Washington, DC — The U.S. Environmental Protection Agency (EPA) draft plan for defining what evidence it will evaluate in its decision-making provides no clarity and should be returned to the drawing board, according to comments filed by Public Employees for Environmental Responsibility (PEER). In particular, EPA’s plan to use Artificial Intelligence (AI) in pollution permitting for Clean Water Act and other issues offers no detailed information on how these tools will be used and to what effect.

EPA is in the process of updating its plan for implementing the Foundations for Evidence-Based Policymaking Act of 2018, also known as the Evidence Act, which requires federal agencies to develop an evaluation policy for the evidence used to support policymaking. EPA’s draft Evidence Plan for FY 2027 was unveiled on April 30, 2026. Initially, only two weeks were allotted for public comment, but the deadline was extended until May 28^th.

EPA’s policy for adopting these plans stresses that the agency must utilize the highest levels of objectivity to produce standards of recognized rigor in a transparent manner. The PEER comments argue EPA’s latest Evidence Plan iteration fails all these standards. For example –

• EPA presupposes that AI will enhance operational efficiencies in permitting without offering any explanation of how;
• EPA says it will rely on “key individuals” and consult with “Subject Matter Experts” without specifying how these people will be identified or selected; and
• The plan does not explain precisely the specified “evidence activities” that will inform EPA policies in practice.

“This ‘plan’ is full of buzzwords without any concrete steps,” commented PEER General Counsel Joanna Citron Day, who submitted PEER’s comments. “Soliciting public feedback on such a vague plan is meaningless. EPA must provide more detailed information and initiate a new comment period before it implements a final plan.”

This new Evidence Plan is being enacted while EPA is shedding much of its scientific capacity. The agency has adopted a new basis for climate science which is far from the scientific consensus and reverses its long-held prior position. Further, it has abandoned placing a value on human life in its cost-benefit analyses of stricter anti-pollution measures.

“EPA’s recent actions indicate that current agency leadership has zero interest in strengthening science-based decision-making,” added PEER Science Policy Director Kyla Bennett, a scientist and attorney formerly with EPA. “This latest so-called Evidence Plan is a far cry from the required objectivity, rigor, and transparency its own policies prescribe.”

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See the proposed EPA Evidence Plan

Compare the PEER comments

Examine EPA’s Policy for Evaluations and Evidence Building

Look at EPA’s recent dramatic loss of scientific capacity

PEER protects public employees who protect our environment, natural resources, and public health. We support current and former environmental and public health professionals, land managers, scientists, enforcement officers, and other civil servants dedicated to upholding environmental laws and values across federal, state, local, and tribal governments.