Category: Public Comment

EDGI crafted public comments

Advancing Public Participation and Community Engagement with the Federal Government
Blog, Public Comment

Advancing Public Participation and Community Engagement with the Federal Government

This comment stresses that the federal government should strive to increase the tangible impact of public participation in federal decision-making. To do this, EDGI recommends OMB design public participation processes that have the appropriate timing and depth to meaningfully influence government actions, and to develop standards for information management to ensure the public can easily learn about issues and opportunities for input.

EDGI Urges White House Scientific Integrity Task Force to Improve Public Information Policies
Blog, Public Comment

EDGI Urges White House Scientific Integrity Task Force to Improve Public Information Policies

Stronger public information policies are necessary for stronger scientific integrity policies. This comment underscores that relationship by providing specific examples of federal website information management decisions during the Trump administration that were at odds with scientific integrity and undermined public trust. The comment then relays a series of recommendations to promote and protect the free flow of scientific information from the government to the public, and utilize websites as a vehicle for building public trust in the government by facilitating greater environmental, scientific, and civic literacy.

Blog, New, Public Comment

EDGI Urges EPA to Withdraw its Ill-Conceived ‘Strengthening Transparency in Regulatory Science’ Proposed Rule

The Environmental Data and Governance Initiative (EDGI) has submitted a public comment on the Environmental Protection Agency’s (EPA) Supplemental Notice of Proposed Rulemaking (SNPRM) regarding its proposed Strengthening Transparency in Regulatory Science rule (STRS), Docket number EPA-HQ-OA-2019-0259-9322. We welcome you to read and draw material from the comment we submitted and urge you to submit a comment as well. The deadline for comments is May 18, 2020.

The EPA’s original 2018 proposal for the STRS rule represented a sweeping proposition to upend the use of science in the EPA’s regulatory developments and decisions. The STRS would require that data and models underlying scientific studies that are pivotal to regulatory action be available to the public, and “dose response data and models” used in regulatory decision-making available for independent validation. The proposed rule states that that would ensure that EPA relied on “best available science” that “enhance the public’s ability to understand and meaningfully participate in the regulatory process.” EDGI’s 2018 public comment on the proposed rule details its problematic ambiguity and misappropriation of transparency to stymie science-based regulations intended to protect human and environmental health…

Archived, Public Comment

EDGI Public Comment on Proposed Revisions to Migratory Bird Treaty Act

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.

Archived, Public Comment

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

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.