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CATF comments on EPA’s Supplemental Notice of Proposed Rulemaking titled Strengthening Transparency in Regulatory Science

May 18, 2020 Category: Policy Work Area: Power Plants

Clean Air Task Force (CATF) respectfully submits these comments on the U.S. Environmental Protection Agency’s (EPA or Agency) Supplemental Notice of Proposed Rulemaking on “Strengthening Transparency in Regulatory Science” (SNPRM). CATF’s lawyers, scientists, policy analysts, and advocates seek to help safeguard against the worst impacts of air pollution and climate change through research, analysis, and advocacy.

EPA’s use of the best available science, especially the well-established body of research linking air pollution and risk of serious harms to public health, is critically important to the Agency’s ability to meet its statutory obligations. If finalized, this supplemental proposal, like the proposed rule which it expands, would actively impede truly science-based decision-making. It is without legal justification, arbitrary, capricious, and an abuse of the Agency’s discretion.