CRE filed comments on EPA’s Information collection request for EPA’s Tier 2 EDSP tests. CRE commented that EPA should not submit, and OMB/OIRA should not approve, this ICR because EPA has not demonstrated that the EDSP Tier 2 tests meet Information Quality Act (“IQA”) Guidelines and Paperwork Reduction Act (“PRA”) requirements. For example, EPA has not demonstrated that the EDSP Tier 2 tests are reliable, reproducible, and useful. EPA has also not demonstrated that the EDSP Tier 2 tests are the least burdensome necessary, and that they are necessary for the proper performance of EPA’s functions.
Click here to read CRE’s comments.
