EPN In Action November-December 2019

Welcome to your EPN In Action newsletter

Over the past two months, EPN submitted seven sets of formal comments on proposed rulemakings, provided oral testimony to three different EPA advisory committees, wrote a letter of concern regarding risk evaluations and a letter of support for an asbestos ban, drafted a fact sheet on EPA’s radon program that may be at risk in future proposed budgets, and continued to be a trusted source of information to reporters, Congress and the public.

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 testified, drafted letters to EPA and Congress, and submitted formal comments on the inadequacies of the Methylene Chloride draft risk evaluation. EPN also commented on the proposed list of the next 20 High-Priority Chemicals for risk evaluations under TSCA and drafted a letter in support of banning asbestos.

  • EPN submitted comments and provided testimony to the Clean Air Scientific Advisory Committee (CASAC) on EPA’s draft Policy Assessment (PA) for Particulate Matter (PM) and CASAC’s report on the PM PA. EPN also requested an extension and submitted comments on EPA’s draft PA for ozone.

  • EPN requested an extension on the proposed revisions to the lead and copper rule (LCR) and provided a statement on the proposed new drinking water standards for perchlorate and the LCR revisions at the December meeting of the National Drinking Water Advisory Council.

  • EPN wrote a letter criticizing the proposed revisions to the Environmental Appeals Board review process and produced a new fact sheet on EPA’s Indoor Air Radon program, which has been cut in previous budget proposals and may be at risk in future proposals.

  • EPN remembered the late Mr. William Ruckelshaus, the first head of the Environmental Protection Agency from 1970 to 1973 and an icon in the history of EPA.

EPN’s Work on TSCA

EPN Submits Comments on Draft Risk Evaluation of the Chemical Methylene Chloride

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

EPN Writes Letters on Serious Health Risks of Methylene Chloride

EPN sent letters to EPA and the House and Senate about the unreasonable health risks of the chemical MC. EPN urged Congress to support the request for EPA to regulate the hazards of MC in two separate stages: first focused on the risks posed by acute neurotoxicity, and then focused on chronic exposure, cancer endpoints, and any remaining uses that present unreasonable risk that were not restricted in the first stage.

EPN Comments on Proposed List of Next 20 High-Priority Chemicals for Risk Evaluation

EPN submitted comments in response to EPA’s proposal to designate the next 20 chemical substances as "High-Priority Substances" for risk evaluation under the reformed Toxic Substances Control Act (TSCA). EPN urges EPA to take quick action to evaluate risks of chemicals currently on the market with documented risks to vulnerable and highly exposed populations; however, as in past comments, EPN urges EPA to discontinue the use of a flawed TSCA systematic review process to prevent endangering public health and the environment.

EPN Writes Letter of Support for Ban on Asbestos

EPN sent a letter to the Chairs and Ranking Members of the House Committee on Energy and Commerce and the Senate Committee on Environment and Public Works expressing strong support for the Alan Reinstein Ban Asbestos Now Act of 2019 due to the grave threat it poses to human health and its extreme pervasiveness in our environment.

TSCA In The News

These Toxic Chemicals Need to Be Banned in the Next 10 Years

Dec 26, 2019 / by

Yessenia Funes /


Penny Fenner-Crisp, EPN member and former Senior Science Advisor to the Director, EPA Office of Pesticide Programs, is quoted in this article about whether some of the most toxic chemicals in our environment, including lead and asbestos, will be banned in the next decade.


EPA Says Little on TSCA New Chemicals Approach but Draws Criticisms

Dec 10, 2019 / by

Maria Hegstad /

Inside EPA

Bob Sussman, EPN member and former EPA Deputy Administrator and Senior Policy Counsel to the EPA Administrator, is quoted in this article about the December 10th public meeting on the implementation of the revised Toxic Substances Control Act (TSCA) New Chemicals program.


EPN’s Work on Particulate Matter & Ozone

EPN Comments on the Draft EPA Policy Assessment for Particulate Matter

EPN submitted comments on the draft Policy Assessment for Particulate Matter (PM), which is part of the current review of the National Ambient Air Quality Standards for PM. EPN found inadequacies in both the independent peer review process and the studies considered in the assessment. 

EPN Comments on Draft Policy Assessment for Ozone

EPN submitted comments on the draft Policy Assessment (PA) for ozone, which is part of the current review of the National Ambient Air Quality Standards (NAAQS). EPN found that EPA should prepare a draft PA that accounts for findings in Murray Energy v. EPA in regards to the secondary NAAQS ozone standard and resubmit it to the Clean Air Scientific Advisory Committee for review.

EPN’s Work on Drinking Water

EPN Requests a Comment Extension on Proposed LCR Revisions

EPN sent a letter to the EPA Office of Water requesting an extension of the comment period for the proposed Lead and Copper Rule (LCR) revisions. Due to the magnitude and complexity of the revisions, a 90-day comment period is recommended to produce the most comprehensive comments.

EPN’s Work on the Environmental Appeals Board & Continued Work on Budget Programs

EPN Writes a Letter on Proposed EAB Amendments

In response to EPA's proposal to revise the Environmental Appeals Board (EAB), EPN submitted a letter finding that the EAB process is not broken and should not be changed. The proposal would allow political leadership to interfere with what has traditionally been an impartial and reliable agency activity.

EPA’s Indoor Air Radon Program

EPN created a fact sheet on EPA's Indoor Air Radon Program to provide awareness of how important this program is to providing healthy indoor environments. This fact sheet is one of many fact sheets that EPN has created to educate the public about programs that have been and may again be cut in proposed budgets.

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 Science Advisory Board, brownfields, attacks on science,  regional environmental issues, coal ash, and continued disputes surrounding PFAS.

Science Panel Staffed With Trump Appointees Says E.P.A. Rollbacks Lack Scientific Rigor

Dec 31, 2019 / by

Coral Davenport and Lisa Friedman /

The New York Times

EPN member Chris Zarba, former Director, EPA Science Advisory Board (SAB), is quoted in this article about letters from the SAB stating that three of President Trump’s most far-reaching and scrutinized proposals to weaken major environmental regulations are at odds with established science. Zarba is quoted in a similar article in Greenwire and Science Magazine.


‘Too Valuable to Throw Away’: Brownfields Programs a Way for Former Industrial Sites to Get New Life

Dec 29, 2019 / by

Natalie Alms /

Salisbury Post

EPN Board member Stan Meiburg, former EPA Deputy Regional Administrator in Region 4 and Region 6 and Acting Deputy Administrator, is quoted in this article about the Kesler Mill “brownfield” site in Salisbury, North Carolina, which has applied for a federal cleanup grant due to pollution left from its industrial past.

Science Under Attack: How Trump Is Sidelining Researchers and Their Work

Dec 28, 2019 / by

Brad Plumer and Coral Davenport /

The New York Times

EPN members Bob Kavlock, former Acting Assistant Administrator, EPA Office of Research and Development, and EPA Deputy Assistant Administrator for Science; and Betsy Southerland, former Director, Office of Science and Technology, EPA Office of Water, are quoted in this article about the Trump administration’s transformation of the federal government through diminishing the role of science in federal policymaking and disrupting research projects nationwide—actions that could reverberate for years.

Great Lakes Mayors Warn Against Cut to Ecological Initiative

Dec 13, 2019 / by

Livingston Contributor /

Livingston Ledger

EPN member Dave Ullrich, former EPA Acting Regional Administrator and Deputy Regional Administrator in Region 5, was quoted in this article about the Trump administration’s potentially devastating cuts to the Great Lakes Restoration Initiative.


People Living Near Coal Plants Could Be Drinking ‘Toxic’ Contaminated Water Until 2028, Thanks to New EPA Ruling

November 8, 2019 / by

Rosie McCall /


EPN members Mustafa Santiago Ali, former EPA Senior Advisor for Environmental Justice and Community Revitalization, and Assistant Associate Administrator for Environmental Justice; and Betsy Southerland, former Director, Office of Science and Technology, EPA Office of Water, were quoted in this article about EPA’s changes to regulations for coal ash and toxic wastewater and their disproportionate impacts on low-income and minority communities.

Maps Highlight Michigan Cities, Groups That Will Bear Brunt Of Climate Change Effects

November 6, 2019 / by

Nardy Bickel /

Michigan News

Trish Koman, EPN member and former Senior Environmental Scientist, Program Manager, and Supervisor in EPA’s Office of Transportation and Air Quality, was quoted in this article about a tool developed at the University of Michigan to map communities that will bear the largest costs of rising temperatures.

Read all recent EPN In The News items here