Protect the Integrity of Science

Apr 6, 2020

The Environmental Protection Agency, in the middle of the COVID-19 pandemic, wants to change the way they value expertise and cherry-pick the data that they use to create regulations that affect public health. Help protect the integrity of sound science by joining us in opposition to this rule.

TAKE ACTION: Please copy the text listed below and paste it in the submission box on this page:

Please reach out to us at [email protected] if you have questions.

Cheryl A. Hawkins, PhD
U.S. Environmental Protection Agency
EPA Docket Center, Office of Research and Development Docket
Mail Code 28221T, 1200 Pennsylvania Avenue NW
Washington, DC 20460

Re.: Docket ID No. EPA-HQ-OA-2018-0259-9322

Dr. Hawkins:

I write with regard to the Environmental Protection Agency’s (EPA) supplemental notice of proposed rulemaking (SNPRM) that proposes changes and modifications to the proposed rule titled “Strengthening Transparency in Regulatory Science Proposed Rulemaking” (“2018 proposed rulemaking,” Ref. 1), published on April 30, 2018. I encourage the Administrator to extend the comment period by 30 days past the conclusion of the national emergency declaration to allow thorough input from the scientific community which is currently dealing with a public health crisis, or withdraw the SNPRM and the underlying 2018 proposed rulemaking altogether.

We are currently in the middle of a pandemic that the medical and scientific community gave ample warning about. Changing the way we value the expertise of the scientific community and the data they collect in the middle of this pandemic is irresponsible. The ‘tiered consideration’ system that EPA is proposing in 40 CFR 30.5 could create instances where regulatory decisions are based on incomplete data that result in situations with increased adverse health implications. Moreover, scientists who are on the front lines battling this pandemic should not be asked to pause their work to comment on these matters.

A thriving economy means nothing if there are no healthy people to participate in it. Policymaking institutions, such as the EPA, that have mandates to safeguard public health can create the necessary regulatory environments to keep our nation productive while limiting harmful pollutants. This SNPRM and the proposed rulemaking is directly at odds with the EPA’s mission and can potentially lead to regulations that put short-term economic benefits ahead of long-term economic and public health benefits.

Thank you for your full consideration of my comments in accordance with all applicable laws, rules, and regulations.


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