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Comments on EPA’s Draft 2022–2026 Strategic Plan

The comments encourage EPA to clearly articulate in its final strategic plan that the agency will incorporate environmental justice and equity into its rulemakings and regulatory impact analyses (as opposed to the draft plan's current, more general promise of embedding environmental justice and equity into the agency's "programs, policies, and activities"). Specifically, we recommend that EPA incorporate EJ and equity into its rulemaking process by:

  • Analyzing the distributional consequences of regulatory alternatives;
  • Developing a standard approach to distributional analysis that accounts for methodological considerations described in the comment; and
  • Conducting a distributional analysis of at least one economically significant regulation within the next year incorporating our recommendations