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

October 6, 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.

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