Public Comments

EDGI supports the thoughtful and thorough recommendations presented by OIRA, and we want to bring attention to a key obstacle to public engagement that is not addressed by these recommendations: the lack of required regulatory information on agency websites. Without addressing this policy gap, the effectiveness of other …

We generally support the CEJST methodology, and believe it can deliver tangible benefits to communities. With that goal in mind, we believe CEQ should consider: EDGI’s Comment on CEQ-2022-0002 1 1. Expanding the list of communities (Census tracts) based on the inclusion of additional criteria, namely, indicators related …

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 …

Chelsea River, aka Chelsea Creek, is the site of seven oil storage facilities whose permits, issued by EPA Region 1 under National Pollutant Discharge Elimination Systems (NPDES), are up for renewal this year. These facilities store 70-80% of the New England region’s heating oil and all of the …

Overall we commend the proposed themes and framework for NCA5, and offer additional recommendations to strengthen the reception and utilization of the information provided by this assessment …

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 …

EDGI’s comment addresses the dissonance between the anticipated impacts of three proposed action alternatives and the US Fish and Wildlife Service’s (FWS) assignment of Alternative A–codifying the interpretation in the DOI Solicitor Opinion M-37050 that the MBTA does not prohibit incidental take–as the agency’s proposed action. EDGI urges …

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 …

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 …

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 …

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 …

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 …