EPN Year in Review: 2018
EPN Work on Budget & Appropriations
Government Shutdown Fact Sheets
EPA joined the ongoing partial government shutdown at midnight, Friday, December 28. Over 13,000 employees were furloughed, and only national security and emergency staff remained. Shutdowns are disruptive, hurt productivity and moral, and are a huge waste of taxpayer dollars.
On December 22, 2018, a partial government shutdown began for nine executive departments, including EPA, due to an impasse over Trump's demands for $5.7 billion to fund a U.S-Mexico border wall. However, according to a message from Acting Administrator Wheeler, EPA will remain open the week of December 24th, with further instructions to be provided should the shutdown continue beyond December 28th.
Budget & Appropriations Analyses
While the House and Senate rejected the severe budget cuts proposed by the Trump Administration for FY2019, their proposed appropriations for EPA were quite different, with the House cutting support for regulatory programs by $228 million and the Senate holding EPA funding at FY2018 levels.
EPN has produced a 10-page analysis of the Trump Administration's FY2019 budget, which proposed astonishing cuts to staff and essential programs and puts at risk congressionally mandated protections for public health and the environment.
The FY2018 Consolidated Appropriations Act put an end to the Trump Administration's proposal to gut the EPA budget, but still left the agency with inadequate funding to fully meet its basic functions.
Budget & Appropriations Fact Sheets
The Trump Administration proposed massive cuts for EPA in its FY2019 budget plan, which aims to eliminate almost 50 programs and make significant cuts to others that protect the American people and their environment. EPN created fact sheets on many of these programs to illustrate what could be lost.
The Trump Administration's proposed FY2019 budget slashed EPA's budget at an unprecedented level, threatening core programs that protect the health of the environment and the American people.
EPN Work on CASAC
EPN Work on Censored Science
EPN and many other science-based organizations released a report describing the ongoing threats to the use of science in decision-making on issues of public health and the environment. The report also provides Congress with recommended steps to take in response to these threats.
In response to EPA's proposal to restrict the use of scientific studies used in decisions on public health and environmental protections, EPN produced comments highlighting EPA's failure to demonstrate why established scientific practice should be abandoned.
Four EPN members delivered testimony defending science and pointing out scientific and legal inadequacies in EPA's "transparency" rule.
EPN provided written and oral comments to the EPA Science Advisory Board for consideration in its discussion of the proposal to restrict the use of scientific studies in agency policy-making if the underlying data and models used to support that data are not made public. The administration's proposal attacked tested and accepted scientific approaches.
On April 24, 2018, EPA Administrator Pruitt proposed to restrict the use of scientific studies in setting rules and agency policies. EPN is taking a very close look at this far-reaching proposal and wrote a letter to EPA asking to extend the public comment period.
In response to EPA Administrator Scott Pruitt's proposal to restrict the use of scientific studies in setting rules and agency policies, EPN provided a legal analysis of the proposal that details why it's not only dangerous to public health, but is also illegal.
EPN provided a policy analysis of Administrator Pruitt's proposal to restrict the use of scientific studies in setting rules and agency policies. The analysis explains how current EPA programs that control toxic pollutants in air, drinking water, and solid waste might not exist today if EPA had adopted a similar proposal in the past.
EPA Administrator Scott Pruitt proposed a regulation that would restrict EPA’s use of scientific studies, unless the raw underlying data and the models used to analyze data supporting the study are available for public review. In response, EPN produced an Executive Summary highlighting the proposal's inconsistency with scientific practice and sound public policy.
EPN Work on Clean Power Plan, Glider Rule and HFCs
The Trump Administration proposed a new rule to replace the Clean Power Plan, which would loosen the restrictions on coal-fired power plants. EPN responded with comments on proposed revisions to EPA’s implementing regulations for emissions guidelines, providing suggestions to clarify and strengthen sections of the rule as well as highlight changes that should not be adopted.
In response to the proposal to repeal EPA's 2016 rule requiring diesel engines installed in new "glider" trucks to meet the same pollution emission standards required for those in new trucks, EPN created a 20-page report on the public health implications ignored by the proposal and the baseless legal theory on which it rests.
The proposed revision to the Refrigerant Management Program under Section 608(c) of the Clean Air Act would relieve businesses of many of their duties in handling leaks, repairs, and record keeping for HFCs. EPN responded with comments on the arbitrary nature of this proposal, its contradiction to statutory intent, and its lack of scientific basis.
EPN Work on Cost Benefit Analysis
EPN Work on EPCRA and Community Right-to-Know
EPN Work on NEPA
A memo on EPA's review responsibilities from EPA Associate Administrator for the Office of Policy Brittany Bolen stated that EPA will no longer assign a letter and numerical rating in its comments on reviews conducted by other agencies. In response, EPN and Save EPA wrote a joint letter urging Acting Administrator Wheeler to continue the rating system while seeking public review and comment in order to avoid confusion and inconsistency.
In response to the White House Council on Environmental Quality's request for input on whether NEPA regulations should be revised, EPN responded with comments that supported the goals of efficiency and avoiding unneeded delays in the environmental review process, but found that changing the regulations would be counterproductive and that these goals could be achieved by implementing existing regulations and applying lessons learned to improve implementation.
EPN Work on SAFE
Save EPA Ann Arbor and EPN members reviewed EPA's proposal to roll back the clean car standards and found that it would increase air pollution, elevate health risks, and raise gas prices.
EPN, in collaboration with Save EPA, created a fact sheet on the proposed regulatory rollback of clean car standards to illustrate the resulting higher gas prices and increased air pollution and health risks.
Three EPA alumni delivered testimony on the dangers of rolling back the clean car standards at public meetings on the SAFE proposal.
EPN Work on TSCA
In June 2018, EPA sought public comment on its new draft guidance document for TSCA risk evaluations of chemicals. EPN commented and found the new systematic review process to be seriously flawed, ultimately weakening the science used to make decisions on chemical risks.
EPN provided comments on EPA draft problem formulations for the chemicals asbestos, HBCD, and carbon tetrachloride. The problem formulations identify conditions of use and pathways of exposure to be considered in risk evaluations. EPN found critical flaws that set dangerous precedents for chemical safety reviews.