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Comments on Proposed Interim Registration Review Decision for Chlorpyrifos and Revised Draft Human Health Risk Assessment, 85 Fed. Reg. 78,849

On February 5, 2021, the Clinic submitted a comment letter urging the Environmental Protection Agency (EPA) to reverse its proposed registration decision for chlorpyrifos and revise the underlying Human Health Risk Assessment (HHRA). The Clinic’s letter calls into question EPA’s decision to use 10% red blood cell acetyl cholinesterase (AChE)…

February 05, 2021

Comments On Strengthening Transparency in Regulatory Science, Supplemental Notice of Proposed Rulemaking 85 Fed. Reg. 15,396 (Mar. 18, 2020) [Docket ID No. EPA–HQ–OA–2018–0259]

On May 18, 2020, the Clinic filed comments on the U.S. Environmental Protection Agency’s supplemental notice for its “Strengthening Transparency in Regulatory Science” proposal on behalf of Harvard President Lawrence Bacow and more than three dozen other leaders in science and medicine from Harvard University. The supplemental notice expands on…

May 18, 2020

Comments On Proposed Rule: Update to The Regulations Implementing the Procedural Provisions of the National Environmental Policy Act, 85 Fed. Reg. 1,684 (Jan. 10, 2020) (Docket ID No. CEQ-2019-0003)

On March 10, 2020, the Clinic submitted comments on behalf of itself and 15 other environmental law clinics on the Council on Environmental Quality’s (CEQ) proposed update to its Regulations Implementing the Procedural Provisions of the National Environmental Policy Act (NEPA). The comments request that CEQ withdraw the proposal because…

March 10, 2020

Comments regarding health equity, environmental justice, and civil rights aspects of proposed revisions to its Lead and Copper Rule in the National Primary Drinking Water Regulations, Docket No. EPA–HQ–OW-2017-0300

These comments submitted by the Clinic, Environmental Defense Fund (EDF), and Dr. Karen Baehler of American University focus on the health equity, environmental justice, and civil rights aspects of the EPA’s proposed revisions to its Lead and Copper Rule (LCR). The Clinic’s/EDF’s analysis of the proposed revisions, as well as…

February 14, 2020

Written Statement for SAB’s draft report on the National Emission Standards for Hazardous Air Pollutants: Coal- and Oil- Fired Electric Utility Steam Generating Units—Reconsideration of Supplemental Finding and Residual Risk and Technology Review, 84 Fed. Reg. 2670

On January 10, 2020, the Clinic submitted comments to the EPA Science Advisory Board (“SAB”) on the SAB’s draft report on the National Emission Standards for Hazardous Air Pollutants: Coal- and Oil- Fired Electric Utility Steam Generating Units—Reconsideration of Supplemental Finding and Residual Risk and Technology Review, 84 Fed. Reg.

January 10, 2020