Agency Self‑Limitation Threatens Public Health

When an agency legally narrows its own rulemaking authority — e.g., asserting it cannot revise a pollution standard more than once even if new science appears — industry can lock in weaker protections and block future updates. That creates a durable institutional handicap: regulators lose a routine corrective mechanism and courts, legislatures, or emergency politics become the only ways to respond to new risks. — If agencies adopt or accept self‑limiting legal theories, it will freeze environmental and health protections in place and shift battles from science and rulemaking into protracted litigation and politics with worse population health outcomes.