EPN In Action July-August 2019

Welcome to your EPN In Action newsletter update for July-August 2019

Over the past two months, EPN submitted two sets of formal comments on proposed rulemakings and a set of comments on a draft chemical risk evaluation, provided written and oral testimonies to an EPA advisory committee and board, and continued to be a trusted source of information to reporters.

About the Environmental Protection Network

The Environmental Protection Network was launched in January 2017 to harness the expertise of former EPA career staff and confirmation-level appointees from multiple administrations to provide an informed and rigorous defense against efforts to undermine the protection of public health and the environment.


EPN’s Work on Draft Risk Evaluations Under TSCA

EPN Comments on Draft Toxicity Assessment of the Chemical 1-BP

EPN commented on the draft risk evaluation of 1-BP to assist the Science Advisory Committee on Chemicals as it reviews the evaluations during its September meeting. EPN objected to the process followed and basis on which EPA conducted the risk evaluations for 1-BP and urged EPA to discontinue use of the flawed TSCA systematic review process.

EPN’s Work on Censored Science and NEPA

EPN Members Testify on Censored Science Issues at SAB Public Teleconference

At the August 2019 SAB teleconference on personally identifying information and confidential business information under the Censored Science rule, EPN testified that the SAB should have been asked to review the entire rule and that none of the proposed approaches can guarantee personal information won’t be released.

EPN Comments on Draft NEPA Analysis and Documentation Guidance for Greenhouse Gas Emissions

EPN submitted comments on CEQ's draft guidance on how NEPA analysis and documentation should address greenhouse gas (GHG) emissions. EPN noted that the guidance fails to address the underlying concern with GHG emissions, which is their contribution to climate change, and urged CEQ to reinstate the previous guidelines until a substitute could be developed that allows federal agencies to meet their NEPA responsibilities.

Censored Science and NEPA In The News

Scientists Fight Trump EPA ‘Secret Science’ Proposal to Exclude Certain Research

August 27, 2019 / by

Rebecca Beitsch /

The Hill

EPN member Roy Gamse, former Deputy Assistant Administrator for Planning and Evaluation and Acting Assistant Administrator for Planning and Management, is quoted in this article about scientists pushing back against a Trump Administration proposal that would block EPA from relying on studies that don’t make their underlying data public.

Former EPA Officials Criticize Alleged Sidelining of Science

August 27, 2019 / by

Stephen Lee /

Bloomberg Environment

EPN members Dr. Bernard Goldstein, former chair, EPA Clean Air Scientific Advisory Committee, and former EPA Assistant Administrator for Research and Development, and Roy Gamse, former Deputy Assistant Administrator for Planning and Evaluation and Acting Assistant Administrator for Planning and Management, are quoted in this article about the Science Advisory Board’s role in consulting with EPA on its Censored Science proposal and the serious practical and ethical problems that arise from it.  

EPA Alumni Balk at Draft NEPA Guidance

August 9, 2019 / by

Niina H. Farah /

E&E News

This article discusses and quotes EPN’s comments objecting to draft guidance issued by the Council on Environmental Quality to assist federal agencies in considering greenhouse gas emissions when they evaluate federal actions, like the construction of roads and pipelines, under NEPA.

EPN’s Work on Region 4 SIP and Perchlorate

EPN Comments on EPA Region 4 North Carolina SIP Alternative Interpretation

In response to EPA Region 4’s proposal for an alternative interpretation of the North Carolina SIP, EPN concluded that the proposal failed to justify why it is warranted, lacks a legal or technical justification that the revision would protect public health, and fails to show that it is consistent with the Clean Air Act.

EPN Comments on EPA’s Proposed Drinking Water Regulation for Perchlorate

In response to EPA's proposed drinking water regulation for perchlorate, EPN produced comments highlighting the shortcomings of the proposal and strongly recommended submitting a new proposal that addresses these issues and excludes the option to withdraw from the 2011 determination to regulate perchlorate.

More examples of EPN In The News

In addition to the news articles above, EPN members contributed to a range of articles on topics such as the Clean Power Plan, changes to the Federal Advisory Committees Act, Trump’s speech on his environmental record, attacks on science, a variety of air issues, methane, and the Safe Affordable Fuel-Efficient Vehicle rule. EPN members have also penned their own op-eds on greenhouse gas emissions and NEPA, as well as budget issues concerning states.

Vehicle GHG Voluntary Deal Could Be Model But Federal Role Preferred

August 30, 2019 / by

David LaRoss /

Inside EPA

EPN member Jeff Alson, former EPA Senior Engineer and Policy Advisor, Office of Transportation and Air Quality, is quoted in this article about how automakers’ voluntary deal with California could be a model for voluntary environmental initiatives in other sectors, but would not be as protective as federal policies backed by enforcement or oversight.

A Toxic Tale: Trump’s Environmental Impact

August 23, 2019 / by

Sanjay Gupta /


EPN member Janet McCabe, former EPA Acting Assistant Administrator, Office of Air and Radiation, was interviewed for this special about the devastating impacts of Trump’s deregulation campaign. 

Erasing ‘Climate Change’ From Federal Agencies Won’t Make It Go Away

August 17, 2019 / by

Cynthia Giles /

The Hill

EPN member Cynthia Giles, former EPA Assistant Administrator, Office of Enforcement and Compliance Assurance, wrote this op-ed about the Trump Administration encouraging federal agencies to downplay and dismiss the risks of climate change in regulations and policies. For example, the White House Council on Environmental Quality’s (CEQ) draft guidance on how federal agencies should consider climate when they evaluate federal actions under the National Environmental Policy Act (NEPA) makes no mention of “climate change.”


These High School Runners Train In ‘Nasty Air,’ So They’re Working To Clean It Up

July 29, 2019 / by

Priscilla Totiyapungprasert /

The Arizona Republic

EPN member Trish Koman, former Senior Environmental Scientist, Program Manager and Supervisor in EPA’s Office of Transportation and Air Quality, was quoted in this article about emissions from school buses and their disproportionate impact on sensitive populations such as young children.

GAO: EPA Skirted Procedures In Overhaul Of Science Boards

July 15, 2019 / by

Ellen Knickmeyer /

Associated Press

Christopher Zarba, EPN member and former Director, EPA Science Advisory Board, was quoted in this article about a report from the Government Accountability Office (GAO) that found that EPA ignored several ethics rules and administrative procedures when overhauling its science advisory panels. This article ran in numerous other publications, including ABCUS News, and The Telegram.

Trump’s Not-So-Secret War On State Environmental Protection

July 6, 2019 / by

David Coursen /

The Hill

David Coursen, EPN member and former EPA Office of General Counsel, wrote this op-ed about the Trump Administration’s attacks on state-level environmental protection efforts, from proposed budget cuts for brownfield programs to potential rescindment of waivers that allow states to set standards that are more stringent than at the federal level.

Read all recent EPN In The News items here