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Comments to EPA on Proposed Dust-Lead Pollution Rules

The Environmental Protection Agency (EPA) proposed revisions to dust-lead post-abatement clearance levels. We submitted comments emphasizing how EPA, itself, concedes that the economic analysis supporting the rule is inaccurate. EPA admits to making an important modification to assumptions late in the process—but was unable to modify or recalculate all relevant estimates. The agency must release an updated economic analysis and provide an additional comment period open to the public.