Comment Letter on EPA Review of the Ozone National Ambient Air Quality Standards

October 1, 2020
|
Sean Hecht, Siyi Shen

On October 1, 2020, 40 legal scholars submitted a comment letter to the U.S. Environmental Protection Agency to express their serious concerns with the Trump Administration EPA's proposed revision to air quality standards for ozone, the primary component of smog. The letter, authored by the UCLA Law Emmett Institute's Sean Hecht and Siyi Shen, argues that the composition and role of EPA’s Clean Air Scientific Advisory Committee render the proposed action legally deficient, and will result in National Ambient Air Quality Standards that contravenes Congress’s will.

The signatory scholars are affiliated with 33 universities in 18 states with substantial professional experience in the areas of administrative and environmental law. In addition to the letter's authors, UCLA Law faculty signing the letter include William Boyd, Ann Carlson, Cara Horowitz, Julia Stein. 

Download the comment letter.

News
See All
Jan 29, 2026

Building Capacity for Robust Pesticide Regulation: Part I – Cumulative Impacts

Read More
Jan 20, 2026

Conflict at the Coast: Protecting California’s Coastal Resources by Ensuring the Consistent Application of the Coastal Act’s Conflict Resolution Provisions

Read More
Jan 14, 2026

A Roadmap for Zonal Decarbonization in California

Read More