-available Medicare cohort.
EPA’s directive that all data be made public undermines the science because the reality is that participants in these studies have the right to demand that personal health information be kept private, and scientists generally agree to do so. EPA should not propose any rule that jeopardizes this practice.
We also strongly urge the agency to clearly identify the problem it seeks to address and how this proposal would solve that problem. Vague appeals to transparency do not warrant the agency impairing its use of quality science. EPA already has peer review processes in place to evaluate influential scientific information that the agency relies on for its regulations.
Finally, we are of the opinion that the agency does not have the necessary statutory authority to implement this rule. This proposal appears to be inconsistent with the Clean Air Act’s mandate to use the latest scientific knowledge, and the statute cited as authority for this rule does not appear to apply to EPA.
Contact: Stuart C. Ross, 914-649-5037 (cell), firstname.lastname@example.org