Comment Letter for 100 Legal Scholars on EPA Supplemental Notice of Proposed Rulemaking—Strengthening Transparency in Regulatory Science

May 18, 2020
|
Sean Hecht, Julia Stein

On May 18, 2020, Emmett Institute supervising attorney and project director Julia Stein and co-executive director Sean Hecht filed a comment letter to EPA on behalf of 100 U.S. law professors urging the agency to withdraw its revamped “Transparency in Science” rule. As written, the rule would foreclose EPA’s ability to rely on important peer-reviewed scientific studies that inform key environmental protections, like safe drinking water standards and pesticide regulations, where the underlying data supporting those studies are not publicly available. EPA's proposal strikes at the very heart of the agency's mission, in clear contravention of EPA’s authorizing statutes. The letter shows that EPA cannot discharge its legal obligations to consider the best science in the name of protecting public health and the environment if controlled by this rule’s limitations. 

Download the comment letter.

News
See All
Apr 20, 2026

Spotlight on the Top 25 Methane Plumes in 2025: Landfills

Read More
Apr 06, 2026

Non-Pipeline Alternatives to Accelerate California’s Gas Transition

Read More
Mar 30, 2026

The Price of Resilience: Understanding Wildfire Cost Allocation in the Transmission Context

Read More