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How the NFL Sidelined Science—and Why It Matters

Photo: Nathan Rupert/CC BY-NC-ND 2.0 (Flickr)

Football was not just the most important social activity on weekends in New Jersey growing up, but it was woven into the family and community in which I grew up. My dad played football in his small town Vermont high school along with his older brother who went on to play college football at the University of Vermont. Hence, weekends at the Reed household were for screaming at TV sets or from real-life bleachers and theatrical displays of cheering played out in falling off of couches and crashing onto floors.

Football players have always carried a sort of badge of honor for playing America’s favorite sport, but it wasn’t until recently that that badge began to carry even more weight due to emerging knowledge about what even just a few years of executing football plays could mean for their quality of life down the line.

Even if you don’t closely follow football, you are likely aware that the NFL has been at the center of the news cycle in recent months, with players kneeling during the playing of the national anthem to protest racial injustice and police brutality. The players’ protest has drawn fire from a number of directions, including the White House. (Here at UCS, our staff joined with the campaign #scientiststakeaknee, supporting these players’ right to protest and the importance of their cause.)

But these protests aren’t the only way that the NFL has come into the spotlight. It’s increasingly clear that the repeated head injuries many football players experience can cause long-term damage—but the NFL has worked hard to bury these facts.

The NFL’s foray into CTE science

A powerful slide from Dr. Ann McKee’s presentation summarizing her findings on CTE at the Powering Precision Health Summit. The BU Brain Bank most recently analyzed 111 brains of former NFL players, finding that all but one had signs of CTE.

The NFL spent years, beginning in the 1990s, working to control the science behind the health consequences of repeated head injuries incurred while playing football. By doing so, the company infringed on its players’ right to know and ability to make informed decisions about their health and career paths. And as the NFL failed to do its due diligence to conduct honest science on the game, players were consistently told to return to play after collisions only to be left with debilitating health issues and devastated family members.

The NFL’s actions closely track with the tobacco and fossil fuel industries, and include examples of just about every tactic in our “Disinformation Playbook,” which are documented in Steve Fainaru and Mark Fainaru-Wada’s 2013 book, League of Denial. Just a few uses of the plays include:

The Fake: The NFL commissioned a Mild Traumatic Brain Injury (MTBI) committee that published a series of studies in the journal Neurosurgery in the early 2000s, which downplayed the risks of repeated head injuries by cherrypicking data and using incomplete data on the number of concussions that were reported during games.

The Blitz: Bennett Omalu, the pathologist who first discovered CTE in an NFL player, faced opposition from the NFL which called for the retraction for his article on the subject in 2005 and then called his second study “not appropriate science” and “purely speculative.” The second chair of NFL’s brain injury committee, Ira Casson, later attacked and mocked Boston University neuropathologist, Dr. Ann McKee, for her work on CTE.

The Diversion: Ira Casson acquired the nickname “Dr. No” by the authors of League of Denial as he willfully refused to accept that repeated head injury could lead to long-term brain damage in football players, even though he spent years studying boxers and had concluded that the sport was associated with brain damage. In a 2010 Congressional hearing on football brain injuries, he held tight to his denial of the link, telling members of Congress that, “My position is that there is not enough valid, reliable or objective scientific evidence at present to determine whether or not repeat head impacts in professional football result in long term brain damage.”

The Fix: The NFL was able to manipulate processes in order to control the science on head injuries sustained while playing football. The editor-in-chief of the journal Neurosurgery in which all of the MTBI’s studies were published was Dr. Michael Apuzzo, a consultant for an NFL football team. The peer review process for this journal, unlike others, allowed papers to be published even if reviewers were harshly critical and rejected the science as long as the objections were published in the commentaries section of the paper. Despite harsh criticism from reviewers who were prominent experts in the field, Dr. Julian Bailes and Dr. Kevin Guskiewicz, the MTBI got away with publishing a series of papers downplaying the health risks of playing football.

In 2016, the NFL finally admitted that there was a link between playing football and the development of degenerative brain disorders like CTE after denying the risks for over a decade. The NFL has since changed some of its rules and has dedicated funding to help make the game safer for players, protections that President Trump argues are “ruining the game.” Trump’s blatant disregard of the evidence on the health impacts of playing football is beyond disappointing but not at all surprising, considering the way that this administration has treated science since day one.

From NFL player to science champion

Chris and I behind the scenes after a full day filming the PSA this August.

I have been fortunate to meet and spend time with former NFL player and science champion, Chris Borland, who has turned his frustration with the league into support for independent science on the impacts of playing football for its child and adult players. Yesterday, he spoke at a scientific conference on the role of the media and others in communicating the CTE science to the general public, so that we all have a better understanding of the risks of playing football, especially during youth. He also spoke about the emerging science on biomarkers that will help diagnose CTE in living players in the near future.

Here’s Chris’s take on why we should be standing up for science and exposing and fighting back against the disinformation playbook:

Chris and I are also featured on this week’s Got Science? podcast. Listen below:

In carrying out plays from the Playbook to sideline science, companies like the NFL break a simple social responsibility to “do no harm.” Take a look at our brand new website detailing the case study of the NFL along with 19 other examples of ways in which companies or trade organizations have manipulated or suppressed science at our expense, and find out how you help us stop the playbook.

Photo: Nathan Rupert/CC BY-NC-ND 2.0 (Flickr)

Post-Harvey, the Arkema Disaster Reveals Chemical Safety Risks Were Preventable

Halloween is right around the corner, but the Environmental Protection Agency (EPA) has been a perpetual nightmare to public safety since Administrator Scott Pruitt arrived, sending long-awaited chemical safety amendments to an early grave this year. The Risk Management Plan (RMP) is a vital EPA chemical safety rule that “requires certain facilities to develop plans that identify potential effects of a chemical accident, and take certain actions to prevent harm to the public or the environment”—but delays to the effective date of the long-awaited updates are putting communities, workers, and first responders directly in the way of harm, as we have witnessed from recent events following Hurricane Harvey.

Last Friday, the Union of Concerned Scientists released a report finding evidence of harm caused to communities by RMP-related incidents in the wake of Hurricane Harvey. The report serves as a supporting document in a lawsuit UCS is involved with against the EPA decision to delay the long overdue RMP update. Our objective was to further highlight how, if the improvements to the RMP had been allowed to go into place as planned, damage from chemical plants during Hurricane Harvey could have been diminished. We provided an in-depth analysis of the steps the Arkema facility could have taken with the proposed changes in effect, and estimated the toxic burden that the surrounding community was exposed to.

Additionally, we examined other incidents (i.e. spills, releases, explosions) that occurred at chemical facilities during Hurricane Harvey, as well as emphasizing the disproportionate impacts of chemical incidents on communities of color and low-income communities. I have taken “toxic tours” on Houston’s east side with our partners at Texas Environmental Justice Advocacy Services (t.e.j.a.s.), and am all too aware that disparities in distribution of RMP facilities and concentration of toxic pollutants exist and are mostly unnoticed by the unaffected public.

Could Arkema have been avoided?

In late August of this year, Hurricane Harvey unleashed massive quantities of rain upon Houston and surrounding towns, flooding streets, homes—and chemical facilities. As a result, the Arkema plant in Crosby, Texas, a town 25 miles northeast of Houston, was inundated with floodwater and left without power or working generators. This meant the refrigerators needed for cooling volatile organic peroxides were not operational, which ultimately led to the exploding of 500,000 pounds of the unstable chemicals. Though we cannot say Arkema would not have had an incident, we do know the damage inflicted upon first responders and nearby residents could have been mitigated by implementing the revisions to the chemical safety rule, which would have required:

  • Coordination with local emergency response agencies—RMP has standards that would require industries to coordinate and provide information to emergency responders. This would have likely prevented the Crosby first responders from being exposed to noxious fumes—at the perimeter of the ineffective 1.5-mile evacuation zone, I might add—after the Arkema explosion. A group of injured first responders are now suing the plant for failing to properly warn the responders of the dangers they faced.
  • Analysis of safer technologies and chemicals—The facility would have had to begin research into safer technologies and chemicals for use in their facility, including less volatile chemicals, or safer storing and cooling techniques to preempt an explosion.
  • Root cause analyses—A thorough investigation of past incidents to prevent similar future incidents would have been required of RMP facilities.
Communities are at risk

Real life isn’t an action film, where explosions abound and the dogged hero emerges from a fiery building unscathed, nary a casualty to be found.  In real life, the consequences of a chemical explosion, leak, or spill are often dangerous and deadly. We have ways to hold chemical facilities accountable for taking necessary preventative measures, but we must urge the EPA to implement the changes to the proposed RMP rule in order to do so.

Voting Technology Needs an Upgrade: Here’s What Congress Can Do

Voting systems throughout the United States are vulnerable to corruption in a variety of ways, and the federal government has an obligation to protect the integrity of the electoral process. At a recent meeting of the National Academies of Sciences, Engineering and Medicine’s Committee on the Future of Voting, the Department of Homeland Security’s Robert Kolasky put it bluntly: “It’s not a fair fight to pit Orange County (California) against the Russians.”

While the intelligence community has not confirmed that the hackers working on behalf of the Russian government to undermine the 2016 election were successful at tampering with actual vote tallies, they certainly succeeded at shaking our confidence in the electoral process, which over time could undermine faith in democracy.

The management of statewide eligible voter lists is a particularly challenging but crucial responsibility. On the one hand, data entry errors, duplicate records and “live” records for deceased voters invite voter fraud and inaccuracies in voting data. On the other hand, overly broad purging of voter lists can result in the exclusion of eligible voters from the rolls.

Two problems with voter list maintenance

Validation of voter eligibility is typically done through “matching” of individuals on voter registration lists with other databases using unique combinations of traits of eligible individuals (birthdays and names, etc.). This process is error-prone in two ways. First, data may not be entered identically for individuals across databases (misspelled names, missing data, etc.), so that individuals fail to get matched and are excluded (false negatives). Second, the computer algorithms used to identify and match records may be imprecise, such that they match the wrong people (false positives) or exclude people from voter lists based on faulty matching techniques (false negatives).

Both assumptions, that matching databases have the correct data, and that the algorithm for identifying individual matches actually does so, have proven challenging. For example, research has shown that the surprisingly high probability that two people in a group of a given size share the same birthday can largely account for inflated estimates of double registrations and people double voting. That is, an algorithm that matches on birthday, and possibly last name, is a poor method for identifying voters, because lots of people share those traits.

But even that poor algorithm assumes that the underlying data is accurate, when it is often not. Even databases containing precisely individualized identifiers, like social security numbers, include enough error to be inappropriate for matching. Indeed, the Social Security Administration accidently declares over 10,000 people dead every year, and attempts to match voter lists with the last four SSN digits have produced error rates above 20%, such that the SSA Inspector General has warned against its use for this purpose.

Sloppy matching algorithms that do not attempt to correct for such data inaccuracies are prone to exclude high numbers of eligible voters. For example, the Crosscheck system, developed by the president’s Electoral “Integrity” Commission Chair Kris Kobach, has actually produced error rates as high as 17% in Chesterfield County, VA, prompting them to abandon the software.

Two solutions that improve voter list management

The solution to these problems is thus twofold: improving the quality of matching algorithms in order to create precise identifiers and overcome data inaccuracies, and reducing the probability of ineligible voters or inaccurate data getting on the voter list to begin with.

Recent advances in algorithmic design have shown that using multiple matching criteria with recoded data to account for common data entry inaccuracies can yield matches that are 99% accurate. For example, Stephen Ansolabehere and Eitan D. Hersh have demonstrated that using three-match combinations of Address (A), Date of Birth (D), Gender (G) and Name (N), or ADGN, is extremely effective in successful matching (and helps explain how Facebook knows everything about you).

For securing and maintaining precise voter list data from the start, the implementation of automatic voter registration, or AVR, is proving increasingly effective and popular. By automatically registering all eligible adults (unless they decline) when people update their own data through government agencies, and by transferring that data electronically on a regular basis, the process “boosts registration rates, cleans up the rolls, makes voting more convenient, and reduces the potential for voter fraud, all while lowering costs” according to the Brennan Center for Justice, which advocates AVR.

Ten states and the District of Columbia have already approved AVR, and 32 states have introduced AVR proposals this year. It is a politically bi-partisan solution, with states as different as California and Alaska having already adopted the practice.
Road Island’s Democratic Secretary of State, Nellie Gorbea, has stated that “Having clean voter lists is critical to preserving the integrity of our elections, which is why I made enacting Automatic Voter Registration a priority.”

Republican Governor of Illinois Bruce Rauner, on signing his state’s AVR law, explained that “This is good bipartisan legislation and it addresses the fundamental fact that the right to vote is foundational for the rights of Americans in our democracy.”

Given the seriousness of the threat, and the fact that such effective solutions for voter list management have already been developed, Congress should ensure that states have the capacity to implement these policies, which are among the most important infrastructure investments that we can make.

Trashing Science in Government Grants Isn’t Normal: The Case of the EPA, John Konkus, and Climate Change

There is now a political appointee of the Trump administration at the Environmental Protection Agency (EPA), John Konkus, reviewing grant solicitations and proposals in the public affairs office. It has been reported that Konkus is on the lookout for any reference to “climate change” in grant solicitations in attempt to eliminate this work from the agency’s competitive programmatic grants. So, is this normal?

Grants and government

The US Federal Government gave out nearly $663 billion in grant funding in fiscal year 2017. Such funding pays for a wide range of state and local government services, such as health care, transportation, income security, education, job training, social services, community development, and environmental protection. Additionally, approximately $40 billion in grant funding from federal agencies funds scientific research annually, although the amount of funding for research and development from the federal government has declined in recent years.

Given the large amount of grant funding that the federal government gives out annually, it is critical that the government has:  1) guidelines that provide guidance on what type of work the government grant will fund, and 2) a process for determining who receives funding. While each grant is unique in its considerations of what makes a good candidate for funding, there is a relatively standard process through which government grants are advertised and funded. The majority of this information can be found at www.grants.gov.

The grant solicitation

The first step in the process for funding of scientific grants is for a government agency to solicit proposals from interested parties (i.e., scientists working outside the government). The US Federal Government refers to these solicitations as “Funding Opportunity Announcements” or FOAs. These FOAs include information about what type of work the agency is expecting and whether or not the applicant would be eligible for funding. Thus, an FOA is extremely important for both the government and the applicant because it highlights the agency’s priorities for the funding, which also serves as a guideline for an applicant’s proposal.

The agency must first consider what type of work is currently needed in the US. In the case of science, the agency assesses what is currently unknown in our scientific knowledge on a given subject. Additionally, agencies will determine what special considerations are needed to make the grant work more impactful—these may include work that focuses on environmental justice or coal communities, for example. These considerations are typically discussed in the FOAs, and grants that include these special considerations in their proposals are typically ranked as more competitive relative to others that do not.

The FOA is reviewed by a panel of experts, which consist of career officials across the federal government for most agencies. It isn’t uncommon for political appointees to review an FOA. Political appointees generally broaden the FOA so it’s more inclusive, asking questions such as, “do you think that we might want to consider adding a special consideration for communities recently affected by natural disasters?” What does seem to be uncommon is eliminating scientifically defensible language like the “double C word.”

Reviewing grant proposals and awards

At many federal agencies, grants are reviewed by career agency staffers who have expertise for the grant program. However, in the cases of the National Science Foundation and the National Institutes of Health, a panel of non-federal scientists who have scientific expertise in the relevant research areas and scientific disciplines review submitted proposals. All proposed federal grants typically go through a first round review where they are screened for eligibility. If the proposal does not meet eligibility criteria, it is not reviewed further.

Those proposals that are eligible for funding are then reviewed by a panel of career agency staffers who are experts for the grant program’s work. The proposals are evaluated based on criteria specific to the grant – for some programmatic grants these criteria are dictated by statutory authority (e.g., grants in the brownfields program at the EPA). Based on these criteria, the panel scores each proposal. The proposals that receive higher scores are deemed more competitive relative to those with lower scores.

Depending on the amount of funding available for a grant program, the panel will recommend a percentage of the top scoring grants to be funded. The panel also takes into consideration other factors that may have been emphasized in the FOA (e.g., a community that was just ravaged by a natural disaster that is in greater need of funding relative to other communities).

The recommended set of proposals for funding are then sent to the head of the program, which can be a political appointee of a presidential administration. The amount of information on recommendations that the appointee might receive varies. Sometimes the appointee might receive abstracts of proposals or they might just receive a list of the institutions or researchers recommended for funding. The appointee typically agrees with the recommendation of the expert panel. It would be uncommon for the political appointee to not fund a proposal recommended for funding, as is being done by Konkus.

Ignoring science in grants will harm others

Is it uncommon for political appointees to have a say in the grant funding process? No. What is uncommon is for political appointees to politicize science in grant solicitation language or in rescinding proposals that were recommended by a panel of experts. As former EPA administration Christine Todd Whitman chimed in on this issue, “We didn’t do a political screening on every grant, because many of them were based on science, and political appointees don’t have that kind of background.”

As is common with this administration, we are seeing proposals that mention the “double C word” as a target. Konkus rescinded funding from EPA to two organizations that would have supported the deployment of clean cookstoves in the developing world—a simple solution to curb the impacts of climate change, but also to limit pollution that disproportionately affects women and children in these areas. Who knows what Konkus will rescind next, but it’s likely to have harmful effects on people. Maybe Konkus should leave decisions for funding up to the expert panels. They are categorized as experts for a reason.

The 5 Worst Plays From Industry’s Disinformation Playbook

When I was 13, this is what I identified as the hardest thing about life then. My trust issues were just beginning to manifest themselves.

I have always had a healthy dose of curiosity and skepticism and a desire to hold people accountable for their statements built into my DNA. Usually, these were borne out in letter-writing campaigns. As a child, I sent a series of letters to the Daily News because I believed its campaign of “No More Schmutz!” was falling short after rifling through the pages and still having gray smudges on my fingers. Inky fingers is a far cry from misinformation about the dangers of fossil fuel pollution, but overall, my general pursuit for the truth hasn’t changed.

My newest project at the Center for Science and Democracy released today is a website that exposes the ways in which companies seek to hide the truth about the impacts of their products or actions on health and the environment. By calling out the plays in the “Disinformation Playbook,” we hope to ensure that powerful companies and institutions are not engaging in behavior that would obstruct the government’s ability to keep us safe, and at the very least aren’t doing us any harm. Unfortunately, as our case studies show, there are far too many examples in which companies and trade organizations have made intentional decisions to delay or obstruct science-based safeguards, putting our lives at risk.

In the Disinformation Playbook, we reveal the five tactics that some companies use to manipulate, attack, or create doubt about science and the scientists conducting important research that appears unfavorable to a company’s products or actions. We also feature twenty case studies that show how companies in a range of different industries have used these tactics in an effort to sideline science.

While not all companies engage in this irresponsible behavior, the companies and trade associations we highlight in the playbook have acted in legally questionable and ethically unsound ways. Here are five of the most egregious examples from the Playbook:

The Fake: Conducting counterfeit science

In an attempt to reduce litigation costs, Georgia-Pacific secretly ran a research program intended to raise doubts about the dangers of asbestos and stave off regulatory efforts to ban the chemical. The company used knowingly flawed methodologies in its science as well as publishing its research in scientific journals without adequately disclosing the authors’ conflicts of interest. By seeding the literature with counterfeit science, Georgia-Pacific created a life-threatening hazard by deceiving those who rely on science to understand the health risks of asbestos exposure. While asbestos use has been phased out in the US, it is not banned, and mesothelioma still claims the lives of thousands of people very year.

The Blitz: Harassing scientists

Rather than honestly dealing with its burgeoning concussion problem, the National Football League (NFL) went after the reputation of the first doctor to link the sport to the degenerative brain disease he named Chronic Traumatic Encephalopathy. What Omalu found in Mike Webster’s brain—chronic traumatic encephalopathy (CTE), a progressive degenerative disease mainly associated with “punch drunk” boxers and victims of brain trauma—broke the NFL’s burgeoning concussion problem wide open. But instead of working with scientists and doctors to better understand the damaging effect of repeated concussions and how the league could improve the game to reduce head injuries, the NFL went after the reputation of Omalu and the other scientists who subsequently worked on CTE. Just this year, Boston University scientists released a study of 111 deceased former NFL players’ brains, revealing that all but one had signs of CTE.

The Diversion: Sowing uncertainty

The top lobbyist for the fossil fuel industry in the western United States secretly ran more than a dozen front groups in an attempt to undermine forward-looking policy on climate change and clean technologies. As a leaked 2014 presentation by Western States Petroleum Association (WSPA) President Catherine Reheis-Boyd revealed, WSPA’s strategy was to use these fabricated organizations to falsely represent grassroots opposition to forward-looking policy on climate change and clean technologies. WSPA and its member companies oppose science-based climate policies that are critically needed to mitigate the damaging impacts of global warming.

The Screen: Borrowing credibility

Coca-Cola quietly funded a research institute out of the University of Colorado designed to persuade people to focus on exercise, not calorie intake, for weight loss. Emails between the company and the institute’s president suggested Coca-Cola helped pick the group’s leaders, create its mission statement, and design its website. A growing body of scientific evidence links sugar to a variety of negative health outcomes, including diabetes, cardiovascular disease, and high cholesterol. Coca-Cola’s actions overrode sensible transparency safeguards meant to ensure the independence of research—and allow consumers to understand the risks of sugar consumption for themselves.

The Fix: Manipulating government officials

After meeting with and listening to talking points from chlorpyrifos producer Dow Chemical Company, the EPA announced it would be reversing its decision to ban the chemical that is linked to neurological development issues in children. In 2016, the EPA concluded that chlorpyrifos can have harmful effects on child brain development. The regulation of chlorpyrifos is additionally an environmental justice issue. Latino children in California are 91 percent more likely than white children to attend schools near areas of heavy pesticide use.

The secret to a good defense is a good offense

By arming ourselves with independent science, we can fight back against these familiar tactics. Granted, it’s not an easy task, especially in the face of a government run by an administration that doesn’t appear to value evidence, believing asbestos is 100% safe and claiming that climate change is a hoax. I hear powerful stories every day of communities working together to crush corporate disinformation campaigns with the hard truth.

Just a couple of weeks ago, community members from Hoosick Falls, New York attended the hearing for “toxicologist-for-hire,” Dr. Michael Dourson, the nominee to head up the EPA’s Office of Chemical Safety and Pollution Prevention. Senator Kristen Gillibrand paid homage to their bravery, “The water that they drink, the water they give their children, the water they cook in, the water they bathe in, is contaminated by PFOA. These families are so frightened.” These individuals had a powerful story to tell about the way in which DuPont downplayed the dangers of the chemical byproduct of Teflon, C8 or PFOA, and Dourson’s consulting firm, hired by DuPont, recommended a far lower standard for the chemical than most scientists believe would have protected exposed residents from harm.

We hope that reading through the playbook will encourage you to stand up for science and join us as we continue to challenge companies that attempt to sideline science, seeking business as usual at our expense. Become a science champion today and take a stand against corporate disinformation by asking your members of congress not to do automakers’ bidding by rolling back valuable progress on vehicle efficiency standards.

Stay curious, stay skeptical, and together we can work toward making corporate culture more honest and transparent by raising the political cost of using the disinformation playbook.

Michael Dourson: A Toxic Choice for Our Health and Safety

When it comes to conflicts of interest, few nominations can top that of Michael Dourson to lead the EPA’s Office of Chemical Safety and Pollution Prevention. Time after time, Dourson has worked for industries and against the public interest, actively downplaying the risks of a series of chemicals and pushing for less stringent policies that threaten our safety.

In short, Dourson pushes counterfeit science, is unfit to protect us from dangerous chemicals, and is a toxic choice for our health and safety.

A litany of toxic decisions

Consider the 2014 Freedom Industries chemical spill into the Elk River in Charleston, West Virginia, which contaminated drinking water supplies for 300,000 people with MCHM and PPH—two chemicals used to clean coal.

After the spill, Dourson’s company, TERA, was hired by the state to put together a health effects panel; Dourson was the chair. He did not disclose the fact, however, that he had been hired to work for the very same companies that manufactured those chemicals, a fact that only later came out while he was being questioned by a reporter.

Dourson was also involved in helping set West Virginia’s “safe” level in drinking water for a chemical used to manufacture Teflon (Perfluorooctanoic acid (PFOA), or “C8”). It was 2,000 times higher than the standard set by the EPA.

In 2015, Dourson provided testimony for DuPont in the case of a woman who alleged that her kidney cancer was linked to drinking PFOA-contaminated water from the company’s Parkersburg, WV plant. Just this year, DuPont settled with plaintiffs from the Ohio Valley who had been exposed to PFOA from the same plant for $670 million after an independent C8 Science Panel made up of independent epidemiologists found “probable links” between PFOA and kidney and testicular cancer, as well as high blood pressure, thyroid disease, and pregnancy-induced hypertension.

From 2007 to 2014, Dourson and TERA also worked closely with Michael Honeycutt and the Texas Commission on Environmental Quality to loosen two-thirds of the already weak protections for 45 different chemicals.

The list of toxic decisions made by Dourson and his team goes on and clearly makes him an unacceptable choice for a leadership role at the agency charged with protecting public health and the environment.

A worst-case choice

During Dourson’s hearing before the Senate Committion on Environment and Public Works (EPW), his answers to questions about recusing himself from decisions regarding former chemicals on which TERA has worked closely with industry were cagey at best. It appears that because much of his work was through the University of Cincinnati, he will not be expected to recuse himself from decisions about chemicals that his research team was paid by industry to assess in the past. His ethics agreement confirms this. So much for the Trump administration’s draining of the swamp.

If Dourson is confirmed, I have no doubt that his appointment will be repeatedly cited as a worst-case-scenario of the revolving door between industry representatives and the government.

His work over the past few decades has been destructive enough, even from a position with little power to help the chemical industry directly skirt tough regulations. Putting him in charge of the office that is supposed to protect the public from toxins would be a grave mistake with national ramifications.

In the coming years, Dourson’s office will be making decisions about safety thresholds and key regulatory actions on chlorpyrifos, neonicotinoids, flame retardants, asbestos, and the other priority chemicals under the Toxic Substances Control Act. There is no room for error, and unfortunately, error is likely with someone like Dourson in charge.

We join with many other members of the scientific community to oppose Michael Dourson for Assistant Administrator of OCSPP and to ask senators to vote no in upcoming committee and confirmation votes.

New UCS Report Finds High Health Risks in Delaware Communities from Toxic Pollution

Refineries, such as the Delaware City Refinery shown here, can emit toxic chemicals that can increase risks for cancer and respiratory disease.

For decades residents of communities in Wilmington, Delaware’s industrial corridor have dealt with high levels of pollution. People in these communities, which have higher percentages of people of color and/or higher poverty levels than the Delaware average, are also grappling with health challenges that are linked to, or worsened by, exposure to pollution, such as strokes, heart diseases, sudden infant death syndrome, and chronic childhood illnesses such as asthma, learning disabilities, and neurological diseases. These are some of Delaware’s environmental justice communities.

To assess the potential link between environmental pollution and health impacts in these communities, the Center for Science and Democracy at UCS collaborated with the Environmental Justice Health Alliance, Delaware Concerned Residents for Environmental Justice, Community Housing and Empowerment Connections, Inc. and Coming Clean, Inc. Analysis of the following health and safety issues using Environmental Protection Agency (EPA) data were conducted:  the risk of cancer and potential for respiratory illnesses that stem from toxic outdoor air pollution; proximity of communities to industrial facilities that use large quantities of toxic, flammable, or explosive chemicals and pose a high risk of a major chemical release or catastrophic incident; proximity of communities to industrial facilities with major pollution emissions; and proximity of communities to contaminated waste sites listed in EPA’s Brownfield and Superfund programs.

The seven communities analyzed—Belvedere, Cedar Heights, Dunleith, Marshallton, Newport, Oakmont, and Southbridge—were compared to Greenville, a predominantly White and affluent community located outside the industrial corridor, and to the population of Delaware overall. The findings from this analysis have been published in a new report titled Environmental Justice for Delaware: Mitigating Toxic Pollution in New Castle County Communities.

Proximity to major pollution sources and dangerous chemical facilities

TABLE 5. Sources of Chemical Hazards and Pollution in Environmental Justice Communities Compared with
Greenville and Delaware Overall. Note: All facilities are located within 1 mile of communities.
SOURCE: Environmental Protection Agency (EPA). No date (i). EPA state combined CSV download files. Online at www.epa.gov/enviro/epastate-combined-csv-download-files, accessed May 18, 2017.

Dunleith and Oakmont have several Brownfield sites and are in close proximity to facilities releasing significant quantities of toxic chemicals into the air. Southbridge has, within its boundaries or within a one-mile radius around it, two high-risk chemical facilities, 13 large pollution-emitting industrial facilities, four Superfund sites, and 48 Brownfield sites. Southbridge is home to more than half of all Brownfields in Delaware. Cedar Heights and Newport also have several large pollution-emitting facilities within one mile as well as being close to two EPA Superfund contaminated waste sites.

Effects of toxic air pollution on cancer risks and the potential for respiratory illnesses

TABLE 2. Cancer Risks for Environmental Justice Communities Compared with Greenville and Delaware Overall
Note: Cancer risk is expressed as the incidences of cancer per million people. For the respiratory hazard index, an index value of 1 or less indicates a level of studied pollutants equal to a level the EPA has determined not to be a health concern, while a value greater than 1 indicates the potential for adverse respiratory health impacts, with increasing concern as the value increases. SOURCE: Environmental Protection Agency (EPA). 2015. 2015 National Air Toxics Assessment. Washington, DC. Online at www.epa.gov/national-air-toxics-assessment, accessed May 18, 2017.

Of the seven environmental justice communities studied, people in Marshallton face the highest cancer and respiratory health risks. Cancer and respiratory health risks there are 33 and 71 percent higher, respectively, than for the comparison community Greenville, and are 28 and 55 percent higher than for Delaware overall.

The communities of Dunleith, Oakmont, and Southbridge, whose residents are predominantly people of color and have a poverty rate approximately twice that of Delaware overall, have cancer risks 19 to 23 percent higher than for Greenville and 14 to 18 percent higher than for Delaware overall. Respiratory hazard in these three communities is 32 to 43 percent higher than for Greenville and 20 to 30 percent higher than for Delaware overall.

For Newport, Belvedere, and Cedar Heights, which have a substantial proportion of people of color and poverty rates above the Delaware average, cancer risks are 21, 15, and 12 percent higher than for Greenville, respectively, and are 16, 10, and 7 percent higher than for Delaware overall. Respiratory hazard in Newport, Belvedere, and Cedar Heights is 44, 30, and 24 percent higher than for Greenville, respectively, and 31, 18, and 13 percent higher than for Delaware overall.

Children at risk

Kenneth Dryden of the Delaware Concerned Residents for Environmental Justice and a former Southbridge resident leads a tour of toxic facilities to teach scientists and community members about the dangers of local air pollution.

Children are especially vulnerable to the effects of toxic air pollution. Particularly concerning is that seven schools within one mile of Southbridge, with a total of more than 2,200 students, are in locations with substantially higher cancer risks and potential respiratory hazards than schools in all other communities in this study.

In addition to having daily exposure to toxic pollution in the air, children in these communities are at risk of being exposed to toxic chemicals accidentally released from hazardous chemical facilities in or near their communities. For example, the John G. Leach School and Harry O. Eisenberg Elementary School near Dunleith, with a total of 661 students, are located within one mile of a high-risk chemical facility.

Achieving environmental justice for vulnerable communities

Using multiple EPA data bases, the findings of this study indicate that people in the seven communities along the Wilmington industrial corridor face a substantial potential cumulative health risk from (1) exposure to toxic air pollution, (2) their proximity to polluting industrial facilities and hazardous chemical facilities, and (3) proximity to contaminated waste sites. These health risks are substantially greater than those for residents of a wealthier and predominantly White Delaware community and for Delaware as a whole.

This research provides scientific support for what neighbors in these communities already know—that they’re unfairly facing higher health risks. We need to listen to communities and the facts and enact and enforce the rules to protect their health and safety. Environmental justice has to be a priority for these and other communities that face disproportionately high health risks from toxic pollution.

Ron White is an independent consultant providing services in the field of environmental health sciences. Mr. White currently is a Senior Fellow with the Center for Science and Democracy at the Union of Concerned Scientists, and also holds a part-time faculty appointment in the Department of Environmental Health and Engineering at the Johns Hopkins Bloomberg School of Public Health. He earned his Master of Science in Teaching degree in environmental studies from Antioch University, and a Bachelor of Arts degree in environmental science from Clark University.  

Science Network Voices gives Equation readers access to the depth of expertise and broad perspective on current issues that our Science Network members bring to UCS. The views expressed in Science Network posts are those of the author alone.

USDA Reorganization Sidelines Dietary Guidelines

Photo: Cristie Guevara/public domain (BY CC0)

Last month, Secretary of Agriculture Sonny Perdue announced a number of proposed changes to the organization of the vast federal department he oversees. With its 29 agencies and offices and nearly 100,000 employees, the US Department of Agriculture (USDA) is charged with a wide-ranging mission, from helping farmers to be profitable and environmentally sustainable to ensuring the nutritional well-being of all Americans. And while some of the organizational changes Secretary Perdue is pursuing (which all stem from a March executive order from President Trump) may seem arcane, they will have real impacts on all of us. The proposed merger of two key nutrition programs is a case in point.

Photo: US Department of Agriculture/Public domain (Flickr)

The plan involves relocating the USDA’s Center for Nutrition Policy and Promotion (CNPP) into the department’s Food and Nutrition Services (FNS). While FNS is well-known in anti-hunger and agricultural communities for its role in administering nutrition assistance programs, including the Supplemental Nutrition Assistance Program (SNAP), CNPP is less so—though not for lack of impact or importance.

Established in 1994, CNPP is the agency responsible for reviewing and compiling the best available scientific literature on human nutrition, developing measures of dietary quality such as the Healthy Eating Index, and (jointly with the Department of Health and Human Services) issuing the Dietary Guidelines for Americans, the cornerstone of federal nutrition policy and dietary guidance. At a time when more than 117 million Americans—half of all adults—are living with one or more preventable, diet-related chronic diseases, the role that CNPP plays in protecting public health has never been more critical.

Reorganization compromises health without achieving efficiency

In the words of Perdue himself, the proposed reorganizations are aimed at making the USDA “the most effective, most efficient, and best managed department in the federal government.”

To be clear, reorganization (or “realignment”) is not an inherently bad thing. Proposals that could successfully increase the effectiveness and accountability of government agencies without compromising mission or purpose would be laudable. But merging CNPP into FNS accomplishes neither—and follows a dangerous pattern of this administration pushing back on science with its policy agenda. Furthermore, the merger poses serious threats to the scientific integrity of the agency charged with developing evidence-based dietary guidelines for the entire country, for several key reasons:

  1. FNS and CNPP serve distinctly different purposes. FNS administers 15 food and nutrition programs targeting distinct populations, serving only a fraction of Americans. CNPP develops science-based recommendations designed to identify nutritional deficiencies and address dietary needs at a population level, which are then applied to dozens of programs across the federal government. To conflate the distinct purposes of each agency would be to detract from the efficiency of each.
  2. The CNPP administrator will lack appropriate credentials to oversee the development of evidence-based national nutrition guidelines. Following the reorganization, CNPP would no longer be headed by a politically-appointed administrator, but instead by a career associate administrator. This individual is highly unlikely to possess the education and level of expertise required by this position.
  3. Merging CNPP into FNS introduces a conflict of interest. Nutrition programs administered by FNS must adhere to dietary recommendations established by CNPP, introducing a potential conflict of interest. Without clear separation between CNPP and FNS, undue influence on the former by the latter—or even the perception thereof—would present a threat to the integrity of evidence-based recommendations.

The USDA received public comments on this issue between September 12 and October 10. The full comment authored by the UCS Food and Environment Program, outlining the risks to scientific integrity and population health posed by the proposed reorganization, follows.

UCS Comments on USDA Notice, “Improving Customer Service”

October 10, 2017

Dear Secretary Perdue and Acting Deputy Assistant Secretary Bice,

On behalf of the Union of Concerned Scientists (UCS), we are compelled to respond to the United States Department of Agriculture (USDA) notice, “Improving Customer Service,” with concerns regarding the proposed merging of the Center for Nutrition and Policy Promotion (CNPP) into the Food and Nutrition Services (FNS). This proposed action would threaten the scientific integrity of CNPP and compromise public health, while providing zero demonstrable financial or public benefit.

UCS, a science-based nonprofit working for a healthy environment and a safer world, combines independent scientific research and citizen action to develop innovative, practical solutions and secure responsible changes in government policy, corporate practices, and consumer choices. The Food and Environment Program at UCS makes evidence-based policy recommendations to shift our nation’s food and agriculture system to produce healthier, more sustainable and just outcomes for all Americans.

CNPP evidence-based recommendations play a critical role in protecting population health.
The current state of US population health poses enormous costs both to quality of life and health care systems. More than 117 million Americans—half of all adults—are now living with one or more preventable, diet-related chronic diseases, including cardiovascular disease, hypertension, diabetes, overweight/obesity, and certain types of cancer. Recent research shows that dietary factors may now play a role in nearly half of all deaths resulting from heart disease, stroke, and type 2 diabetes. In 2012, the direct medical expenses and lost productivity due to cardiovascular disease alone averaged $316 billion, while those due to diagnosed diabetes totaled $245 billion. In total, chronic diseases account for approximately 86 percent of all US health care expenditures.

However, just as diet is a key factor driving these trends, it also offers great potential to reverse them. The federal government has a critical role to play in promoting health and reducing the burden of chronic disease by supporting evidence-based policies and programs that improve the dietary patterns of Americans. For more than twenty years, CNPP has filled this role. The Nutrition Evidence Library (NEL) at CNPP applies rigorous scientific standards to conduct systematic reviews of current nutrition research, and informs a range of federal nutrition programs, including the National School Breakfast Program, National School Lunch Program, Special Supplemental Nutrition Program for Women, Infants and Children (WIC), and the Supplemental Nutrition Assistance Program (SNAP). Working jointly with the Department of Health and Human Services (DHHS), CNPP is also responsible for overseeing the development of the Dietary Guidelines for Americans, the nutrition recommendations that are a cornerstone of federal nutrition policy and dietary guidance. As an autonomous agency, CNPP is well positioned to deliver unbiased and scientifically sound recommendations to other federal agencies and to the general public.

The proposed merger is unlikely to result in increased efficiency.
As stated in USDA-2017-05399, Executive Order 13781, “Comprehensive Plan for Reorganizing the Executive Branch,” was intended to improve efficiency, effectiveness, and accountability through agency reorganization. However, there is no duplication of function between CNPP and FNS. FNS administers 15 food and nutrition programs targeting distinct populations, serving only a fraction of Americans. CNPP develops science-based recommendations designed to identify nutritional deficiencies and address dietary needs at a population level, which are then applied to dozens of programs across the federal government. To conflate the distinct purposes of each agency would be to detract from the efficiency of each. Changes in allocation of resources from restructuring would also threaten the ability of CNPP to conduct its mission.

The proposed merger threatens the scientific integrity of CNPP, compromising its core function.
Merging CNPP into FNS will weaken the ability of the USDA to provide the most current evidence-based nutrition guidance to federal food and nutrition programs. The change would also jeopardize the ability of CNPP to comply with Congressional mandates, chiefly the National Nutrition Monitoring and Related Research Act of 1990, which requires the establishment of dietary guidelines at least once every five years and the promotion of these guidelines by any federal agency carrying out a federal food, nutrition, or health program.

The proposed reorganization would degrade the scientific integrity and core function of CNPP, particularly if:

  1. The CNPP administrator lacks appropriate credentials to guide the development of science based recommendations, including the Dietary Guidelines for Americans (DGA).
    The CNPP administrator has previously been appointed by the Food, Nutrition, and Consumer Services program. With the proposed reorganization, this position would be filled by a career official lacking necessary technical expertise. In its recent review of the DGA process, the National Academy of Sciences, Engineering, and Medicine (NAS) stated that it is of critical importance that “the DGA be viewed as valid, evidence-based, and free of bias or conflict of interest.” As the individual responsible for overseeing management of the NEL and development of DGAs and other science-based recommendations, the CNPP administrator must have strong credentials, including a background in dietetics, nutrition, medicine, and/or public health, with demonstrated experience relevant to nutrition science/research, population health, chronic disease prevention, epidemiology, economics, surveillance systems, and nutrition communications and marketing. This individual must also possess experience in advanced management and budget oversight; continuous quality improvement; program planning; implementation and evaluation; data analytics; information technology; and public policy.
  2. There is inadequate separation of agency function, diminishing the autonomy of CNPP.
    The application of dietary recommendations in programs administered by FNS introduces a potential conflict of interest. Without clear separation between CNPP and FNS, undue influence on the former by the latter—or even the perception thereof—would present a threat to the integrity of evidence-based recommendations. The development of the DGAs and the USDA Food Plans (e.g. Thrifty Food Plan) are of particular concern, as they inform programs administered by FNS.

The Union of Concerned Scientists appreciates the USDA’s efforts to increase the effectiveness and accountability of government agencies. However, the merging of CNPP into FNS accomplishes neither. The ability of CNPP to effectively and independently fulfill its mission of developing evidence-based dietary guidelines without undue influence may be compromised by: 1) the replacement of an appointed administrator with a career associated administrator who may not possess the qualifications needed to oversee the development of science-based federal nutrition recommendations; and 2) the inherent conflict of interest that occurs by way of FNS oversight over CNPP, as the latter develops guidelines that the former must adhere to in the implementation of various nutrition programs.

Given the alarming trajectory of diet and disease in the US, it is in the best interests of the public and the US healthcare system that CNPP continues to operate independently from FNS to produce evidence-based recommendations for population health. As the Director of the Office of Management and Budget considers proposed agency reorganizations to meet the directive of Executive Order 13781, “Improving Customer Service,” UCS is hopeful that the Director recognizes the magnitude of the potential risks associated with merging these agencies and rejects the proposed action.

EPA Administrator Scott Pruitt Accelerates Politicization of Agency’s Science Advisory Board

Earlier today, EPA Administrator Scott Pruitt strongly suggested that the agency will not consider any candidate for EPA’s science advisory committees who has received a grant from agency. Such a gobsmackingly boneheaded move would further hamstring the ability of the EPA to accomplish its public health mission. The administrator is directly challenging the intent of Congress, which established the Science Advisory Board to provide independent scientific advice so that EPA can effectively protect our health and environment.

So why now? Administrator Pruitt’s schedule offers some clues. House Science Committee Chairman and serial scientist harasser Lamar Smith is a champion of the EPA Science Advisory Board Reform Act, flawed legislation that would increase industry control over the Science Advisory Board and, yes, prevent EPA grant recipients from serving. UCS’s Yogin Kothari summed up the legislation for the New Republic:

“They’re basically saying that people who are experts in environmental science, who have spent their careers working on this and may have received EPA grants to do their work, are inherently conflicted, whereas people who are working in the industry, who would be impacted by the board’s advice, are not conflicted,” Kothari said. “I mean, that’s bananas, right?”

Congress has for years failed to pass this legislation, which was vehemently and repeatedly opposed by UCS and many other mainstream science organizations. So in April 2017, a presumably frustrated Chairman Smith got together with Administrator Pruitt to talk about the bill. Pretty persuasion from the congressman seems to have worked.

EPA Administrator Scott Pruitt is taking more steps to politicize the EPA Science Advisory Board, defying Congress in the process. Photo: Wikimedia

Now keep in mind, Administrator Pruitt already has a parade of lobbyists and advisors providing him with the perspectives from oil, gas, and chemical companies. He already thinks he has all the right friends, but would be best served to hear from independent experts, too.

The Science Advisory Board, for now, can be a check on political influence and can help the agency determine whether the special interests are telling it straight. I can see why a man of his outlook would want to neutralize it.

There are plenty of extremely well-qualified, universally respected candidates who can provide scientific advice to an administrator who really needs it. Getting science advice from the EPA Science Advisory Board is like getting basketball tips from 40 Steph Currys. It’s the best in the business, volunteering their time in service of the public good.

Industry participation on the Science Advisory Board is not a problem. But candidates should be evaluated on their scientific expertise and ability to remain objective. So let’s recap: according to some, scientists who receive money from oil and chemical companies are perfectly qualified to provide the EPA with independent science advice, while those who receive federal grants are not. It’s a fundamental misrepresentation of how conflicts of interest work.

Soon, we’ll hear who the EPA will appoint after controversially dismissing qualified scientists earlier this year. Will the new appointees be Yes Men or responsible researchers? All signs point to the former.

If Administrator Pruitt continues to politicize the Science Advisory Board, he’ll be willfully setting himself up to fail at the job of protecting public health and the environment. It’s not something we should stand for.

US Withdrawal from UNESCO Will Undermine Collaboration on Science and Culture

The Trump Administration’s war on science has intensified with the announcement that the US is withdrawing from UNESCO, the international organization that works to promote peace & security through international cooperation on education, science and cultural programs. 

Founded in 1945, when nations were seeking ways to rebuild educational systems and cultural connections in the immediate aftermath of World War II, UNESCO today is a leading multi-lateral organization working on a range of issues crucial for achieving peace, equity and sustainability world-wide.

“Every day, countless Americans and American communities pour their time and their hearts into UNESCO-led international collaborations on science, on education and on culture” says Andrew Potts who practices cultural heritage law at Nixon Peabody LLP.  They work on preventing violent extremism via youth education, on literacy and educating women and girls, on science for development, and on free speech and journalist safety. And of course, they fight for cultural diversity and heritage through UNESCO projects like the World Heritage program, biosphere reserves and the Creative Cities initiative.

UNESCO recognition benefits US communities

Mission San Antonio de Valero “The Alamo”, in San Antonio, Texas. Photo: NPS

UNESCO recognition and connections can bring economic benefits to US communities. For example, according to a State Department news bulletin from August 2017, Tucson, Arizona, which was listed as a UNESCO Creative City of Gastronomy in 2015, has experienced an increase in tourism and restaurant revenues as a direct result, as well as millions of dollars of earned media coverage.

The US withdrawal announcement on October 12th came smack in the middle of Iowa City’s eight-day UNESCO City of Literature Book Festival. It also came right on the heels of San Antonio, Texas’ second World Heritage Festival, a new annual event that already attracts thousands of visitors to celebrate and learn about the San Antonio missions – including the Alamo – that were added to the UNESCO’s World Heritage list in 2015.

Although US World Heritage sites won’t lose their status when the US leaves UNESCO, there will likely be little or no federal support for collaboration and engagement with the international agency or its staff.

Relationship status: It’s complicated

The US has a complicated history with UNESCO. It helped to found the organization and has always been actively engaged, but it has also withdrawn once before.

At the height of the cold war in 1984, Ronald Reagan pulled the US out. At that time, a report on the implications for US science published by the National Research Council identified disruptions to international scientific collaborations, reduced confidence in US scientific leadership and forfeiture of the right to participate in governance of UNESCO-led scientific initiatives.

The US ultimately continued to provide an equivalent level of international financial support for science, culture and education, but the impacts of withdrawal were significant in the scientific community.

George W. Bush took the US back into UNESCO nearly 20 years later in 2002, and then in 2011, the Obama administration drastically cut back on financial support to UNESCO in response to Palestine being granted full membership.

The process for withdrawal takes some time, and the US will not formally cease to be a member of UNESCO until December 31st, 2018. The State Department has said the US remains committed to UNESCO’s important work and will seek observer status.

Secretary Tillerson could put action behind that talk by committing to put the equivalent of the US’s former UNESCO dues payments into other international collaborations in science, education and culture.

“Wars begin in the minds of men”

The opening words of UNESCO’s constitution carved in 10 languages in Toleration Square, Paris. Photo: UNESCO.

Meanwhile, it is the words of the American poet Archibald MacLeish that are enshrined in UNESCO’s constitution and etched in 10 languages on the Tolerance Square wall at the organization’s headquarters in Paris: “Since wars begin in the minds of men, it is in the minds of men that the defences of peace must be constructed.”

According to outgoing UNESCO Director-General Irina Bokova, “[that] vision has never been more relevant” than it is today. In a moving and very personal statement in response to the news of the US withdrawal, Bokova said,

At the time when the fight against violent extremism calls for renewed investment in education, in dialogue among cultures to prevent hatred, it is deeply regrettable that the United States should withdraw from the United Nations agency leading these issues.

Under Bokova’s leadership, with major involvement from the US, UNESCO has been at the forefront of efforts to protect heritage sites and museum collections in Iraq and Syria as ISIS forces have tried to destroy monuments and stamp out culture.

She has also spearheaded implementation of the United Nations Plan of Action on the Safety of Journalists and the Issue of Impunity, in a world where journalists’ freedom to work and safety is constantly under threat.

Through its Science for Sustainable Development program which many US universities participate in, UNESCO has launched important initiatives to increase the number of women in science, to ensure science is at the heart of policy-making for sustainable development, to fully value Traditional Ecological Knowledge and to champion open access to scientific information.

Protecting World Heritage

UCS led the team that produced UNESCO’s 2016 report on climate change and World Heritage. Photo: UNESCO.

It is probably for its work on World Heritage that UNESCO is best known to most Americans. The World Heritage Convention was set up to help protect for future generations, natural and cultural heritage deemed to be of universal value for humankind.

There are 23 World Heritage sites in the US, amongst them, the Statue of Liberty, Independence Hall in Philadelphia and Yellowstone, Yosemite and Mesa Verde national parks. Many of America’s World Heritage sites and cultural sites are at risk from climate change impacts including worsening wildfires, more intense storms, sea level rise and coastal flooding.

The National Park Service, which is a global leader in researching and responding to the effects of climate change on protected areas, has historically been a major player in the World Heritage Convention under UNESCO’s leadership.

Indeed, just as the US is planning to withdraw from UNESCO, the international World Heritage Committee is preparing a major effort to step up its engagement with the implementation of the Paris Agreement (a global commitment to act to reduce global warming emissions to address climate change), and the IPCC (Intergovernmental Panel on Climate Change), and to update its policy on climate change for the first time in a decade.

UCS will be fully engaged in that process, building on the policy recommendations in our report on climate and world heritage, published with UNESCO and UNEP in 2016.

The Trump administration, however, is relegating federal scientists, experts and agencies to bystander status with one more pointlessly anti-science jab at the international community. In response Potts says,

Now more than ever, as with the Paris Agreement, it will be incumbent on US cities, universities and NGOs to pick up the reins of global education, science and cultural collaboration; to continue to make American contributions to all these critical endeavors and to make sure American communities benefit from their progress.

 

 

How Pruitt Listens: Removing Clean Power Plan Web Resources Undermines Public Engagement

On Monday, Scott Pruitt, Administrator of the Environmental Protection Agency, announced his long awaited formal proposal to repeal the Clean Power Plan, the defining regulation in President Barack Obama’s battle against climate change. Talk of the repeal has made headlines for months, after President Donald Trump’s executive order addressing energy and climate policy and his announcement that he intended to withdraw from the Paris Climate Accord. News about a potential replacement for the rule has swirled for weeks.

Yet amid all of the discussion, the Web resources and information that the government has long provided to help inform us about climate change, the social cost of carbon, and the Clean Power Plan itself have been disappearing from federal websites. For members of the public looking to learn about the science and the policy analyses that underlie years of rulemaking and debate, the sources have become harder to find. We’ve found and reported on a number of examples of these types of removals through our work monitoring federal websites at the Environmental Data & Governance Initiative.

Web resources gone missing

After the EPA’s announcement on April 28 that it would be overhauling its website to “reflect the agency’s new direction under President Donald Trump and Administrator Scott Pruitt,” most of the sections of EPA.gov devoted to climate change and work to adapt to and mitigate its harms were removed. While most of these resources were archived, few have been returned or replaced on the official EPA website, where they can be most easily accessed. Certain portions, like “A Student’s Guide to Global Climate Change,” never even made it into an EPA Web archive, likely due to copying errors.

During the same set of EPA website removals, the website for the Clean Power Plan was itself removed and its URLs began redirecting to a new website about implementing President Trump’s executive order. While the previous website hosted resources for the public to understand the Clean Power Plan and for states to develop emissions plans, the new website links to the Federal Register, the order notice, and related news releases, but provides minimal informational resources directed at communicating the significance of the policy shifts to the public. The previous website linked to Spanish language Web resources, like Clean Power Plan facts sheets and community resources, which were also removed without being archived, likely as a result of the same errors mentioned above.

In Administrator Pruitt’s announcement and in the proposed repeal itself, Obama-era analyses of the potential health benefits of the rule and the overall social cost of carbon have been questioned and tossed aside. The information and resources that could provide the public insight into this debate have, once again, been removed: the EPA’s webpage on the social cost of carbon was part of the April 28 removals and the White House webpage on the topic, containing a wealth of relevant links, was removed and archived on inauguration day.

The legal basis for the requirement that EPA regulate greenhouse gas emissions, known as the endangerment finding, is another crucial resource in understanding the debate over the rule. But the EPA’s endangerment finding webpage, too, was swallowed up by the April 28 removals, and has since been either hard to access or, at times, simply not available.

The importance of well-informed public comment

Notice-and-comment rulemaking, used by the federal government whenever it puts new regulations in place or removes existing ones, relies on the ability of the public to provide informed input about the ways in which we will all be affected by a new regulation and how we weigh the costs and benefits. Public comment dockets today are often dominated by industry groups and civil society organizations. Making government-funded information harder to access simply serves to further the divide between those who have the capacity to craft a substantive public comment and those who do not.

A scientist or member of the public working on their own time to write a public comment, relying only on public information resources, can make an impact, as their comment has equivalent standing to any other submission and must be accounted for just the same. The public information that the government has historically made available about the Clean Power Plan’s projected air quality improvements, for example, would provide a way for people to weigh in on the debate over how to value the regulation’s predicted health benefits. But without access to public information, we’re allowing the idea of regulation with citizen input to become nothing more than a myth.

The likely replacement for the Clean Power Plan, if there is one, will be designed to masquerade as a sufficient regulation of emissions in order to evade litigation. Instead of a comprehensive rule like the Clean Power Plan, regulating pollution from coal power plants by considering wholescale how they use energy and produce emissions, it will likely focus only on reducing pollution through improvements in efficiency or fuel replacements at individual power plants. Past EPA studies have determined that these types of changes would result in only an approximate 4% increase in coal plant efficiency.

After approving the proposed repeal on Tuesday, Administrator Pruitt said, “Any replacement rule will be done carefully, properly, and with humility, by listening to all those affected by the rule.” It’s clear from his Administration’s removal of Web resources, however, that he has no intention of enabling that pledge by ensuring that public resources remain available to help citizens understand the proposed policy shifts.

When the health and well-being of the public are threatened so directly by the harms of climate change, we cannot allow our government to censor the information that facilitates the public’s crucial expression in forming new policy.

How you can make an impact

While an overturn of the proposed repeal is unlikely, it is still important that we, as members of the public, weigh in on the benefits that the Clean Power Plan would have to the climate and public health. What we have to say must be taken into account during the rulemaking process and will bolster any litigation that occurs after the repeal.

Once the Federal Register publishes the Notice of Proposed Rulemaking in the coming days, the public will have 60 days to submit comment. Find out how to submit a comment here.

Resources

Here are resources about the Clean Power Plan and its benefits, some mentioned above, that have been removed from federal websites and can be used to craft your comment:

 

Toly Rinberg is a Fellow at the Sunlight Foundation working on documenting and contextualizing changes to federal websites, and understanding how these changes affect public access to Web resources. He also helps lead the website monitoring working group at the Environmental Data & Governance Initiative, working with a volunteer team to track and report on changes to environmental, climate, and energy websites. He is currently taking time off from his Ph.D. in applied physics at Harvard University.

Andrew Bergman is a Fellow at the Sunlight Foundation, where he is classifying changes to federal websites, and a member of the Environmental Data & Governance Initiative, where he helps lead the website monitoring team. He is also working to monitor and coordinate response to environmental agency oversight issues with partners, like UCS. He is currently on leave from his Ph.D. in applied physics at Harvard University.

Science Network Voices gives Equation readers access to the depth of expertise and broad perspective on current issues that our Science Network members bring to UCS. The views expressed in Science Network posts are those of the author alone.

Pruitt Puts Coal Before Children

Photo: Rushlan Dashinsky/iStockphoto

In announcing his abandonment of the Clean Power Plan, Environmental Protection Agency Administrator Scott Pruitt boasted, “The war on coal is over.”

That means the war on children has begun.

The irony is particularly cruel because a draft copy of Pruitt’s repeal order says with a straight face that it complies with President Clinton’s 1994 environmental justice executive order protecting vulnerable populations.  The order says it is “unlikely to have disproportionately high and adverse human health or environmental effects on minority populations, low-income populations and/or indigenous peoples.” For further insult, the home page of EPA’s website has a banner at the bottom declaring that October is Children’s Health Month. “Children are often more likely at risk from environmental hazards,’ the banner read. “Find ways you can protect children from environmental risks.”

Pruitt is increasing the risks and making a mockery of the agency’s name in throwing out the CPP proposed by former President Obama to curb carbon emissions that harm both climate and health. Using Voodoo Economics 2.0, Pruitt claims repeal will save Americans $33 billion in needless industrial compliance.

The reality is that even without the CPP, which Pruitt helped hold up in the courts when he was attorney general of Oklahoma, renewable energy is a powerhouse that already dwarfs the supposed savings of CPP repeal. Its growth is being felt in red states, blue states, and purple states alike. Nationwide, the trade association Advanced Energy Economy estimates that the sectors of energy efficiency, solar and wind power add up to a $108 billion industry.

The $33 billion in total industrial savings boasted by Pruitt are obliterated by the annual benefits of up to $34 billion a year in better health from the cleaner air delivered by the CPP. The EPA projected 3,600 less premature deaths a year, along with 1,700 less heart attacks, 90,000 less asthma attacks and 300,000 less missed workdays and school days. An independent analysis two years ago by eight researchers, including scientists from Harvard, Syracuse and Boston universities published in the journal Nature Climate Change, found there would be about 3,500 fewer premature deaths with the cleaner air proposed by Obama. Their study concluded:

“Carbon standards to curb global climate change can also provide immediate local and regional health co-benefits.” The researchers found that in the scenario closest to the Clean Power Plan, most of the states with the highest health benefits are also those that burn the most coal to generate electricity. Some of those same researchers last year published a study on the financial benefits in the online science journal PLOS One. They found that the CPP would result in $38 billion in annual net health and social benefits. The study said, “The health co-benefits gained from air quality improvements associated with climate mitigation policies can be large, widespread, and occur nearly immediately once emissions reductions are realized.”

The health implications are so widespread it indeed constitutes an environmental justice issue. The Department of Health and Human Services says Latino children are 40 percent more likely to die from asthma attacks than white children. And among all racial groups, according to the Centers for Disease Control and Prevention, African American children have the highest rate of asthma, one in six, and had the highest rise in asthma from 2001 to 2009, 50 percent.

The benefits are also economic for the parents of these children. For instance, Latino workers are particularly vulnerable to the hotter temperatures of climate change as, according to the Department of Labor, they constitute 42 percent of construction laborers up to 75 percent of farm field workers.

But make no mistake, Pruitt’s repeal has the potential to hurt everyone. In response to Pruitt’s repeal of the CPP, an editorial Tuesday in the Portland Press Herald, a leading newspaper in the very white state of Maine, said, “Maine children have some of the highest rates of asthma in the nation, partly as a result of our position downwind from the power plants in the Midwest and Great Lakes states, putting young lungs at the end of the nation’s tailpipe.”

Unfortunately, this is hardly the first decision Pruitt has made in his first half year running the EPA that puts children in harm’s way. He has reversed the ban on chlorpyrifos, a pesticide known to be associated with reduced brain function in children. He is reviewing or pledging to reverse other Obama-era rules designed to curb water pollution and toxic chemical spills.

In his press release Tuesday, Pruitt claimed he was “reinstating transparency into how we protect our environment.” All he actually did was clarify his role as a puppet of fossil fuel, at the utter expense of the health of the nation’s children. When the Obama administration proposed the Clean Power Plan, the health benefits to children were at its center.

The word “children” is not uttered once in Pruitt’s official announcement of repeal.

Conflicts of Interest? NOAA’s Nominees AccuWeather CEO Barry Myers, and Dr. Neil Jacobs of Panasonic

The slow process by the Trump administration of selecting and nominating candidates for high level government positions to lead federal agencies is continuing to creep along now nearly ten months into his presidency.  

Why should we care? These agency leaders affect the lives of literally every person in this country. I recently reviewed some of the nominees for key science-based agencies.   There is a pattern of nominating people with conflicts of interest, or that have a history of opposing the very mission of the agencies they are appointed to lead.  And there are some nominees that just don’t hold the qualifications needed for the positions they are being appointed to.  While I didn’t do a comprehensive review, I found too many examples of these problems to ignore.

As a former NOAA scientist and manager, it was particularly troubling to me that two nominees this week to lead my former agency fit this disturbing pattern.  Last night, President Trump nominated Barry Myers to be the Undersecretary of Commerce for Oceans and Atmosphere, the Administrator of NOAA.  Earlier, he nominated Dr. Neil Jacobs to be the Assistant Secretary of Commerce for Environmental Observation and Prediction.  Adm. Timothy Gallaudet to be Assistant Secretary of Commerce for Conservation and Management.

To be fair, I believe that Admiral Gallaudet, former oceanographer of the Navy is an excellent choice for NOAA, as do others I respect.

Myers and Jacobs:  conflicted leaders?

A nominee to head the National Oceanic and Atmospheric Administration (NOAA) just been announced and follows the pattern of nominating conflicted business leaders to lead agencies.

The nominee, Barry Myers, is the CEO of AccuWeather. His company is highly successful and perhaps better known to many than NOAA itself. Basically, their business model is to take NOAA data and products on weather, developed with taxpayer dollars, and deliver them to the public in a proprietary form that customers want. He has been a strong advocate against NOAA having the capability to provide such products directly to the public, hence the rather boring form of NOAA forecasts which is interpreted and commoditized by companies like AccuWeather and many others.

AccuWeather has been active in efforts to undercut the role of NOAA. In 2005, AccuWeather, under the leadership of Myers’ brother Dr. Joel Myers, worked with Senator Rick Santorum on a bill to severely restrict the National Weather Service’s ability to provide weather forecasts to the public. The company donated to Santorum’s then Senate campaign and has been vocal about their interest in downsizing NOAA in the interest of privatizing weather forecasting.

Compounding these concerns, Dr. Neil Jacobs, Chief Atmospheric Scientist for Panasonic Weather Solutions has also advocated for a greater role for private weather data.  His company sells their data and model outputs to NOAA as input to weather forecasts.  He has advocated for a greater role for the private sector much as Mr. Myers has. Testifying before the House Science Committee in July Dr. Jacobs advocated for the proprietary model his company developed as “better” than the NOAA forecasting models.  According to a report from the hearing Dr. Jacobs stated that, “… that a private company like Panasonic can move more quickly than NOAA in improving its models and processes, because it does not have to go through the years of quality and reliability testing that NOAA requires when implementing major model upgrades.”  That is probably true but far from comforting for a service vital to public safety.  Will Dr. Jacobs carry that approach, shortcutting reliability testing in order to get a product to market, into NOAA?  I hope not.

If appointed, Myers and Jacobs will now be in a position to make such decisions about NOAA’s work. It is easy to see how private weather companies like AccuWeather or Panasonic could directly benefit from decisions made by Myers and Jacobs; and the likely incentivizes to make decisions that benefit Myer’s family’s business and the business Jacobs worked with and advocated for for years.

Will Myers cut all financial ties to AccuWeather before accepting such an appointment?  How about Jacobs? I won’t hold my breath, given the current industry ties still held many members of this administration starting at the top.

Do people have a right to accessible weather information that they pay for with their tax dollars? Myers and AccuWeather, as well as Jacobs and Panasonic appear to think not. I happen to think Americans deserve access to the life-saving forecasts and other weather information provided to the public by NOAA scientists.

NOAA’s mission is to protect people and property

Most of the public may only know of NOAA because their logo appears on hurricane or tornado forecasts. Others because they follow weather forecasting closely and many forecasts refer to NOAA.

For those of us who spend a lot of time on the ocean, we certainly know that NOAA is responsible for producing nautical charts. In fact the part of the agency that produces nautical charts critical to shipping, boating, and naval operations is the oldest physical science department in the government dating to 1807. The National Weather Service (NWS) in NOAA was formed in 1870, and the National Marine Fisheries Service (NMFS), which studies and manages living marine resources, dates to 1871. I am a proud former scientist and manager of NMFS, first as a student trainee and ultimately as the deputy director of the agency.

Ok, that’s all ancient history (including my time at NOAA), so what does the agency do? Simply put, NOAA does a wide range of basic and applied scientific research to better understand our oceans and atmosphere, from deep sea exploration to space weather. (If you can’t imagine why we care about weather in space, you can find out how it can affect everything from satellites to cellphones!)

NOAA’s research provides information to the public, policy makers, and other scientists in the US and around the world. NOAA scientists partner with a huge number of scientists in academia, industry, and private institutions in collaborative research in addition to providing critical long-term data series that no one else has the resources nor the mandate to collect and share with the public.

So NOAA is a science agency, but its science is applied to create weather forecasts, manage fisheries, protect whales and other marine mammals, help states manage coastal areas, create charts, inform international negotiations on addressing the challenges of management of shared resources in the oceans and atmosphere, forecast tsunami risks, measure and monitor the ongoing process of climate change, and more.

The leadership of the agency can impact all of us in one way or another. Care about severe weather and risks to your life and property? Better thank NOAA. Care about your favorite beach and whether it is eroding or will it be clean and safe? Better thank NOAA. Care about your farm and the coming growing season’s weather? Better thank NOAA. Or the fish you enjoy to catch or eat? Better thank NOAA.

A lack of respect for science

Mr. Myers is not a scientist but a businessman. That is in the same vein as many other Trump appointees. Some say that bringing a business approach to government is essential. I am not one of them. I have been a senior manager in government and have also run a small business. Totally different perspectives. But of course even these different perspectives can inform one another.

But NOAA is truly a science agency. The leader of the organization doesn’t have to be a scientist but needs to be deeply engaged in the process and perspective of science and scientists in order to be successful with regard to the public interest.

Mr. Myers was interviewed about his leadership of Accuweather by the Wall Street Journal in 2014. This Q & A jumped out at me:

“Did you ever think about going into meteorology?

I did actually. I was originally enrolled in meteorology as an undergraduate. I then dropped out of school because I was a horrible student. I was never interested in learning, which I look at now as sort of funny.

Well, not that funny really. There is always a lot to learn at NOAA. I found that out to my continuous joy. I hope the next leader of the agency is deeply steeped in its scientific work and embraces the chance to learn how that science is critical to the nation.

The EPA’s Crucial and Unsung Role in Puerto Rico and the Virgin Islands

After a major hurricane there is an urgent need to rebuild the infrastructure needed for clean water and sewers. The EPA has a critical role to play in that effort. Here flooding is shown in Carolina, Puerto Rico, after Hurricane Maria. Photo: Sgt. Jose Ahiram Diaz-Ramos/USDA (Flickr)

The recent hurricanes have spotlighted the federal government’s crucial role in response and recovery. But much of the coverage has focused on FEMA, funding, and the US military. Rarely in the news—and yet critical to response and recovery efforts—is the work of the Environmental Protection Agency.

During the Trump administration, the EPA has seen cutbacks in staff, major funding reduction proposals, and a real change in culture. And while much of the public discussion about the EPA has focused on its regulatory role, there is far more to the agency than just regulation—and all of its functions are being affected by recent changes.

To understand why we need a strong and capable EPA to respond to disaster like Hurricane Maria (and Irma and Harvey) I spoke with two former leaders of EPA, Thomas Burke and Stan Meiburg. Dr. Burke served as the EPA Science Advisor and Assistant Administrator for Research and Development until the end of the Obama Administration. Now on the faculty of Johns Hopkins, he is widely recognized for his work in public health and risk assessment.

As he emphasized, “EPA has a very important role because Maria is, unfortunately, first and foremost an environmental disaster… the biggest challenge is that there is a fundamental change in risks to the populations in island communities and coastal areas.”

Before the storm

Stan Meiburg served as the Deputy Administrator of the EPA from 2014-2017. In his 39 years with the agency he worked in both regional offices and headquarters. He is now on the faculty of Wake Forest University directing their sustainability program.

Dr. Meiburg explained that the EPA’s role begins before a storm like Maria hits. Hurricane forecasting, by NOAA’s National Hurricane Center, has come a long way over the last few decades, so EPA officials watch closely as a hurricane intensifies. At the EPA, the job of preparing for the storm means activating the incident command center at the EPA Regional Office (Region 2 in New York for Puerto Rico and the USVI), Dr. Meiburg explained. The regional office of EPA includes about 40 permanent staff in Puerto Rico itself and has experience with the communities at risk from the oncoming storm. To the extent possible, the agency also pre-deploys mobile labs and other equipment—a task that naturally presented a special challenge for the islands.

As the regional office begins this work, Dr. Burke noted that the EPA also must mobilize on a broader scale. “EPA should be at the table for the national effort coordinated at the highest level with the National Security Council with FEMA, Department of Defense, Health and Human Services, and Center for Disease Control. It’s a team approach,” he said, adding that “the military is great because they have the capabilities to do the heavy lifting, but they constantly need scientific guidance. They constantly need analytical capability and risk assessment. That’s the role for the EPA at all levels.”

Recovery

After Hurricane Maria passed, its devastation became apparent as island officials described the enormity of the humanitarian crisis. Dr. Burke explained that, for the EPA, the focus must be “all about exposure and getting back the necessities of life.” As he put it, “you need the folks who know the water systems—who can be out there to assess water quality, damage to infrastructure for waste water treatment or the drinking water system to make sure people aren’t exposed to waterborne diseases and contaminants. That’s EPA.”

Dr. Meiburg agreed. He stressed that electricity is the dominant concern because, without that, it is difficult to deal with anything else. He noted that the decision to put the Army Corps of Engineers in charge of rebuilding the electric grid makes a lot of sense. But the next urgent need is to rebuild the infrastructure needed for clean water and sewers, as well as waste disposal (including for the debris from the storm). In that effort, he says, the EPA has a critical role to play. Dr. Burke pointed out that with water, sewer, and disposal systems down, the risks from both waterborne and vector-borne (e.g., mosquitoes, rats) disease can very quickly rise. And the EPA is the agency with expertise with pesticides and other control methods.

Dr. Meiburg also pointed out several other high-priority efforts for the recovery that EPA must staff. The integrity of Superfund hazardous waste sites must be checked as soon as possible, he said.  Industrial facilities need attention for leaks, spills, and in their restart operations. And hazardous waste from both commercial and household sources are a difficult and dangerous problem in wake of the storm.  All of these require staff and other resources. And the problems are urgent.

The long road

Given the scale of the disaster in Puerto Rico and the USVI, indeed throughout much of the Greater Antilles, the recovery road is a long one—even with a massive effort. Both Drs. Burke and Meiburg emphasized the need for EPA to have a sustained presence on the islands, as well as in the other areas impacted by hurricanes over the last month or so. That means that the agency will have extraordinary responsibilities that will require the staff and resources to provide the help that’s urgently needed.

Rebuilding critical infrastructure means constant attention from scientists and engineers in the agency. It also means deep and sustained coordination with the Commonwealth’s government as well as in the USVI.  As Dr. Burke noted, “it is all about human health.” That means the EPA regional office, the EPA national laboratories and headquarters staff must take on huge additional responsibilities.

The Environmental Protection Agency is a crucial national asset, every bit as important as the military in responding to humanitarian crises. Its staff needs our appreciation, but more than that, they need adequate resources and support to effectively do their vital work.

The Trump Administration Fakes Science to Justify Restrictions on Birth Control Access

The Trump administration is using bogus science to justify restrictions on birth control access, building on a legacy of Presidential administrations' politicization of science around contraceptives. Photo: www.quotecatalog.com

Birth control access is now the latest casualty in the Trump administration’s attacks on science. Last Friday, the administration issued rules that roll back the birth control mandate of the Affordable Care Act, i.e. the guarantee that insurance companies cover birth control whether they like it or not.

This means that companies can now more easily refuse to cover birth control costs for their employees. The administration claimed that scientific evidence supported their decision, but like many things with this administration, they got the science all wrong.

Here is a sampling of the actual science that the administration questioned or misrepresented

1) Birth control works and access to it reduces unwanted pregnancy. The administration’s rules question this long understood science. Since the introduction of the pill decades ago, medical professionals have documented the effectiveness of contraceptives in preventing pregnancy.

At the community scale, scientists also observe that access to birth control reduces rates of unwanted pregnancies, births, and abortions. One important study known as the Choice Project gave free contraceptives to teenagers in St Louis. The results showed that pregnancies, births, and abortions reported were half compared to the national average.

2) Contraceptives have many health benefits. The administration misrepresented the science on the benefits and risks of birth control, claiming that use of contraceptives may lead to riskier sexual behavior. But scientific evidence doesn’t support this.

Studies have not found increases in riskier sexual behavior following access to free birth control. In the Choice study mentioned above, participants reported no change in their sexual activities after receiving contraceptives. It is also worth mentioning the myriad reasons that women are on birth control. In addition to the benefit of having control over family planning, contraceptives are also used to treat other medical conditions, such as excessive menstrual bleeding and pre-menstrual syndrome symptoms.

3) Health risk from contraceptive use is extraordinarily low. The Trump administration emphasized risks and downplayed benefits of birth control, a key tactic often used by those who want to disparage scientific evidence. For example, the administration’s rules emphasized the risk of blood clots from birth control use. This risk does exist (on the order of 5-12 cases per 10,000 births) but scientists point out that your risk of blood clots during pregnancy is higher. And of course, this risk is far lower than risks involved in other things people regularly engage in, like riding in a car, taking a flight, and living with a city with air pollution. Emphasizing this risk as a justification for restricting access to the birth control is disingenuous.

A history of politicization of the science on birth control

Unfortunately, the Trump administration isn’t the first to politicize birth control. In the modern era, several presidential administrations have inserted politics into what should have been science-based decisions on birth control access.

Under the George W Bush Administration, political officials went against the scientific community and restricted access to the emergency contraceptive Plan B One-Step. While the product was shown to be safe and FDA scientific advisory committee members overwhelmingly recommended (23 to 4) that the drug be available over the counter, FDA officials, with involvement of the Bush White House, failed to take the scientific advice and kept access to the drug restricted.

Despite public outcry and legal challenges, the administration continued to delay making a science-based decision, ultimately resulting in the resignation of the FDA director of the Office of Women’s Health Susan Wood. In a resignation email, Wood wrote “I can no longer serve as staff when scientific and clinical evidence, fully evaluated and recommended for approval by the professional staff here, has been overruled.”

Under the Obama Administration, too, we again saw political interference in contraceptive science. President Obama’s Health and Human Services (HHS) Secretary Kathleen Sebelius failed to make Plan B emergency contraceptive available over-the-counter for all ages despite science demonstrating it was safe. The FDA’s own scientists made clear the drug was safe and FDA commissioner Margaret Hamburg agreed. But in a bold and unprecedented move, the HHS secretary publicly overruled the FDA commissioner. Shockingly, Secretary Sebelius and the administration claimed that it was uncertainty in the science showing how safe the drug was that caused the political move.

President Obama was quoted, “As I understand it, the reason Kathleen made this decision was she could not be confident that a 10-year-old or an 11-year-old … should be able to buy a medication that potentially … could end up having an adverse effect.” This of course is out of context, as medications with far worse potential side effects are already widely available over the counter in drug stores across the country. Court battles ensued and Plan B One-Step was made available over the counter for all ages in 2013.

Dismissing the science, harming public health

In many ways, it’s strange that birth control has long been a victim of politicization. It is not only widely popular but the science is very clear. This is something we know very well. The health effects are minimal and the benefits are tremendous. This is a no-brainer.

If we’d like to improve public health outcomes, evidence tells us that we should make birth control widely available. Indeed, this is what many countries have chosen to do. Yet the Trump administration has chosen to sideline science at nearly every turn. Unfortunately, birth control is now joining the ranks.

Much to Grouse About: Interior Department Calls for Changes That Could Threaten Sage Grouse Protection

The sage grouse's survival is entirely dependent on sagebrush. Photo: Jennifer Strickland, USFWS

That the current administration places very little value on the merit of robust scientific evidence when considering its actions (or inactions) is no longer shocking, but it remains an intolerable practice. In this week’s episode of “How is the Trump Administration Dismantling Science-Based Protections?”, we visit the Interior Department’s decision to formally reconsider a widely heralded Obama-era agreement for protections of the greater sage grouse in the West.

On Thursday, the Interior Department published a formal notice of intent to rework 98 sage grouse management plans across the quirky bird’s 11 state range. This change comes after a mere 60 days deliberation by the Interior Department’s internal Sage-Grouse Review Team (appointed by Secretary Ryan Zinke) and Sage-Grouse Task Force (representatives of Governors of the eleven Western States) – and much to the chagrin of the many stakeholders who worked for several years to craft a cooperative land use agreement in an effort to protect the sage grouse and its habitat.

What’s the deal with the sage grouse?

The sage grouse is the chicken of the “Sagebrush Sea” — an ecosystem which is “suffering death by a thousand cuts”, as former Secretary of Interior Sally Jewell put it. Habitat fragmentation, invasive species, and wildfires in the sagebrush have all contributed to the decline of this magnificent bird.

Importantly Secretary Jewell worked to put in place federal-state partnerships in order to protect the sage grouse. In 2010 the FWS proposed listing the sage grouse under the Endangered Species because of the threats its survival faced. After much input from stakeholders and the public, the agency in 2015 chose NOT to list the species and instead put efforts into state management plans, assuring us all that states could put programs in place to ensure the bird’s protection.  With Secretary Zinke’s moves, we’re now paving over (perhaps literally) those state protection plans, leaving the sage grouse at least as vulnerable as it was when the FWS proposed listing it under the Endangered Species Act.

The sage grouse has long been caught in the crosshairs of political controversy, especially when it comes to undermining the science behind conservation efforts. For example, in 2004, Julie MacDonald, a political appointee at the Fish and Wildlife Service (FWS), altered scientific content in a report examining the vulnerability of the greater sage grouse, which was subsequently presented to a panel of experts that recommended against listing the bird under the Endangered Species Act (ESA)(read my colleagues’ thoughts on political interference in sage grouse conservation efforts here and here).

Ignoring the science

The Sage-Grouse Review Team (SGRT) recommendations include potentially removing or modifying the boundaries of critical habitat called sagebrush focal areas (SFAs), as well as setting population targets and captive breeding, and modifying or issuing new policy on fluid mineral leasing and development. Also worth noting is that an Obama-era moratorium on mining claims in six Western states recently expired, with no indication of renewal from Secretary Zinke.

The problem with the Interior changing the conservation plans is twofold: 1) the motivation for reviewing the sage grouse management plans was to “ease the burden on local economies” by opening protected lands to development, which could have negative impacts on already rapidly-dwindling sage grouse populations, and 2) reopening the plans could spell more trouble for recovery efforts and potentially force FWS to list the sage grouse under the ESA in the future, which is precisely what states wanted to avoid. The conservation plan is critical, but it only works with the agreed upon protections in place.

The decision to undo years of collaboration and compromise between federal, state, local, and tribal governments, NGO’s, scientists, industry, landowners, ranchers, and hunters in a matter of two months sends a loud message to the public that economic considerations prevail over scientific evidence, even at the cost of an entire ecosystem and the species dependent upon it.

The SGRT recommendations ignore the science and put the entire sagebrush landscape at risk, much to the detriment of the sage grouse. Wyoming Governor Matt Mead is critical of the new plan, concerned that it ignores scientific consensus. “We’ve got to have good science lead the way, and that trumps politics,” Mead said. “Let’s look at what the states have done, and what biologists, folks who know this, are telling us.”

Sage advice

We cannot allow our government to irresponsibly cater to oil and gas industry at the expense of our wildlife and public lands. Instead, we must urge the Department of Interior to focus their efforts on collaborative, science-informed management of the sage grouse and its habitat.

Jennifer Strickland, USFWS Wikimedia Commons

What’s Tax “Reform” Got to Do with Science and Public Well-being?

Photo: USCapitol/Flickr

In the days since the “Big Six” group of Congressional leaders and Trump administration officials unveiled the outlines of their tax “reform” proposal, there’s been a fierce debate—and rightly so—over who stands to win and who lose. Will the average working American get anything significant from this tax plan, or are most of the benefits skewed towards the wealthy and profitable corporations?  More on this in a minute.

What’s gotten less attention is the impact of this plan on the public science enterprise and the well-being of all Americans.

An unprecedented assault

Federal government investments in science research and innovation have led to discoveries that have produced major benefits for our health, safety, economic competitiveness, and quality of life.  This includes MRI technology, vaccines and new medical treatments, the internet and GPS, earth-monitoring satellites that allow us to predict the path of major hurricanes, clean energy technologies such as LED lighting, advanced wind turbines and photovoltaic cells, and so much more. The work of numerous federal agencies to develop and implement public and worker health and safety protections against exposure to toxic chemicals, air and water pollution, workplace injuries, and many other dangers has also produced real benefits.

These essential programs are already under unprecedented assault. UCS president Ken Kimmell has called President Trump’s proposed FY18 budget “a wrecking ball to science.” Others at UCS have detailed the devastating impacts of Trump’s proposed budget cuts on the Environmental Protection Agency, the Department of Energy, the Department of Agriculture, the Federal Emergency Management Agency, the National Oceanic and Atmospheric Administration, worker health and safety, the Forest Service, and early career scientists.

UCS and our allies are pushing back hard on these proposed budget cuts, and we remain vigilant to ensure that when Congress takes final action on the FY18 appropriations bills in December, these irresponsible cuts will be rejected.

All these programs (along with veterans’ care, homeland security, transportation and other infrastructure, law enforcement, education, and many other core government programs) fall within the non-defense discretionary (or NDD) portion of federal spending, which has been disproportionately targeted for spending cuts over the last decade. As an analysis by Paul Van de Water of the Center for Budget and Policy Priorities points out, “NDD spending in 2017 will be about 13 percent below the comparable 2010 level after adjusting for inflation (nearly $100 billion lower in 2017 dollars).”

Even if the draconian Trump budget cuts are beaten back, the very real need to increase spending on entitlement programs such as Social Security and Medicare, along with a push by many in Congress to maintain (or increase) defense spending, will continue to squeeze NDD expenditures in the years ahead.

Creating long-term pressure on essential programs

Here’s where the Republican tax plan comes in, as it will almost certainly reduce government revenues substantially and add to the national debt. While Treasury Secretary Steven Mnuchin told ABC News that the tax plan would generate higher economic growth rates and “will cut the deficit by $1 trillion,” few independent economists agree with that rosy outlook.

The Committee for a Responsible Federal Budget estimates the plan could increase the deficit by $2.2 trillion over the next decade; CRFB president Maya MacGuineas cautioned that “tax cuts shouldn’t be handed out like Halloween candy,” and said they “certainly don’t pay for themselves.”

Senate Republicans openly acknowledge that the tax plan will increase the deficit; the Budget Committee resolution that they plan to put before the full Senate for a vote later this month contains reconciliation instructions to the Finance Committee that would allow the deficit to increase “by not more than $1.5 trillion over the next 10 years.”

Deficit spending is sometimes justified, such as for investments in infrastructure, education, public health, and other forms of physical and human capital that more than pay back over time, or to kick-start the economy when unemployment is high. But that’s not the case here; as discussed below, the bulk of the benefits from this plan would flow to the wealthiest Americans, with low- and middle-income Americans receiving only modest direct benefits, if any.

Moreover, the resulting increase in the federal deficit would lead to louder calls for cuts in programs that benefit low- and middle-income Americans, including food assistance programs, student loans, unemployment insurance, economic development, and worker retraining.  As another analysis by the Center for Budget and Policy Priorities put it, “the majority of Americans could ultimately lose more from the program cuts than they would gain from the tax cuts.”

The government needs more revenue, not less

Looking down the road, it’s clear that the aging of the American population, continued increases in health care costs, the need to replace crumbling infrastructure, and other factors are creating pressure for federal spending to increase substantially over the next few decades.

The Center for Budget and Policy Priorities estimates that to accommodate these factors, federal spending will need to grow from 20.9 percent of gross domestic product (GDP) to 23.5 percent of GDP by 2035. This is largely driven by increased costs for Social Security, Medicare, and Medicaid; CBPP projects that defense and non-defense discretionary spending will decrease somewhat as a share of GDP over the next couple of decades. As the CBPP report observes, the need to increase federal spending is “hardly a controversial notion. Budget plans from such diverse organizations as the National Academy of Sciences, the Bipartisan Policy Center, and the American Enterprise Institute have reached the same conclusion.”

To keep the national debt from growing faster than the overall economy, CBPP estimates that annual budget deficits need to be held to an average of 3 percent of GDP; this in turn means that federal revenues should increase from some 17.8 percent of GDP in 2016 to at least 20.5 percent in 2035. There are any number of ways to do this, from closing special interest loopholes in the tax code to putting a tax on carbon dioxide emissions or other forms of pollution. Of course, given the current political realities in Washington, no one expects a serious discussion of this issue anytime soon; the current challenge is just to avoid making the situation worse.

Tax fairness: the rhetoric and the reality

President Trump and Republican leaders insist that their aim is to provide tax relief for the middle class, and that taxes won’t be cut for wealthy Americans; President Trump even asserted that this tax plan is “not good for me. Believe me.”

But a preliminary analysis of the framework by the Tax Policy Center found otherwise. While acknowledging that several details remain to be filled in, TPC estimates that in 2018 under the “Big Six” plan, “taxpayer groups in the bottom 95 percent of the income distribution would see modest tax cuts, averaging 1.2 percent of after-tax income or less. The benefit would be largest for taxpayers in the top 1 percent (those making more than $730,000), who would see their after-tax income increase 8.5 percent.”

Over half of the total benefit of the tax cuts would accrue to taxpayers in the top 1 percent, increasing to nearly 80 percent of the benefits by 2027. Others have examined how the elimination of the alternative minimum tax, the abolition of the estate tax, and several other provisions of the plan would personally benefit President Trump—and his heirs.

Private interests vs. the public good

It’s clear that the stakes in the tax debate now under way in Washington are not just about the critical issue of whose tax bills go down (or up) and by how much. The outcome will also have an impact on our ability to maintain America’s global leadership on scientific and medical research and technology innovation, improve air and water quality, avert the worst impacts of climate change (and cope with the impacts we can’t avoid), upgrade our transportation, energy, and communications infrastructure, and many other important issues.

It’s hard to dispute the need for real tax reform—a plan that clears away the dense thicket of special interest loopholes and simplifies the tax code, in a way that’s equitable to all Americans. But that’s not what’s on offer right now—instead we’re seeing a drive to give trillions of dollars in handouts to profitable corporations and the wealthiest Americans, while laying the groundwork for deep cuts in a broad range of important federal programs down the road.

Our elected officials can – and should – do much better than this; if they’re unwilling to, they should observe the Hippocratic oath, and “first do no harm.”

 

 

Sociological Gobbledygook or Scientific Standard? Why Judging Gerrymandering is Hard

In Tuesday’s historic Supreme Court case, the question asked was how to identify and remedy unconstitutional partisan gerrymandering, where electoral district boundaries are drawn so as to benefit one political party’s voters over others.  The phrase uttered during oral argument that is getting the most attention is Chief Justice Roberts’ assessment of the various techniques that have been proposed to measure it: “sociological gobbledygook.”  It’s a funny way to describe Roberts’ apparent distaste for mathematical, as opposed to legal, explanations, but it also reveals a serious problem for the use of scientific evidence in the court.

Let’s look at the evidence.

One of the core issues in these cases, as I’ve previously discussed, involves the discovery of “workable standards.”  To be workable, a standard must identify a constitutional (fundamental) harm, as opposed to a de minimus (minor) harm, so as not to inundate the court with cases.  Further, the standard must be capable of being practically applied by justices who are not themselves scientists.

Whether or not tests for the standard of partisan symmetry, the equal treatment of voters regardless of which party they support, are workable, was the primary point of contention when Justice Roberts made his remark.

In describing his concern about judicial overreach into the political process, Roberts proclaimed that “you’re taking these issues away from democracy and you’re throwing them into the courts pursuant to, and it may be simply my educational background, but I can only describe as sociological gobbledygook.”

On the one hand, Roberts is identifying a serious problem that needs to be addressed by scientists in the courtroom.  Statistics can be manipulated and are open to interpretation in ways that other forms of legal evidence are often not.

In many cases, both parties trot out potentially motivated “experts” to exchange criticisms in specialized language, leaving judges to make decisions based on evidence that their educational background does not train them for.  Consider two examples taken directly from yesterday’s argument.

The term “false positives” was used by the defense (the state of Wisconsin) to refer to the inaccuracy of one way to measure symmetry, the efficiency gap.  “False positive” refers to a Type I error, when the test for something (like pregnancy, using a urine test that measures levels of the hormone chorionic gonadotropin) turns up positive, but has not actually occurred (no fertilized egg embedded in the uterus, which produces the hormone).  Pregnancy tests have about a 3% false positive rate.  But back to gerrymandering.

In this case, the claim of “false positive” was misapplied, and expanded to describe any state with a significant efficiency gap, where the plan was not drawn by the state legislature.  That is, the defense implied that districting plans not drawn by parties (those drawn by courts through litigation or by commissions, etc.) could not be biased.  But the efficiency gap is not a test of who draws a districting map, it is a measure of bias.

Even randomly drawn maps using computer simulations can result in quite biased plans, depending on the underlying geographic distribution of voters.  None of the justices seemed to pick this up.  Justice Alito, responding to such claims, expressed grave concern about “the dozens of uncertainties about this whole process.”

Worse still was Chief Justice Roberts’ mistaking of symmetry for “proportional representation, which has never been accepted as a political principle in the history of this country.”

Partisan symmetry is explicitly not a test of proportionality in election results (where a party receives the same percentage of seats as its percentage of votes).  In fact, symmetry was intentionally designed as an alternative standard of testing the principle of political equality in U.S. elections, because proportionality is a higher standard than what the Constitution demands.

These mistakes might have been avoided through a more thorough reading of the many scientific briefs offered to the court for review (or the video above).  Nevertheless, the burden is on scientists to communicate our work clearly and concisely to non-experts, otherwise this problem will only persist.

On the other hand, several of the Justices had a strong grasp of how scientific standards operate within the voting rights framework.  Justice Kagan, for example, correctly noted that both partisan symmetry and the one-person, one-vote standard (prohibiting unequally populated districts) address the dilution of voting strength for individual voters as a function of statewide plans, not single electoral districts.

Moreover, Justice Sotomayor, responding to the defense’s claims about inaccuracies in estimating the impact of Wisconsin’s plan, pointed out that “every single social science metric points in the same direction.”  That is the sort of understanding about probabilistic estimates that scientists need to convey to judicial authorities.  It is how scientists forecast everything from economic growth to health epidemics and weather patterns.  The Justice continued, noting that the same types of statistical estimates were used to create Wisconsin’s maps in the first place, and that “it worked.  It worked better than they even expected, so the estimate wasn’t wrong.  It was pretty right.”

Judges have their work cut out for them if the Supreme Court finally provides a means by which political parties can be restrained from advancing their partisan interests at the expense of voters’ fundamental right to an equally weighted vote.  But it is up to the scientific community to work with the judiciary in the appropriate application of statistical evidence.  The consequences, which feedback through the entire policy making process, make it well worth the effort.

Can Science (and The Supreme Court) End Partisan Gerrymandering and Save the Republic? Three Scenarios

Photo: Wikimedia Commons

On October 3, the US Supreme Court will hear a case concerning the state of Wisconsin’s legislative districts that could resolve a pending constitutional crisis and dramatically improve electoral representation.

At the center of the dilemma is the applicability of a scientific standard to measure discrimination resulting from district boundary manipulation. What’s new in this case is that social scientists have developed a standard. But what the court will do with it is anybody’s guess. So let’s guess.

We have a scientific standard that is discernible and manageable

Social scientists have been hard at work since 2004, when the Supreme Court issued a fragmented, 5-4 decision in Vieth v Jubelier holding that “plaintiffs failed to establish a standard” to determine when partisan gerrymandering has gone too far  The analytical tools for estimating various forms of partisan discrimination have dramatically improved since Vieth, as described in one of the many amicus briefs submitted to the court.

Consensus has emerged around partisan asymmetry as a scientific standard that is both discernible (logically grounded in constitutional protections) and manageable (so that courts can apply it). It measures any difference in the percentage of seats that a given percentage of voters (say 50%) receive, depending on what party they vote for. Asymmetries can be easily estimated with actual election results and computationally simulated vote swings across districts, along with measures of statistical confidence.

Similarly, the mean-median test, comparing each party’s actual vote share in its median district to overall mean vote share, is another way of estimating asymmetries between voters. There are important theoretical and methodological differences between various measures, including the efficiency gap, which compares “wasted” votes between parties. But all are empirically accurate at identifying partisan bias where it matters most: in competitive states where voters from one party have a major seat advantage.

However, the fact that a standard has emerged is no guarantee that it will be adopted. Attention will focus on convincing Justice Anthony Kennedy, who welcomed the discovery of “workable standards” as the swing vote in Vieth. His level of satisfaction with these results is likely to drive the justices toward one of the following three scenarios.

Scenario one: Kennedy keeps the Supreme Court out of the thicket

In a crushing defeat to defendants and electoral reformers in both parties, Justice Kennedy is unpersuaded, leading to another 5-4 decision in which the more liberal justices (Ginsburg, Breyer, Kagen, and Sotomayor) agree that symmetry is a workable standard, but they don’t have the votes. A plurality of the court’s conservatives either dismiss outright the idea that courts ought to be entering the political thicket of partisan competition, or they reassert a version of Antonin Scalia’s Vieth opinion, holding that symmetry is a standard measuring discrimination against parties, not people, with only the latter having constitutional rights (although it has been demonstrated that symmetry reflects individual political equality).

Kennedy writes a concurrent opinion with the conservatives, articulating a more nuanced failure on the part of plaintiffs to specify “how much is too much” as both plaintiffs and most of the scientific briefs submitted explicitly placed responsibility for specifying a threshold of unconstitutional discrimination with the courts. Kennedy could also point to in-fighting among political scientists over our favored measures as lack of consensus. Talk about a tragedy of the commons.

Scenario two: Wisconsin’s districts are thrown out, but the real work is left for future courts

A focused interrogation by Kennedy results in a majority opinion that overturns Wisconsin’s gerrymandered map. Several measures of bias are incorporated into a multi-pronged test that verifies if 1) the district boundaries caused the observed discrimination (asymmetry), and 2) the extent of asymmetry is not likely to be reduced through changing voter preferences. That is, even a “wave” of public opposition would allow the entrenched party to hold power.

However, the majority does not go so far as to prescribe a general threshold for “how much is too much” gerrymandering. There is no precise level of necessary asymmetry, or responsiveness, or competitiveness specified that constitutes a violation of equal protection or free speech. Standards are left to emerge through future cases, of which there are many. Some version of this outcome seems most likely, given the scientific consensus, the level of extreme gerrymandering witnessed in the 2011 redistricting cycle, and the bipartisan response to it.

Scenario three: A precise standard is adopted with clear direction for lower courts

In this third, and probably least likely scenario, the justices not only establish a multi-prong test to identify unconstitutional partisan discrimination, they also specify the degree of relief that discriminated voters are entitled to. The question of “how much is too much” discrimination is answered precisely through a specific measure, either when asymmetry would result in a single seat change, or change in majority control of a legislative body, or a mean-median difference greater than 5 percent (which is rare) or an efficiency gap greater than 7 percent (which is also rare), etc.

The court could apply the breadth of knowledge that we have to specify thresholds of tolerance, below which any hypothetical districting plan would be invalidated. But because the process of districting involves maximizing numerous conflicting principles, such as geographic compactness and bias, the justices are unlikely to go this far, at this time. And only time will tell if a more cautious approach will be adequate.

Can a constitutional crisis be averted?

If the Supreme Court fails to rein in partisan gerrymandering, the fundamental democratic principle of majority rule is undermined. The Electoral College has enabled minority control over the executive, and majority control of the Senate has been determined by a minority of voters due to the underrepresentation of large states.

In 2018, a majority as large as 56 percent of Americans could vote against the governing party (currently the Republican Party) in the House of Representatives, while they retain control of a majority of (gerrymandered) seats. It is up to the Supreme Court to re-establish a republic “of the people.”

President Trump is About to Give a Speech That Directly Undermines Science

Next week, President Donald Trump is going to deliver a speech highlighting his only major policy “achievement” to date: sidelining science and rolling back critical public health, safety, and environmental protections. You’re probably going to hear a lot about the president’s absurd executive order that requires agencies to cut two regulations (aka public health protections that provide us clean air, safe consumer products, and more) for every new one issued and you’ll probably hear some muddled thinking and misinformation about the cost of regulations and all the rules the administration has reversed.

The president might even frame all this deregulatory talk as “winning.”

But this is not what his speech is about. This speech is about President Trump and his administration sidelining science-based safeguards, stripping away vital public health, safety, and environmental protections from the American people. These are regulations that keep our air and water clean, our food safer to eat, our household products and our kids’ toys safer to play with, and our workers safer at work. And it is these regulations that can and should have the greatest positive impact on low-income communities and communities of color, who are often disadvantaged and facing some of the worst public health and environmental threats.

Deregulation = Real world impacts

We’ve already seen the administration’s deregulatory policies in action. Earlier this year, the administration delayed updates to the Risk Management Program, designed to enhance chemical risk disclosure from industrial facilities and improve access to information for first responders, workers, and fenceline communities, all while encouraging the use of safer technologies.

After Hurricane Harvey hit Houston, Arkema’s chemical plant in Crosby exploded, highlighting the importance of this public protection. People were forced to stay away from their homes, first responders suffered injuries and weren’t informed about the dangerous chemicals being stored there (and are now suing Arkema), and Harris County had to divert critical resources from hurricane recovery efforts to respond to the explosion (and is now also suing Arkema).

This is just one example of how sidelining science and rolling back safeguards can negatively impact communities across the country. In a recently released report, UCS chronicled several examples of how the administration has delayed many science-based rules and weakened protections from hazards at work and home. This is what the president’s speech is about.

Science-based policymaking ¯\_(ツ)_/¯

This administration has shown zero interest in evidence-based policymaking. Even when it comes to rolling back regulations, the administration has used inaccurate information to support its actions. In other instances, it has simply used misleading information to support its delay tactics. The Environmental Protection Agency (EPA), whose mission is to protect human health and the environment, has an administrator who is only interested in meeting with representatives from regulated industries, instead of meeting with independent scientists and communities who need the federal government to step up and implement strong protections.

What the administration is focused on though is using any means available to them to invalidate public health protections that took years to develop.

All this flies in the face of how science-based policymaking should happen. You look at the threat, the scientific and technical evidence, and then figure out how to mitigate it and ensure the public is not in danger. You don’t arbitrarily decide which public protections should stay in place and which should be rolled back. Nor should our government only take input from vested interests who favor their bottom line over protecting the public.

But that is the Trump Doctrine on regulations. And for this reason, scientists need to continue to watchdog the administration’s actions and hold agencies accountable to ensure that we have science-based protections in place and policies are based on facts not politics.

Threats are threats. They cannot be addressed only when another public protection is no longer on the books. In the future, if the Food and Drug Administration were to issue a rule to ensure safe food, should the EPA be forced to roll back standards for clean water?

The bottom line is when it comes to protecting public health, the ideas championed by President Trump make no sense. Regulations matter, and protecting the system of evidence-based policymaking matters. The only thing President Trump’s speech will be good for is to show the American people how many losses we have taken in the first 10 months of this administration.

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