Public Comments

Public comments are a critical component of environmental decision-making, and a cornerstone of democratic participation in federal rule-making.

EDGI’s Public Comment on Proposed Definition of Waters of the United States

October 7, 2026
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 …

EDGI’s Comment on the Updated Proposal for the Definition of “Waters of the United States” (10/6/26)

October 6, 2026
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 …

EDGI’s Comment on NSF’s Proposal to Politicize Grantmaking

August 26, 2026
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 …

EDGI’s Comment on EPA’s Proposal to Weaken PFAS Regulations

July 17, 2026
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 …

EDGI’s Comment on OMB’s Proposal to Politicize Federal Grantmaking

July 13, 2026
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, …

EDGI’s Comment on EPA’s Proposal to Weaken the Risk Management Program

May 11, 2026
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; …

EDGI’s Comment to the EPA on its Proposal to Weaken Standards for Ethylene Oxide Emissions

May 2, 2026
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 …

EDGI’s Comment on the Proposed Redefinition of “Waters of the United States”

January 5, 2026
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 …

EDGI’s Comment to the EPA on the Proposed Reconsideration of the Greenhouse Gas Reporting Program

November 3, 2025
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’s Comment to the EPA on the Reconsideration of the Endangerment Finding and Greenhouse Gas Vehicle Standards

September 22, 2025
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 …

EDGI’s Comment to Michigan Department of Environment on Enbridge’s Line 5 Proposed Tunnel Construction (8/29/25)

August 29, 2025
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 …

EDGI’s Comment to the EPA on the Proposed High-Priority Substance Designations under the Toxic Substances Control Act (TSCA); Vinyl Chloride

October 23, 2024
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 …
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