Public Comment

EDGI crafted public comments

EDGI’s Public Comment on the EPA’s Supplemental Notice of Proposed Rulemaking: Strengthening Transparency in Regulatory Science

by

While this Supplemental Notice resolves some of the ambiguities of the original proposal (See Public Comment 2 below) , EDGI recommends its rejection. The notice vastly expands the scope of the proposed rule, actively dissuades public input, makes agency decision-making vulnerable to political persuasion, exploits the concept of transparency, and provides an avenue for unwarranted dismissal of high quality science.

EDGI’s Comment on the National Climate Assessment 5

by

This comment supports the themes and framework proposed for the NCA5, and recommends enhancing the overall framework with a
climate justice lens, more substantial discussion of mitigation strategies and potential
effects, and using language commensurate with the climate crisis we are facing. We also recommend including more regional and sub-regional analyses in order to provide information that is resonant and actionable for diverse audiences.

EDGI’s Take on Proposed Revisions Undercutting the Migratory Bird Treaty Act

by
EDGI’s Take on Proposed Revisions Undercutting the Migratory Bird Treaty Act

Photo: Jeffrey Hamilton By Marcy Beck, Gretchen Gehrke, and Aaron Lemelin EDGI welcomed the opportunity to comment on​ the U.S. Fish and Wildlife Service (FWS) Proposed Rule: Migratory Bird Permits; Regulations Governing Take of Migratory Birds (Docket No. FWS-HQ-MB-2018-0090) in March 2020. This rule would narrow the scope of the Migratory Bird Treaty Act (MBTA) … Read more

EDGI Public Comment on Proposed Revisions to Migratory Bird Treaty Act

by

EDGI’s comment addresses a) removals, omissions, and revisions of Migratory Bird Treaty Act (MBTA) resources on the U.S. Fish and Wildlife Service’s (FWS) websites, including those related to incidental take, that constrain the public’s ability to effectively participate in the rulemaking process, along with b) incomplete and selective information in the proposed rule document.

EDGI/EHAC Critiques Trump Admin’s Efforts to Weaken the National Environmental Policy Act

by
EDGI/EHAC Critiques Trump Admin’s Efforts to Weaken the National Environmental Policy Act

In January 2020, the Trump administration proposed dramatic regulatory changes that, if instituted, will undermine one of the nation’s most effective environmental laws, the National Environmental Policy Act (NEPA). The Act, celebrating its 50th anniversary this year, is a cornerstone of the laws and regulations put into place in the 1970s to protect the environment … Read more

EDGI/EHAC’s Public Comments on Proposed Changes to NEPA

by

Submitted by the Environmental History Action Collaborative (EHAC) and members of the Website Monitoring Team, EDGI’s comments finds that the majority of the proposed rule changes are at cross-purposes with the original intent of NEPA, and urges rejection of proposals that: (a) minimize the substantive elements of NEPA; (b) arbitrarily limit the scope and length of EIS review; (c) reduce public participation in the NEPA process; (d) expand categorical exclusions; (e) limit the consideration of indirect and cumulative effects, and (f) restrict judicial review.

EPA MUST PROVIDE MORE ACCESSIBLE AND INFORMATIVE RESOURCES FOR AUTHENTIC PUBLIC COMMENT

by
EPA MUST PROVIDE MORE ACCESSIBLE AND INFORMATIVE RESOURCES FOR AUTHENTIC PUBLIC COMMENT

EDGI’s comment focuses on removals of and reductions in access to online resources directly relevant to the proposed redefinition of Waters of the U.S. (WOTUS) under the Clean Water Act (CWA) that constrain the public’s ability to effectively participate in this rulemaking process, to understand the impacts of the proposed changes to which aquatic resources would be designated as jurisdictional, and to track CWA implementation.

Strengthening Transparency in Regulatory Science

by

In this comment, we show that transparency, best available science, and
meaningful public participation are not the goal of this rule. Rather, the goal is to
reduce the range of evidence that is used in regulatory decision-making and to
make it harder to use scientific evidence that shows harm caused by chemical
exposures. This rule will prevent deeper understanding by scientists, regulators,
and the public of the risks of chemical exposures and, ultimately, will delay action
to protect environmental and public health.

EDGI’s Comment on EPA’s Clean Power Plan (CPP) Proposed Repeal

by

EDGI’s comment points to the substantial amount of information relevant to the Clean Power Plan and its proposed repeal that was removed from the EPA website over the course of the previous year. For the public and regulated bodies to understand the feasibility of implementing the CPP, they must have continued access to comprehensive information about the purpose and scope of the Plan, the basis for calculating its costs and benefits, technological considerations, and proposed implementation strategies. March 12, 2020 Comment Title: “Public Comments on the Proposed Changes to the National Environmental Policy Act. ” Submitted by the Environmental History Action Collaborative (EHAC) and members of the Website Monitoring Team, EDGI’s comments finds that the majority of the proposed rule changes are at cross-purposes with the original intent of NEPA, and urges rejection of proposals that: (a) minimize the substantive elements of NEPA; (b) arbitrarily limit the scope and length of EIS review; (c) reduce public participation in the NEPA process; (d) expand categorical exclusions; (e) limit the consideration of indirect and cumulative effects, and (f) restrict judicial review.