Public Comments

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 …

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 …

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 …

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 …

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 …

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 …

Late last fall, the Office of Science and Technology Policy (OSTP) sought to gather information and feedback for developing a coordinated Federal strategy to identify and address gaps in science, data, and research related to environmental justice. EDGI submitted a public comment responding to OSTP’s questions.   Below are …

The draft Guidelines for Cumulative Risk Assessment Planning and Problem Formulation include some strides forward in the agency’s approach to CRAs. However, we at EDGI are disappointed that the guidelines provide very little guidance for risk assessors to actually integrate cumulative risks into their assessment process …

This comment and a related oral comment were delivered to the FOIA Advisory Committee. The comment urges the FOIA Advisory Committee to guide agencies to preserve key features of FOIAonline as agencies launch independent FOIA portals, particularly: (1) the public posting of completed requests, (2) the ability to …

This comment and a related oral comment were delivered to the Chief FOIA Officers Council. The comment petitions the Chief FOIA Officers Council to maintain and improve the public accessibility of records released through FOIAonline when agencies launch independent FOIA portals, especially through (1) maintaining the public availability …

We urge the CFO Council to consider the federal efficiencies that can be gleaned by providing browsing and powerful search functioning in agency or government-wide FOIA portals. The better the public is able to browse and search material that has already been laboriously collected, collated, and disseminated by …

Comment Title: “Comments by the Environmental Data and Governance Initiative on Broadening Public Engagement in the Federal Regulatory Process.” This comment urges the Office of Information and Regulatory Affairs (OIRA) to address information policy gaps that will undermine efforts to broaden public engagement in regulatory affairs, particularly the …