EPN In Action March-April 2020
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.
Highlights
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EPN created a snapshot of the expected health and environmental impacts of some of the most significant actions taken by the EPA over the past few years.
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EPN requested an extension of the public comment period for the proposed supplemental provisions to the 2018 “censored science” rule proposal. EPN members also presented testimony on the proposed supplemental provisions at a virtual hearing held by the Union of Concerned Scientists.
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EPN sent two letters requesting extensions of the public comment period for draft risk evaluations of 20 chemicals under the Toxic Substances Control Act (TSCA). EPN also submitted formal comments on the draft risk evaluation of trichloroethylene (TCE) and sent a letter to Administrator Wheeler calling for a ban on most uses of TCE.
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EPN issued a press release in response to EPA’s regulatory finding on the Mercury and Air Toxics Standards (MATS) that it was not “appropriate or necessary” to regulate mercury and other hazardous air emissions from coal- and oil-fired power plants. (See more EPN work on MATS here.)
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EPN issued a press release when the administration finalized the Safer Affordable Fuel Efficient (SAFE) Vehicles Rule, which rolled back clean car regulations that have reduced greenhouse gas emissions, improved air quality, and increased fuel economy. (See more EPN work on fuel efficiency here.)
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EPN submitted comments in response to the Council on Environmental Quality’s (CEQ) proposal to update regulations for implementing the procedural provisions of the National Environmental Policy Act (NEPA). EPN members also presented testimony on the “Guidelines for Preparing Economic Analyses” during a public meeting of the Science Advisory Board Economic Guidelines Review Panel.
EPN Highlights Estimated Health and Environmental Impacts of Trump’s Rollbacks
EPN’s Work on Censored Science
EPN Members Testify about Supplemental Notice of the Proposed Censored Science Rule at Union of Concerned Scientists’ Virtual Hearing
EPN members presented testimony at a Union of Concerned Scientists' virtual public hearing on EPA's supplemental notice of the proposed rulemaking on "censored science." Despite the current COVID-19 public health crisis, EPA declined to adequately extend the comment period or hold virtual hearings on this proposal, which limits the role science plays in EPA decision-making.
EPN Requests to Extend the Comment Period on Supplemental Notice to the Proposed Censored Science Rule
EPN sent a letter to EPA Administrator Wheeler requesting an extension of the comment period for the supplemental notice to the proposed “censored science” rule. Due to the COVID-19 pandemic, as well as the confusion and ambiguity created by the supplemental notice, EPN requested an extension of 60 days beyond the proposed comment period of 30 days. In addition, this 90-day period would begin after the current state of emergency to allow the public to prepare the most comprehensive comments possible.
Censored Science In The News
Trump Agencies Push Forward on Rollbacks as Pandemic Rages
Stan Meiburg, EPN member and former EPA Deputy Regional Administrator in Region 4 and Region 6 and Acting Deputy Administrator, was quoted in this article regarding the pace of EPA rollbacks, including the proposed “censored science” rule, amid the COVID-19 pandemic. This article was reprinted by the Bradenton Herald.
US EPA Aims to Expand Scope of Former Chief Scott Pruitt’s ‘Secret Science’ Rule
EPN members Betsy Southerland, former Director, Office of Science and Technology, EPA Office of Water, and Dr. Bernard Goldstein, former chair, EPA Clean Air Scientific Advisory Committee, were quoted and EPN was mentioned in this article focusing on the supplemental notice to EPA’s proposed “censored science” rule, which would limit the scope of studies available in the setting of pollution standards. Betsy was also quoted in Bloomberg, EcoWatch, E&E News, The Hill, The Hill’s Overnight Energy & Environment, and the Washington Examiner about the supplemental proposal.
EPN’s Work on Toxic Substances
EPN Requests to Extend the Comment Period for 20 Draft Risk Evaluations Under the Toxic Substances Control Act
EPN sent a letter to EPA Administrator Wheeler requesting an extension of the comment period for draft risk evaluations of 20 chemicals under the Toxic Substances Control Act (combining two sequential announcements of 13 and 7 chemicals, respectively). EPN noted that it was unreasonable to expect public review and substantive comment on such a large number of documents in the 45-day period allowed.
EPN Submits Comments on EPA’s Draft Risk Evaluation of Trichloroethylene
In response to EPA's request for public input on the draft risk evaluation of trichloroethylene (TCE), EPN submitted comments pointing out ongoing concerns about the flawed TSCA systematic review process, as well as highlighting instances where EPA failed to use the best available science. In addition, EPN believes that the administration may have intervened in the scientific assessment of TCE, raising concerns about previous and future risk evaluations.
EPN Writes Letter on Serious Health Risks of Trichloroethylene
EPN sent a letter to EPA Administrator Andrew Wheeler about the unreasonable health risks associated with the chemical trichlorethylene. EPN urged Administrator Wheeler to take immediate regulatory action because EPA has determined on multiple occasions that TCE presents an unreasonable risk to human health.
EPN’s Work on Mercury and Air Toxics
Mercury and Air Toxics In The News
EPA Weakens Mercury Standards, Which Experts Say Could Put Pollution Controls at Risk
Janet McCabe, EPN member and former Acting Assistant Administrator, EPA Office of Air and Radiation, was quoted in this article on the Trump administration’s rollback of the Mercury and Air Toxics Standards (MATS).
Guess What: It’s No Longer ‘Appropriate or Necessary’ to Regulate Mercury Emissions From Power Plants
EPN members Mustafa Ali, former Senior Advisor for Environmental Justice and Community Revitalization and Assistant Associate Administrator for Environmental Justice, Joe Goffman, former Associate Assistant Administrator for Climate and Senior Counsel, EPA Office of Air and Radiation, and Ellen Kurlansky, former Air Policy Analyst and Advisor, EPA Office of Air and Radiation, were quoted in this article on the rollback of the Mercury and Air Toxics Standards (MATS).
Mercury Pollution — the Slippery Slope
Ellen Kurlansky, EPN member and former Air Policy Analyst and Advisor, EPA Office of Air and Radiation, wrote this op-ed in on the Trump administration’s rollback of the Mercury and Air Toxics Standards (MATS). Ellen was quoted in similar articles by The Hill, E&E News, Roll Call, Reuters, Yale Environment 360, The Washington Times, Gizmodo, and Electrek.
EPN’s Work on Clean Car Standards
Clean Car Standards In The News
The Pandemic Hasn’t Stopped Trump’s Rollback of Clean Car Standards
Jeff Alson, EPN member and former EPA Senior Engineer and Policy Advisor, Office of Transportation and Air Quality, published this op-ed concerning the Trump administration’s finalization of the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule. Jeff was also quoted by The Hill regarding a recent ruling by the 2nd Circuit Court of Appeals, which said it was wrong for the administration to withhold information about its SAFE models.
Trump’s Environmental Rollbacks Find Opposition Within: Staff Scientists
EPN members Dan Costa (former National Program Director, EPA Air, Climate, and Energy Research Program), Kathy Kaufman (former RIA team lead within EPA’s Air Economics Group), Margo Oge (former Director, EPA Office of Transportation and Air Quality), and Betsy Southerland (former Director, Office of Science and Technology, EPA Office of Water), were quoted in this article on opposition to the Trump administration’s environmental rollbacks within EPA.
EPN’s Work on NEPA and Economics
EPN Submits Comments on Proposed Revisions to Regulations Implementing the National Environmental Policy Act
In response to the White House Council on Environmental Quality's proposal to update regulations for implementing the procedural provisions of the National Environmental Policy Act (NEPA), EPN submitted comments opposing the proposal because it is inconsistent with NEPA, Congressional intent, and years of practice.
EPN Members Present Testimony on Guidelines for Preparing Economic Analyses
EPN members presented testimony to EPA's Science Advisory Board Economic Guidelines Review Panel on the "Guidelines for Preparing Economic Analyses." These guidelines are relied upon for important subjects such as costs and benefits, and ensure a safe environment and healthy economy. It is critical that they represent current peer-reviewed and established economics practices.
Economics In The News
EPA Cost-Benefit Guide Draws Advocacy on Co-Benefits, Climate, Jobs
EPN members Roy Gamse, former EPA Deputy Associate Administrator for Policy, and Karl Hausker, former Deputy Assistant Administrator for Policy, were quoted in this article on EPA’s update to its economic guidelines and what it will mean for evaluating the effects of climate change.
EPN Member Op-Eds on COVID-19
EPN members penned their own op-eds on the administration’s environmental actions during the COVID-19 pandemic.
Trump’s EPA Uses the Coronavirus Crisis to Mask Environmental Deregulation and Suspend Enforcement
Joel Mintz, EPN member and former EPA Enforcement and Supervisory Attorney, published this op-ed on EPA’s decision to suspend enforcement of environmental regulations.
Trump’s Clean Cars Rollback: A First Test of Our Post-Coronavirus Society
Margo Oge, EPN member and former Director, EPA Office of Transportation and Air Quality, published this op-ed on the finalization of the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule amid the COVID-19 pandemic. In a previous op-ed in Forbes, Margo discussed the links between combatting COVID-19 and climate change.
It’s Time to Sound the Alarm for Communities Most Vulnerable to the Coronavirus
Mustafa Santiago Ali, EPN member and former EPA Senior Advisor for Environmental Justice and Community Revitalization, and Assistant Associate Administrator for Environmental Justice, penned this op-ed about the environmental justice implications of COVID-19. Mustafa also wrote two op-eds in The Guardian on the inequities of the COVID-19 pandemic and how EPA’s suspension of enforcement exacerbates COVID-19 mortality rates.
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 Water Act, enforcement, and particulate matter standards.
Trump’s Rewrite is Finalized. What Happens Now?
Mark Ryan, EPN member and former EPA Regional Counsel, Region 10, was quoted in this article concerning the finalization of the Trump administration’s Navigable Waters Protection Rule, which replaces and redefines what water bodies are protected under the Clean Water Act (CWA). Mark was quoted in similar articles by S&P Global and Our Daily Planet.
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We Put Science Back Into EPA Air Pollution Standards, but …
April 15, 2020 / by
John Bachmann, Chris Zarba, Chris Frey, and Gretchen Goldman /
Scientific American
EPN members, John Bachmann, former Associate Director for Science/Policy and New Programs, EPA Office of Air Quality Planning and Standards and Chris Zarba, former Director, EPA Science Advisory Board, penned this op-ed alongside co-authors Chris Frey and Gretchen Goldman on the Trump administration’s proposal to retain the particulate matter standards.
Noncompliance with Environmental Rules Is Worse Than You Think
Cynthia Giles, EPN member and former Assistant Administrator, Office of Enforcement and Compliance Assurance, published this report on the harms of noncompliance with environmental rules. This was part two of her Next Generation Compliance series.