Public comments are a critical component of environmental decision-making, and a cornerstone of democratic participation in federal rule-making.
October 7, 2026
EDGI’s Public Comment on Proposed Definition of Waters of the United States
On September 9, 2026, the Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers released a Supplemental Notice of Proposed Rulemaking (SNPRM) seeking further comment on the November 2025 proposed rule to update the definition of “Waters of the United States” (WOTUS). The agencies seek comment …
October 6, 2026
EDGI’s Comment on the Updated Proposal for the Definition of “Waters of the United States” (10/6/26)
The Environmental Data & Governance Initiative (EDGI) opposes the regulatory alternatives presented in the Supplemental Notice of Proposed Rulemaking (SNPRM) on the basis that they do not address concerns raised in our public comment on the original Notice of Proposed Rulemaking (NPRM, or “proposed rule”) for an updated …
August 26, 2026
EDGI’s Comment on NSF’s Proposal to Politicize Grantmaking
The Environmental Data & Governance Initiative (EDGI) opposes the proposed revisions to the NSF’s Proposal and Award Policies and Procedures Guide (PAPPG) and we urge the agency to revoke the proposed guidance on financial assistance (GFA) in its entirety …
July 17, 2026
EDGI’s Comment on EPA’s Proposal to Weaken PFAS Regulations
The Environmental Data & Governance Initiative (EDGI) opposes the proposed rescission of regulatory determinations and MCLs for PFHxS, PFNA, HFPO-DA (GenX), and mixtures of these three PFAS plus PFBS on the basis that the proposed rule is not in line with the administration’s continued publication of information on …
July 13, 2026
EDGI’s Comment on OMB’s Proposal to Politicize Federal Grantmaking
The Environmental Data & Governance Initiative (EDGI) opposes the proposed changes to the OMB Guidance for Federal Financial Assistance because they would undermine the integrity, quality, and accessibility of federally-funded research. The proposed rule would place significant administrative and financial burdens on research institutions of the United States, …
May 11, 2026
EDGI’s Comment on EPA’s Proposal to Weaken the Risk Management Program
The Environmental Data & Governance Initiative (EDGI) opposes the proposed weakening of Risk Management Programs under the Clean Air Act on the basis that the proposed rule provides inadequate justifications for limiting information availability; the proposed rule places first responders, facility workers, and fenceline communities in unnecessary risk; …
May 2, 2026
EDGI’s Comment to the EPA on its Proposal to Weaken Standards for Ethylene Oxide Emissions
The Environmental Data and Governance asserts that the removal and restriction of access to resources relevant to the EPA’s proposed rule undermines the notice-and-comment rulemaking process by restricting commenters’ ability to account for the harms, risks, and impacts of ethylene oxide in their comments. By removing EPA webpages …
January 5, 2026
EDGI’s Comment on the Proposed Redefinition of “Waters of the United States”
EDGI opposes the proposed redefinition of “Waters of the United States” on the basis that 1. the proposed rule lacks consideration of relevant impacts of climate change, and 2. the agencies have removed and restricted access to crucial web resources relevant to the proposed rule before and during …
November 3, 2025
EDGI’s Comment to the EPA on the Proposed Reconsideration of the Greenhouse Gas Reporting Program
Since its inception in 2009, the Greenhouse Gas Reporting Program (GHGRP) has provided the Environmental Protection Agency (EPA) and other agencies, industry, and stakeholders with valuable, standardized data on direct greenhouse gas (GHG) emissions from facilities and indirect emissions from fuel suppliers. The GHGRP has produced the most …
September 22, 2025
EDGI’s Comment to the EPA on the Reconsideration of the Endangerment Finding and Greenhouse Gas Vehicle Standards
EDGI opposes the proposal to rescind the Environmental Protection Agency’s (EPA) Endangerment Finding under Section 202(a) of the Clean Air Act. EDGI analyzes changes to environmental governance policies and practices, including the federal provision of public information, and our findings demonstrate that the EPA has restricted public access …
August 29, 2025
EDGI’s Comment to Michigan Department of Environment on Enbridge’s Line 5 Proposed Tunnel Construction (8/29/25)
The Environmental Data and Governance Initiative – Environmental Enforcement Watch recommends that this permit be denied, and underscores calls from Oil and Water Don’t Mix and others for a full Great Lakes Submerged Lands Act review of Enbridge’s proposal …
October 23, 2024
EDGI’s Comment to the EPA on the Proposed High-Priority Substance Designations under the Toxic Substances Control Act (TSCA); Vinyl Chloride
We support EPA’s determination to reopen vinyl chloride’s risk prioritization. We encourage the EPA to go further. The historical evidence shows that the industry has pushed against the known evidence of harm to communities, workers, and the U.S. public as vinyl chloride (especially given the replacement of lead …