Community Letter: Regulatory Reform

May 15, 2017

Dear Administrator Pruitt,

On behalf of the undersigned organizations and our millions of members and supporters, we write to express our deep concern over the Environmental Protection Agency’s (EPA) recently noticed process for evaluating existing regulations that can be “repealed, replaced, or modified.” See U.S. EPA, Evaluation of Existing Regulations, 82 Fed. Reg. 17,793 (Apr. 13, 2017) (Docket ID EPA-HQ-OA-2017-0190). The public process in which EPA is now engaged flows from a memo from EPA Administrator Pruitt to senior EPA leadership and Regional Administrators issued on March 24, 2017. See Memorandum from Scott Pruitt, Administrator, U.S. EPA, to select EPA staff (Mar. 24, 2017).

We object to the false premise that public safeguards are holding back our nation. In reality, environmental protections have saved lives, improved health, conserved resources and spurred innovation, all while allowing for economic growth and providing far more in benefits than they cost. There is no evidence that EPA is saddling industry with numerous outmoded or unnecessary regulations. EPA should ensure that it runs an open and balanced process if it is to get a true picture of what regulations are doing for Americans and how they feel about them. It is vital that you put in place a process that provides the public with adequate notice and the ability to meaningfully comment.

We see no reason to believe that, even after the arduous process for promulgating regulations and previous retrospective reviews, EPA’s current framework of protections is filled with obsolete, ineffective or counter-productive rules. Rather, this exercise is driven by an ideological opposition to all regulation, no matter how needed. Indeed, the docket’s reliance on Executive Order 13771 – an order illegally focused on the costs and ignoring the benefits of regulations – betrays its intentions to create a one-way ratchet, tailored to hear from industry special interests voicing their displeasure with protections that help the broad public, instead of considering those areas where the public remains at risk and where EPA regulations are vitally needed. EPA ought to be asking for guidance on how to better carry out its mission of protecting public health, not how to retreat from it.

This single-minded (and closed-minded) focus on eliminating protections could have immense consequences on EPA’s core mission to protect human health and the environment. Offices at the agency have delivered enormous benefits to the public in implementing their legal obligations – obligations that a regulatory review will not change.i

With so much at stake, it is essential that EPA provide the public with a meaningful opportunity to comment as part of this process. Yet, the agency has provided little advance notice, has indicated no interest in holding hearings outside the DC-Metro area, and has given no clear signal even as to which EPA divisions will be involved. Some offices are holding limited, invitation-only sessions, while another is only holding a teleconference in lieu of actually interacting with the public.

The fundamental rights that every American enjoys to clean air, clean water, and a healthy environment have been thrown into doubt by EPA’s announcement. It is therefore vital that EPA reconsider its current process, which is substantively flawed, transparently biased, and procedurally deficient.

Sincerely,

Alabama Rivers Alliance

Alaska Community Action on Toxics

Alliance of Nurses for Healthy Environments

American Sustainable Business Council

Amigos Bravos

Arkansas Advanced Energy Association

Asbestos Disease Awareness Organization

Beyond Toxics

Breast Cancer Prevention Partners

Cahaba River Society

California River Watch

Calusa Waterkeeper

Center for American Progress

Center for Coalfield Justice

Center for Public Environmental Oversight

Center for Water Advocacy

Citizen Power

Citizens for a Clean Pompton Lakes

Clean Corvallis Air

Clean Water Action

Clean Water Action California

Coalition for Smarter Growth

Conservation Voters New Mexico

Conservation Voters New Mexico Education Fund

Earth Conservation Corps

Earthjustice

Earthworks

Eastside Portland Air Coalition

Ecology Center

Elders Climate Action

Endangered Habitats League

Environment America Environment Arizona Environment California Environment Colorado Environment Connecticut Environment Florida Environment Georgia Environment Illinois Environment Iowa Environment Maine Environment Maryland Environment Massachusetts Environment Michigan Environment Minnesota Environment Missouri Environment Montana Environment Nevada Environment New Hampshire Environment New Jersey Environment New Mexico Environment New York Environment North Carolina Environment Ohio Environment Oregon Environment Rhode Island Environment Texas Environment Virginia Environment Washington

Environmental Defense Fund

Environmental Working Group - EWG

Farmington River Watershed Association

Farmworker Association of Florida

FreshWater Accountability Project

Friends of Cibolo Wilderness

Friends of the Earth

Gasp, Inc.

God's Country Chapter of Trout Unlimited

Greater Edwards Aquifer Alliance

Green America

Green Team, Unitarian Universalist Church of Loudoun

GreenLatinos

Gulf Restoration Network

HEAL Utah

Healthy Schools Network

Human Synergy Works

Huron River Watershed Council

Idaho Rivers United

Illinois Council of Trout Unlimited

Interfaith Power & Light

Iowa Citizens for Community Improvement

Kansas Alliance for Wetlands and Streams

Kentucky Waterways Alliance

League of Conservation Voters

League of United Latin American Citizens

League of Women Voters of the United States

Massachusetts Rivers Alliance

Midwest Environmental Justice Organization

  Milwaukee Riverkeeper

Minnesota Center for Environmental Advocacy

Montana Environmental Information Center – MEIC

Mountain Lakes Preservation Alliance

NextGen Climate America

Natural Resources Defense Council

Northwest Atlantic Marine Alliance

Occupational Health Clinical Centers

Ocean Futures Society

Ohio Environmental Council

Oil Change International

Oregon Environmental Council

PennEnvironment

Powder River Basin Resource Council

Power Shift Network

Prairie Rivers Network

Progress For All

River Network

San Juan Citizens Alliance

Sierra Club

South Portland Air Quality

Southern Environmental Law Center

Southwings

STIR, Save The Illinois River

Sugar Law Center

Surfrider Foundation

Texas Campaign for the Environment

The Dalles Air Coalition

The North Shore Waterfront Conservancy of Staten Island

To Nizhoni Ani

Union of Concerned Scientists

United Sludge Free Alliance

Unity with Nature committee, Baltimore Yearly Meeting of the Religious Society of Friends

Washington Conservation Voters

Washington Environmental Council

WE ACT for Environmental Justice

Wisconsin Environment

Yukon River Inter-Tribal Watershed Council

 

i The Office of Air and Radiation administers laws, including the Clean Air Act and Atomic Energy Act, designed to limit air pollution, stratospheric ozone depletion, climate change, acid rain and radon exposure, among others. This protects public health, helping prevent asthma attacks, birth defects, respiratory and cardiovascular disease and cancer. The Clean Air Act alone has saved millions of lives and more than $30 trillion in avoided healthcare costs over the course of its implementation.

 

The Office of Water administers laws, including the Clean Water Act and Safe Drinking Water Act, designed to limit contaminants in drinking water and protecting our streams and wetlands. Benefits include reducing flood risks, a critical issue for the approximately $360 billion dollars-worth of properties, including 9.6 million homes, in flood-prone areas.

 

EPA’s Environmental Justice programs and the Office of Environmental Justice help the federal government engage communities, work with sovereign tribes, and ensure that enforcement is not neglected where it is needed most – low-income areas and communities of color that are disproportionately on the frontlines of injustices like polluted air and unsafe water.

 

The Office of Land and Emergency Management is charged with responding to emergencies, such as the West Texas chemical plant explosion. It also develops and implements safeguards to prevent such emergencies from happening in the first place.

 

The Office of Chemical Safety and Pollution Prevention implements the Toxic Substances Control Act, the Federal Insecticide, Fungicide, and Rodenticide Act, and other laws to protect people from unhealthful exposure to chemicals. These laws are meant to prevent the use of the riskiest and most dangerous toxic chemicals, whether they are on or in our food, in our drinking water, or used on products in our homes and workplaces. The Office also manages the annual publication of the Toxics Release Inventory. This database, created by the Emergency Planning and Community Right to Know Act, empowers citizens to learn about toxic releases in their communities and has led to the largest voluntary reduction of toxic discharges of any voluntary program.

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