“It has been EPA’s practice, and often a legal requirement, for the Agency to provide adequate notice and opportunity for comment when the Agency undertakes a significant action or scientific review. In the case of the upcoming SAP review, adequate Agency notice includes providing the public the technical documents that are the basis of the review. The public has a meaningful opportunity to comment only when those documents are provided sufficiently prior to the SAP for substantive technical review and analysis. Sufficient time for public review will assist the SAP and Agency to address the critical scientific and policy issues at hand. EPA has implemented a truncated review process that will bypass robust public review and inhibit adequate peer review. By any standard, this is not acceptable. This is inconsistent with existing procedural standards and is contrary to President Obama’s commitment to scientific integrity, transparency and public participation. We urge EPA to rectify this situation.”
See complete comments EDP