Comment submitted by Howard J. Feldman, Director of Regulatory and Scientific Affairs, American Petroleum Institute (API)

The Guidance Document should be finalized expeditiously. Once the Guidance Document is finalized, EPA should expeditiously move to have the Guidance Document undergo formal rulemaking, consistent with the NAS recommendation. Furthermore, there is wide variation in the extent to which the principles described in the draft guidance have actually been applied to models used by EPA in regulatory decision-making. API encourages EPA to institute a program to test compliance with it across key programmatic areas using models in decision- making. API further recommends that EPA institute a program to promote and encourage compliance with the key elements described in the Guidance Document by EPA personnel and contractors who use environmental models for risk assessment and regulatory decision-making.