EPN In Action September-October 2019

Welcome to your EPN In Action newsletter

Over the past two months, EPN submitted two sets of formal comments on proposed rulemakings, provided oral testimony to an EPA advisory committee, drafted a letter of concern regarding risk evaluations, and continued to be a trusted source of information.

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

  • EPN provided oral testimony to the Clean Air Scientific Advisory Committee (CASAC) during their October meeting to review EPA’s Policy Assessment for Particulate Matter (PM) as part of the National Ambient Air Quality Standards (NAAQS) process.

  • EPN commented on the proposed error correction for sulfur dioxide (SO2) designations in several Texas counties.

  • EPN drafted a letter to EPA further raising issues and shortcomings about the risk evaluation of 1-Bromopropane (1-BP) under the Toxic Substances Control Act (TSCA).

  • EPN commented on the proposal to update regulations on water quality certification under Section 401 of the Clean Water Act (CWA).

Volunteer and staffing updates:

  • We now have a robust database of over 470 EPA alumni across the country volunteering to help protect human health and the environment.

  • EPN hosted a Meet & Greet and Fundraiser in D.C. and raised over $38,500. Thank you to all who attended and/or made a donation

  • EPN co-hosted an event with Union of Concerned Scientists and the Bay Area Air Quality Management District in San Francisco for Region 9 alumni. We have members all over the country and hope to continue to host regional events.

  • Please welcome our newest team member, Operations Assistant Michelle Montoya. We are very excited to have her on board. 

EPN’s Work on NAAQS: PM and SO2

EPN Presents Testimony on Particulate Matter on the CASAC Public Teleconference

On October 22, 2019, EPA held a public teleconference of the Chartered Clean Air Scientific Advisory Committee to provide public comments for consideration prior to its peer review of EPA's Policy Assessment for Particulate Matter. EPN presented oral testimony raising concerns about the review process, its outcome, and potential threats to public health and the environment.

EPN Comments on EPA’s Proposed Error Correction to NAAQS Non-attainment Designations for Sulfur Dioxide in Texas Counties

EPA proposed an error correction for a number of Texas counties found to be out of compliance with the 1-Hour Primary NAAQS for sulfur dioxide. EPN cautioned EPA that if finalized, this rule would set a dangerous precedent for the use of error correction, would be contrary to clear direction in the Clean Air Act, and would put Texas residents near an operational power plant at risk.

PM and SO2 In The News

Soot Standard Vote Adds To Controversy Over Advisory Panel

October 28, 2019 / by

Sean Reilly /

E&E

John Bachmann, EPN member and former Associate Director for Science/Policy and New Programs, EPA Office of Air Quality Planning and Standards, was quoted in this article about the Clean Air Scientific Advisory Committee’s unprecedented split vote on particulate matter standards, demonstrating the effects of eliminating key scientific expertise from the panel.

Former EPA Staff See ‘Dangerous Precedent’ In SO2 Designation Revision

September 25, 2019 / by

Stuart Parker /

Inside EPA

EPN members Sara Schneeberg, former Assistant General Counsel, EPA Air and Radiation Law Office, and Janet McCabe, former Acting Assistant Administrator, EPA Office of Air and Radiation, were quoted in this article about comments submitted by EPN regarding EPA’s decision to allow five Texas counties to escape sulfur dioxide regulation.

EPN’s Work on TSCA and Water Quality


TSCA and Water Quality In The News

Trump Critics Press EPA To Address Advisors’ TSCA Evaluation Concerns

October 2, 2019 / by

Maria Hegstad and David LaRoss /

Inside EPA

EPN is mentioned in this article about EPA’s draft risk evaluations for pigment violet 29 and pressure from environmentalists to revise the conclusion that the chemical does not present a significant risk to human health; it was the first completed draft risk assessment under the amended Toxic Substances Control Act (TSCA).

Lawyers Expect EPA’s New CWA 401 Plan To Spur Lengthy Litigation ‘Mess’

September 23, 2019 / by

Lara Beaven /

Inside EPA

Mark Ryan, EPN member and former EPA Regional Counsel, Region 10, was quoted in this article about an EPA proposal to scale back state authority to review whether federal programs under the Clean Water Act would harm state water quality standards.

EPN Op-Eds

EPN members penned their own op-eds on tensions with California and the auto industry and on the Clean Water Rule.

EPA’s War On California

October 9, 2019 / by

Dave Coursen /

The Hill

Dave Coursen, EPN member and former EPA Office of General Counsel, wrote this op-ed about the conflict between EPA and California over air and water quality following the state’s deal with automakers to maintain fuel efficiency standards.

Repealing The Clean Water Rule Is Not About Protecting Farmers

September 20, 2019 / by

Betsy Southerland and Mark Ryan /

The Hill

EPN members Betsy Southerland, former Director, Office of Science and Technology, EPA Office of Water, and Mark Ryan, former EPA Regional Counsel, Region 10, wrote this op-ed about the repeal of the 2015 Clean Water Rule and the law’s crucial role as an authority protecting national waterways and wetlands.

White House Prepares to Revoke California’s Right to Set Tougher Pollution Rules

September 5, 2019 / by

Coral Davenport /

The New York Times

EPN member Margo Oge, former Director, EPA Office of Transportation and Air Quality, is quoted in this article about the Trump Administration considering a plan to revoke California’s legal authority to set state tailpipe pollution standards that are stricter than federal regulations. A similar article ran in Courthouse News.

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 benefits considered by the agency during rulemakings, lead in drinking water, the relationship between environmental policy and federalism, the continued dismantling and undermining of science, changes in animal testing policies, cuts to science advisory boards,  disputes with California, changes to methane policies, and continued disputes surrounding PFAS.

How Much Is A Human Life Worth? The Agency Has An Answer

October 15, 2019 / by

Jean Chemnick /

Climatewire

EPN member Rob Wolcott, former EPA Senior Counsel, Office of Air and Radiation, was quoted in this article about the value of statistical life assigned by EPA to analyze the benefits of avoidable mortalities when crafting particulate matter regulations.

EPA Looks To Lead on lead

October 10, 2019 / by

Josh Siegel and Abby Smith /

Washington Examiner

Carl Reeverts, EPN member, former Deputy Director of the Drinking Water Protection Division, EPA Office of Ground Water and Drinking Water, was quoted in this article about EPA’s proposed lead and copper rule, which relaxes requirements for replacing lead-lined pipes and allows contamination to continue.

States Demand Wheeler Explain EPA’s Stance on Federalism (2)

September 27, 2019 / by

Stephen Lee /

Bloomberg Environment

EPN members Janet McCabe, former Acting Assistant Administrator, EPA Office of Air and Radiation, David Coursen, former EPA Office of General Counsel, and Betsy Southerland, former Director, Office of Science and Technology, EPA Office of Water, were quoted in this article about the Trump Administration’s fight with California regarding fuel efficiency standards.


‘The Silenced’: Meet The Climate Whistleblowers Muzzled By Trump

September 17, 2019 / by

Oliver Milman /

The Guardian

EPN members Jeff Alson, former EPA Senior Engineer and Policy Advisor, 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 about former government officials who blew the whistle on the Trump Administration regarding environmental rollbacks and scientific censorship. This article also ran in the New Mexico In Depth and Truthout.

EPA Plans To ‘Reduce, Replace And Refine’ Animal Testing

September 10, 2019 / by

Ariana Figueroa /

Greenwire

Penny Fenner-Crisp, EPN member and former Senior Science Advisor to the Director, EPA Office of Pesticide Programs, was quoted in this article about a recent announcement from EPA Administrator Wheeler about plans to reduce animal testing and eliminate mammal testing by 2035 as alternative methods for chemical and pesticide toxicology continue to develop.

Science Advisory Boards See Major Cuts And Controversial Changes Under Trump Administration

September 5, 2019 / by

Ruth Milka /

Nation of Change

Mustafa Santiago Ali, EPN member and former EPA Senior Advisor for Environmental Justice and Community Revitalization, and Assistant Associate Administrator for Environmental Justice, was quoted in this article about the Trump Administration’s attacks on science, from proposed budget cuts at EPA to new regulations that ban qualified scientists from serving on advisory panels.

Read all recent EPN In The News items here