Does EPA Have Authority to Promulgate Cumulative Risk Assessment Guidance?
Law and Environment
SEPTEMBER 18, 2023
I freely confess from my ivory tower located in deep-blue Massachusetts that I don’t always agree with the TCEQ. Guidance is non-binding, often not media-specific, and no substitute for rulemaking , which would provide state agencies with authority to consistently apply CRAs and CIAs in decision making as contemplated by EPA.
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