Key Points:
-Congress should reclaim its authority to make the major policy decisions under federal environmental law.
-The CAA needs to stipulate minimal criteria for risk assessment of health effects to include:
-EPA risk assessment must be peer-reviewed by truly independent body.
-Toxicological studies and clinical trials carry more weight than Epidemiological studies.
-Abandon the no-threshold linear regression modeling assumptions.
-Use representative estimates of actual exposure and not implausible worst-case scenarios.
-Physical measurement trumps models.
-Plausible biological mechanism – prerequisite of health-effects findings.
-We need a comprehensive, cumulative cost-benefit analysis of all rules.
-Make EPA's risk assessments judicially reviewable.