The Center for Regulatory Effectiveness (CRE) has submitted comments to the Environmental Protection Agency (EPA) that threaten to challenge the data quality of comments submitted by the Natural Resources Defense Council (NRDC), should EPA use them. The NRDC submitted comments to EPA on its draft risk assessment for land-applied biosolids that stated the draft risk assessment underestimated risks from dioxin and related compounds. CRE claims that the NRDC comments contain substantial inaccuracies, omissions, and biases, and lack reproducibility.