Washington, D.C. August 14, 2018 – EDF and a group of environmental, conservation, and social justice organizations yesterday submitted comments to Environmental Protection Agency urging it not to move ahead on an ‘Advance Notice of Proposed Rulemaking’ that could lead the Agency to undercount the huge health and environmental benefits of standards. As the comments note, EPA has an obligation to fully account for all the benefits that result from EPA health safeguards and pollution limits– including co-benefits for health and the environment – and cannot use the existence of some degree of uncertainty as an excuse to ignore potential benefits.
The comments also strongly oppose EPA’s efforts to ignore well-established science showing that reducing harmful particulate matter pollution saves lives and improves health at all levels of exposure.
As the comments state: “Despite the tremendous record of success demonstrated by EPA safeguards, and the enormous benefits they provide for the health and well-being of the American public, the current administration has relentlessly sought to undermine and dismantle these life-saving protections. . . This notice is another piece of the administration’s efforts to undermine justifications for protections that safeguard our health and well-being.”
The comments were joined by Environmental Law & Policy Center, National LGBTQ Task Force, National Parks Conservation Association, Natural Resources Defense Council, and Waterkeeper Alliance. A diverse array of other organizations, including the National Association of Clean Air Agencies, have also voiced concerns about this notice.
The notice seeks comment on potential action by EPA to promulgate a rule purportedly to increase consistency and transparency in the consideration of weighing costs and benefits in making regulatory decisions. However, it responds directly to requests from industry polluters for EPA to irrationally devalue actual health and environmental benefits resulting from protections including lives saved, asthma attacks avoided, and school and work days that otherwise would have been lost. This would undermine bedrock health and clean air protections, further endangering communities across the nation.