Earthjustice Comments Take on “Harvesting,” July 2001
“Suggestions have been made by some that PM-induced mortality strikes the “weakest” individuals, who might have died within a short period anyway. See, e.g., Brief of American Trucking Associations in American Trucking Assns. v. Browner, Sup. Ct. No. 99-1426, at 13, 19.”
“This attempt to impose a crude social Darwinism on the Clean Air Act is morally repugnant and must be rejected,” states Howard Fox, Earthjustice Attorney, in comments filed with EPA July 12, 2001.
Supplemental comments filed by Earthjustice make the points that:
1) The Clean Air Act NAAQS Provisions are precaustionary; and
2) The Clean Air Act requires that NAAQS be based on public health and welfare effects of air pollutants, and not on other factors such as control costs.
Copies of two sets of July 2001 comments by Earthjustice Attorney Howard Fox on the EPA Criteria Document and Staff Paper are attached.
Attachments
- Earthjustice Comments on Staff Paper, 7-12-01
- earthjustice-comments-7120.pdf
Earthjustice Comments on Staff Paper, 7-12-01
- Additional Earthjustice Comments on Staff Paper, 7/30/01
- earthjustice-comments-7300.pdf
Additional Earthjustice Comments on Staff Paper, 7/30/01
