Combined UCS Blogs

Nuclear Hawks Take the Reins in Tokyo

UCS Blog - All Things Nuclear (text only) -

Japan’s Defense Minister Itsunori Onodera and Foreign Minister Taro Kono shake hands with U.S. Secretary of State Rex Tillerson and Defense Secretary James Mattis before sitting down for U.S.-Japan security talks.

Donald Trump’s plan for a more muscular US nuclear posture got a ringing endorsement from the increasingly right-wing government of Japan. Not long after the Trump administration released its Nuclear Posture Review (NPR) in early February, Foreign Minister Taro Kono said he “highly appreciates” the new approach to US nuclear weapons policy, including the emphasis on low-yield nuclear options the United States and Japan can rely on to respond to non-nuclear threats. 

Kono’s endorsement of Trump’s NPR was a surprise to those who saw him as a moderate who could temper Prime Minister Abe’s geopolitical ambitions, which include amending Japan’s pacifist constitution to allow for an expansion of the size and role of Japan’s military forces.

Support within the conservative leadership of Abe’s Liberal Democratic Party (LDP) for an increased US emphasis on the role of nuclear weapons is not new. Nine years ago, foreign ministry officials loyal to the LDP testified to a US congressional commission advising the Obama administration on US nuclear weapons policy. Their testimony reads like a blueprint for some of the most controversial sections of Trump’s NPR—especially its emphasis on low-yield nuclear weapons, which used to be called tactical nuclear weapons because they were options for fighting limited nuclear wars against nuclear and non-nuclear states, rather than strategically deterring the use of nuclear weapons by others.

Prime Minister Abe recently promoted one of the officials who testified to the commission in 2009, Takeo Akiba, to the top bureaucratic post in Japan’s Ministry of Foreign Affairs.  Mr. Akiba and the rest of the LDP’s nuclear hawks may have had to wait a long time to get what they wanted, but their view of the role of US nuclear weapons in Asia is about to become official US government policy.

Then and Now

UCS obtained a copy of a statement Mr. Akiba submitted to the congressional commission on 25 February 2009, along with hand-written notes—taken by commission staff—of responses to questions. That statement, titled “Japan’s Perspective on the U.S.’s Extended Deterrence,” makes two primary requests:

  • A US presidential statement that places “nuclear deterrence as the core of Japan – US security arrangements.”
  • The maintenance of US nuclear weapons capabilities that are: “(a) flexible, (b) credible, (c) prompt, (d) discriminating and selective, (e) stealthy/demonstrable, and (f) sufficient to dissuade others from expanding or modernizing their nuclear capabilities.”

Obama’s 2010 NPR undoubtedly disappointed the Japanese officials who submitted that statement. Obama emphasized the declining role of US nuclear weapons in regional security.:

When the Cold War ended, the United States withdrew its forward deployed nuclear weapons from the Pacific region, including removing nuclear weapons from naval surface vessels and general-purpose submarines. Since then, it has relied on its central strategic forces and the capacity to redeploy nuclear systems in East Asia in times of crisis.

Although nuclear weapons have proved to be a key component of U.S. assurances to allies and partners, the United States has relied increasingly on non-nuclear elements to strengthen regional security architectures, including a forward U.S. conventional presence and effective theater ballistic missile defenses. As the role of nuclear weapons is reduced in U.S. national security strategy, these non-nuclear elements will take on a greater share of the deterrence burden.

President Trump’s NPR discusses the future role of US nuclear options in Asia in a way that is much more in line with the preferences in the statement Mr. Akiba submitted to the congressional commission in 2009. Trump’s NPR states:

Expanding flexible U.S. nuclear options now, to include low-yield options, is important for the preservation of credible deterrence against regional aggression… In the 2010 NPR, the United States announced the retirement of its previous nuclear-armed SLCM [sea-launched cruise missile], which for decades had contributed to deterrence and the assurance of allies, particularly in Asia. We will immediately begin efforts to restore this capability…

Mr. Akiba’s testimony to the US congressional commission suggested a preference for retaining the SLCM President Obama retired, since it “provides the flexibility of options (namely, it is low-yield, sea-based (stealthy), stand-off (survivable) and can loiter).” That SLCM was the nuclear Tomahawk Land-Attack Missile, TLAM/N.

These types of “flexible” nuclear options figure prominently in Trump’s NPR. The Japanese statement defined nuclear flexibility as having weapons that, “could hold a wide variety of adversary threats at risk.” These threats included “deep and hardened underground facilities, movable targets, cyber attack, anti-satellite attack and anti-access/area denial capabilities.” In this case, the Japanese statement’s use of “anti-access/area denial” was a reference to China’s conventional military capabilities.

The Trump NPR gives Japan’s nuclear hawks all the “flexibility” they asked for in 2009, backed up by an unambiguous declaration that the United States will use nuclear weapons to respond to non-nuclear attacks, including “new forms of aggression” like cyber attacks. It also appears to endorse a strategy of offsetting China’s conventional military capabilities, including space and cyber capabilities, with new US nuclear weapons. The Trump administration’s intention to use nuclear weapons to counter non-nuclear Chinese military capabilities is repeated in the administration’s National Defense Strategy.

Making Okinawa Nuclear Again?

The handwritten notes on the 2009 Japanese statement indicate one of the commission co-chairs, former US Secretary of Defense James Schlesinger, asked if Japan could adjust its domestic policies to prepare for the redeployment of US nuclear weapons in Okinawa. Mr. Akiba responded by warning Schlesinger there was still strong domestic support for the Japan’s Three Non-Nuclear Principles, which were first announced in 1967, and subsequently reaffirmed by various members of the Japanese government as well as a 1971 vote in the Japanese Diet. The principles declare that Japan would not possess, manufacture, or allow the introduction of nuclear weapons into Japan.

But despite these concerns about Japanese public opinion, Akiba told Schlesinger that preparing to return US nuclear weapons to the Japanese island of Okinawa “sounds persuasive to me.” Given the Trump NPR’s emphasis on new tactical nuclear weapons that can be redeployed in Asia, and the Abe government’s unequivocal support for Trump’s NPR, it is worth investigating the possibility both sides have agreed to upgrade US munitions storage facilities in Okinawa so they can store US nuclear weapons on the island.

There are several reasons why redeploying nuclear weapons in Okinawa may make sense to bureaucrats, like Mr. Akiba, who support an increased role for US nuclear weapons in the Asia.

The first is the existence of a secret agreement between Japan and the United States that allows the US military to redeploy US nuclear weapons in Okinawa.  The agreement was signed by US President Nixon and Japanese Prime Minister Sato in 1969 as part of the legal process that returned sovereign control of the island to the government of Japan. The United States had occupied Okinawa since the end of WWII and built an expansive set of US military bases that remain there today. Some of those bases housed US nuclear weapons, which were removed in 1972 at the request of the Japanese government.

The agreement was kept secret for decades and both sides still refuse to discuss it publicly. Many of the details were finally made public in an official investigation conducted by Japan’s Ministry of Foreign Affairs during a brief period when the opposition Democratic Party of Japan (DPJ) controlled the government from September 2009 to December 2012.

Another reason redeploying US nuclear weapons in Okinawa might sound persuasive to Mr Akiba is that US and Japanese officials can use ambiguities in the language of the Nixon-Sato agreement, and tight controls on the dissemination of information about related bilateral discussions, to obscure the process that would be followed if the United States decided to make Okinawa nuclear again.

Schlesinger’s question and the Japanese answer suggest the United States would ask the Japanese government for permission. But that permission need not be explicit, or public. It may not even be necessary. The language of the Nixon-Sato agreement is intentionally vague and suggests simple notification at a relatively low level of the bureaucracy might be enough. This kind of low level agreement would give the prime minister and other LDP officials the same kind of plausible deniability they used to avoid discussing the Sato-Nixon agreement on redeploying nuclear weapons in Okinawa for more than 50 years.

The potential presence of US nuclear weapons in Okinawa would be further obscured from public view by the US government’s non-confirm, non-deny policy on military deployments. US silence on the question would make it a lot easier for the Japanese government to consent to redeployment. In the absence of an external inquiry, US nuclear weapons could be put back in Okinawa quietly, without public knowledge or debate.

The final reason Okinawa might sound persuasive to Mr. Akiba is that the United States is building a new military base in the Okinawan village of Henoko. The project includes significant upgrades to a munitions storage depot, adjacent to the new base, where US nuclear weapons were stored in the past. Henoko is specifically mentioned in the 1969 Nixon-Sato agreement as a mutually acceptable location for the possible redeployment of US nuclear weapons in Japan.

Birds of a Feather

Japanese Prime Minister Shinzo Abe is one of Donald Trump’s most loyal international supporters. He was the first world leader to visit Trump Tower during the transition and he highlighted his close personal friendship with the US president during recent Japanese elections.

Mr. Akiba is Abe’s chief foreign policy advisor, especially on the question of extended nuclear deterrence. Akiba selected, organized and led the first several Japanese delegations to the US-Japan Extended Deterrence Dialogue (EDD) and has toured US nuclear weapons facilities. With the release of the new US nuclear posture review and the Abe government’s unapologetic endorsement, it seems clear that all three men agree on the need to increase the role of US nuclear weapons in Asia.

The LDP support for the Trump NPR may seem surprising to many members of Congress, whose last impression of Prime Minister Abe’s opinions on nuclear weapons is the image of him greeting President Obama in Hiroshima. At a recent meeting in Washington an exceptionally well-informed national security staffer of a veteran member of the House, when informed of Foreign Minister Kono’s statement of support for Trump’s NPR, asked if Abe had publicly corrected Kono’s misstatement.

US opponents of Trump’s NPR should take note. As the debate over the NPR unfolds in the coming days, weeks and months, the LDP officials voicing their support for Trump’s NPR do not represent the majority of the Japanese public and their elective representatives, who are opposed to a larger role for US nuclear weapons in the defense of Japan. But they do represent the views of Prime Minister Abe, who has lined up firmly behind the Trump NPR.

The “Versatile Fast Neutron Source”: A Misguided Nuclear Reactor Project

UCS Blog - All Things Nuclear (text only) -

The Union of Concerned Scientists (UCS) supports a moderate level of Department of Energy (DOE) research funding to make nuclear power safer and more secure—for example the agency’s program to develop accident tolerant fuels for nuclear reactors. Conversely, UCS does not support programs that not only would cost a lot of money, but also could make nuclear power more dangerous and less secure. That’s why the organization is troubled by a bill that was passed by the House of Representatives on February 13.

The bill in question, H.R. 4378, authorizes the secretary of energy to spend nearly $2 billion over the next seven years to build what’s called a “versatile reactor-based fast neutron source.” As its name indicates, the primary purpose of this facility would be to provide a source of high-energy neutrons to help researchers develop fuels and materials for a class of advanced nuclear reactors called fast reactors.

What is it?

What may not be clear from the name is that this facility itself would be an experimental fast reactor, likely fueled with weapon-usable plutonium. Compared to conventional light-water reactors, fast reactors are less safe, more expensive, and more difficult to operate and repair. But the biggest problem with this technology is that it typically requires the use of such weapon-usable fuels as plutonium, increasing the risk of nuclear terrorism. Regardless, the House passed the bill with scant consideration of the risks and benefits of building it. Hopefully, the Senate will conduct a due diligence review before taking up a companion bill. Caveat emptor.

Based on what little public information there is available about the plans for this facility, it would be a fast reactor of at least 300 thermal megawatts (or about 120 MW of electricity if it is also used for power generation). This power level is the minimum necessary to achieve the desired rate of neutron production. This would make the reactor about five times larger than the last experimental fast reactor operated in the United States, the EBR-II, which shut down in 1994. One proposed design, called FASTER, would have a peak power density three times higher than the EBR-II, making it much more challenging to remove heat from the core. This design would require about 2.6 metric tons of metallic fuel containing about 500 kilograms of plutonium per year. One third of the reactor fuel would be replaced every 100 days. (The DOE also is apparently considering a different fast reactor design that would use high-assay, low-enriched uranium fuel, but this material is in short supply and a new production source would have to be established. In any case, the DOE has not yet determined if it is feasible to use low-enriched uranium.)


The amount of funding authorized by H.R. 4378 for designing and constructing this fast reactor is less than 60 percent of its estimated cost of $3.36 billion, and the aggressive timeline mandated by the bill, which calls for full operation by the end of 2025, is significantly shorter than the optimistic 11- to 13-year schedule anticipated by its designers. By low-balling the initial authorization and construction time, H.R. 4378’s sponsors may have been trying to make it more palatable, but they are also undermining their project.

It’s also important to keep in mind that the estimated cost of $3.36 billion is just a fraction of the project’s total cost. It does not include a facility to fabricate the plutonium fuel, which could add billions to the final price tag. The current cost estimate for the DOE’s Mixed Oxide Fuel Fabrication Facility at the Savannah River Site, which is being built to convert 2 metric tons of plutonium annually into fuel for operating light-water reactors, is more than $17 billion. Then there’s the cost of managing and disposing of the several tons of plutonium-containing spent fuel that would accumulate each year at the fast reactor site.

We’ve been down this road before. As the Union of Concerned Scientists reported last year, the DOE’s Idaho National Laboratory has been unable to deal effectively with the spent fuel legacy of the defunct EBR-II, which is similar to but less hazardous than the spent fuel that the FASTER test reactor would produce because it contains far less plutonium. (Only a small fraction of the fuel rods irradiated in the EBR-II were fabricated with plutonium.)

The project’s high cost and risks might be justified if there were a critical need for a new fast neutron source in the United States. That’s simply not the case.


The primary purpose of the facility would be to assist private companies that want to develop and sell fast reactors, but most of those companies aren’t sold on the idea. According to a report last year by the DOE’s Nuclear Energy Advisory Committee, “some of the industry representatives (e.g., AREVA, GE-Hitachi, TerraPower, Westinghouse, and Terrestrial Energy) who have an interest in pursuing advanced reactors … [are] of the view … that a test facility was not essential for the commercial advancement of their technology.” Moreover, the DOE hasn’t determined that there is an actual need for the project. On February 6, Principal Deputy Assistant Secretary for Nuclear Energy Edward McGinnis told the House Energy and Commerce Committee that “a decision whether or not to deploy an advanced fast spectrum test reactor has not been made.…”

H.R. 4378’s mandate that the DOE to proceed with design and construction, therefore, is premature at best.

Finally, what agency will oversee the safety and security of this risky project? The DOE. By designating this reactor as a neutron source, and building it at a DOE site, it will be exempt from licensing and oversight by the Nuclear Regulatory Commission. While NRC licensing is far from perfect, it would be far superior to DOE self-regulation.

To summarize, H.R. 4378 authorizes constructing a fast reactor without assessing the need or evaluating its costs and benefits. It compels the DOE to build an experimental fast reactor, using an experimental fuel, at a scale and power density that has never been demonstrated, on a rushed schedule, with insufficient funding.

This is simply the wrong way to pursue nuclear energy research and development. Instead, DOE should undertake projects only if they pass a rigorous peer review and make safety and security a priority.

Science For Justice: A New Blog Series

UCS Blog - The Equation (text only) -

Science and social justice are inextricably linked. Science provides the foundation for a strong democracy, and is critical to improving and maintaining quality of life. Evidence-based public safeguards are vital to protecting the health, safety, and well-being of communities and individuals.

But the reality is that scientific evidence has been used to justify oppressive behaviors and disenfranchisement of certain groups in our nation. Historically, people have been made targets of unfair practices based on their race, religion, country of origin, gender and sexuality—both systemically and individually. Laws meant to improve lives in America have been improperly enforced or used as weapons against certain groups, leaving them marginalized and fighting for basic freedoms, often with limited resources.

In an effort to bring these social injustices to light, the UCS Science Network has created the “Science for Justice” blog series. The series is intended to engage scientists who are working with and within the most impacted communities and use their scientific expertise to inform issues of social justice, and to amplify the communities and grassroots organizations that scientists work with, while also offering guidance on best practices for respectful, mutually beneficial partnerships. It is important for scientists to recognize the fraught history of social justice in America and to be aware of the space they are entering.

The series will also serve as a platform to offer tips and resources for scientists looking to use their skills to help communities advance their work for just and equitable solutions, from scientists and community members already in this space.

It is critical for our collective health and safety for scientists to realize the power they hold in being able to inform policies which will protect this and future generations’ access to the land, water and air. The “Science for Justice” series intends to teach scientists how to utilize this power—for the people.


Our Science for Public Good Project: Hosting a Holiday Air and Water Quality Party NABEEHAH AZEEZ, JENNIFER KUNZE, AND ANNA SCOTT, UCS SCIENCE NETWORK, UCS | FEBRUARY 12, 2018, 3:10 PM EST

Congress must address gun violence safety

UCS Blog - The Equation (text only) -

Yesterday, was a tragic day. A 19-year-old teen opened fire on his former classmates, killing 17, wounding many more, and affecting the lives of thousands in a community just north of Miami, Florida.

It was yet another tragic day in a long line of tragic days. Since 2013, there have been 290 school shootings, an average of nearly one per week. In 2018, there have been 18 school shootings in 45 days. On average, that is about one shooting every three days.

Overall, in 2018, there have been 30 mass shootings in the United States.

This is unacceptable. This has always been unacceptable.

The United States can do better. And Congress can do better. We continue to hear the popular refrain of thoughts on prayers from our elected officials, but it isn’t enough. It wasn’t enough for the victims in Parkland, Las Vegas, San Bernadino, Orlando, Newtown, and many more, and it won’t be enough for the victims of the next mass shooting.

That’s why Congress must show leadership. Over the next few weeks, as Congress works to finalize a spending bill for the rest of the 2018 fiscal year, and as it begins work on a spending bill for the 2019 fiscal year, there is one concrete thing that our elected officials can do to move the ball in the right direction.

Congress must lift the ban restricting gun violence research and fund critical work at the Centers for Disease Control and Prevention (CDC).

The policy rider, which has been embedded into spending bills since 1996, while not expressly prohibiting research on gun violence and gun violence safety, is written in such a way that it has created a chilling effect at the CDC and suppressed inquiry into this public health crisis.

Over the years, the Union of Concerned Scientists has advocated for removing this policy rider from spending legislation and we will continue to do so when we meet with legislators and their staff.

In a radio interview, Speaker Paul Ryan said that “as public policymakers, we don’t just knee-jerk before we even have all the facts and the data.” Speaker Ryan, I couldn’t agree more. Now let’s put some money where your mouth is and lift the ban that restricts gun violence research at the CDC.

Speaker Ryan in radio intv on Parkland, FL shooting: "it’s just a horrific, horrific, horrible shooting. I think we need to pray, and our hearts go out to these victims. And I think, as public policymakers, we don’t just knee-jerk before we even have all the facts and the data"

— Alex Moe (@AlexNBCNews) February 15, 2018

Congress should not be discouraging scientific research on gun violence. It must be looking for solutions. Gathering information and seeking data to help inform the conversation on what we as a nation must do to prevent these senseless tragedies would be a good start.

Federal Scientists! Make a Note for the Record. We All Need to Know of Your Work.

UCS Blog - The Equation (text only) -

To say that federal employees are working in a challenging environment is probably a gross understatement. I’ve heard reports of employees not being allowed to take notes in meetings or told not to use specific words in communications. The Union of Concerned Scientists has reported on scientific advice being sidelined by political staff across a broad range of decisions. As my colleague Joel Clement, formerly of the Department of Interior, said, most career professionals in the agencies just want to do their jobs.

So how can scientists and other professionals in the agencies maintain the integrity of your work place? How can you ensure that the information and technical input you provide isn’t simply suppressed? One option is to make notes for the record as you do your work. You can document in real time by writing a contemporaneous account of the projects you are involved in, dated and signed. That preserves a record of what’s happening inside federal agencies. You can briefly document meetings and calls you participate in, and include any documents that are a key part of the decision-making process. You might want to keep separate copies at home or securely in your office. In keeping with best practices for data management, back up your notes periodically or keep them in multiple formats.

I am not suggesting some nefarious effort to undermine agencies nor to catch anyone out, or challenge the administration, but simply to document the professional work that you do. Be aware that what you write will likely be seen by others. It may become part of an administrative record behind a decision. So, take care with what you write and maintain professional standards at all times.

The purpose of our government is to serve the public interest. The professional staff at federal agencies know that well. Keeping a record of your work is also the act of a professional. I certainly understand the stress that many agencies are feeling, as a former fed myself. So, take care and continue to do the work you do, and that the country so sorely needs. And as you do, help fight the censorship of science by making sure that that work will ultimately be accessible to all Americans. And for anyone reading this blog, remember to #ThankAGovScientist today.

How Bad Are Proposed Budget Cuts at the EPA? Let Me Count the Ways

UCS Blog - The Equation (text only) -

Proposed budget cuts threaten the health and safety of all Americans, especially our children. Photo: USEPA/Flickr

While President Trump just released a proposal that would result in deep cuts for critical science-based agencies in fiscal year 2019, Congress still must pass a spending bill that will determine funding levels for critical agencies that we rely on to advance science, keep our air and water clean, and protect children’s health for the rest of this fiscal year by March 23.

Unfortunately, the proposals currently on the table for funding our government would slash the budget of the Environmental Protection Agency (EPA) and include harmful “poison-pill” anti-science policy riders, thereby threatening the public health and safety of everyone across the US. 

The proposals to cut EPA funding and undermine the agency’s ability to implement evidence-based policies are deeply troubling given the critical role—and successful track record—of the agency.  Remember the saying: you can’t argue with success? Well, that’s certainly not a saying used by the current administration, nor the appropriations committees in Congress, on this matter. There, the majority party seems to overlook the singular success of the people’s Environmental Protection Agency.  (I refer to “the people’s” EPA because the agency is there first and foremost for us—to protect and preserve our health, our communities, our environment.)

Perhaps these budgeteers think the quality of the air we breathe and the water we drink simply improved on their own over time. Or that the polluters decided to ratchet down toxics in our environment out of the goodness of their hearts. Perhaps they forgot that rivers once caught fire and that really dirty air plagued our cities and communities, exacting an enormous toll on the public’s health.

Or maybe they just think our environment is clean enough. Perhaps in their zeal to help EPA Administrator Scott Pruitt “get back to basics,” they ignore the science and data that tell us otherwise. Many communities, along with health professionals, know full well that the environment is NOT clean enough. The proposed cuts by Congress (and the president) to the EPA budget—significant for an agency already underfunded and stretched thin—fail to recognize that air pollution remains a significant risk factor for cancer, cardiovascular disease, respiratory illness and premature death in this country. They sideline such facts as:

  • More than half of all Americans—166 million people—live in counties where they are exposed to unhealthful levels of these pollutants—like ozone and particulates.
  • Nearly 3.6 million children and close to 11.4 million adults with asthma live in counties of the United States that received an F for at least one pollutant.
  • More than 24.8 million people with incomes meeting the federal poverty definition live in counties that received an F for at least one pollutant. Nearly 3.8 million people in poverty live in counties failing all three tests. Evidence shows that people who have low incomes may face higher risk from air pollution.

Ignorance may be bliss for some, but it sure doesn’t protect and improve the public’s health.

The good, the bad, and the ugly

There is no overarching silver lining to the EPA budget proposals coming out of Congress (or the White House)—though I suppose we could acknowledge that their proposals are not as draconian as President Trump would have liked.

There is one significant sliver of good news: Senate appropriators directed the EPA to continue reimbursing the Department of Justice for expenses incurred in litigating Superfund cases and forcing polluters to pay for cleaning sites they left contaminated with hazardous waste. This was a practice Pruitt wanted to shut down. And the bill increases the Superfund program budget slightly (by $2 million).

OK. But, these bits of good news are completely overshadowed by the BIG hit that the EPA would take in the Senate bill along with the litany of poison pill riders that would fly in the face of scientific advice. Given how long ago it now feels that the House and Senate bills came out, and given the looming March 23 deadline for Congress to pass a spending bill or pass another extension, here is a reminder of the bad and the ugly.

On the chopping block

Across-the-board cuts in the EPA budget would be bad enough, but they fall most heavily (and predictably) on some programs in the most recent proposals. No surprise that compliance and enforcement programs are a target. The House proposed a 15% cut in enforcement and a 5% cut in compliance programs within the Environmental Program and Management Account. The Senate bill cuts enforcement and compliance within the Environmental Program and Management Account by 10% each. Never mind that enforcement and compliance programs are essential for ensuring that regulated industries are abiding by our country’s science-based environmental standards—whether through assistance or sanction—and paying the price when they aren’t. (Strong enforcement also helps level the playing field for those companies that comply with environmental regulations. Violators should not get a free ride.)

Cuts to EPA enforcement and compliance programs could also mean:

  • Fewer actions to protect the public, especially young children, from exposure to lead in paint. From October 2016 to September 2017, EPA filed 123 civil lead-based paint administrative actions leading to 120 settlements and three outstanding civil complaints. In fact, EPA enforcement actions have reached a 10-year low.
  • Fewer cases to force reductions in harmful air emissions from petrochemical facilities
  • Less company investment in pollution control equipment to reduce air pollution and to improve public health in local communities previously impacted by pollution
  • Fewer actions to prevent future chemical spills and clean up past ones
  • You get the picture.

EPA’s Science and Technology Account is also on the chopping block, despite the central role EPA plays in providing the research, scientific knowledge, and technologies needed to prevent and abate current pollution as well anticipate and prepare for future hazards and risks. The House bill cuts this critical function by almost 15%, while the Senate bill cuts it to a little more than 10%. This is a significant cut to this gem in our nation’s research enterprise, potentially affecting research areas critical to the health and safety of our children, our communities, and our future. These include, for example,

  • Conducting cutting-edge science to inform quality standards for the water we drink and the air we breathe
  • Evaluating the potential health impacts of chemicals and emerging materials, as well as enabling safer and more sustainable use of new chemicals
  • Developing or jumpstarting the scientific and engineering solutions we need to manage current and future environmental risks
  • Providing the science and technology needed to effectively respond to, and recover from, intentional or accidental environmental catastrophes

These cuts also put the capacity, productivity, and effectiveness of our national labs at risk, as well as the likelihood of additional job loss. (I say additional because Pruitt is already orchestrating an exodus of EPA staff and expertise through hiring freezes, buyouts, and offers of early retirement–see here and here). Among others, this cut puts the National Vehicle and Fuels Emission Laboratory at risk. That’s the one that verified and provided the data needed to prosecute Volkswagen for Dieselgate. And, speaking of diesel, the Senate bill cuts the program that provides funds to replace or retrofit older diesel vehicles by almost a third—from $65 million if FY 2017 to $40 million in FY 2018.

Work on environmental justice is another mission-critical area of the EPA. Established in 1992, EPA’s environmental justice program was established to address the disproportionate impact of environmental pollution on minority, low-income, and disenfranchised communities. The Office of Environmental Justice—though small itself—has provided leadership, support, resources, and small grants to engage and help communities create and implement local solutions to environmental justice concerns where they live. Yet instead of doubling down on this problem, the Senate bill slashes the budget of the office by 10%, which could mean:

  • Less financial support for impacted environmental justice communities
  • Fewer tools, resources, and opportunities for EJ community engagement in EPA policy processes and decisions
  • Less technical assistance for communities to enhance their ability to better understand the science, regulations, and policies of environmental issues and EPA actions

How these cuts make America great is beyond me.

Not content with mere chopping, the Senate bill eliminates the Integrated Risk Information System (IRIS). This is the program that assesses and evaluates the potential health risks of our exposure to chemicals in the environment. These assessments are used by federal and state regulators (and even internationally) to set exposure limits on hazardous chemicals. Easy to understand why the chemical industry and their favorites in Congress have had their sights on IRIS for quite a while (more on that here).

Now, to be fair, while totally gutting IRIS, the Senate bill transfers resources and directs the EPA to build this effort into its revised Toxic Substances Control Act (TSCA) Program. The bill also calls on EPA to work closer with industry as it crafts the next generation of risk assessment methods. Should we have any confidence that this new approach will serve the public interest? Notwithstanding the fact that the IRIS program and the TSCA program have different mandates. And it’s Nancy Beck who heads the EPA’s Toxics Office. She is a former policy director at the American Chemistry Council, so just call me skeptical.  And I’m being generous here.

Poison pills—those ugly riders

We can be forgiven for thinking that spending bills are all about funding. But our elected leaders can sneak or even boast about attaching anti-science, poison pill policy riders to spending bills.   And the spending bill introduced in the Senate that should be clearly focused on funding public health and science-based policymaking is no exception.

Here are a few poison pills they are asking us to swallow:

  • Exempt any EPA effort to withdraw the Clean Water Rule from the Administrative Procedures Act (APA). This is the rule that defines which waterways are covered by the Clean Water Act. Yeah, the water we might drink fish, swim, or play in.  And bypassing the EPA means the agency can withdraw the rule without any public comment. (Score 1 for Pruitt, 0 for democracy.)
  • Require EPA and other agencies to continue to treat forest biomass as carbon-neutral, again sidelining science.
  • Roll back the critical science-based ozone standard which results in cleaner air and healthier people.
  • Prohibit agencies from requiring Clean Air Act permits to emit carbon dioxide, methane, and other gases from livestock production.
  • Prevent agencies from issuing rules that require greenhouse gas emissions from manure management systems.
  • Endorse EPA efforts to “reshape” its workforce—another word for downsizing—that is already hollowing out the agency. This loss of experience and expertise will take decades to rebuild.
What to do? Light up those phones!

Congress has until March 23 to pass a spending bill which would fund the government for the rest of the year, so now is a key moment to let your Senators know: Any cuts to the EPA and any “poison pill” anti-science poison-pill riders are unacceptable!

Call your senators. You can reach them by calling 1-833-216-1727.

Tell them you are opposed to any cuts to the EPA budget and to harmful anti-science poison pill policy riders that prevent the agency from doing its job. Speak specifically to cuts in the EPA Science and Technology Account, the Environmental Program and Management Account (which fund enforcement and compliance), the Office of Environmental Justice, and the elimination of the IRIS program.

Call them, and then call them again. Tell them the EPA is the people’s EPA and this bill does not serve the people.

Tell Congress to Send Support, Not Poison Pills, to Endangered Species Protections

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Photo: USFWS

Valentine’s Day. It’s the time of year where we, as a nation, spend an exorbitant amount of money on roses, heart-shaped chocolates, and oversized teddy bears. In 2017, America spent $18.2 billion (an average of $136.57 per person) on gifts to show their affection for that special someone.

In contrast, the federal government designated about $1.5 billion to the entire US Fish and Wildlife Service (FWS) last year—out of which only $240 million went to Ecological Services (the office responsible for administering the Endangered Species Act) and a mere 20.5 million went toward the listing of endangered species. While the budget was settled in time to avoid a shutdown last week, that doesn’t mean we’re in the clear. The appropriations race will be on to designate how exactly the money will be spent, which means there are sure to be some sneaky anti-science provisions.

Congress’s poison arrows

Endangered species protections are under constant threat from politically motivated decisions. The recent border wall construction waivers, opening of large swaths of critical habitat to oil and gas leasing, and legislative attacks in the form of “poison pill” budget riders all undermine protective, science-based statutes like the Endangered Species Act.

This year’s spending legislation contains several riders that would remove federal protections for the following species:

  • Preble’s meadow jumping mouse—True love is hard to find…but so is the Preble’s meadow jumping mouse, found only in Colorado and Wyoming. The diminutive mouse is currently protected as a threatened subspecies, though not without controversy.
  • Sage grouse—The sage grouse is no stranger to heartache. As I’ve mentioned in the past, the sage grouse cannot catch a break. The Bureau of Land Management (BLM) under Secretary Zinke reopened the sage grouse management plan for public comment last year, despite years of collaborative efforts to create the plan to keep the bird off the endangered species list. Its delicate sagebrush habitat is also at risk of being destroyed by oil and gas development. And now, yet again, there is a rider that would prohibit the FWS from even considering the sage grouse as a candidate for listing under the Endangered Species Act.
  • Gray wolf—The gray wolf populations in Idaho and Montana (and parts of Washington, Utah, and Oregon) had their endangered species protections unceremoniously removed in 2011. The gray wolf remained listed in Wyoming until 2012, after which it was put under state management. It was subsequently relisted in 2014, and again delisted in 2017. The riders would make it such that 1) the delisting rule of 2011 would apply to the state of Wyoming and the Great Lakes states, and 2) the gray wolf would be prohibited from receiving any funds for protections under the Endangered Species Act.
  • Lesser prairie chicken—This rider would prohibit the use of federal funds for listing the lesser prairie chicken as threatened or endangered under the Endangered Species Act. The lesser prairie chicken’s numbers have dwindled over the years because of climate change and habitat fragmentation, destruction, and degradation, and will require increased protections to make a full recovery. Let’s not let Congress stop protections for the chicken that danced its way into our hearts.
  • North Carolina red wolf—The recovery program for the red wolf began in 1967, after its populations were drastically reduced due to predator control programs and human activity, but its population has not yet recovered. This rider would end the recovery program for the red wolf, effectively declaring it extinct. Captive breeding of the red wolf has brought the total population to about 250.
Roses are red, violets are blue; these species are in danger, here’s what you can do

These “poison pill” riders insert another level of political interference into science-based protections, actions that could lead to the destruction of essential habitat and otherwise preventable species extinctions. This year, I propose we show our love and our federal dollars to endangered species by supporting the Endangered Species Act and rejecting damaging riders to appropriations bills.

If you’re a scientist, you can join forces with over 950 other scientists and sign on to a letter asking Congress to reject efforts to gut the science-based law, and you can also check out our toolkit and accompanying webinar for more information on how to get engaged in advocacy around the Endangered Species Act. And any science supporter out there can show their love for endangered species by reaching out to your members of Congress and asking them not to support any anti-science riders and to increase funding for endangered species. Extra candy hearts for those who mention species in your state that are affected by the law—making your comment relevant locally means your decisionmaker has more cause to oppose these riders.


I would like to acknowledge and thank my colleague Amy Gutierrez, legislative associate for the Center, for her legislative acumen and input. 

Photo: USFWS

President Dumps Clean Energy in Proposed Budget

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Photo: US Department of Energy

Today, the president released his budget proposal for the upcoming fiscal year (FY 2019) and as expected, it seeks to eviscerate research and development (R&D) in clean energy technology. The proposal would slash funding in the applied energy technology offices within the Department of Energy (DOE), now housed within the Office of Energy. As my colleague points out, the proposal is “not scaling back, it’s eviscerating the work,” and is another example of this administration’s attacks on clean energy. As the Nation needs to continue to develop and deploy clean energy technologies to solve the threats posed by climate change, hopefully Congress will do what it did last year: yawn, ignore the current administration’s ideologically driven proposal, and do what is best for the Nation.

The Budget Process

The President’s budget request usually happens in February each year, as the Congressional appropriations process begins for the upcoming fiscal year in October. This request follows a massive budget deal signed into law by the president last week. In addition to lifting the debt ceiling, the deal raises domestic and military spending levels by $300 billion in total through September 2019. And it keeps the government open for another six weeks while lawmakers work out a longer-term spending bill that will fund the government through the end of FY 2018, which runs to the end of September.

Republicans seemed eager to raise spending as well as the debt ceiling, even though the party fought tooth and nail against the Obama administration on these issues. Still, Congress rejected the president’s proposed budget cuts last year, giving a bit of hope that Congress will ignore his current proposal as well.

The Hit List
  • ARPA-E, funded at $261 million in FY 2017, would receive no funding in FY 2019. According to the White House, the agency “will wind down operations in FY 2018 with the expectation that it will shut down in FY 2019, with remaining monitoring and contract closeout activities transferred elsewhere within DOE.” Given wide bipartisan support, this seems unrealistic.
  • Energy Efficiency and Renewable Energy (EERE) is slated for drastic cuts—from $2.1 billion in FY 2017 down to just $696 million in FY 2019. This represents a two-thirds cut in funding for clean energy R&D, not much better than the 72 percent cut reported earlier.
  • The Office of Electricity Delivery and Reliability (OE) would be split into two offices focusing on grid reliability (Electricity Delivery) and cybersecurity. Together, the two offices would receive $157 million in FY 2019, which is still a 31 percent cut from OE’s enacted FY 2017 level. Worse, energy storage R&D faces a sharp 74 percent cut ($8 million in FY 2019 compared to $31 million enacted in FY 2017).
  • Other important programs within Electricity Delivery are also facing steep cuts: transmission reliability and resiliency ($44 million to $13 million) and resilient distribution systems ($54 million to $10 million). These cuts seem particularly harsh given all the recent impacts on the electricity system due to severe weather.
  • The budget also completely axes the Low Income Home Energy Assistance Program (LIHEAP) block grants managed by the Department of Health and Human Services (HHS). Last year, LIHEAP released about $3.03 billion in block grants for states and tribes to help low-income households pay heating and cooling bills. The president’s budget proposes $0—meaning states and tribes would be left to figure out how to make up the shortfall.
  • The president also proposes eliminating the successful Title 17 Innovative Technology Loan Guarantee Program. The loans have helped companies commercialize energy technology, and the program has turned a profit for taxpayers, raising more than $1.79 billion in interest payments since its inception in 2005. The program could even be used to support energy infrastructure projects.
Reflecting the Administration’s Ideology

This president’s budget request reflects a prioritization of basic research and early stage R&D over later stage R&D—but it’s misguided to slash all funding that is deemed “applied research” and assume that the private sector will pick up the slack. As I’ve written previously, DOE’s new organizational structure separates basic research from applied science. The short summary from DOE notes that the Office of Science is slated to receive $5.4 billion in funding in FY 2019—the same as FY 2017 enacted—while the Office of Energy faces a cut of $1.9 billion—roughly a 43 percent cut compared to the $2.5 billion enacted in FY 2017:

“The FY 2019 Request provides $2.5B for energy and related programs, $1.9B below FY 2017 Enacted, and continues the Administration’s prioritization of the early-stage R&D that takes place at the National Laboratories.”

What the number crunchers at the White House don’t seem to recognize is that the National Labs work on both basic science and applied science, as well as both early stage and later stage R&D. All parts of the innovation ecosystem are needed in order to bring new technologies to commercialization.

What’s Next

Congress will continue its work on funding the government for the rest of FY 2018, which ends at the end of September. Once that work is complete, it will move toward deciding on spending levels for FY 2019. We’ll be pushing for Congress to use the power of the purse string to invest in clean energy technology and innovation and ignore the White House’s proposed budget.


Update 2/13/18, 12:11 pm: An additional bullet point was added, mentioning the elimination of the Title 17 Innovative Technology Loan Guarantee Program.

Why Climate Change and Equity Matter for Infrastructure: An Interview with Chione Flegal of PolicyLink

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The wildfires in northern California in 2017 destroyed more than 8,000 structures, exacerbating the existing housing crisis and creating a jobs shortage for low-income workers, especially farm workers, domestic workers, and workers in the tourism industry. Photo: National Guard

Yesterday, President Trump unveiled his administration’s outline for upgrading the country’s deteriorating infrastructure system. While massive investments are much-needed, the proposed framework is short-sighted and will make it that much harder to deliver on promises to help build a better future for all Americans and to ensure federal tax dollars are well-spent. UCS President Ken Kimmell has summarized UCS’ serious concerns with the plan here.

Ms. Flegal is an expert on infrastructure, and has more than 20 years of experience building coalitions and leading policy campaigns to improve outcomes for low-income communities and communities of color in California.

Among the concerns is the fact that it fails to address two critical shortcomings of existing infrastructure systems and practices: they are not prepared for a growing number of extreme weather events and climate-related stressors, and they do not serve all communities. Over the past year alone, we have seen our infrastructure fail under increasingly extreme hurricanes, heat, floods, and wildfires, with serious impacts on communities and businesses. We also know that both an “infrastructure gap” and a “climate gap” leave underserved and disadvantaged communities more vulnerable to these risks.

I recently sat down with Chione Flegal, Senior Director at PolicyLink, a national institute advancing racial and economic equity, to discuss climate risks to vulnerable communities, and the important role “climate smart” infrastructure can play in achieving healthy, thriving communities in the face of climate change. While our conversation focused on California, her insights will likely resonate with many other communities across the United States.

Let’s start with the current state of our infrastructure in California. How would you describe it, especially in disadvantaged and vulnerable communities?

Like the rest of the country, California has a history of investing in infrastructure to promote growth, but has now had a long period of disinvestment. Even in the best of times, infrastructure investments varied across communities. In a New York Times column last year, PolicyLink CEO, Angela Glover Blackwell, highlighted the millions of Americans who lack access to public transportation, clean water, and other critical infrastructure.

Similarly, across California, there are communities, disproportionately low-income and of color, that lack the basic features of a healthy, sustainable neighborhood—potable water, sewer systems, safe housing, public transportation, parks, sidewalks, storm drains, streetlights, schools, and libraries.

This not only affects the health and opportunity of residents, but has serious consequences for the state as well.For example, one million Californians are served by water systems that don’t meet safety standards. This presents health risks and means residents may be spending limited income buying bottled water on top of their water bill.

Unfortunately, for too many communities, current infrastructure investments are insufficient, or are invested in projects that exacerbate, rather than address, health and economic inequities. This is, in part, why PolicyLink initiated the Center for Infrastructure Equity to ensure that public investments in infrastructure create economic opportunity and health in all communities. Equity is not only a moral imperative, but an economic one: evidence shows that increasing equality and diversity is the superior model for sustained economic growth.

How does climate change affect these communities?

Climate change affects communities of color and low-income communities first and worst.

They already experience social and environmental vulnerabilities that negatively impact their lives. Climate change exacerbates these vulnerabilities, deepening the health and economic challenges they already experience.

The tragic irony of the climate gap is that low-income people and people of color contribute less to climate change. However, the negative impacts of industries that drive climate change — industrial facilities, oil extraction and refining activities, unsustainable agriculture, poorly planned transportation systems, roads, freeways, etc. — disproportionately affect them, and the longer-term climate impacts will also hit them hardest.

We often talk about climate resilience. What does that mean in your work? And what role does climate-smart infrastructure have in supporting climate resilient communities?

I am challenged by the terminology of resilience because communities of color and low-income people are the most resilient of communities. Our communities have persisted and survived in the face of racism, pollution, disinvestment, and more. So, resilience feels like a strange aspiration for communities that are already incredibly resilient.

At PolicyLink, we want communities to thrive now and in the future, despite climate change. As part of our policy advocacy in California, this means working to make the necessary investments so that ALL Californians are healthy, prepared for work, and have the supports they need to raise their family and reach their full potential.

As surface water supplies decreased during the most recent California drought, over-pumping of groundwater led to thousands of well failures, impacting low-income rural communities in the Central Valley.

Making sure infrastructure is climate-smart is key. Building a water system that won’t work when it floods or won’t work because we’re dependent on a water source that disappears in a drought, won’t allow a community to thrive. Because infrastructure is foundational to achieving healthy communities of opportunity, infrastructure needs to be able to function and provide support and services for communities, regardless of what happens with our changing climate.

What do you see as the biggest challenges to ensuring more equitable outcomes as California advances climate resilience in infrastructure?

This country’s history is grounded in a pattern of exploitation and disinvestment in communities of color – like redlining and highway construction and “eminent domain” that benefited wealthier suburbs while running right through communities of color – and California is no different.

We have to turn that around, which means making really intentional choices that overcome historical patterns of segregation, disinvestment, and discrimination. We can begin to do this by giving low-income people and people of color agency in the decisions about how we invest in public infrastructure.

There are examples of community leaders stepping up to demand that their voices be included, and the projects are better as a result. In Fresno, community leaders worked to get their voices heard in projects like Bus Rapid Transit and the Transformative Climate Communities effort; in the Bay Area, partners demanded equity be considered as the region developed its Sustainable Community Strategy; in Los Angeles communities worked hard to have their voices included in the planning for restoration of the LA River.

We must envision, plan, design, and build projects and include community knowledge and expertise from the start so that projects address the needs and priorities of our communities. This is a different way of approaching infrastructure planning and investment, which has been a highly technical and specialized field where engineers and politicians make choices and the resulting projects are often at odds with community needs.

What are the biggest policy opportunities over the coming year to advance equity, climate resilience, and climate-smart infrastructure?

We’re in a moment where Californians understand that investing in infrastructure is critical for health, well-being, and prosperity. We’ve passed a new transportation funding measure, have extended our climate trading program, have a parks and water bond on the ballot in June, and a housing bond on the ballot in November. Together, these programs will invest billions of dollars in infrastructure every year.

This creates an opportunity to change how we make investments. We need to be deliberate about targeting our investments to disinvested communities, for projects that will improve health and opportunity, and allow all to reach their full potential, in spite of our changing climate.

UCS and PolicyLink are currently collaborating on a project to advance solutions and help address key climate risks to infrastructure and the impacts of climate-related infrastructure disruption and failure on underserved, vulnerable, and disadvantaged communities in California. Stay tuned for more information!

President Trump’s 2019 Budget Nixes Popular Nutrition Program for Farmers and Families

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Photo: Erik Scheel/CC0 BY SA, Pexels

Late this morning, the Trump administration released its proposed budget for the 2019 fiscal year. By and large, the proposed cuts to nutrition programs outlined in An American Budget are devastating, if unsurprising. Much like the administration’s 2018 budget proposal, this one includes a 21.5 percent cut to the Supplemental Nutrition Assistance Program (SNAP) in the 2019 fiscal year, and a total of $213 billion less over the course of 10 years—cuts that would leave millions of children and families hungry next year. It also effectively eliminates the Healthy Food Financing Initiative, a program that provides grants, tax credits, and low-cost loans to fund new grocery stores, corner stores, and other healthy food retail outlets in low-access areas, by removing funding for Community Economic Development (CED) grants.

But what blindsided many this morning was the apparent elimination of another program that has enjoyed broad bipartisan support and popularity among farmers and families. The Food Insecurity Nutrition Incentives program, which funds community efforts to help low-income families purchase more fresh fruits and vegetables straight from farmers, was defunded in the president’s budget.

Although FINI was just created in the 2014 Farm Bill, it has made fast friends. As Wendy Peters Moschetti of LiveWell Colorado, a group that coordinated statewide partnerships to implement a FINI project in 2016, put it: “This program helps to stretch people’s food dollars and keep fruits and vegetables on their plates—which are often the foods that get dropped when living on a tight budget—all while directing these dollars to our farmers and keeping money in our communities.”

Why do we need FINI?

If you’re familiar with the nutrition programs in the Farm Bill, you might be thinking: Doesn’t SNAP already help low-income families buy healthy food?

And you’re right—sort of. SNAP, formerly known as the food stamp program, helps low-income households bridge the gap between what they have and what they need in their monthly food budget. In 2014, the program lifted an estimated 4.7 million people out of poverty—including 2.1 million children, who make up about 4 in 10 SNAP users—and protected many from the effects of hunger and food insecurity.

But even if the president weren’t proposing to take a hatchet to SNAP, that program’s benefits rarely go far enough to help families afford a complete diet, much less a complete healthy diet—which often comes with a higher price tag. Research shows that families using SNAP frequently run out of benefits by the end of the month, resulting in as much as a 25 percent decrease in caloric intake. And a recent study by researchers at UCS and North Carolina State University found that SNAP benefits—even when used only to supplement household food budgets, as the program was intended to function—may only help families cover between 43 and 60 percent of what it costs to achieve a diet consistent with federal dietary guidelines.

As diet-related diseases continue to impact the lives of more than half of all American adults, with low-income populations disproportionately bearing the consequences, a number of solutions have been proposed to enable SNAP users to make healthier choices. These include raising benefit levels and restricting the purchase of certain unhealthy foods—the former of which is a political Hail Mary at present; the latter of which has become a subject of heated debate, and was rejected anew by the USDA just this month.

One thing that has worked, both in politics and in practice? Incentives to help families afford fresh, healthy foods—often, right from the farmers who grew them.

A nutrition program that’s good for families and farmers

FINI awards competitive grants to nonprofit and state/local government agencies for programs that provide point-of-sale incentives, such as rebates or bonuses, to SNAP users purchasing fruits and vegetables.

For example, Double Up Food Bucks, a FINI-funded program operating in over 200 farmers markets and retail outlets throughout Michigan, gives shoppers an extra $10 to spend on local fruits and veggies for every $10 in SNAP benefits they spend at participating stores and markets. And while FINI grant recipients aren’t required, only encouraged, to apply the incentives to local produce, most do—and their farmers and food producers are better for it. In its first five years, Double Up Food Bucks helped SNAP customers purchase more than 3 million pounds of healthy food and directed more than $5 million in purchases to Michigan farmers and vendors. During that time, SNAP sales at farmers markets statewide grew to $1.7 million—putting Michigan among the top five states in the nation on that measure.

A 2015 evaluation of FINI-funded programs showed that between 74 and 94 percent of SNAP farmers market shoppers participating in an incentive program reported buying or consuming more fruits and vegetables as a result, and one California study found that over three quarters of program participants reported improved health among their families. Meanwhile, between 55 and 74 percent of participating farmers reported making more money as a direct result of the program, and many noted that increased sales had allowed them to expand their operation.

Let your elected officials know where you stand

Here’s the good news: The White House gets to propose a budget, but it’s ultimately Congress that holds the purse strings. Want to make sure we secure a win for this win-win program? First, be loud and clear about your opposition to the funding cuts to nutrition programs outlined in the proposed budget: share some blogs, tweet some tweets (I recommend following Karen Perry Stillerman), and let your voice be heard. Second, tell your senators and representatives you support SNAP and the reauthorization of the Food Insecurity Nutrition Incentive program in the 2018 Farm Bill. They’ll have an opportunity to act soon, as a marker bill supporting the program’s reauthorization is expected to be introduced within the month, and it will help to hear from you. And third, check out the nearest FINI-funded market near you to reward yourself with some farm-fresh treats.

Photo: Erik Scheel/CC0 BY SA, Pexels Photo: USDA

Our Science for Public Good Project: Hosting a Holiday Air and Water Quality Party

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Photo: Anna Scott

Nothing says ‘happy holidays’ like environmental justice, so the three of us co-hosted a holiday party in West Baltimore to talk about a recent lead water testing campaign and an upcoming air quality monitoring campaign called Baltimore Open Air. Anna is a graduate student studying climate science. Jennifer is an organizer with Clean Water Action, a grassroots environmental organization focused on water and air quality, climate change, and environmental justice. And Nabeehah works for a grassroots community organization called Communities United in West Baltimore which addresses trauma and building resiliency. We know each other from Baltimore’s People’s Climate Movement table, and were excited about receiving a grant from the Science for Public Good fund.

We decided to highlight key environmental justice challenges that Baltimore neighborhoods face.  Rates of lead poisoning are high, especially among children. Much of the risk is from lead paint, still present in many homes throughout the city. Water is a concern too: more than ten years ago, water fountains in all Baltimore Public Schools were shut off after water repeatedly failed to meet safe lead standards. They still haven’t been turned back on.  Air pollution is likewise a major health threat: in 2013, the asthma hospitalization rate in Baltimore City was 2.3 times higher than the average rate for Maryland, driven by nearby coal plants, trash incinerators, and highways. We’re each involved in monitoring and advocacy campaigns to clean up Baltimore’s water and air, and wanted to share information and ways for people to get involved.

Coalition partners in West Baltimore were invited to attend, and to share the event with their members. Nabeehah went door-to-door in the surrounding community to tell residents about water testing and air quality monitoring, and invited residents to come to our event to learn more. Anna researched answers to questions about the health impacts of lead, water contaminants, and air pollution, and prepared information on her study of local air quality using citizen science and affordable monitors. Jennifer found a local caterer to serve food, and shared information local campaigns against big polluters and her organization’s study of lead drinking water pipes in Baltimore. (You can see the presentation we put together here.) And we all worked together to write questions and answers for a fun game of Environmental Justice Jeopardy. About 50 people from West Baltimore attended the party and learned more about what local organizations are doing to fight for clean air and water in the community.

Does this sound like something you’re interested in doing, but don’t know where to start?

First off, it’s critical to partner with a local group working in the community. What community members in West Baltimore tell Nabeehah and her colleagues is that they have been “surveyed to death.” They have been offered help that never came. Residents see that their community is receiving grants and funding, but they can’t account for what it was spent on. These experiences have led people to be wary of even well-intentioned organizers, psychologists, scientists, and others who start working in their community—particularly when it hits the news due to a traumatic event—without building relationships first.

Seeing this happen over and over makes communities feel used and taken advantage of. The best way to bring science to communities is to start with building relationships and trust by finding organizations that are already working there.

To find those organizations, start being present in the community. Is there a community association meeting coming up? See if you can attend just to listen and learn about what’s happening in the neighborhood. Have you heard about a campaign to address problems that residents face? Follow the news, see who is leading those efforts, and get in touch. Finally, if you are connected with any fellow scientists working on Community-Based Participatory Research or other community efforts, ask them how they got started.

This collaboration was an excellent experience because it helped us develop an understanding of how these core principles directly correlate to science: just as scientists must maintain an open mind, exhaust every possibility, and follow data where it leads, organizers and others pursuing social change must work to invite and involve everyone in a community, practice the skills of listening before leaping to conclusions, attack all angles of injustice, and commit to continuous self-transformation as we change both our society and ourselves.

Anna Scott is a graduate student studying climate science. Jennifer Kunze is an organizer with Clean Water Action, a grassroots environmental organization focused on water and air quality, climate change, and environmental justice. Nabeehah Azeez works for a grassroots community organization called Communities United in West Baltimore, which addresses trauma and building resiliency.

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.


The Truth about Coal, in Under Three Minutes

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Photo: CSIRO/Wikimedia Commons

Coal’s been on the way out for a while now. Why is that? For a quick and accessible look at the state of the coal industry—where it’s been and where it’s going—check out the new video from the Union of Concerned Scientists.

We’ve been writing about coal’s decline and its implications—and setting the record straight on misinformation about coal—for quite some time: responding to the administration’s cheerleading of coal, assessing and understanding the shift away from coal-fired electricity, why the transition away from coal is hard on workers and communities, and how intrepid business leaders in Coal Country are leading the way to new economic opportunities.

We kicked off a blog series recently with an explanation of why a slight increase in coal jobs in 2017 is no indication of a long-term trend. In this second Coal in Context blog, I’d like to highlight a short video on the reasons behind coal’s decline.


The need for a just transition

Here at UCS, we value facts and evidence—and we’re doing our part to set the record straight in a time of great uncertainty. It’s important to emphasize that the coal industry is not returning to its heyday and will instead continue to decline, despite what you may hear from administration officials and the president himself. That propaganda is dangerous because it leads to false hope—leading some to refuse training opportunities in other industries, hoping that coal mining jobs materialize.

Let’s take the longer-term view and understand that coal communities will need to develop new economic sectors to support good-paying jobs in the future—and that it is our collective responsibility to invest in those communities—through proposals like the RECLAIM Act and the POWER Initiative—so they can succeed.

We also need to take the longer-term view on the power sector as a whole– to address the urgent threat of climate change. Yet the administration continues its efforts to rescind the Clean Power Plan, something I testified against back in November in West Virginia. Please join our efforts to push back on these misguided actions—and share the video with your friends to help spread the truth.

ExxonMobil’s Climate Disinformation Campaign is Still Alive and Well

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An ExxonMobil-funded senator from Oklahoma, James Inhofe, cited a debunked ExxonMobil-funded study at a recent Senate hearing. C-SPAN

In a recent blog post, ExxonMobil executive Suzanne McCarron reiterated her company’s claim that it fully accepts the reality of climate change and that it wants to do something about it.

“I want to use this opportunity to be 100 percent clear about where we stand on climate change,” she wrote. “We believe the risk of climate change is real and we are committed to being part of the solution.”

So why is the company still a part of—in fact, a major part of—the problem?

An exchange between Oklahoma Sen. James Inhofe and Environmental Protection Agency (EPA) Administrator Scott Pruitt during a recent oversight hearing is a case in point, providing a window into how ExxonMobil’s undue influence continues to block climate action.

During the January 30 hearing, which was held by the Senate Environment and Public Works (EPW) Committee, Sen. Cory Booker inadvertently provoked Inhofe by raising the issue of environmental justice. The New Jersey Democrat cited the threat climate change-induced flooding poses to three dozen Superfund sites in his state and asked Pruitt if he was “taking into account the environmental burdens disproportionately impacting communities of color, indigenous communities and low-income communities.”

Inhofe seized the opportunity to contradict Booker, claiming that minority and low-income communities are disproportionately harmed by environmental protections, specifically citing the Obama administration’s Clean Power Plan, which would have dramatically reduced carbon emissions from coal-fired power plants if Pruitt hadn’t repealed it.

Booker, Inhofe said, was implying that Pruitt was trying to “punish” vulnerable Americans. “I wanted to just remind you,” Inhofe told the committee, “that we had a guy I remember so well, Harry Alford. He was the president of the National Black Chamber of Commerce. He provided some of the most powerful testimony that I have ever heard when it comes to the effects of the Clean Power Plan and some of the other regulations … on black and Hispanic poverty, including job losses and increased energy costs.

“[Alford] was very emphatic as to who was paying the price on these,” the Oklahoma Republican continued, “and I think sometimes that the previous administration forgot that there are already people out there who are paying all they can pay just to try to eat and keep their house warm.”

ExxonMobil’s Echo Chamber

Inhofe’s source for his assertion? A discredited, ExxonMobil-funded study by an Exxon-funded advocacy group that was based on discredited studies by other ExxonMobil-funded organizations.

Inhofe rested his argument on previous congressional testimony by Harry Alford, president of the National Black Chamber of Commerce (NBCC), a shoestring, mom-and-pop operation that is unapologetic about taking fossil fuel industry money. “Of course we do and it is only natural,” Alford wrote on NBCC’s website. “The legacy of Blacks in this nation has been tied to the miraculous history of fossil fuel…. [F]ossil fuels have been our economic friend.”

One of NBCC’s closest economic friends is ExxonMobil, which has donated more than $1.14 million to the group since 2001.

What did the company get for that money?

In 2015, NBCC commissioned a report that claimed the Clean Power Plan would “inflict severe and disproportionate economic burdens on poor families, especially minorities.”

In fact, unchecked climate change would more than likely hurt those communities most, and investments in energy efficiency under the plan would ultimately lower electricity bills across the country.

How did NBCC arrive at its upside-down assessment? The Union of Concerned Scientists took a close look at the report and found it was based on several flawed fossil fuel industry-friendly studies. Two of those bogus studies were produced by ExxonMobil grantees: the Heritage Foundation, which received $340,000 from ExxonMobil between 2007 and 2013, and the U.S. Chamber of Commerce, which received $3 million between 2014 and 2016.

The Chamber study, which came out just days before the EPA released a draft of the Clean Power Plan, was debunked not only by the EPA, but also by and The Washington Post. Among its many faults, the Chamber study—which was co-sponsored by the American Petroleum Institute—wildly inflated the cost of the plan and failed to consider the benefits of cutting carbon emissions.

ExxonMobil Spreads its Money Around

But there’s more than just the fact that ExxonMobil financed deliberately flawed studies to try to derail the Clean Power Plan. The company also is a major supporter of a number of Senate EPW Committee members, including Inhofe, who are adamant climate science deniers.

Inhofe has deep ties to the oil and gas industry, which has donated $1.85 million to his campaign war chest over his long career in Congress, more than twice than any other industry. Three oil and gas companies are among the senator’s top 10 corporate contributors: Koch Industries, Devon Energy and … ExxonMobil.

Six of the other 10 Republicans on the EPW Committee also are on ExxonMobil’s donation list, including Wyoming Sen. John Barrasso, the current committee chairman. Roughly half of the $119,500 ExxonMobil contributed to the seven senators over the last decade went to Barrasso and Inhofe, the committee’s previous chairman.

Then there’s ExxonMobil’s link to Pruitt, Oklahoma’s attorney general before President Trump tapped him to run the EPA. From 2012 through 2013, he chaired the Republican Attorneys General Association (RAGA) and afterward served on the organization’s executive committee. From 2014 through 2016, ExxonMobil gave RAGA $160,000 in three annual installments.

Just a few weeks after the company made its 2016 donation of $50,000, Pruitt and then-RAGA Chairman Luther Strange, at the time Alabama’s attorney general, co-authored a National Review column attacking a coalition of state attorneys general investigating ExxonMobil and other fossil fuel companies for misleading investors and the general public about climate change. Parroting ExxonMobil’s argument, Pruitt and Strange charged that the coalition was violating the company’s first amendment right to free speech.

“The debate” over climate change, they wrote “is far from settled. Scientists continue to disagree about the degree and extent of global warming and its connection to the actions of mankind. That debate should be encouraged — in classrooms, public forums, and the halls of Congress. It should not be silenced with threats of prosecution. Dissent is not a crime.”

Inhofe Upstaged

In this case, Inhofe’s counterfactual comment didn’t make it into the ensuing media coverage. Along with nearly everything else that was said during the two-and-a-half hour marathon, it was eclipsed by a bombshell dropped by Sen. Sheldon Whitehouse. The Rhode Island Democrat revealed that during a February 2016 radio interview, Pruitt said Trump would be “more abusive to the Constitution than Barack Obama, and that’s saying a lot.” Whitehouse read Pruitt’s remark aloud and asked him if he recalled making it.

“I don’t,” Pruitt responded, “and I don’t echo that today at all.”

“I guess not,” Whitehouse replied.

Not surprisingly, that embarrassing nugget was the story. There was no way that Inhofe’s rambling, ExxonMobil-sponsored falsehood could compete in the media with red meat like that. But overshadowed or not, Inhofe provided yet another incontrovertible piece of evidence that—despite ExxonMobil’s statements to the contrary—the company is still very much engaged behind the scenes in trying to stymie any government attempt to seriously address climate change.

Science Alert to EPA Chief Pruitt: Pollution Kills People

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An X-ray showing the affected lungs from acute exacerbation of chronic obstructive pulmonary disease, which can be triggered by air pollution. Photo: Wikimeda

President Trump’s chief of the Environmental Protection Agency (EPA), Scott Pruitt, has been hard at work undermining some of our nation’s most important public health safeguards in the guise of “reform.” His talking points omit the fact that these policies, guidelines, and programs have a strong record of protecting us from toxic chemicals and harmful air pollutants. And he’s leveraging the fact that many have obscure sounding names, hoping the public won’t notice that he’s stripping away safeguards at a time when the science on air pollution and health signals the need to strengthen protections for our families and communities.

Let’s dig into the details.

Less MACT means more HAPS

Breaking with more than 20 years of precedence in implementing the Clean Air Act, late last month the EPA reversed long-standing guidance that limits hazardous air pollutants (HAPS) such as the neurotoxins mercury and lead from major sources like power plants and large industrial facilities.

The agency’s new guidance means that major sources of HAPS may no longer be required to employ Maximum Achievable Control Technology (MACT), which reforms guidance that has been singularly successful in reducing toxic air pollution. Giving polluting facilities that have been employing available MACT technologies for years a way out of that requirement may line pockets of the polluting parties, but it is certainly not in the public interest. This is especially true for environmental justice and low-income communities and for people of color; they are already bearing a disproportionate burden of toxic pollution. Read more about all this here and here.

All eyes on IRIS

The EPA’s chemical risk assessment program—the Integrated Risk Information System (IRIS)—is the gold standard for chemical toxicity reviews at the federal, state, and local level, and even internationally. Because IRIS provides a scientific basis for regulating chemicals, it has been a target of criticism by the chemical industry, trade groups, and their friends in Congress and the White House.  IRIS is at serious risk. Read more here.

And then there’s TSCA

After years of effort and with the bipartisan support that now seems a distant memory, Congress passed legislation in 2016 to update and reform the Toxic Substances Control Act (TSCA). Enacted 42 years ago, TSCA is a fundamental safeguard meant to protect our nation’s children, families, and communities from the health effects of dangerous chemicals—health effects like cancer, birth defects, and reproductive disorders.

Two years ago, many public health and environmental leaders cheered this much-needed reform (read more here). But then the Trump administration gave the task of writing new rules to Dr. Nancy Beck, formerly director of regulatory science policy at the American Chemistry Council, the chemical industry’s leading lobbying group. Not surprisingly, under her leadership, the agency has rolled out rules that reflect industry-favored positions, despite objections from the EPA’s own scientists and staff, who warned that the new changes could seriously underestimate health risks and make it harder to track and thus regulate dangerous chemicals. Read how and why the agency shifted here.

Pollution control is good for the economy and public health

Contrary to what Mr. Pruitt and the Trump administration say, pollution control is healthy economically. Air quality improvements in high-income countries have not only reduced deaths from cardiovascular and respiratory disease, but have also yielded substantial economic gains. In the US, an estimated $30 in benefits (with a range of $4 – $88) has been returned to the economy for every dollar invested in air pollution control since 1970. Read more here and here.

What the science says—a global look

Given these and other threats to clean air and to the science-based protections that have been established to safeguard public health, it seemed like a good time to take a look at what the latest science says about pollution and health—both globally and here at home.

The Lancet Commission on Pollution and Health provides the most recent, overarching, and in-depth analysis of the health and economic impacts of pollution. Its report covers air pollution, water pollution, and soil pollution, as well as occupational pollutants and the emerging threats of developmental neurotoxicants, endocrine disrupters, and pesticides. Its focus is global, but the report includes some country-specific data and information. The report shows that no country is unaffected. And it also notes while that many effects of chemical pollutants are yet to be determined, much is already known.

Quoting directly from the report, here are some of the findings and key takeaways:

  • Pollution is the largest environmental cause of disease and premature death in the world today—responsible for an estimated 9 million premature deaths in 2015 alone. That’s three times more deaths than from AIDS, TB, and malaria combined and 15 times more than from all wars and other forms of violence.
  • Pollution disproportionately kills the poor and the vulnerable. In countries at every income level, disease caused by pollution is most prevalent among minorities and the marginalized.
  • Children are at high risk of pollution-related disease and even at extremely low-dose exposure to pollutants during windows of vulnerability in utero and in early infancy, which can result in disease, disability, and death in childhood and across their lifespan.
  • Pollution endangers planetary health, destroys ecosystems, and is intimately linked to global climate change. Fuel combustion—fossil fuel combustion in high-income and middle-income countries and burning biomass in low-income countries—accounts for 85 percent of airborne particulate pollution and for almost all pollution by oxides of sulphur and nitrogen. These pollutants cause some serious health effects, like asthma, shortness of breath, wheezing, and other respiratory problems.
  • More than 140,000 new chemicals and pesticides have been synthesized since 1950.The 5,000 produced in greatest volume have become widely dispersed in the environment and are responsible for nearly universal human exposure.
  • [There is] increasing movement of chemical production to low-income and middle-income counties where public health and environment protections are often scant.
What the science says—a US look

A recent nationwide study of seniors in the US sounds similar alarm bells. Researchers at the Harvard School of Public Health studied 60 million Americans—nearly 97 percent of people 65 years of age and older—and found that long-term exposure to fine airborne particulates (PM2.5) and ozone increases the risk of premature death. Even at levels below current EPA national ambient air quality standards (NAAQS). And that the “effect was most pronounced among self-identified racial minorities and people with low income.”

Francesca Dominici, principal investigator of the study, commented on the study’s unprecedented statistical power given the massive size of the study population, noting that the “findings suggested that lowering the NAAQS for fine particulate matter will produce important public health benefits, especially among self-identified racial minorities and people of low income.” These findings build on past work that has long showed the effect of long term exposure to particulates on mortality.

A second Harvard study examined short-term exposure to the same pollutants (PM2.5 and ozone) and also found a link to higher premature death among US elders—again with low income, female, and black elders at higher risk. The study found that “Day-to-day changes in fine particulate matter and ozone exposures were significantly associated with higher risk of all-cause mortality at levels below current air quality standards, suggesting that those standards may need to be reevaluated.”

Lead author Qian Di noted that “No matter where you live—in cities, in the suburbs, or in rural areas—as long as you breathe air pollution, you are at risk.” [Can’t resist a shout out to Qian Di, a doctoral student in environmental health—and to other early career scientists who are out there bringing their science to bear on critical matters of public policy, public health, environmental protection, and environmental justice.]

Study co-author Dr. Sara Grineski noted that “We’re only now realizing how toxins don’t just affect the lungs but influence things like emotional development, autism, ADHD, and mental health…” Photo: RuslanDashinsky/iStock

What the science says—a look at our kids

There is robust scientific evidence on the adverse impacts of air pollution on children’s health—from health impacts of fossil fuel combustion (nice summary of research here) to new research on children’s exposure to neurotoxins. Researchers at the University of Utah studied air pollution exposure in nearly 90,000 public schools across the US using EPA and census data. They found that ambient neurotoxins like lead, mercury, and cyanide compounds pose serious risks to children at our public schools.

Chicago, Pittsburgh, New York, Jersey City, and Camden were among the 10 worst polluted areas. They also found racial disparities, with students attending high risk schools nationwide significantly more likely to be Hispanic, black, or Asian/Pacific Islander.  In a lengthy  Guardian piece on the research, study co-author Dr. Sara Grineski noted that “We’re only now realizing how toxins don’t just affect the lungs but influence things like emotional development, autism, ADHD, and mental health…“ Socially marginalized populations are getting the worst exposure….“This could well be impacting an entire generation of our society.” Other recent studies and reports of air pollution impacts on children’s health can be found here , here, here, here .

EPA, please follow the science

This new research pretty much puts the kibosh on arguments that our nation’s air is clean enough and that it’s time to “reform” (read weaken) current policies, guidelines, and programs.

The science is clear—this is not the time to roll back efforts to control pollution, to squelch reviews and assessments of environmental chemicals, and to otherwise defund and de-staff critical public health protection programs at the agency. The EPA’s mission is to protect human health and the environment; this means putting the public interest first. In his goal to remake the EPA, we can’t let Mr. Pruitt sideline science and put our public health at risk.

Here at UCS we are doing our best to monitor and fight back against attacks on science and on the science-based policies that protect our public health and safety. Many partner organizations—from large national organizations to small grassroots groups and organizers fighting for environmental justice—are doing the same.

You can help by speaking out to elected officials in Congress, to your regional EPA office, and directly to Mr. Pruitt. He needs to understand that our public health is his priority, not easing industry’s path to higher profits. Join us as a science champion; we provide information and other resources to help you engage in this effort.

UCS is Surveying Federal Scientists Working Under the Trump Administration

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Beginning on Monday, February 12, UCS is administering another survey that will assess the status of scientific integrity across 16 federal science agencies. More than 63,000 government scientists will have the opportunity to anonymously share their perspectives on scientific integrity in the government.

UCS is partnering with Iowa State University’s Center for Survey Statistics and Methodology (CSSM) because of their deep expertise in the technical and operational aspects of sample surveys. CSSM has taken the technical steps needed to fully assure the anonymity of federal scientists who choose to take the survey on their personal time and equipment. Scientists will have the option of completing the survey online, on paper or by phone. The survey will close the morning of March 26, providing scientists with a large window of time to complete the survey.

The results will be used to get a quantitative measure of the status of scientific integrity across the government. Such a study is especially important now, as we live in a world of quick news cycles and anecdotal evidence. When it comes to science under the Trump administration, the public knows about individual cases that have made the news, but we have a less clear sense of the extent and pervasiveness of these problems. Are scientists being inhibited from conducting and communicating their work? How common are incidents of political interference? Are some agencies faring better than others? What can be done to better ensure scientists are able to carry out the missions of their science-based agencies? The survey will shed light on these critical questions.

Surveying scientists—a history

In 2015, under the Obama administration, UCS administered a survey that assessed the status of scientific integrity at federal agencies. In this survey, we asked the following open-ended question: How do you think the mission of your agency and the integrity of the scientific work produced by your agency could best be improved? The responses to this question run the gamut, from scientists stating that more transparency about scientific integrity policies at agencies is needed, to scientists saying that science needs to be less driven by politically motivated policies. Answers to questions like these provide crucial feedback on what’s happening at federal agencies, especially now, as concerns have been raised about the Trump administration’s treatment of science.

UCS has been conducting surveys to assess federal scientific integrity since 2005. The information provided through these surveys has been incredibly useful and in some cases has led federal agencies to update their policies to create a better work environment for federal scientists and allow science to inform government decisionmaking. For example, in 2011, the National Science Foundation developed a media policy in response to survey responses and policy analysis developed by the Union of Concerned Scientists. In 2013, the US Geological Survey improved its social media policy to better ensure scientifically accurate agency communications.

The Trump administration’s attacks on science and scientists make it more important than ever to conduct a survey now. Scientists have blown the whistle on the Trump administration for reassigning them to do tasks for which they do not have expertise. Right out of the gate, the Trump administration gagged federal agency scientists from speaking to the press. Additionally, scientists have been barred from attending professional meetings and presenting their work. It also has been reported that scientists may be being told or choosing not to use politically contentious language such as “climate change” or “evidence-based.”

These stories, and others, suggest that science in the federal government is currently being conducted in an environment that discourages the use of scientists’ knowledge in decision-making; yet little is known about the environment in which most federal scientists conduct their day-to-day work and how this affects their ability to meet the goals of their science-based agencies’ mission. Are these isolated examples of the worst-case scenarios? We don’t have a measure of the extent of the problems.

Giving scientists a voice

In a time when federal scientists and their work are likely under attack, surveys such as these are important to fully understand what kind of conditions America’s federal employees are working under. Federal scientists provide important knowledge that guides US science-based policies to be most effective to protect public health and safety. Thus, we need to ensure that these workers are taken care of and that science reaches the decisionmakers, journalists, and members of the public who need it. If we don’t, who will?

For further information about UCS and CSSM’s 2018 survey on scientific integrity, see UCS’s web page and a FAQ on this project at, or visit CSSM’s survey web page.

If you are a federal scientist who was not identified for participation in the survey but would like to share your thoughts and views with UCS, learn how to connect with us with the level of confidentiality and anonymity that is most appropriate to your situation here:

An Unseasonably “Hot” February for California’s Clean Energy Landscape

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By and large, major policy action for California’s electricity sector mimics the seasons: winter is a relatively quiet, reflective time and major policy developments start to bud in the spring. As the air heats up, so do policy debates in Sacramento, which ultimately bloom fully or die on the vine in September, when the Legislature wraps up its session.

But lately, the weather in California and electric sector policy developments seem unseasonably hot. For example, it’s currently 75 degrees outside my office in Oakland. And below are some of the things happening in the policy world that also seem particularly “hot”:

CPUC approves a 2030 clean energy blueprint.

Late last week, the California Public Utilities Commission (CPUC) approved a blueprint laying out the electricity sector investments through 2030 that will be necessary to reach greenhouse gas reduction goals consistent with the statewide requirement to reduce emissions 40% below 1990 levels by 2030.

This system-level blueprint is the first phase of what’s called the Integrated Resource Plan (IRP); the next step is for all investor-owned utilities (IOU) and community choice aggregators (CCA) to submit their individual plans, which are due in August. More information about the IRP and individual IOU and CCA progress can be found here. The publicly-owned utilities (POUs) in the state will submit their plans to the California Energy Commission (CEC) and progress can be tracked here.

UCS conducted analysis in the IRP proceeding to underscore a key blind spot in the CPUC’s own work: the fact that all of the gas generation capacity that exists today was assumed to still be around in 2030 to provide energy and grid services.

It’s well known that California has an excess of natural gas generation capacity on the grid, and it remains a significant source of global warming pollution in California. We built a lot of natural gas plants in the 90s and early 2000s, and we don’t need it all now. Our own analysis showed that a significant portion of the natural gas peaker generation capacity may not have much value to the grid in 2030. But, we also know that some gas will be important for reliability through 2030.

The question is, which plants stay and which plants go? The IRP decision underscores the need to understand the role of gas in California’s clean energy future, to make sure that the inevitable downsizing of the fleet does not jeopardize grid reliability, and benefits people that are most impacted by gas plant pollution, especially “fenceline” communities that bear the brunt of this pollution. UCS is planning some additional analysis on this issue, so stay tuned.

Big bills are being discussed in Sacramento.

Senate Bill (SB) 100, a bill that would set a bold and achievable target of getting 100% of California’s electricity from carbon-free resources by 2045 is still alive, and waiting to be taken up for a vote in the Assembly. Although there is a lot of public support for SB 100, the policy is getting hung up by potential amendments that deal with the treatment of distributed energy resources. UCS is trying to do what it can to break that logjam and in the meantime, communicate to the Assembly that we’d like to see SB 100 move forward without additional amendments.

Assembly Bill (AB) 813 is a bill that would make it possible for the California Independent System Operator (CAISO)—which operates the grid that serves about three quarters of California’s electricity needs—to expand and include other western states. Pivoting California’s energy market into one that’s west-wide is ambitious and complicated, but worth the effort. Expanding the pool of resources that a grid operator has to manage the system is one of the most cost-effective ways to incorporate more wind and solar generation onto the electricity system.

Energy storage and small-scale renewables are giving natural gas a run for its money.

In early January, the CPUC issued a resolution that authorizes PG&E to hold competitive solicitations for energy storage or “preferred resources” (e.g. demand response and distributed solar) to meet local reliability requirements that have previously been met with gas power plants. This decision, combined with the CEC’s recent decision to reject NRG’s request to build a natural gas peaker plant in the Oxnard, is evidence of what will hopefully become a very significant shift away from the assumption that gas plants are the best and most cost-effective way to provide grid reliability services in the future.

These are just three examples of major clean energy advancements that have unfolded in the last six months. And, many decisions are still developing about whether the state will pass SB 100 and nearer-term plans we’ll need in order to move towards a cleaner grid. Clearly, there is more work to do. But there’s no doubt in my mind that we are making meaningful progress on these “hot topics,” and UCS will be working to make sure California continues its clean energy momentum and climate leadership to “cool down” global warming.

Pruitt Squirming away from the Weight of Climate Evidence

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Photo: Gage Skidmore

Since taking office, EPA Administrator Scott Pruitt has shifted how he talks about climate change. You may have heard that he recently suggested that global warming might actually be a good thing. If the consequences of global warming weren’t so serious for Americans, his determination to take down one of the most studied scientific topics of our time would be silly in a Wile E. Coyote and the Road Runner kind of way. However, the shifts in his tactics may signal just how difficult it is to refute such an enormous body of evidence.

The beginning

Of course, we know more than enough about how our climate is changing and the degree to which humans are causing these changes for decision makers to take action. In fact, the U.S. government’s latest assessment of the state of our climate told us that human activity likely contributed to at least 92% of the change in Earth’s average temperature observed since 1951.

Out of step with the science, at his confirmation hearing, Administrator Pruitt remarked that, “The climate is changing and human activity impacts our changing climate in some manner. The ability to measure with precision the degree and extent of that impact, and what to do about it, are subject to continuing debate and dialogue.”

The middle

By mid-summer 2017, about six months into his tenure, Administrator Pruitt expanded on his question of the extent to which scientists can measure the effect of human activity on climate (answered above). This time, in an interview with Reuters, Administrator Pruitt shifted toward questioning the harm that climate change will cause: “It is not a question about whether the climate is warming. It is not a question about whether human activity contributes to it. It is a question about how much we contribute to it? How do we measure that with precision? And by the way, are we on an unsustainable path? And what harm… is it causing an existential threat?”

This is an interesting shift, because Administrator Pruitt seems to be trying to move the conversation away from whether humans are the primary cause of climate change (which again, science is very clear on), to a conversation about whether we are headed down a harmful path or not. Fortunately or unfortunately, the science is also very clear about this – we know that in the US, we are likely to see more frequent large wildfires in the West, category 4 and 5 hurricanes, coastal flooding, and intense heat waves in a warming world (among other impacts). All of these have real, harmful effects on people’s lives.

Where he is now

Administrator Pruitt continued his shift away from questioning whether or not humans are the primary cause of climate change, to whether or not climate change will harm Americans. Again, perhaps that is because the science on this is so difficult to refute.

Now, Administrator Pruitt is trying to shift conversations toward an idea that climate change may not be harmful, but beneficial, and is questioning what the ideal temperature of the Earth should be.

As we’ve already covered, global warming is projected to cause significant damage to American infrastructure, health, and wellbeing. We are already seeing these effects – we know, for example, that global warming increased the chances – and damaging impacts – of Hurricane Harvey.

And governments and scientists have already come together through the Paris Agreement to decide what the limit of warming should be to avoid dangerous climate change – between 1.5 and 2 degrees Celsius since pre-industrial times. Now, scientists are refining our understanding of the difference in how bad the impacts will be at these two levels, and what it will take to avoid the worst damages of climate change. Given the billion-dollar disasters associated with extreme weather, global emissions reductions have human health, economic, and societal benefits for the United States.

Why question climate science?

All of this begs the question – why is Administrator Pruitt (and others in this Administration) so adamant about refuting climate science findings? (While considering this, it is important to take into account his deep connections to the fossil fuel sector and how this shapes his perspective and priorities with respect to climate action.) The logic behind questioning the science seems two-fold for Administrator Pruitt:

  • Each time he questions the scientific consensus that climate is changing and humans are the primary cause, he contributes to confusion that helps stall significant action on climate change.
  • If he can find his Loch Ness Monster amidst the ocean of climate science (the Loch Ness Monster in this instance being fundamental errors in the science of climate change), Administrator Pruitt could open the door to taking down the EPA’s endangerment finding, which underpins the regulation of carbon dioxide as a pollutant under the Clean Air Act.

In the end, enacting policies that accept the scientific consensus on climate change might be a lose-lose for Administrator Pruitt’s agenda, but it would be a win-win for Americans.

Making the Leap from Coal to What Could Be: New Mexico’s Energy Future

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Photo: San Juan Citizens Alliance/EcoFlight

After decades and decades of commitment to coal, New Mexico is rapidly heading toward a future that’s coal free.

But a commitment to transition away from coal is just one part of the story; equally important is a commitment to where that transition will lead. What’s more, how this transition plays out—like who has access, and what happens to the communities and industries otherwise left behind—can have ramifications that last long into the future.

Now, legislators in the state are wrestling with one policy tool for transitioning to a truly clean and low-carbon future, and are considering several more that could help speed the journey along.

Legislation that asks not whether, but how

New Mexico’s lawmakers are in the midst of racing their way through this year’s 30-day legislative session, doing their best to deploy limited hours against a towering to-do list.

During these short sessions, which alternate years with regular 60-day sessions, lawmakers tend to prioritize budgetary issues above all else. But as a testament to the growing recognition of just how economically pivotal the state’s energy transition is, this year legislators are also devoting serious hours to SB 47/HB 80, or the Energy Redevelopment Bond Act.

Legislators have the opportunity to deploy policies that will help propel the state to a better, cleaner future.

This bill is a historic piece of legislation, and has the potential to catalyze the clean energy transition that New Mexico’s economy so desperately needs, and that New Mexicans so fully deserve. Achieving that potential, though, is key, and it turns on the central issue flagged above—a commitment away from something just isn’t enough; there must also be a commitment to what comes next.

At its core, SB 47/HB 80 is about enabling the state’s largest power provider—PNM—to issue securitized bonds to recover costs from the early retirement of San Juan Generating Station. Because the terms of such bonds result in much lower interest rates, customers can actually save money by paying PNM to, effectively, move on from coal.

But the bulk of the debate surrounding the bill is not about the proven securitization tool itself. Instead, it has to do with everything that could—and should—happen as a result.

Securitization presents an incredible opportunity to intentionally shape the state’s energy future, and squandering that opportunity (or worse, using it to point the state down a bad path) is too serious to let slide. That’s why stakeholders have been so deeply engaged in trying to make the initial proposal much stronger, including:

  • Securing meaningful support to ensure Farmington and San Juan County are provided a viable opportunity to diversify, develop, and ultimately transition their economy away from the dwindling coal sector.
  • Committing PNM to a future energy mix that would supply customers with 40 percent renewable energy by 2025 and 50 percent renewable energy by 2030—strong and critical waypoints that would keep the utility moving toward an ever-cleaner (and more cost-effective) energy future.
  • Requiring more market competition for the renewable energy resources that replace coal.
  • Ensuring that the Public Regulation Commission (PRC) has full authority to review PNM’s proposed closure costs.

Stakeholder negotiations to develop a consensus bill have improved the text from its original form, but it’s still not yet where it needs to be to warrant passage. A few central issues that demand prudent resolution include:

  • Making sure that a coal plant retired under this legislation cannot reopen again as a coal plant further down the road.
  • Limiting the amount of new resources PNM is guaranteed to own, as more market competition can drive down prices for ratepayers and create more development opportunities for the state’s growing clean energy industry.
  • Ensuring the PRC is sufficiently empowered to do its job as regulator, including by being able to adequately vet any securitization proposals that cross its desk.
  • Making sure the bill works for the communities it’s directly affecting by ensuring all stakeholders have a say.

The negotiating process for this bill has been a winding one, with stakeholders on both sides being brought together to try to come to a workable, consensus agreement. And in a sign that there’s still hope that a sufficiently improved bill will emerge this session, the legislation was tabled—not killed—in a vote by the Senate Conservation Committee last week. If designed well, the tool has incredible potential. We’re looking for legislation that ensures all that potential is met.

But transitions take a lot more than one bill, and a lot more than just bills

The remaking of New Mexico’s power sector cannot hope to be resolved in a single bill. There are many, many policies and regulations that can be brought to bear to best facilitate and accelerate New Mexico’s transition to a vibrant clean energy economy—one that’s open to participation and innovation from people all across the state.

Just this session alone there are multiple additional energy bills under consideration that could help pull the state forward, including:

  • A proposal to reinstate the solar tax credit: Especially in light of the Trump Administration’s recent enactment of solar import tariffs, the state can play a critical role in supporting its nascent-but-growing solar industry by making sure solar stays affordable—and available—for all New Mexicans as the costs of solar continue to fall.
  • A proposal to re-fund the Renewable Energy Transmission Authority (RETA): Cost-effectively shifting to a high-renewables future means taking advantage of all the state’s incredible renewable resource potential, which will require the buildout of new transmission lines to ensure the best opportunities can be brought to market. Refunding RETA would allow for the development of a strategic and centralized transmission planning approach.

And then, of course, there are all the many and varied ways that progress is being facilitated outside the legislature, from local community commitments to go green, all the way up to the PRC investigating the feasibility of PNM joining a broader energy market and considering the development of a Clean Energy Standard, and so much else in between.

New Mexico’s transition away from coal should lead directly to a clean energy future—the least-cost, healthiest, and most economically favorable future for the state. This transition must be open to all, and supportive of those who could otherwise get left behind.

State legislators have the chance now to make a leap toward this vibrant clean energy future—they should do everything they can to make the best of it.

Mr.TinDC/Creative Commons (Flickr)

Top Clean Cars and Trucks of 2018

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Some of the cleanest cars you can buy today are powered by electricity, though the emissions of an electric vehicle (EV) varies depending on where it is plugged in. Even though parts of the U.S. still partially rely on coal fired power, the average EV sold in the U.S. produces the emissions equivalent of a gas vehicle that gets 73 MPG, and over 70 percent of Americans live in an area where driving an EV results in fewer emissions than a 50 MPG gas-powered vehicle. Check out how electric vehicles (EVs) fare in your neck of the woods with this interactive tool that will calculate an EV’s emissions via zip code.

Looking for the most fuel-efficient SUV or pickup truck? Read on as I’ll detail the most fuel efficient vehicles in each of these classes below.

1. Toyota Prius Prime (Plug-in Hybrid Electric Vehicle) – 133 MPGe running on electricity + 54 MPG running on gas

Image via Toyota

This isn’t necessarily the most exciting vehicle on the planet, but the 2018 Toyota Prius Prime offers serious fuel economy and a modest electric range at a reasonable price (from $27,100 before any federal or state credits or rebates). The 2018 Prime is equipped with both a fuel-sipping 1.8 liter four-cylinder engine and an electric motor that runs off an 8.8 kWh battery pack that can be recharged in just 5 hours from any regular outlet, or around 2 hours from a 220V outlet (the type of outlet used by home appliances like a washer/dryer. For more info on different types of EV charging, head here). But even when out of juice, the Prime will still achieve a city/highway combined 54 mpg when running off gasoline alone. Overall, EPA gave the 2017 Prime an estimated fuel economy rating of 133 MPGe making it one of the most fuel-efficient vehicles that still uses gasoline today.


2. Nissan Leaf (Battery Electric Vehicle) – 112 MPGe

Image via Nissan

If you’re ready to ditch gasoline for good, you may want to check out the 2018 Nissan Leaf. The all-new Leaf not only got a style upgrade, but it also got a 40-kWh battery that provides an EPA-estimated 151 miles of all-electric range and a fuel economy rating of 112 MPGe. This is a big improvement from the original Leaf’s 84-mile range, and enough of a range boost that will make the Leaf work for even more people’s driving needs. Charging at home or on-the-go should be easy for Leaf owners as well. The Leaf can be fully charged in as little as 40 minutes with DC fast fast charging, or charged in around 8 hours via level 2 (220V) charging. Starting at $29,900, the Tennessee-built Leaf is cheaper than many of its all-electric competitors, though has slightly less range than the Chevy Bolt (238 miles) or Tesla Model 3 (220 miles).


3. Honda Clarity PHEV (Plug-In Hybrid Electric Vehicle) – 110 MPGe running on electricity + 42 MPG running on gas

Image via Honda

Like the Prius Prime, the 2018 Honda Clarity Plug-In Hybrid (PHEV) includes both a gasoline engine and an electric motor powered by a 17 kWh battery pack, which is good for an EPA-estimated 48 miles of all-electric range. When the electric range is exhausted, the Clarity PHEV relies on an efficient 1.5 liter 4-cylinder engine that produces a 42 mpg, which is very good for a big sedan. The Clarity PHEV base price is $33,400, but don’t forget about the $7,500 federal tax credit, which can knock the sticker price down to $25,900. Overall, the Clarity PHEV offers the best pure electric range of any plug-in hybrid sedan and should be able to compete with other PHEVs like the Toyota Prius Prime, Hyundai Ioniq PHEV, and Chevy Volt.


4. Chevy Bolt (Battery Electric Vehicle) – 119 MPGe

Image via Chevy

The Bolt was MotorTrend’s Car of the Year in 2017, will go 0-60 in just 6.5 seconds, and has an estimated all-electric range of 238 miles. The 2018 Bolt EV remains largely the same, and starts at $37,495. Of course, this price can be lowered by qualifying for the $7,500 federal tax credit and any other state EV credits or rebates. Interested in what EV incentives apply in your neck of the woods? Head over here for a handy guide. The Bolt’s battery pack can gain 90 miles of charge in just 30 minutes from DC fast charging and a full charge from empty will take about 9 hours via level 2, 220V charging. The Bolt charge time shouldn’t be a deal breaker considering the vast majority of EV charging is done at home – and mostly overnight. It’s also important to note that EV drivers typically don’t need a full charge every time they plug-in. If you drive 50 miles in a day, for example, then you only need to replace that 50 miles of lost range, which can happen in a matter of minutes from a DC fast charger or hours from a level 2 charger.


5. Tesla Model 3 (Battery Electric Vehicle) – 130 MPGe

Image via Tesla

There’s not too much to say about the Model 3 that hasn’t already been said. The Model 3 remains one of the most exciting clean vehicles on the market. Just how clean depends on where you plug-in, but UCS analysis has found that for over 70 percent of Americans, driving the average EV results in fewer emissions than a 50 MPG gasoline vehicle. The Model 3 comes with either 50 kWh or 75 kWh battery pack that gives the sedan a range of 220 miles or 310 miles, respectively, and can be fully charged in around 12 hours from level 2 (220V) charging or up to a 50 percent charge in 20 minutes via Tesla’s network of supercharger charging stations. Of course, Tesla has had some trouble meeting the 400,000 Model 3 pre-orders, but they are still taking reservations if you want to get in line and wait an estimated 12-18 months for one of the most hyped electric vehicles of all-time.


6. Hyundai Ioniq PHEV – 119 MPGe running on electricity + 52 MPG running on gas

Image via Hyundai

The Ioniq is Hyundai’s first foray into the electric vehicle market and offers a great alternative to the Toyota Prius Prime at a comparable price – the 2018 Ioniq PHEV starts at $25,835 and the Prime starts at $27,100. The Ioniq also marks the first-time American car buyers will be able to choose between a conventional hybrid, a plug-in electric hybrid, or a battery electric version of the same model. Giving consumers a family of clean options in the same vehicle is a clever move by Hyundai, and one that other automakers may seek to duplicate in their efforts to make electric drive more mainstream.

The 2018 plug-in hybrid version of the Ioniq includes an 8.9 kwh rechargeable battery pack that provides more than 25 miles of all-electric range and can be fully charged in two hours and 18 minutes from a Level 2 charger. Given its inoffensive styling and techno-inclusions like Apple CarPlay, Android Auto, and wireless smartphone charging, the Ioniq may challenge the Prius for hybrid sedan market share—a welcome sight for clean car enthusiasts everywhere. Also, the gas-only version of the Ioniq gets a best-in-class 58 combined MPG!


7. Ford F-150 Diesel – 30 MPG (estimated)

Image via Ford

Truck sales continue to outpace passenger vehicle sales. Ford, for example, sold more than 820,000 F-series trucks in 2016, which is more than double the sales of the Toyota Camry, the top-selling passenger car. So it’s critical that manufacturers improve the fuel economy of pick-ups to meet both the consumer demand for more fuel efficient vehicles and the demands of the federal fuel economy standards. So, it’s exciting to see the first F-150 with a diesel engine and 10-speed transmission heading to showrooms this spring, because it is expected to be the first full-size pickup to crack the 30 MPG barrier. This MPG doesn’t come at the expense of towing power either. The 2018 F-150 is expected to deliver a maximum tow rating of 11,400 pounds, which beats its closest rival, the Ram 1500 Ecodiesel, by over a ton and puts it in the upper echelon of all light duty pickups. In addition to the diesel, Ford recently announced plans for an F-150 hybrid, set to hit the market in 2020.


8. Lexus RX 450h – 30 MPG

Image via Lexus

Just because you may need an SUV doesn’t mean that you necessarily need to sacrifice fuel economy. The 2018 Lexus RX 450h gets a respectable 30 combined MPG and offers a 3 row configuration that can fit 7 or 8 passengers and a decent amount of cargo space. The standard all-wheel drive on this hybrid model is powered by a 308 horsepower V6 motor, and comes with the luxury amenities Lexus is known for. While not exactly a bargain, this model can transport a whole lot of people and stuff while achieving the same fuel economy as the similar sized Land Rover Discovery (22 MPG) or BMW x5 (16 MPG).  If this model is out of your price range, you may want to check out the Toyota Highlander I highlighted in this post.

NRC’s Project Aim: Off-target?

UCS Blog - All Things Nuclear (text only) -

A handful of years ago, there was talk about nearly three dozen new reactors being ordered and built in the United States. During oversight hearings, Members of Congress queried the Members of the Nuclear Regulatory Commission on efforts underway and planned to ensure the agency would be ready to handle this anticipated flood of new reactor applications without impeding progress. Those efforts included creating the Office of New Reactors and hiring new staffers to review the applications and inspect the reactors under construction.

Receding Tide

The anticipated three dozen applications for new reactors morphed into four actual applications, two of which have since been cancelled. The tsunami of new reactor applications turned out to be a little ripple, at best.

The tide also turned for the existing fleet of reactors. Unfavorable economics led to the closures of several reactors and the announced closures of several other reactors in the near future.

The majority of the NRC’s annual budget is funded through fees collected from its licensees. For example, in fiscal year 2017 the owner of an operating reactor paid $4,308,000 for the NRC’s basic oversight efforts. For extra NRC attention (such as supplemental inspections when reactor performance dropped below par and for reviews of license renewal applications), the NRC charged $263 per hour.

Still, the lack of upsizing from new reactors and abundance of downsizing from existing reactors meant that NRC would have fewer licensees from whom to collect funds.

Enter Project Aim

The NRC launched Project AIM in June 2014 with the intention of “right-sizing” the agency while retaining the skill sets necessary to perform its vital mission. Project Aim identified 150 items that could be eliminated or performed more cost-effectively. Collectively, these measures were estimated to save over $40 million.

Fig. 1 (Source: Nuclear Regulatory Commission)

Project Aim Targets

Item 59 was among the highest cost-saving measures identified by Project Aim. It terminated research activities on risk assessments of fire hazards for an estimated savings of $935,000. The NRC adopted risk-informed fire protection regulations in 2004 to complement the fire protection regulations adopted by the NRC in 1980 in response to the disastrous fire at the Browns Ferry Nuclear Plant in Alabama. The fire research supported risk assessment improvements to better manage the fire hazards—or would have done so had it not been stopped.

Item 61 was also a high dollar cost-saving measure. It eliminated the development of new methods, models and tools needed to incorporate digital instrumentation and control (I&C) systems into probabilistic risk assessments (PRAs) with an estimated savings of $735,000. Nuclear power reactors were originally equipped with analog I&C systems (which significantly lessened the impact of the Y2K rollover problem). As analog I&C systems become more obsolete, plant owners are replacing them with new-fangled digital I&C systems. Digital I&C systems fail in different ways and at different rates than analog I&C systems and the research was intended to enable the PRAs to better model the emerging reality.

Item 62 eliminated development of methods, models, tools, and data needed to evaluate the transport of radioactive materials released during severe accidents into aquatic environments. For example, the 2011 severe accident at Fukushima involved radioactive releases to the Pacific Ocean via means not clearly understood. This cost-saving measure seems to preserve that secret.

Fig. 2 (Source: Nuclear Regulatory Commission)

Project Aim Off Target?

The need to reduce costs is genuine. Where oh where could savings of $935,000 come if not from killing the fire research efforts? Perhaps the Office of Management and Budget (OMB) has the answer. On May 11, 2012, OMB issued Memorandum M-12-12 that capped the amount federal agencies spent on conferences at $500,000. This OMB action pre-dated Project Aim, but seems consistent with the project’s fiscal responsibility objectives.

But the NRC opts not to abide by the OMB directive. Instead, the NRC Chairman signs a waiver allowing the NRC to spend far more than the OMB limit on its annual Regulatory Information Conferences (RICs). How much does the RIC cost? In 2017, the RIC cost the NRC $932,315.39—nearly double the OMB limit and almost exactly equal to the amount fire research would have cost.

987 persons outside the NRC attended the RIC in 2017. So, the NRC spent roughly $944.60 per outsider at the RIC last year. But don’t fixate on that amount. Whether the NRC had spent $1,000,000 per person or $1 per person, the RIC did not make a single American safer or more secure. (It also did not make married Americans safer or more secure, either.)

Eliminating the RIC would save the NRC nearly a million dollars each year. That savings could fund the fire research this year, which really does make single and married Americans safer. And next year savings could fund the development of digital I&C risk assessment methods to better manage the deployment of these systems throughout the nuclear fleet. And the savings the following year could fund research into transport of radioactive materials during severe accidents.

Fig. 3 (Source: Nuclear Regulatory Commission)

If the cliché “knowledge is power” holds any weight, then stopping fire research, development of digital I&C risk assessment methods, and many other activities leaves the NRC powerless to properly manage the associated risks.

RIC and risk? Nope, non-RIC and lower risk.


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