The Association of Public and Land-grant Universities (APLU), Association of American Universities (AAU), Association of American Medical Colleges (AAMC), and Council on Governmental Relations (COGR) collectively submitted a formal request to the U.S. Environmental Protection Agency (EPA) seeking an extension of the public comment period for the supplemental proposed rule, “Strengthening Transparency in Regulatory Science.” The signatories emphasized that the proposed rule is complex and has significant implications, thus necessitating a more comprehensive review than the current 30-day comment period allows. The urgent challenges posed by the COVID-19 pandemic, which have placed extraordinary demands on universities and medical institutions, further limit these organizations’ capacity to evaluate and respond effectively within the allotted timeframe.
The associations argue that extending the comment period to 90 days would allow for a more thorough and informed response while enabling academic institutions to focus on addressing the unprecedented impacts of the pandemic. They highlight the essential role of scientific expertise in regulatory decision-making, especially under circumstances such as those imposed by COVID-19. The letter also references previous feedback provided in 2018, reiterating the importance of using the best available evidence in regulations affecting public health. The organizations underscore their commitment to education, research, and public service, and stress that a longer comment window is necessary to maintain the integrity and quality of their contributions to this regulatory process.