EPA's Science Advisory Board (SAB) sought comments on its draft peer review report on EPA’s Draft Revised Environmental Justice Technical Guidance (EJTG). This report reviews the methods and procedures described in EPA’s Draft Revised EJTG for evaluating environmental justice concerns in regulatory actions. The Institute for Policy Integrity submitted comments making three key recommendations that the SAB can use to advise EPA:
- The SAB should advise EPA to distinguish environmental justice analyses from analyses that characterize distributional effects in the Draft Revised EJTG.
- When conducting quantitative analyses, the SAB should advise EPA to encourage analysts to monetize effects when possible instead of presenting only probability risks or volumetric values.
- If EPA determines that it cannot conduct a particular analysis or cannot fully monetize or quantify elements of an analysis, the SAB should advise EPA to document its reasons for that decision.