American Chemistry Council
EPANonrulemakingEPA-HQ-OGC-2024-0192

Proposed Consent Decrees in Community In-Power and Development Association Inc. v. EPA, Case No. 1:23-cv-02715 (D.D.C.) and American Chemistry Council v. EPA, Case No. 1:23-cv-03726 (D.D.C.)

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Jun 3, 2024
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closed 791d ago
American Chemistry Council filings
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Activity

American Chemistry Council filed 2 comments on this docket between May 30, 2024 and May 30, 2024. 0 other organizations filed here. The comment window closed 791d ago.

What American Chemistry Council filed (2)

May 30, 2024· Comment submitted by American Chemistry Council’s Formaldehyde Panel· EPA-HQ-OGC-2024-0192-0004

Comment of the American Chemistry Council's Formaldehyde Panel on the proposed CD in in Community In- Power and Development Association Inc. v. EPA

May 30, 2024· Comment submitted by The American Chemistry Council (ACC)1 1,3-Butadiene TSCA Risk Evaluation Consortium· EPA-HQ-OGC-2024-0192-0005

May 28, 2024 Submitted via email and regulations.gov Stephanie Schwarz Pesticides and Toxic Substances Law Office Office of General Counsel U.S. Environmental Protection Agency schwarz.stephanie@epa.gov RE:American Chemistry Council 1,3-Butadiene TSCA Risk Evaluation Consortium Comments on the Proposed Consent Decree Regarding High-Priority Chemical Risk Evaluation Deadlines, Toxic Substances Control Act Suit; Docket ID Number EPA-HQ-OGC-2024-0192 Dear Ms. Schwarz: The American Chemistry Council (ACC)'s 1,3-Butadiene TSCA Risk Evaluation Consortium (the Butadiene Consortium) appreciates the opportunity to provide comments on the proposed Consent Decree to address the lawsuit filed by Community In-Power and Development Association Inc., Learning Disabilities Association of America, Louisiana Environmental Action Network, Sierra Club, and Texas Environmental Justice Advocacy Services in the United States District Court for the District of Columbia on September 18, 2023: Community In-Power and Development Association Inc. v. EPA, Case No. 1:23-cv-02715 (D.D.C.). Please find attached the Butadiene Consortium's comments. We appreciate your consideration of these comments. The Butadiene Consortium continues to support a robust science-based assessment of 1,3-butadiene consistent with TSCA. Should you have any questions, please feel free to contact me at Neeraja_Erraguntla@americanchemistry.com. Sincerely, Neeraja Erraguntla, Ph.D.; DABT | American Chemistry Council Director, Chemical Products & Technology Division neeraja_erraguntla@americanchemistry.com 700 2nd Street NE | Washington, DC | 20002 O: (202) 249-6712 www.americanchemistry.com

Abstract

The cases were consolidated on January 17, 2024. The CIDA Plaintiffs and ACC filed the cases pursuant to the Toxic Substances Control Act (“TSCA”), alleging that EPA failed to perform non-discretionary duties under TSCA to timely complete several risk evaluations. EPA is providing notice of the proposed consent decrees, which would resolve all claims in both cases by establishing deadlines for EPA to take action on the subject risk evaluations.

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