Combined UCS Blogs

Bipartisan Outrage as EPA, White House Try to Cover Up Chemical Health Assessment

UCS Blog - The Equation (text only) -

Photo: US Air Force/Senior Airman Julianne Showalter

Citing a potential “public relations nightmare,” the Trump administration successfully stopped the publication of a study measuring the health effects of a group of hazardous chemicals found in drinking water and household products throughout the United States. Many of the contaminated sites are on military bases across the country and affect military families directly. Multiple Republicans and Democrats have expressed concern about the censorship and have called for the report to be released, and Trump administration officials are scrambling to contain the political fallout. 

The two email chains (here and here) show the exchanges among White House, Environmental Protection Agency (EPA), and Department of Defense (DoD) attempting to strong-arm the Agency for Toxic Substances and Disease Registry (ATSDR) into censoring the report. The emails were released to UCS by the EPA as part of a larger request under the Freedom of Information Act for documents related to an attempt to restrict the types of science that are used in EPA public health protection decisions (the EPA subsequently tried to bury the documents).

The White House tried to cover up a study related to the health impacts of PFAS, a group of chemicals that are often present at dangerous levels around military bases. Firefighting foam used by the military contains PFAS chemicals. Photo: United States National Guard

Politico broke the story on Monday:

Scott Pruitt’s EPA and the White House sought to block publication of a federal health study on a nationwide water-contamination crisis, after one Trump administration aide warned it would cause a “public relations nightmare,” newly disclosed emails reveal.

The intervention early this year — not previously disclosed — came as HHS’ Agency for Toxic Substances and Disease Registry was preparing to publish its assessment of a class of toxic chemicals that has contaminated water supplies near military bases, chemical plants and other sites from New York to Michigan to West Virginia.

The study would show that the chemicals endanger human health at a far lower level than EPA has previously called safe, according to the emails.

Nancy Beck, one of the EPA political appointees with ties to the chemical industry involved in the effort to prevent the study from being released, knows very well how one agency can put pressure on another. She helped the Department of Defense slow down EPA efforts to protect drinking water from perchlorate, an ingredient in rocket fuel, when she worked in the White House under President George W. Bush.

Both Republicans and Democrats have expressed concern about the cover-up and demanded the ATSDR report be released, including Senator Maggie Hassan (D-NH),  Representative Mike Turner (R-OH), Representative Bryan Fitzpatrick (R-PA), and several Democratic senators including Senate Minority Leader Chuck Schumer (D-NY).

West Virginia Republican Shelley Moore Capito questioned embattled EPA Administrator Scott Pruitt in a Senate hearing today about the EPA’s actions. Administrator Pruitt refused to take responsibility for slowing down the release of the study, but acknowledged that it is important for this kind of health information to be public. West Virginia has had specific problems with PFAS contamination.

This kind of congressional oversight of the administration is crucial as part of our system of government, the checks and balances the founding fathers talked about.  Executive branch actions have direct consequences for public health and the environment. We desperately need more congressional scrutiny of the ways in which science is being suppressed and sidelined in executive branch agencies.

And at least in this case, the pressure is working. According to Inside EPA (paywalled), ATSDR has subsequently begun preparations for releasing the report. Below are more details about this developing story.

A Michigan Department of Environmental Quality employee visits a home to test well water for chemical contaminants. Photo: Michigan DEQ

What are these chemicals?

“PFAS” stands for “per- and polyfluoroalkyl substances.” “PFOS” and “PFOA,” the two most studied PFAS, stand for “perfluorooctane sulfanate” and “perfluorooctanoic acid,” respectively. PFAS are a group of man-made chemicals found in many consumer products (such as non-stick cookware and water-repellent clothing) as well as in firefighting foam used by the military. Studies on PFOA and PFOS have indicated links to cancer, thyroid disease, and immunological effects. Here’s the EPA’s current FAQ on PFAS.

What are more specific health effects?

According to ASTDR, studies have shown certain PFAS may impact fertility; increase cholesterol; elevate cancer risk; interfere with the body’s natural hormones; and negatively affect growth, learning, and behavior of infants and older children.

What is the current EPA guidance on the issue?

In May 2016, EPA established drinking water health advisories of 70 parts per trillion for the combined concentrations of PFOS and PFOA. This number is important because in “PFAS CDC Study 2,” an employee of the White House Office of Management and Budget was worried about the fact that ATSDR’s numbers for minimal risk for some populations went as low as 12 ppt. For more, see EPA’s factsheet on PFAS.

What’s the DoD connection?

The Department of Defense emerges in many PFAS water source contamination stories because DoD’s firefighting foam contains PFOS and PFOA. The Politico story notes that in a March report to Congress, the Defense Department listed 126 facilities where test of nearby water supplies showed the substances exceeded the current safety guidelines. These facilities have caused congressional concern and the Government Accountability Office has studied the issue.

How has the EPA approached PFAS?

Administrator Pruitt has publicly said that he wants to make controlling PFAS a priority and has planned a leadership summit on the issue next week. The summit was planned after the Senate refused to confirm Michael Dourson, President Trump’s nominee to lead EPA’s chemical safety division. North Carolina’s two Republican senators refused to support him for PFAS-related reasons; Dourson’s previous work for the chemical industry recommended dramatically higher “safe” levels of the chemicals than the EPA had found (more here and here).

Mick Mulvaney leads the White House Office of Management and Budget (OMB). OMB has a history of interfering in or slowing down federal agency scientific assessments.

What do the two emails show?

In mid-January, an email chain with EPA political and career employees discussed a call between EPA and the Agency for Toxic Substances and Disease Registry (ATSDR) about PFAS. Both the political and career employees noted that EPA and ATSDR did not entirely agree on the science.

In a January 30 internal email chain, an unnamed White House political appointee flagged for an EPA political appointee that ATSDR’s draft Toxicological Profile for four PFAS (PFOS, PFOA, PFHX, and PFNA) had very low Minimal Risk Level numbers. The OMB employee noted that ATSDR’s release of its draft would have a “huge” response, that the impact to EPA and the Department of Defense would be “extremely painful,” and that releasing the draft would be a “potential public relations nightmare.”

The OMB message was forwarded to three EPA political appointees: chief of staff Ryan Jackson, Assistant Administrator for the Office of Research and Development Richard Yamada; and Nancy Beck. Jackson noted that the ATSDR estimate is 10 times lower than the EPA’s numbers; Beck recommended OMB interagency review; Yamada noted that ORD was going to DoD to discuss. More than three months later, ATSDR still has not released its draft Toxicological Profile, and the agency initially said there are no plans to release it.

How should legitimate scientific disagreements between EPA and ATSDR scientists be handled?

Scientists may or may not agree with the ATSDR analysis. But there’s no way to critique a peer-reviewed study that isn’t public. Further, any legitimate disagreements should be handled among scientists, not negotiated among political appointees.

The White House Office of Management and Budget (OMB) has a role to play in ensuring that agencies talk to one another. But it has also been used to try to alter science for political reasons. UCS has recommended that peer-reviewed scientific documents be shared publicly when sent to OMB for interagency review. The PFAS case is evidence for why this kind of policy is sorely needed.


Building the Right Project: An Engineer’s Perspective on Infrastructure Adaptation to Extreme Weather Events

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The view from aerial tour of Hurricane Sandy damage of New Jersey's barrier beaches, Nov. 18, 2012. (Official White House Photo by Sonya N. Hebert)

Infrastructure Week 2018 is upon us, and it’s important that we highlight the state of our nation’s infrastructure and why it’s critical to our economy, society, security, and future. So what is the status of our infrastructure?

The National Infrastructure Report Card is issued by the American Society of Civil Engineers (ASCE) every four years. The Report Card offers a comprehensive assessment of our nation’s 16 major infrastructure categories providing information on their conditions and needs, assigning grades and making recommendations to raise those grades. While first issued in 1998, not much has improved. ASCE has yet to give a grade out of the “D” range; in 2017, America’s infrastructure earned a “D+”.

The work to change the depressing state of our infrastructure is daunting, but I try to be calm and take in my unique privilege as a professional engineer to be involved in the many facets of infrastructure and how we need to better plan, design, build, operate, and maintain these critical projects and systems. As an environmental engineer that also has science and policy backgrounds, I am involved in all facets of the infrastructure lifecycle: planning, design, construction, operations, and financing. I also work in the third largest transit agency in the United States and am responsible for the environmental, sustainability, and resiliency efforts associated with the agency’s infrastructure.

Climate change presents engineering challenges

Let’s face it, our infrastructure is crumbling and significant investments are needed to improve our grade. Regardless of your politics, we see evidence of exacerbation of these impacts through the effects of increasing frequency and intensity of extreme weather events: increasing ambient temperature, higher frequency of high heat days, more extreme flooding and inundation, more intense storms, and greater length of droughts and heat waves. These conditions are now more common; and forget about the impacts across the world, you need not look beyond your neighborhood. While infrastructure is traditionally designed to hold up to rare but expected extreme weather events, these events are no longer rare, and their durations and intensities are now well beyond normal expectations.

As an engineer, I am faced with a new set of design challenges that force me to rethink how infrastructure should be planned, designed, constructed, operated and maintained for conditions that are substantially changing in unpredictable ways. As a scientist, I am struggling to define what information I should use to ensure the infrastructure we build remains useful throughout its expected life, and keeps people safe while enhancing their quality of life. And as a person and global citizen – of Filipino ancestry and having visited many parts of the world – I am humbled and amazed seeing how those who have the least are able to survive the harshest of environments and economic conditions. We need not go far, as many of us who live in the poorest of our American neighborhoods have come to adapt to similar conditions, and chose to survive after hurricanes, wildfires, floods, and droughts. Many of us involved in this conversation about infrastructure have differing life experiences and perceptions.

A multi-disciplinary approach to infrastructure planning

The facts about our deteriorating infrastructure and a future with more weather extremes should make us think very hard about how we as a society will continue to maintain our livelihoods and well-being. A unifying philosophy that brings us all to the table should be the realization that maintenance of the built infrastructure has primarily been a neglected element of society; consequently the cost of less (or even no) action has never been so great and the urgent need to address the compounded issue is now! We should look more closely into how resilient communities do it and learn from them. To design for a resilient future that can handle more extremes, we must upend some engineering paradigms and approach solutions in inclusive, collaborative, multi-disciplinary, and multi-sectoral ways.

As the executive who oversees the implementation of environmental compliance and sustainability at a major public transportation agency, I am immersed in a transportation revolution here in Los Angeles. This revolution goes beyond pure transportation projects, but involves all the things that the transportation system touches or connects. And infrastructure, transportation in particular, touches everything – energy, water, mobility, housing – and is affected by all types of extreme events – heat, droughts, floods, wildfires, and sea level rise.  Because engineers can also be systems thinkers, I get pulled into a variety of situations where not only environmental issues need to be resolved, but other topics are common fare: policy deliberations, energy resiliency, climate change impacts, alternative financing, social equity, fresh food access, electrification, and of course engineering and science, among others. This multi-faceted approach, which also requires people skills, understanding of human behavior and finding common ground, is fundamental to advancing infrastructure solutions that will function under a future with more extremes.

Promising Developments to Integrate Climate Science into Infrastructure Standards

The Climate-Safe Infrastructure Working Group, under the California Department of Natural Resources, is a pioneering effort to foster this needed cross-discipline dialogue by bringing together climate scientists, engineers, architects, and other professionals to discuss how to incorporate climate change impacts into infrastructure. I was appointed as a member of this Working Group, and with my fellow members have been deliberating how to integrate scientific data concerning projected climate change impacts into state infrastructure engineering and develop and make specific recommendations to the California Legislature and the Strategic Growth Council later in 2018.

Our Working Group’s task gets to the core of making a major overhaul in the way infrastructure projects are planned, designed, constructed, and operated. We are grappling with questions on risk and liability, governance, equity, means and methods of construction, and most importantly identification of the gaps from translating science into practice are debated and discussed. How does this information get incorporated into the standards and practices of civil engineering and architecture? How can the workforce, who have been trained to plan, design, build, operate and maintain infrastructure in a certain way, strategically transition to incorporate modifications that account for new and changing environmental conditions, as well as integrate natural infrastructure solutions? How can financial instruments be used to minimize infrastructure risk to public health, safety, and well-being? The experience has reminded me of the community meetings I often lead or attend: seeking input, debating on the solutions, and in the end, gaining consensus on what is best to make infrastructure serve all stakeholders while simultaneously promoting social cohesion and economic development. I anticipate this to be the flavor of our final report.

The disconnect between disciplines and a lack of an integrated approach across jurisdictions is recognized as a problem by many in the engineering and infrastructure fields. Agencies like mine, the Los Angeles County Metropolitan Transportation Authority (LA Metro), have navigated through this dilemma by incorporating into our design criteria and specification the requirements to build climate-safe infrastructure based on information we know now.

In addition, the American Society of Civil Engineers has been advancing new approaches to integrate climate science into infrastructure. Under Canon 1 of ASCE’s Code of Ethics, engineers have the obligation to hold “safety, health, and welfare paramount and shall strive to comply with the principles of sustainable development in the performance of their professional duties”. ASCE Policy Statements 360 and 418, about climate impacts and the role of civil engineers in sustainability, are key drivers to the execution of this obligation. ASCE’s National Committee on Sustainability (COS) is working on the continued development of a Sustainable Infrastructure Standard as well as an ASCE Policy for infrastructure owners to recognize the value and importance of building sustainable infrastructure. The COS is working hand in hand with the ASCE Committee on Adaptation to a Changing Climate in ensuring infrastructure resiliency and sustainable infrastructure principles and frameworks align with one another.

Investors are listening as well. Here at LA Metro, we are using the revenues generated from the sale of our low carbon fuel standards carbon credits to exclusively invest in carbon emissions reducing strategies, energy conservation and resiliency, renewable energy, and similar projects. We tendered about $500 million in Climate Bond certified Green Bonds in October 2017 for others to invest in our transportation related projects. My invitation to participate in two important symposia on how to finance and make the business case for sustainable infrastructure here in California  in February 2018 and Massachusetts in March 2018 creates a significant degree of personal excitement and inspiration to do more with the financial community to advance climate resilience.

Advancing a new engineering paradigm

There is no other time to do more than now.

Whether we like it or not, infrastructure plays a major role in ensuring that we as a species survive the increasing negative impacts of extreme weather events. But the cost of ignoring infrastructure investments is mounting. More importantly, we need to reassess how we continually value the benefits of a well maintained infrastructure. We need to build the right project as much as we need to build the project right. While I see advances on many fronts, we need more engineers and our partners to step up and take a leadership role in advancing this new paradigm.

Finally, many of these discussions have concentrated on the consideration of the most vulnerable populations or those who are “not in the room” with the professionals. This is not about working to relieve these communities of their burdens but instead all about how we learn from them. With all the tools we have at our disposal, we need to re-think and reassess such tools in the context of how the most vulnerable of communities survive significant stressors. Let’s step-up our active engagement with them for that very reason.


Dr. Cris B. Liban, P.E., ENV SP is a professional engineer and a Fellow of the American Society of Civil Engineers, with a focus on environment and transportation. He has chaired or participated in multiple research panels through his involvement with the National Academies of Sciences’ Transportation Research Board, translating research into policy through his work as an environmental executive and political appointee in federal, state, county, and city governments, currently as the Executive Officer, Environmental Compliance and Sustainability at the Los Angeles County Metropolitan Transportation Authority. He is also the Chair of the National Committee on Sustainability of the American Society of Civil Engineers. More on Dr. Liban’s work here.

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.

Among President Trump’s Dismal Judicial Nominees, Wendy Vitter Stands Out for Promoting Unscientific Myths

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Wendy Vitter has been nominated by President Trump for a lifetime appointment to the U.S. District Court in Louisiana, and is expected to receive a vote in a Senate committee tomorrow. Vitter has a track record of promoting anti-science myths which call into question her capacity to impartially evaluate evidence and expert testimony as a future judge. Senators should think long and hard if they want someone with this kind of judgement on the bench.

Vitter is on record perpetuating the myth that abortion causes breast cancer. When speaking on a panel called Abortion Hurts Women’s Health, Vitter claimed that there is a “connection between cancer and post-abortive women.” The American Cancer Society has rigorously assessed this claim and dismissed it as false. So have the World Health Organization and numerous other medical associations.

Wendy Vitter answers questions at her April 2018 confirmation hearing. Vitter, who received the lowest “qualified” rating from the American Bar Association, is President Trump’s nominee for a lifetime judicial appointment.

At the panel, Vitter publicly urged people to pressure medical providers to distribute a brochure titled “The Pill Kills.” One of the most pernicious and unscientific myths included is the statement that hormonal birth control causes “spontaneous abortions” (the pill actually prevents eggs from ever being fertilized in the first place). The same literature claims that birth control causes miscarriages, makes women “more likely to develop lethal infections” and “die a violent death.” Through these false claims, Vitter confuses people about the science of birth control and makes it harder for them to access much-needed health services.

How could it be that such a nominee would not be laughed out of the Senate chamber? Well, let’s not forget that it’s considerably easier now to pack the courts with unqualified nominees since the elimination of the filibuster for judicial nominees. Further, the Trump administration does not have a great track record of vetting judicial nominees, and the Senate’s willingness to set aside unqualified nominees has been non-existent: not a single Republican senator has voted against a single nominee.

This allowed President Trump to appoint four times as many judges in his first year as President Obama did in his. The American Bar Association gave Vitter’s nomination its lowest qualified rating.

Multiple scientific and public interest organizations urged the Senate to vote against Vitter’s nomination:

Governmental policy and decision-making should be informed by scientific evidence and the best available data. When hearing cases involving governmental policies or actions, judges must be able to evaluate evidence about harms and benefits in an independent and careful manner by evaluating the weight of the evidence. Failing to consider relevant, compelling evidence and placing inappropriate weight on poorly supported assertions should disqualify nominees from judicial appointments…

To merit confirmation, judges must exhibit an ability to appropriately weigh and contextualize scientific evidence when matters involving science are before them. Vitter’s misrepresentations of scientific evidence call into question her ability to do so appropriately. 

Judges need to be able to evaluate expert testimony and scientific evidence in an impartial way. How can we trust Vitter to appropriately evaluate evidence and expertise in a courtroom when she refuses to disavow the distribution of materials that distort the science on women’s health?

California Could Pass Innovative Legislation on Key Climate, Energy and Transportation Issues

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California State Capitol

California has a well-earned reputation as a world leader in promoting clean energy and other solutions to climate change. However, as anyone paying attention to the climate crisis knows, we have far more work to do. Fortunately, the California Legislature is considering many bills in 2018 that would further address climate change. With three and half months until the Legislature adjourns for the year, UCS is working with lawmakers to make progress on a suite of policy prescriptions to promote renewable energy, clean transportation, and better preparedness for climate change impacts.

Create a clean electricity system

California has made great progress adding renewable energy to the grid. To meet our climate goals, we must continue our clean energy momentum and work to reduce reliance on natural gas power plants. This year UCS is working to:

  • Establish a goal of 100 percent clean energy. Achieving 100 percent clean energy is an ambitious goal we must reach for to create a cleaner and healthier future, and to continue California’s tremendous momentum advancing clean energy.
  • Establish standards for California electricity providers to join a western regional electricity grid. UCS is working to help pass AB 813 (Holden) to prepare the ground for a regional grid that would make it easier and more cost-effective to integrate renewable energy by sharing electricity generation across a larger area.
  • Reduce reliance on natural gas power plants. California needs to study the fleet of natural gas power plants to create a strategy to reduce the use of natural gas electricity generation in an orderly, cost-effective, and equitable manner. In addition, UCS is supporting work to limit the use of the dirtiest natural gas power plants at times and in locations with bad air quality.
Create a clean transportation system

For decades California has led the nation with policies to reduce pollution from vehicles and promote clean fuel and vehicle technologies. As our transportation system faces dramatic changes in coming years—electrification, car-sharing, automation—we must ensure these changes result in reduced emissions and other key objectives (such as safety and accessibility). In 2018, UCS is working to:

  • Pass a state budget that includes much-needed incentives for electric cars, trucks, and buses. Incentives for electric cars vehicles are critical to overcome higher upfront costs that still exist and to increase consumer interest in this new technology. Each year lawmakers must appropriate funding for important incentive programs for light-duty and heavy-duty vehicles and UCS is working to make sure adequate funding is appropriated for the year ahead.
  • Ensure autonomous vehicles (AVs) reduce pollution and congestion and enhance access to mobility. AVs may become the most significant innovation in transportation since the mass introduction of automobiles early last century. However, public policy needs to guide the safe introduction of this emerging technology for widespread adoption of AVs to result in positive outcomes in the years ahead. UCS supports SB 936 (Allen), which will create an expert task force to make recommendations to provide guidance for how we can shape this new transportation technology to achieve these public benefits.
  • Increase use of electric vehicles by ride-hailing services. Ride hailing services—like Uber and Lyft—are a rapidly growing part of our transportation system. As these services grow and carry more and more passengers, it will become increasingly important that they move toward vehicle electrification to reduce pollution—just as electrification is important for personal vehicle use and transit buses alike. SB 1014 (Skinner) looks to address this issue. While UCS supports the concept of this bill, there are important details that remain to be resolved.
Better prepare California for a changing climate

California is facing a “new normal” of increasing variability and extremes in climate conditions with enormous impacts on people, communities, and the infrastructure on which our safety and economies depend. We must start to plan, design and build California’s infrastructure to be “climate-smart” and withstand the new reality of climate change. This year UCS is working to:

  • Create a state adaptation center to support decision-making on state infrastructure projects. The state should establish an office within the state government to provide various state agencies with actionable climate-related information and real-time guidance on specific analytical approaches and data choices as they grapple with decisions about planning and designing infrastructure projects.

I look forward to working on these and other issues on behalf of UCS and our supporters and Science Network members. Hopefully the Legislature will pass legislation advancing many of these priorities this year, keeping California on a path to a safe and sustainable future that utilizes science as a foundation for policy-making.

UCS Joins Lawsuit to Stop Pruitt from Rolling Back Clean Car Standards

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UCS joined a coalition of non-profit organizations in filing a lawsuit to challenge EPA Administrator Scott Pruitt’s attempt to roll back a regulation designed to improve vehicle gas mileage, save you money, and tackle transportation-related emissions, the biggest source of climate change pollution in the U.S.

A brief history of the fuel efficiency standards

This suit opens a new chapter in an epic saga that is longer than any George R.R. Martin or Robert Jordan series. Was this saga TL;DF (too long, didn’t follow)? Here is a brief primer.

In 2009 automakers agreed to a federal standard that requires them to gradually raise the average mpg of their vehicles through 2025. But, two days after President Trump took office, automakers and their trade groups asked the White House to weaken the standard. The Trump Administration agreed, and subsequently relied on bogus, industry-funded science to determine that the standards need to be changed.

How, exactly, the standards will be changed is TBD, but even before we allow EPA to get to that stage, UCS and our allies are asking a panel of federal judges to review the EPA decision to reexamine the standard. If the court finds that EPA’s decision to overlook the reams of science-based evidence that supported the original standard was improper, then EPA will have to go back to the drawing board and the current standard will remain intact.

Is this all the automakers fault?

In a word, yes. But blame must also be placed on the Trump Administration, which has turned this program into such a boondoggle that automakers have begun to change their tune and claim that EPA isn’t doing what they asked for. Don’t feel too bad for the automakers, though. They led a bull into a china shop and are now upset that the bull is destroying too much china.

What happens if EPA wins

This isn’t the final chance to stop the fuel efficiency standards from being destroyed. Even if EPA wins this case and the similar suit filed by 17 states and the District of Columbia, EPA still needs to submit an additional rulemaking for public comment that details exactly what the standards will be out to 2025. EPA will receive tens – if not hundreds – of thousands of comments in support of maintaining a strong standard, though it is unlikely they will listen to any of them. So, a weak rule will probably get finalized, which will prompt an opportunity for another lawsuit. That lawsuit will be the final crack at striking down what EPA is trying to do but, given how fast the federal government operates, won’t be initiated for quite some time.

In the interim, it’s important to keep pressure on EPA by having the judiciary rule on whether what they did was within the bounds of their authority. EPA ultimately chose to modify a standard that is based on the best available science, years of stakeholder input, and broad public support – and the small army of attorney’s representing the coalition of NGOs and states will make sure the court hears that argument loud and clear. It will also be important to submit comments to future EPA rulemakings on this issue – even if they don’t persuade the agency. An overwhelming number of comments in support of a strong rule clearly demonstrates how Americans view fuel efficiency standards, and can help a court find that EPA did not act in the public interest in weakening the standards.

Back to Bad Air: The Trump EPA’s Attack on Science and Our Health

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Smoggy skyline in Salt Lake City, Utah Photo: Eltiempo10/CC BY-SA 4.0 (Wikimedia)

Most Americans wake up and breathe comfortably every day because we’ve enjoyed decades of strong science-based clean air policies. These policies limit the emissions from cities, cars, factories and more to keep the air clean and free from most harmful air pollutants.

When he was first appointed, EPA Administrator Scott Pruitt vowed to bring the agency “back to basics” by focusing on clean air and water. One could be forgiven for assuming this meant he intended to preserve and strengthen America’s air pollution protections. That’s why it’s so jarring to see how severely his actions have undermined them. The Trump Administration’s EPA is working hard to unravel these life-saving protections on multiple fronts. This week, Administrator Pruitt and his air chief, William Wehrum, will testify on the Hill. They should be asked about how these actions bring EPA back to basics and fulfill its mission to protect public health and the environment.

More hazardous air pollutants with MACT rule change

In February, the EPA issued new guidance to weaken a policy that protects us from hazardous air pollutants from major sources like power plants and chemical manufacturing facilities. By repealing the “once in, always in” policy, the administration is allowing major polluters to evade using the maximum achievable control technologies (MACT) that have minimized our exposure to cancer-causing chemicals for years. Under the new guidance, at least 21 states could see increased emissions of pollutants like benzene and hydrochloric acid that can cause certain cancers and respiratory illnesses.

Gutting the science in ambient air pollutant decisions under NAAQS

Moreover, following up on a presidential memo last month, the EPA last week released guidance changing how the agency sets standards for ambient air pollutants like ozone, lead, and carbon monoxide. Together, the presidential memo and EPA guidance chip away at the long-standing science-based process that has effectively and drastically reduced ambient pollution in this country for decades.

Air pollution statistics cartoon

Changes at the EPA mean that the agency may soon have far less independent science feeding into its decisionmaking on air pollution protections.

The National Ambient Air Quality Standards (NAAQS) are a widely effective program that ensures the government sets standards for protecting clean air, based solely on what’s protective of public health. This has, by and large, allowed science and public health to prevail even in the face of political or commercial pressures. But the Trump administration has now opened the door to upending this process.

While the EPA guidance claims to “differentiate science and policy judgments,” it in fact does the opposite. Under the proposal, the EPA and its science advisors must not solely consider public health (as the law requires) but must elevate consideration of potential adverse impacts from setting a health-based standard, such as economic impacts. The process would be removed from EPA’s Office of Research and Development—where much of the agency’s scientific expertise lies—and the comprehensive document outlining the state of the science on pollutants and health that the administration relies on to make a science-based decision may be combined with a regulatory impact assessment, blurring the distinction between scientific and political judgments. This builds on a presidential memo that limited the kinds of scientific analyses the EPA can use when determining whether states are meeting the standard.

Restricting the science that EPA can use for decisionmaking

To put more salt in the wound, these actions come on the heels of the EPA’s recent, widely opposed, and dangerous, proposal to restrict the science that the agency can use to make rules. This proposal originated as a ploy by the tobacco industry to stave off second-hand smoke rules, and while its effects would be far broader than air pollution policy, protections against pollutants like ozone and particulate matter are clearly its main target.

Dwindling air pollution law enforcement

EPA enforcement of air pollution laws is also down. The agency issued only around half the average number of penalties against polluters in the first year of the Trump administration as in the same period of the past three presidential administrations.

Wrecking EPA’s science advisory committees

As if these things weren’t enough to undermine the EPA’s basic responsibilities, the administration also has worked to gut the agency’s science advisory committees, kicking academic experts off and replacing them with unqualified or deeply conflicted representatives. Industry representation on the EPA’s Science Advisory Board, for example, has tripled. The consequence will be far less independent science advice reaching EPA decisionmakers—and fewer checks on Pruitt’s ability to undo rules.

And we have some indications of the administration’s priorities here. In its proposed FY 2019 EPA budget, President Trump and Administrator Pruitt are looking to cut EPA funding that supports scientific research related to clean air by 27 percent.  Such a cut would threaten the ability of the EPA to monitor air quality levels, estimate population exposure to air pollutants, examine the effects of air pollution on public health, and reducing associated risks, and provide models, tools, and technical guidance to states. This clearly signals the administration’s disregard for air quality work at the EPA.

Administrator Pruitt’s biggest scandal

The sum of these policy changes is likely to mean dirtier air for all of us. This increased pollution is especially dangerous for the vulnerable groups who already disproportionately suffer from the harmful effects of air pollution. Children, the elderly, and those with lung diseases already face health challenges at current air pollution levels; weakening current standards will certainly exacerbate harm for these groups. Low-income neighborhoods and communities of color, which already experience disproportionate impacts from air pollution due to the cumulative impact of being near multiple pollution sources, will also be harmed by these policy changes.

Looking out for public health is supposed to be the “basic” responsibility of the EPA and its administrator.  The most scandalous thing about Scott Pruitt is how he’s abandoned the mission of the agency. If he won’t do the job, the rest of us need to speak up for clean air and the science that helps us protect it. Our lungs depend on it.

Photo: Eltiempo10/CC BY-SA 4.0 (Wikimedia)

SNAP is a boon to urban and rural economies—and small-town stores may not survive cuts

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In case you missed it, Congress is in the midst of a pretty major food fight. At the center of it is the Supplemental Nutrition Assistance Program (SNAP), which is the first line of defense against hunger for more than 21 million American households. Going forward, however, an estimated 2 million people stand to lose SNAP benefits if the farm bill proposal passed by the House Agriculture Committee last month becomes law. The bill’s draconian work requirements and eligibility changes threaten to upend the lives of some of the nation’s most vulnerable individuals and families. But it could also deliver a serious blow to the economic vitality of many rural and small-town communities, in an economic domino effect that often starts at the local grocery store.

Despite improvements in the national economy since the 2008 recession, rural communities across the United States continue to face economic uncertainty, and grocery stores are among the small-town businesses that are finding it hard to stay afloat. The challenges faced by rural food retailers are numerous: competition from increasingly powerful “big-box” stores, the rise of online retailers, and high operating costs are but a few of the challenges threatening the economic viability of today’s grocery stores. But there’s another major driver of food sales that impacts rural retailers and residents alike, and it has to do with how much families can afford to spend.

Many households in low-wage, low-prosperity rural counties turn to SNAP to augment their food budgets—in fact, they do so at higher rates than their urban counterparts. About 16 percent of households in rural or non-metro areas participate in the program, compared to 13 percent in metro areas. And in a recent analysis of publicly available data, UCS found that 136 of the 150 counties with the highest percentages of SNAP participation by household are located in rural areas.

We know the benefits that SNAP dollars bring to the people who use them. SNAP participation bolsters financial stability and food security; increases the likelihood that kids complete high school, while decreasing their risk of obesity and metabolic syndrome into adulthood; and saves about $1,400 in annual medical costs for low-income adults. But where do those dollars go next?

The ripple effect of SNAP spending

Following the path of a SNAP dollar can help us understand the invaluable role SNAP plays in supporting local industries and bolstering the broader economy. The graphic below shows the path of a dollar spent at a local grocery store.

It isn’t difficult to see how SNAP dollars are a boon to grocery stores—particularly for businesses in low-income areas, where SNAP purchases account for a greater share of sales. Dr. David Procter, Director of Kansas State University’s Center for Engagement and Community Development, knows a thing or two about the food economy. He’s been working with rural grocers for over a decade as part of the Rural Grocery Initiative, which helps small-town stores develop sustainable business models in the face of a food landscape that is rapidly changing.

“Small town grocery stores stand as a bulwark against the ever-rising number of rural Americans living in food deserts,” says Procter. “These food retail businesses are a vital element of the local food system, providing residents with access to produce, dairy, breads, grains, and meats. They are important to the local economy, creating jobs and generating tax revenue. Finally, these stores are community hubs, gathering places where social capital is built and maintained.”

Beyond the grocery checkout, SNAP dollars keep working

But the economic impact of SNAP doesn’t end at the store; in fact, this is only the beginning of a series of transactions that results in what is referred to as a “multiplier effect.” The standard USDA model estimates that, during a weak economy, $1 in SNAP spending generates about $1.80 in economic activity. This would mean that the $64.7 billion in SNAP benefits distributed in fiscal year 2017 could have generated an estimated $114 billion in economic activity, creating and supporting more than 567,000 jobs across the country.

So how does it work? Suppose the economy in Anytown, USA takes a turn for the worse. A factory relocates, or maybe a natural disaster shuts down the town’s major industry for an extended period of time. Many households find that they have less money to spend, and business at local establishments slows. Because of hardships resulting from the economic downturn—perhaps job loss, or reduced hours—some families apply for SNAP benefits. As those families use SNAP dollars to help put food on their tables, the grocery stores they shop at begin to recover. With more revenue, these stores can hire back staff; resume full operation and pay for operational costs like lighting and refrigeration; and, of course, purchase more food from farmers and distributors to meet growing demand. And as SNAP spending is propagated through the supply chain, each sector that gets a share of that additional money is able to spend more money in turn.

The effect extends to a wide range of sectors. Here’s why: studies have suggested that each additional dollar received in SNAP benefits results in between 26 and 60 additional cents spent on food—meaning an extra SNAP dollar received doesn’t equal an additional dollar spent on groceries. This is because, as many of us know, low-income households (including those experiencing temporary financial distress) are constantly making difficult decisions about how and when to pay for necessities such as housing, education, and transportation. And when SNAP benefits relieve some of the strain on a family’s food budget, they also help to free up a portion of income once spent on food for other expenses. From an economic standpoint, this means that a range of industries outside of the food supply chain also benefit indirectly—and not insignificantly—from SNAP spending. This multiplier effect shows how SNAP can effectively guide economic recovery.

Strong nutrition policy can help build strong communities and economies

This brings us back to the farm bill. If we want to preserve SNAP’s essential function as a safety net for our families and for our economy during tough times, we need to protect the program from the ill-advised overhaul making its way through Congress.

We can also leverage farm bill legislation to ensure that more of each SNAP dollar goes straight into farmers’ pockets and stays in our local communities. According to USDA models, the jobs that could have been created or supported by SNAP spending during fiscal year 2017 include nearly 50,000 agricultural jobs—a significant number, yet less than 9 percent of the estimated total. Many of the programs contained in the Local FARMS Act, a bipartisan marker bill introduced early in the farm bill process, offer win-win solutions that help farmers expand local and regional food sales while providing low-income populations with greater access to fresh, nutritious foods. Though these “tiny but mighty” programs represent a small fraction of the farm bill budget, they provide the means to effectively amplify the return on federal investment in programs like SNAP—which can make all the difference for families and rural farming communities that have been slower to recover from economic depression.

The full House is expected to take up H.R. 2 this week, with the possibility of introducing amendments before a final vote. UCS is working to ensure that members of Congress in both houses reject a SNAP overhaul, and instead take meaningful action to support low-income households in both rural and urban communities—while also giving a boost to small and midsize farmers. Got five minutes and want to make a difference? We’ve made it easy to call your members of Congress today to tell them to vote NO on H.R. 2.

La EPA elimina una protección vital para mantener el aire libre de sustancias tóxicas, poniendo nuestra salud en peligro

UCS Blog - The Equation (text only) -

View of the ship channel in Houston with city in the back, and air pollution.

Por décadas, la Ley de Aire Limpio nos ha protegido de los nocivos efectos a la salud que causan los contaminantes atmosféricos industriales. Muchos de estos contaminantes son tóxicos;  respirarlos o cualquier contacto con ellos puede causar cáncer, al igual que enfermedades respiratorias y neurológicas degenerativas que pueden causar la muerte. Algunas, como el cloro y el ácido hidroclorídrico, por ejemplo, pueden inflamar los pulmones y las vías respiratorias. El estireno, solvente utilizado con frecuencia en la elaboración de plásticos y hule sintético, está ligado a trastornos degenerativos como la esclerosis múltple y otras enfermedas similares al Parkinson. Gracias a las regulaciones que nos protegen de 187 sustancias tóxicas, la Agencia de Protección Ambiental (EPA en inglés) estima que se han evitado cada año desde 1990 la emisión de 1.5 millones de toneladas de contaminantes atmosféricos tóxicos.

Pero recientemente la EPA—sigilosamente—ha eliminado estas protecciones. A la extensa lista de los escándalos de corrupción, conflictos de interés, intervención política en la ciencia y nepotismo en la agencia, le añadimos la derogación de la política conocida como “once in, always in” (abreviada “OIAI”, y que se traduce “una vez presente, siempre presente”).

Este cambio, sin previo proceso de consulta pública y escuetamente anunciado como una “reinterpretación” de la ley, le permitirá a las instalaciones industriales altamente contaminantes, como las fundiciones metalúrgicas e instalaciones petroquímicas, eliminar el uso de tecnologías para controlar la contaminación tóxica que emiten al aire.  El uso de tecnologías y procesos para reducir contaminantes tóxicos se conocen como Maximum Achievable Control Technologies (MACT), y hasta hace poco fueron de uso obligatorio por parte de las instalaciones altamente contaminantes.

En una nota previa a completar nuestro estudio sobre las consecuencias de la derogación de ésta norma (aquí en inglés), advertí que aumentará las emisiones de contaminación causante de cáncer. Mi colega, la Dra. Gretchen Goldman, ya nos explicó (en inglés) que las comunidades de justicia ambiental–donde la mayoría de las personas son afroamericanos, latinos o pertenecientes a otras minorías étnicas  y/o de bajo ingreso—serían las más afectadas. En efecto, hemos encontrado en nuestro estudio que muchas de las comunidades donde ya existen altos niveles de contaminación tóxica se verán expuestas aún más.

Tomemos como primer ejemplo a las comunidades de Galena Park y Manchester aledañas al canal marítimo de Houston en Texas. Junto con nuestros colaboradores—vecinos de estos barrios y activistas de la organización TEJAS, quienes son en su mayoría latinos y muchos de bajos recursos—, hace poco demostramos que la cercanía a múltiples instalaciones industriales que al presente emiten muchos contaminantes tóxicos está teniendo efectos negativos en la salud de estas comunidades.

El distrito legislativo 29 (TX-29), donde están dichas comunidades, contiene 15 instalaciones que reducen sus emisiones de manera significativa mediante MACT. Con el cambio en la norma de la EPA, once de éstas pudieran emitir unas 205 toneladas de contaminantes atmosféricos tóxicos por año, lo cual representa un incremento de casi 70 por ciento.

Algunas fuentes mayores de contaminantes atmosféricos tóxicos como la fábrica de químicos Deer Park en Houston, TX (perteneciente a OxyChem), pudiera incrementar sus emisiones de contaminantes atmosféricos tóxicos de 0.64 a casi 25 toneladas por año si deja de utilizar MACT para controlar sus emisiones.

La nueva directriz impactará a los estados de formas distintas. Algunos estados dependen exclusivamente de las normas federales de contaminantes tóxicos para proteger la calidad de su aire, mientras otros estados establecen sus propios umbrales. Algunos de los estados con normas propias permiten las emisiones de contaminantes dependiendo del caso, mientras otros han establecido normas más estrictas en general.

¿Cómo puede usted conocer los posibles impactos en su región? Puede consultar el mapa interactivo que creamos donde mostramos el número de instalaciones que pudieran incrementar emisiones tóxicas en su distrito electoral. Por ejemplo, si selecciona el districto electoral 16 de Pensilvania (PA-16), podrá ver que once de las catorce instalaciones que al corriente usan MACT para reducir sus emisiones tóxicas pudieran emitir 209 toneladas por año, y que el estado no cuenta con protecciones adicionales para limitar contaminantes tóxicos.

Si desliza la ventana un poco hacia abajo podrá encontrar el nombre y número de teléfono de su representante. Le urgimos que lo contacte  para preguntarle cómo le exigirá a la EPA y a la agencia de calidad ambiental de su estado que protejan a la salud pública de este peligroso cambio.

¿Usted qué puede hacer?

Hay muchas maneras de expresar su preocupación sobre la posibilidad que las instalaciones industriales en su comunidad emitan contaminantes tóxicos del aire debido al debilitamiento de las protecciones existentes.

  • Si usted vive en un estado donde la contaminación tóxica del aire podría aumentar, presione a sus legisladores para que establezcan leyes estatales que protejan a su comunidad de estos contaminantes tóxicos. A continuación podrá encontrar algunas ideas para participar, y consejos para comunicarse con legisladores (enlace en inglés).
  • Pida un cita en persona con su representante o miembros de su equipo y comparta su preocupación.
  • Organice o participe en reuniones, cabildos abiertos, y otros eventos comunitarios. Aproveche el marco de las elecciones del 2018 en donde ocurrirán muchos de estos tipo de eventos y pida compromiso con este tema. Encuentre cabildos abiertos en este enlace  o en la página de su representante, y utlice esta guía para organizar un evento comunitario (en inglés).    
  • Pregúntele a la agencia responsable de la calidad del aire en su estado sobre cómo los cambios en “once in, always in” podrían afectar a su área. Encuentre su agencia estatal en la página de la EPA.
  • Utilice los medios de comunicación para atraer la atención del público sobre el tema. Escriba cartas al editor, editioriales, o reúnase con periodistas locales y juntas editoriales y comparta su preocupación. Lea estos consejos sobre cómo hacerlo (en inglés).
  • Contacte directamente a la compañía que opera la instalación industrial en su comunidad y pídales que se comprometan a mantener su clasificación y a utilizar la tecnología MACT con todos sus requisitos. Vuelva a contactarlos si no le responden en el plazo de una semana y comparta las respuestas, o los silencios, con medios locales, representantes y su comunidad.
  • Dígale a Scott Pruitt, director de la EPA, que cumpla su mandato de proteger la salud pública y al medioambiente y revoque la nueva directriz.
  • Envíele trinos en Twitter a Scott Pruitt, director de la EPA, y etiquete a sus representantes al congreso.

¿Quiere recibir la información más reciente sobre los ataques federales a nuestra salud, seguridad y protecciones ambientales, y notificaciones personalizadas sobre cómo usted puede defender la ciencia? Si tiene un posgrado, puede unirse a la Red de Científicos y su iniciativa de vigilancia (en inglés). Si usted es un líder local, únase a nuestro grupo de Science Champions (en inglés).

Industry Criticizing… Industry? This is What Effective Advocacy Looks Like

UCS Blog - The Equation (text only) -

The only way to get what you want is to work for it. Nothing is easy. Hard work pays off if done well.

Old coal-burning power plants have the greatest emissions per energy delivered.

In UCS’s battles against the utility company PJM,  two “black swan events” provided reminders that can encourage activists everywhere. PJM is the regional grid operator, or “RTO,” for 13 states and the District of Columbia.

The Federal Energy Regulatory Commission, aka FERC, is the main arena for this advocacy and the unexpected breakthroughs. The context is how the low prices of renewable energy and natural gas are driving coal and nuclear plants over 40 years old out of business.

These plants boil water and use the steam to spin a turbine, which is a less efficient and slower-responding design than modern power plants.

My goal on comments and presentations to FERC is to increase the recognition and reliability value of renewable energy. Ever since the very cold weather of the 2014 polar vortex, the utility industry has been debating how to deal with the behavior of gas-burning power plants that did not contract for gas deliveries for power production in the coldest weather, and the simultaneous failure of coal plants due to weather conditions. These two sets of outages at fossil plants were not anticipated, and defied the assumption that fossil plant outages would not be correlated.

While the fossil industry scrambled and imposed spectacular higher costs on consumers from their lack of preparedness, the grid was better off than it would have been otherwise because of an underestimation of the reliability of wind generation and demand response.

The first unexpected moment (in advocacy, not the unexpected black eye for coal and gas units) came in late April on a panel discussing the reliability contributions of electric generation. I described a blind spot in planning for winter reliability, something I had previously discussed with PJM experts and put into writing for FERC. I said out loud that there was no assurance that that every fossil generator can deliver its expected capability in winter.

PJM reported coal and gas plants shut down in cold weather far beyond expected outages.

The conversation in the room stopped, and the session moderator asked that I repeat what I said.

On one side of me was Joe Bowring, the Independent Market Monitor, an expert economist who can be a very influential pessimist. He said, “that was unexpected.” He had been speaking previously about black swan events. Joe even mentioned he saw his child bitten by a black swan, which explains a lot about his obsession with unexpected and lasting unintended consequences. On my right was a PJM representative, who conceded that my point was true, though there was no doubt that the system was studied to confirm that the system was reliable.

We were debating the seasonal risks behind the PJM policy that requires any generator to be able to provide its full output in any hour in order to be counted for reliability payments in the capacity market. Going back to 2014, the lesson was “don’t assume that each generator has adequate gas pipeline capacity.” I had been saying for some time we have not confirmed each generator has adequate electric transmission capacity.

This time, they heard it.

While this was going on, the debate that started with gas generators out-competing coal and nuclear plants took a national stage with the US DOE promoting the idea that coal plants offer “resilience” and should be paid all their costs and profits, forever. FERC did not adopt this rule, but did ask the grid operators how to define resilience, what is done to ensure resilience, and what else needs to be done.

In response to the grid operators’ answers, UCS emphasized what most of the grid operators said in their comments about transmission, renewables, and sophisticated forecasting. PJM used this opportunity to push its agenda on a variety of payments related to flexibility and hidden costs that it had previously presented to FERC for approval. PJM’s response about resilience included a call for FERC to take PJM’s list and make all the grid operators evaluate and create similar rule changes.

Here’s where the second black swan came in. Five independent system operators other than PJM, all in the US, filed a response saying to FERC that PJM had gone too far and should not be granted this request. These grid operators laid it, plain and simple: “The Commission Should Not Impose on Other RTOs/ISOs the Actions and Deadlines Specified in PJM’s Response.” They said “Although not all RTOs/ISOs identified immediate or imminent resilience concerns in their regions, each identified specific potential improvements intended to enhance resilience within their respective region.”

This is the first time people can recall when one of the grid operators was singled out by the others for making inappropriate demands on the industry. The consumer and environmental advocates have been saying for years that PJM has trampled on the policies enacted by states and used too-narrow definitions of the public interest and energy resources valued by society.

While PJM is holding its annual meeting this month, I’ll remind myself and allies the only way to get what you want is to work for it. Nothing is easy. Hard work pays off if done well.

Scott Pruitt’s Incredible, Perpetual, Public Time-Wasting Machine

UCS Blog - The Equation (text only) -

Photo: Gage Skidmore/Flickr

The limbo king of record worsts has notched another low.

Last month, awash in an unrelenting cycle of scandal after headline-stealing scandal, EPA Administrator Scott Pruitt found himself summoned to a day of hearings with lawmakers on Capitol Hill.

The performance affirmed an agency head devoid of personal accountability, with Mr. Pruitt managing to gasp his way to another day solely by clambering atop the back of one scapegoat after the next.

But even more arresting than that shameless show was the display of Mr. Pruitt’s overt disregard for science and statute. When confronted with questions about his evident regulatory malfeasance, such as by Congresswoman Chellie Pingree around his roll-back of the Clean Power Plan, Administrator Pruitt had the audacity to defend himself by suggesting he was simply awaiting policy vetting from “the marketplace”:

“I’ve actually introduced an advanced notice of proposed rulemaking in the marketplace to solicit comment on our authority to regulate GHG.”

The catch, of course, is that this “marketplace” has already weighed in. Fully and completely. That authority in question? It’s already been determined. And that resulting authority? It was developed into a proposed rule. And that proposed rule? It was revised and strengthened based on expert insights and public comment. And that resulting revision? It was issued as a final rule. And hey, get this: that final rule? It was already even considered in court.

But Administrator Pruitt has elected to overlook all that and head straight back to square one—not just for the Clean Power Plan, but for rule, after rule, after ruleignoring those scientific inputs, blocking those expert comments, and forestalling those relevant legal judgments.

Marvel, indeed, at E. Scott Pruitt’s Incredible Perpetual Public Time-Wasting Machine.

Oh, how low that man can go.

Mr. Pruitt goes to market

Now you’d be forgiven for wondering what, exactly, Administrator Pruitt was referring to when he pushed back against assertions of inaction by suggesting he was simply awaiting direction from “the marketplace.”

The marketplace? Which marketplace?

Well, we know it can’t be the economic marketplace, because although one would be forgiven for concluding that Mr. Pruitt only navigates by the light of the corporate stars, the administrator spent the bulk of his latest visit to the Hill swearing up and down and side to side that there was nary a Pruitt impropriety to be found. Clean as a whistle, straight shooter through and through.

We also know it can’t be the legal marketplace, because it turns out that Mr. Pruitt has done everything he can to stave off Clean Power Plan judgments from the courts, despite the fact that the court has already heard the case, and, what’s more, the EPA is now mind-bogglingly using the resulting “legal uncertainty” and existence of “open questions” to support its decision to return to regulation creation square one.

And so it must be, then, that Mr. Pruitt intended to suggest his work would be informed by the marketplace of ideas, otherwise known as expert opinions, science advisement, and public comment.

Of course, up until this moment the administrator has been working incredibly hard to consistently and repeatedly ignore, block, or reject all the inputs, evaluations, and expert judgments that have been previously submitted to said marketplace. Like for the Clean Power Plan. And fuel efficiency standards. And hazardous air pollutants. And coal ash. And chemical disasters. And methane leakage. And on, and on, and on.

But still.

For the moment, let’s meet him where he says is. To the marketplace we’ll go!

The Clean Power Plan takes another spin ’round the public comment block

It just so happens that on the same day as Mr. Pruitt’s recent hearings, the Clean Power Plan—the nation’s landmark rule on carbon emission standards for the electric power sector—was confronting something of an ignominious milestone of its own: the deadline for comment on its Pruitt-proposed repeal.

Now because Administrator Pruitt has ostensibly committed himself to being guided by these comments, it seems instructive to take a closer look. So here, an array of excerpts from the more than 1 million submissions the EPA has received—starting with those from select relevant scientific, oversight, business, and governing experts:

  • Prominent climate scientists: “The compelling motivation for a United States response to human-caused climate change, including its increasingly damaging impacts, have led a number of us to participate both in defending the CPP as amici in the earlier D.C. Circuit Case, as well as now strongly urging against the rescission of the CPP proposed currently.”
  • Former FERC commissioners: “We are a group of former Commissioners of the Federal Energy Regulatory Commission (“FERC”), who were appointed by President George W. Bush or President Barack Obama. […] The CPP does not interfere with the authority of FERC, nor does it threaten the affordability and reliability of the nation’s electricity supply. EPA’s suggestions to the contrary are incorrect and are not an adequate basis for its proposed repeal of this important measure to address climate change.”
  • Apple Inc.: “Apple believes the United States must re-assert its position as a global leader by deploying well-designed, nationwide strategies – with flexibility for states – to regulate and reduce overall greenhouse gas emissions. Apple believes the Clean Power Plan is one of those strategies. […] Repealing the Clean Power Plan will subject consumers like Apple and our large manufacturing partners to increased investment uncertainty, and frustrate reasonable expectations.”
  • US Conference of Mayors and National League of Cities: “We oppose the Agency’s efforts to repeal the CPP, as well as have concerns with the process the Agency is using to repeal and potentially replace the CPP. […] The nation’s mayors, councilmembers and cities strongly support the CPP as a means of nationally reducing greenhouse gas emissions and mitigating the growing negative impacts of climate change on our communities.”
  • Joint Comments of Environmental, Health, and Conservation Groups: “The Proposal’s complete flight from facts and evidence and abdication of the Administrator’s decision-making responsibility render the Proposal unlawful and arbitrary and capricious.”

UCS also filed comments of our own, as well as with coalition partners relating to the unlawful nature of the proposed repeal, the faulty assessments found in its supporting Regulatory Impact Analysis, a reiteration of climate science, and the flawed estimates of the social cost of carbon.

The Peoples Climate Movement, Washington, D.C., 2017. Credit: Audrey Eyring/UCS.

Our comments reminded the administrator that climate change is a real and urgent threat, and that the EPA has clearly established authority—and obligation—to limit greenhouse gas emissions. We called out the insufficient rationale for repeal, as well as the flagrantly unlawful disregard for the robust record underpinning the rule. Finally, we hammered the agency’s intentionally deceptive analytical practices that overstated costs, understated benefits, and effectively ignored at-risk populations.

And then, of course, there were the million or so other comments submitted to the docket, impassioned and thoughtful, touching on issues from asthma and public health to clean energy and the nation we hope to be.

To be sure, these offer just the faintest hint of a glimpse. No matter what, though, it seems clear that if Administrator Pruitt is actually ready to move forward with these comments, and not just use them to further stall, he’s got a whole lot of external intelligence to work with.

Looking up, looking ahead

It seems hard to believe that Administrator Pruitt has much time left at EPA, what with wave after pounding wave of scandal cresting and crashing upon him. But today, even as the flotsam and jetsam of corruption and malfeasance buffet him about, he’s still the head of the EPA, and he’s still setting record lows.

It’s time to stop wasting people’s time, and devastating public health.

It’s time to pull EPA back from the depths, and realign the agency’s work with its mission: to protect public health and the environment.

Gage Skidmore/Flickr

Automakers Pretend President Trump Isn’t Giving Them Exactly What They Asked For—We Don’t Buy it.

UCS Blog - The Equation (text only) -

Today, automakers are meeting with President Trump to discuss his administration’s plans to rollback fuel efficiency and emissions standards on light-duty vehicles. Since reports of the proposal first began to leak, we’ve seen a number of statements from automakers claiming that this wasn’t what they asked for.  Unfortunately, these statements ring hollow—and their own proposals explain why.

You can’t renegotiate a Faustian bargain

It took just two days after President Trump was elected for the Alliance of Automobile Manufacturers to request that his administration put the brakes on any decision regarding the 2022-2025 standards, fearing that the agency would follow the science and not their wishes to weaken the standards. When EPA moved forward with this decision and correctly determined that automakers could not just meet but exceed the standards, and that these vehicle emissions standards remained appropriate, the Alliance again went to the administration to have the process reversed.

Enlisting an ideological administration to pull back on regulations amounts to a Faustian bargain—when regulations stop being based in scientific rigor and instead are based in political expediency, a technically indefensible proposal like freezing progress at 2020 levels is exactly what you get.  This was an entirely foreseeable result, and automakers and their lobbyists are neither so stupid nor naïve as to not see this coming—for them to feign surprise now at the outcome is insulting. Of course, it’s made even worse by the fact that they themselves have been in the driver’s seat as we’ve headed down this road.

What the industry has asked for thus far

From the get-go, automakers have been asking for “harmonization” while failing to acknowledge that these requests come at the cost of increased emissions and fuel usage. In fact, in their first letter to the President, they requested that the administration approve a petition that would result in 150 million barrels of additional oil consumption by overcrediting vehicles that had already been sold and adding “flexibilities” to the program that directly undermine the standards.

Administrator Scott Pruitt and the CEOs of the National Automobile Dealers Association, Alliance of Automobile Manufacturers, and the Association of Global Automakers

Administrator Scott Pruitt and the CEOs of the National Automobile Dealers Association, Alliance of Automobile Manufacturers, and the Association of Global Automakers, smiling as the administration announces its plan to roll back the 2022-2025 vehicle emissions standards (EPA).

Of course, the Alliance has not limited themselves to executive action when it comes to lowering the bar—they’ve asked Congress to intervene as well, with legislation that would result in at least 350 million barrels of additional oil use and put the industry on a path to 2025 that is 8-10 mpg lower than the standards already on the books.  That endpoint is within spitting distance of the current proposal, so it seems hard to argue this isn’t President Trump’s administration just naturally following the Alliance’s lead.

Similarly, while manufacturers like Honda, Ford, and GM have all come out and said they don’t want a full rollback of the standards, some of the details surrounding these announcements raise serious doubts. For example, while Honda has come out with the most vocal support for the standards, requesting that the targets be maintained as is, that came with a major caveat regarding additional incentives for electric vehicles were requested, as did Ford’s. GM’s proposal included a request for credits based on the unproven benefits of autonomous electric vehicles.

The impact of these types of “flexibilities” is massive—for example, extending EV multipliers and ignoring emissions associated with the electricity powering these vehicles would result in additional emissions and oil usage in the near-term, to the tune of over 230 million metric tons just over the lifetimes of vehicles sold through 2025 by our estimate, even at modest EV sales (< 5% in 2025).  That’s equivalent to freezing the standards at 2022 levels—not a far cry from the administration’s proposal—and the impact would be even worse if EV sales outpace those expectations. Similarly, giving away credits for safety or automated vehicle technologies is a strategy which would have serious consequences for the robustness of these rules and may not even result in any real reductions.

What the industry should be asking of the President

If the industry is now having second thoughts, it is time to eschew the sort of wiggle room granted in the public statements thus far and stick with a clear proposal to ensure we maintain the benefits of strong standards. To that end, here is what the automotive CEOs should tell the President in today’s meeting:

  • We can meet the standards as they stand. Ford told its shareholders yesterday that they are planning to exceed the current standards—now they need to say that to the President. Of course, this is consistent with the technical record underpinning the Obama administration determination that these standards are appropriate.
  • These standards have accelerated technology investment. Automotive manufacturers and especially suppliers have both invested significantly in the technology needed to reduce oil use and emissions from light-duty vehicles.
  • To continue that investment, we need certainty. Not only does pulling back on strong standards send the wrong market signal to continue that improvement—it also all but ensures continued uncertainty as these rules wind up in years of litigation.
  • Oil prices are on the rise, and these standards protect our customers from that volatility. Domestic manufacturers were ill-prepared the last time gas prices rose dramatically, and these standards act as a hedge against a volatile, global oil market that finds prices at the highest they’ve been since 2014.
  • Respect state leadership—the entire country benefits. California and the 12 states that follow California’s policies are going to enforce the 2025 standards as they stand today—don’t fight that progress. California stepped up to the plate to set the first-ever vehicle emissions standards, and we continue to reap the benefits of that today nationwide.
  • These standards are job creators—so get out of the way and let us get to work “making America great.” Analysis is clear—these cost-effective standards are great for consumers, and because those savings get reinvested into the economy, they end up creating new jobs not just in the automotive sector but across the economy.

Instead of quibbling about how weak is weak enough, they need to push for strong policy commitments.  Given the repeated asks of the administration to weaken the standards, I find recent automaker pleas a bit dubious—but at the moment, they at least have the ear of the President, so they need to make it count.

If the automakers can’t succeed in putting the genie back in the bottle, we will see more than 200 billion gallons of additional oil use by 2050, costing consumers hundreds of billions of dollars at the pump and forestalling investment in technologies needed to address the challenge of climate change. And they will shoulder the blame for generations to come.

Made in Chattanooga

UCS Blog - All Things Nuclear (text only) -

What do the Arkansas Nuclear One Unit 2, Beaver Valley Unit 1, Beaver Valley Unit 2, Big Rock Point, Callaway, Calvert Cliffs Unit 1, Calvert Cliffs Unit 2, Catawba Unit 2, Comanche Peak Unit 1, Comanche Peak Unit 2, Connecticut Yankee, Cooper, Diablo Canyon Unit 1, Diablo Canyon Unit 2, Donald C. Cook Unit 1, Edwin I. Hatch Unit 1, Edwin I. Hatch Unit 2, Fort Calhoun, HB Robinson, Indian Point Unit 1, Indian Point Unit 2, Indian Point Unit 3, James A. FitzPatrick, Joseph M. Farley Unit 1, Joseph M. Farley Unit 2, Fermi Unit 2, Kewaunee, LaSalle Unit 1, Maine Yankee, Marble Hill, McGuire Unit 1, Millstone Unit 1, Millstone Unit 2, Millstone Unit 3, Nine Mile Point Unit 1, Oyster Creek, Palisades, Palo Verde Unit 1, Palo Verde Unit 2, Palo Verde Unit 3, Pilgrim, Point Beach Unit 2, Salem Unit 1, Salem Unit 2, San Onofre Unit 1, San Onofre Unit 2, San Onofre Unit 3, Seabrook, South Texas Project Unit 1, South Texas Project Unit 2, St. Lucie Unit 1, St. Lucie Unit 2, Vogtle Unit 1, Vogtle Unit 2, Waterford, and Wolf Creek nuclear power reactors have in common?

True, they are all mentioned in this same question. But the subject commonality has a broader dimension.

Also true, they are all located on planet earth. But the subject commonality has a narrower dimension.

Hint: Check out the title of this commentary.

Yes, the reactor vessels for all these nuclear plants, and many others worldwide, were manufactured by Combustion Engineering at their factory in Chattanooga, Tennessee.

Indeed, the Chattanooga factory made the vessels for boiling water reactors like FitzPatrick and Pilgrim, for Westinghouse pressurized water reactors like Diablo Canyon and Indian Point and for Combustion Engineering pressurized water reactors like Palo Verde and Waterford.

In the days before FedEx, how did reactor vessels made in the hills of east Tennessee get to so many locations coast to coast? The Tennessee River winds through Chattanooga and empties into the Mississippi River. Whenever possible, the reactor vessels were lifted onto barges in Chattanooga and floated to the plant sites. For example, the Unit 1 reactor vessel for the Nine Mile Point nuclear plant in Oswego, New York took the scenic route down the Tennessee River, up the Mississippi River, up the Illinois River, across four of the five Great Lakes.

Fig. 1 (Source: Daily Standard (October 7, 1966))

It took 29 days for Pilgrim’s reactor vessel to make the 3,587-mile journey down the Tennessee and Mississippi Rivers, across the Gulf of Mexico and along the Atlantic coast to Plymouth, Massachusetts. (The plant is scheduled to permanently shut down by June 2019. On behalf of my fellow citizens of Chattanooga, the current owner should check out the “No Return” provision in the contract.)

Fig. 2 (Source: UPI Telephoto published in News Journal (March 4, 1970))

The Unit 1 reactor vessel for the San Onofre Nuclear Generating Station in southern California began its 2,000-mile journey on a barge, was transferred onto a freighter for passage through the Panama Canal, was transferred back onto a barge, and then loaded onto a train car for delivery to the site.

Fig. 3 (Source: Daily Republican (April 23, 1965))

Not all the journeys were event-free. The Unit 3 reactor vessel for the Indian Point nuclear plant in Buchanan, New York was dropped on January 12, 1971, as it was being unloaded at the plant. Well, it was not actually dropped. It underwent an “unscheduled descent during its installation” at the plant. An overhead crane rated for 175-tons was being used to lift the 456-ton package of reactor vessel and shipping rig. Somehow, the motor for the 175-ton rated crane became overheated as it was lifting the 456-ton load. The 456-ton load had been raised from its original horizontal configuration to nearly the vertical (i.e., 90°) position when the lift was halted to let the overheated crane motor cool down. The 175-ton crane’s hoist failed, dropping the load—or letting the load make its unscheduled descent back to the horizontal position.

Fig. 4 (Source: Oak Ridge National Laboratory)

Scientists from Oak Ridge, representatives of Combustion Engineering in Chattanooga, and workers from Westinghouse huddled to determine whether the unscheduled descent of the reactor vessel resulted in its unscheduled dis-use. They reviewed results from magnetic particle and ultrasonic examinations and concluded the vessel could be used.

Scientists from the Oak Ridge National Laboratory traveled to Buchanan to view the Unit 3 reactor vessel. They heard contradictory accounts as to the position of the reactor vessel when it began its unscheduled descent. Some eyewitnesses said the vessel and rig were about three feet off the ground. Others insisted it was not off the ground at all. Similarly, the scientists received varying accounts of how long it took the vessel to complete its unscheduled decent. Some eyewitnesses reported the descent took 15 seconds. Others claimed the descent went on for nearly 60 seconds. The discrepancies might be attributed to the eyewitnesses making unscheduled departures from the vicinity.

UCS Perspective

UCS has staffed a remote office in Chattanooga for the past eight years. At the time, we knew the city was the location for the International Towing Museum, but did not realize that the city played such a prominent role in the development of nuclear power reactors in the United States. And as if making tow trucks and reactor vessels was not enough, but Moon Pies were invented in Chattanooga in 1917.

Chattanooga also has the offices for the Nuclear Division of the Tennessee Valley Authority (TVA), with TVA’s Sequoyah Nuclear Plant within sight of downtown. Chattanooga also has the Nuclear Regulatory Commission’s Technical Training Center as well as a Westinghouse training facility.

But Chattanooga no longer makes reactor vessels. Combustion Engineering scaled back manufacturing at the factory as demand for nuclear components dwindled in the U.S. and abroad. In 2007, the nearly idled manufacturing plant was acquired by French-based Alstom with intentions to make components to support the nuclear renaissance. The factory did not need a first shift, yet alone a second or third shift, to handle all the non-orders for reactor vessels and other nuclear plant parts. The factory closed shop in 2016.

But don’t despair. Chattanooga still makes Moon Pies and tow trucks.

The Past, Present, and Future of Carbon Pricing in Washington State

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Washington State Capitol. Photo: Jon Connel CC-BY-2.0 (Flickr).

Despite what’s shaping up to be a summer of uncertainty in DC, with President Trump’s EPA attempting to dismantle a generation’s worth of science-backed environmental protection and climate progress, momentum is building in Washington state to move forward on innovative climate policy.   

Washington has a lot at stake.  Climate change impacts including increased wildfires, drought, flooding, sea level rise, ocean acidification, and changes to agriculture threaten the state today, and will get much worse unless we take action.  

To prevent the worst impacts of climate change, Washington voters and legislators in recent years have considered – but not approved — binding carbon pollution limits and a price on carbon pollution. This year, a proposed ballot initiative measure, Initiative 1631 would create a fee for carbon polluters. It is sure to add to a robust and healthy nationwide discussion about what are the best policies to reduce carbon and prevent the worst impacts from climate change.   

Carbon pricing is a way to help incentivize reducing climate pollution while providing revenue to invest in clean energy and fuels and provide transition assistance to workers and communities. The initiative could show how state-level action can be a potent antidote to retrograde motion in DC.  

Past progress and approaches to pricing 

Washington state, like the entire West Coast, is a leader on forward-thinking climate policy with legislative targets for emission reductions, a greenhouse gas inventory of major emitters, and a Clean Air Rule adopted by the Inslee Administration. The state has not yet instituted an economy-wide carbon price but has considered two approaches previously. 

In 2016, Washington debated ballot initiative I732, a carbon tax measure that would have instituted a  carbon tax offset by a 1 percent cut in sales tax, a cut to manufacturing taxes, and a low-income tax credit.  I732 was intended to be revenue-neutral and to provide a progressive tax rebate. However, the initiative failed decisively at the polls after drafting errors came to light, and other controversies divided climate action supporters .  (UCS was neutral on the measure, for reasons we described here.

In 2017, the legislature considered a measure backed by Governor Jay Inslee, SB 6203 (Carlyle et al) that would have instituted price on fossil fuels that would rise gradually until 2035. The funds were to be used for carbon reduction measures, forestry, water improvements, low-income assistance, community investment, rural economic development, and utility rebates. The bill also exempted so-called “energy intensive, trade exposed” (EITE) industries that could be economic disadvantaged by competition from out-of-state entities not subject to a carbon fee. Despite diverse support from Washington business, labor, environmental, and social justice groups (and thanks to opposition from some industrial, business, and agricultural entities) the bill didn’t advance to a floor vote, in part because 2017 was a short, two-month session that didn’t allow sufficient time to consider the complexity of the measure.   

And now a unified proposal from a broad coalition 

While the other measures were being debated, a coalition of environmental, environmental justice, business, labor, tribal, public health, faith and other groups under the banner of the Alliance for Jobs and Clean Energy, has been hard at work finding common ground on climate policy. Now, the group has introduced initiative 1631 that incorporates both a polluter-pays carbon fee starting at $15 per ton of CO2 in 2020 and an investment plan for clean energy, forests, water, and healthy communities.  

The initiative provides exemptions for certain EITEs and provides rebates to utilities while investing heavily in job assistance for displaced fossil fuel workers and also in tribal and low-income areas. The fee is increased at a rate of $2 per year plus inflation to an estimated level of about $55 and stays at that level if the state is on track to meet its 2035 emissions reduction target of 25 percent below 1990 levels.   

The unique design of this carbon fee was arrived at after intensive consultation among many Washington communities, businesses, and groups.  It differs from California’s cap and trade program, British Columbia’s carbon tax, and Oregon’s proposed carbon cap and invest policy (similar to California’s, to be taken up in the 2019 legislative session.)  

The fact that different jurisdictions are looking at different approaches towards carbon pricing shows that there is latitude among pricing design to meet local needs and conditions. Some programs, like California’s that is linked to Ontario and Quebec, are designed to encourage participation from other jurisdictions, in part to lower costs. Washington’s program would not link out of state, but would provide a level of price certainty in the fee structure that other programs do not have.   

For our future, the most expensive thing we can do is nothing 

Despite the hard work of a large group of interests who have found a common vision for carbon pricing in Washington, I 1631 is certain to generate intense opposition from the fossil fuel industry and their allies.  They will invoke the usual pieties about how yes, climate change is real, but this approach is all wrong.  They will say that it’s bad for the economy. Of course oil producers and other fossil fuel interests do not want to help the state transition away from their products and the harm they cause.  The fact is that carbon prices are features of several state and national economies, including British Columbia and California, that are thriving. 

While carbon pricing is not the only approach to reducing emissions, it does start to internalize the costs of climate pollution and make the needed investments for a safer, healthier future.  UCS has long supported carbon pricing and we recognize that there are different advantages to different approaches, along with numerous economic benefits.  The greater threats to our economy, not to mention our well-being, are climate change-related impacts that are already costing billions of dollars, devastation of property and the environment, and loss of life.  In fact, the most expensive thing we can do is nothing.    

The New Farm Bill’s Pesticide Provisions are a Sneak Attack on the Environment

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A bald eagle resting on a log by a lake in Umbagog National Wildlife Refuge.

Bald eagles, such as this one in the Umbagog National Wildlife Refuge in New Hampshire and Maine, were driven to near extinction in the contiguous 48 states by pesticides. Photo by Derrick Z. Jackson

If fish could wail, they would scream over the lethal powers granted to the Environmental Protection Agency in part of the draft farm bill recently rolled out by the House Agriculture Committee. The bill, passed out of committee by Chairman Mike Conaway (R-TX) on a party-line vote last month, desperately fails farmers and low-income families. It also contains a number of sneak attacks on the environment. One such provision would allow the EPA to approve new pesticides with no assessment of their potential impact on fish and wildlife covered under the Endangered Species Act.

That means that EPA would no longer need to wait for independent research on the toxicity of pesticides in rivers, wetlands and prairies from the US Fish and Wildlife Service in the Interior Department, or in estuaries and coastal waters from the National Marine Fisheries Service in the Commerce Department. The bill chillingly specifies that the EPA administrator “shall not be required to consult or communicate with the Secretary of the Interior or the Secretary of Commerce.”

To date, most of the national publicity about the House farm bill has understandably focused on its potentially devastating effect on America’s poor, with expanded work requirements that the Congressional Budget Office estimates would eliminate 1.2 million people from the Supplemental Nutrition Assistance Program rolls. The CBO also estimates that 400,000 households would lose benefits under higher income thresholds, eliminating free school lunch for 265,000 children. The bill also slashes child support and home heating and cooling assistance.

When it comes to wildlife, the bill envisions an EPA that pays no heed to environmental science, potentially wreaking a different kind of devastation.

Chlorpyrifos clearance only the beginning

This continues the attack on federal environmental science that began in earnest a year ago when EPA Administrator Scott Pruitt derailed a ban on chlorpyrifos that was long in the works during the Obama administration. In 2000, the EPA ended that neurotoxin’s use in residential lawn and garden and indoor pest control for its toxicity to children. However, it remained America’s most-used conventional insecticide in commercial agriculture, used so heavily that the Obama-era EPA could not conclude that human exposure in residues and water runoffs met federal safety standards. One study last year found that 7-year-old children in Salinas Valley, California who lived near farms using organophosphates such as chlorpyrifos, diazinon and malathion suffered deficits in intelligence and verbal comprehension.

But Pruitt cleared chlorpyrifos after meeting with the CEO of Dow Chemical, the top maker of the pesticide. The Los Angeles Times exposed the meeting after an EPA spokesman lied that it never happened.

Emboldened by that success, Dow, which donated $1 million to President Trump’s inaugural committee and spent nearly $14 million on lobbying in 2016, pursued a far more outrageous free pass for its toxic products. It feared the results of a massive National Marine Fisheries Management study launched by the Obama administration that was not yet final, but that would likely render a very negative biological opinion on the effect of chlorpyrifos, diazinon and malathion on fish and wildlife. As reported by the Associated Press, Dow’s Washington law firm wrote Pruitt, Interior Secretary Ryan Zinke and Commerce Secretary Wilbur Ross, urging them to dismiss any results that would come of that research, complaining that the methodology wrongly produced “unrealistically high and sometimes physically impossible estimates.”

A fleeting victory for science

For a hopeful second, it appeared that Dow had lost the argument when the fisheries service officially concluded that chlorpyrifos and malathion were each likely to directly “jeopardize” 38 species of sea life, including several species of salmon, sturgeon and killer whales, and diazinon would jeopardize 25 species. The pesticides would also “adversely” harm about the same number of critical habitats. The opinion emphasized: “Species and their prey residing in shallow aquatic habitats proximal to pesticide use sites are expected to be the most at risk.”

But Conaway (who has received nearly $5 million in campaign contributions from the agribusiness sector since 2005, according to the Center for Responsive Politics) and his fellow republicans want to come to the rescue of Dow and the entire toxic agricultural chemical industry. Complaining that it took too long for EPA, the National Marine Fisheries Service and the Fish and Wildlife Service to complete reviews to register new compounds, all 26 Republicans, over the opposition of all 20 Democrats, voted to allow the EPA to utterly ignore any assessments by the NMFS or Fish and Wildlife.

If reauthorized as written, the farm bill would also allow the “lawful use” of pesticides to kill endangered species without fear of federal penalties and would prevent EPA and the states from requiring pesticide permits under the Water Pollution Control Act for discharges into navigable rivers. Plus, even though a vast majority of farmers embrace sustainable practices to avoid erosion and pollution, a fact recently highlighted by UCS Senior Analyst for Food Karen Perry Stillerman, the farm bill would eliminate the Conservation Stewardship Program.

For humans, the danger of chlorpyrifos alone was enough for the American Academy of Pediatrics and the Environmental Working Group to write a joint letter to Pruitt last summer saying his EPA was rejecting years of the agency’s own science that said the pesticide’s “risk to infant and children’s health and development is unambiguous.”

A Dining Bald eagle in Conowingo, Maryland eating fish.

Dining Bald eagle, Conowingo, Maryland. In the DDT era, consumption of poisoned fished lead eagles to lay eggs too thin to hatch, leading to near-complete nesting failure by the 1970s. Photo by Derrick Z. Jackson

Specter of silent spring

For both humans and wildlife, the Republican reauthorization of the farm bill would usher in the weakest federal protections against pesticide abuse since Rachel Carson charted the destruction of species by overuse of DDT and other pesticides in her seminal 1962 book Silent Spring. She wrote of pesticide poisonings, and mental illness to people, documented by American, British, New Zealand and Australian researchers. One study by the University of Melbourne noted how three chemical scientists, eight greenhouse workers and five farm workers suffered from impaired memory, schizophrenia and depression. “All had normal medical histories before the chemicals they were using boomeranged and struck them down,” she wrote. She said their illness was “a heavy price to pay for the temporary destruction of a few insects, but a price that will continue to be exacted as long as we insist upon using chemicals that strike directly at the nervous system.”

As regards wildlife, Carson chronicled the near complete “annihilation” of young Coho salmon in one river in Canada and massive die-offs of trout, bluegill, sunfish, crappies, bass, catfish and many other prized fish and the insects and prey they eat in Maine, Montana, Alabama, California, Florida, Texas, Pennsylvania, Louisiana and Oklahoma. Poisoned fish went up the food chain to lead to the near extinction in the contiguous 48 states of America’s national bird, the bald eagle.

In a haunting reminder of how far pesticides can travel and their ability to destroy far more than their intended pest, Carson wrote about a pesticide induced fish kill that stretched for 200 miles down the Colorado River and about how pesticides led to the decimation of 20 to 30 tons of some 30 different species of fish in a Florida salt marsh. A marine biologist by training, Carson concluded that the threat of pesticides to America’s freshwater and saltwater fisheries alike “can no longer be doubted. If we would divert to constructive research even a small fraction of the money spent each year on the development of ever more toxic sprays, we could find ways to use less dangerous materials and to keep poisons out of our waterways. When will the public become sufficiently aware of the facts to demand such action?”

The proposed farm bill forces Americans to ask that question all over again. The House Agriculture Committee and the EPA under Pruitt already have their answer and the facts do not appear to matter to them. If concern for the developing brains of children was not enough to provoke the Trump administration into any real environmental protection with chlorpyrifos, concern for fish, birds and other wildlife will almost certainly not constrain EPA from approving toxic pesticides at will. The rest of America will have to wail for the fish and sing for the birds to prevent this latest attempt to roll back environmental gains from delivering another silent spring.

So, What Does the Endangered Species Act Mean to Me?

UCS Blog - The Equation (text only) -

I was born and raised in Fairbanks, Alaska, a land of extremes. Temperatures could drop below -50ᵒ Fahrenheit in the winter and the darkness would seem to stretch out endlessly, while the summers provided radiant sunshine for months that infused a sense of magic into our town. Certainly, for me, the most charmed experiences from my childhood all happened in the Alaskan wilderness. I deep-sea fished on my grandparent’s boat in Prince William Sound, spending a week on the ocean each summer exploring coastline that would reach up and tower over me like a fern-covered arctic rainforest, trees hung with pale green moss. I saw sea otters floating on their backs in the surf, and watched sea birds dive for scraps cast off by anglers as they cleaned their catch on the docks. These experiences throughout Alaska shaped my desire to work in a field that allowed me to study and protect the natural world around me, including threatened and endangered species.

In southern Nevada doing some rare plants surveys.

I moved to Reno, Nevada to attend college, and ended up in the Great Basin Desert, a landscape that felt about a million miles away from the forests I’d grown up in. My first field research job entailed hiking around the desert one autumn mapping the water boundaries of the Amargosa toad, an amphibian up for listing consideration under the Endangered Species Act (ESA) at the time. Post-undergraduate work led me to an environmental non-profit, where I coordinated the monitoring of habitat restoration projects for the Greater sage-grouse, a large bird also being considered for protections under the ESA during that period. Now, in graduate school and subsequent professional experiences, I’ve worked on rare and endangered plant surveys, hiking across harsh desert terrain to search for shy little species like the Black wooly pod.

As I look back on my experiences, I’ve realized that in the decade since I began my journey as a research scientist, I’ve been fortunate to be involved in not one, but two ESA success stories. Through a collective effort by government organizations, private landowners, and other stakeholders, both the Amargosa toad and the Greater sage-grouse are no longer up for listing under the ESA. These accomplishments have been the product of incredibly large-scale collaborations across agencies, disciplines, and state boundaries, and were no easy feat. However, the Trump administration has recently proposed loosening the hard-won protections for sage-grouse, underlining the need for continued vigilance by scientists and science-supporters to ensure those interest groups benefiting from such a decision are held accountable.

I’m still early in my career, and I found it difficult at first to articulate what the Endangered Species Act means to me. But, after reflecting on my experiences, I’ve realized my personal and professional journey to where I am today has been wholly influenced by the ESA.

Nevada scientist Rob Mrowka and I went to Washington, DC, to meet with our legislators and advocate to protect the Endangered Species Act.

I was able to advance my support for the law when I traveled to Washington, D.C. this past February to take part in a collaborative effort between the Union of Concerned Scientists and the Endangered Species Coalition to bring awareness to threats against the Endangered Species Act. Along with Rob Mrowka, a career scientist from Nevada, I met with our state legislators and their staff to discuss the importance of protecting the ESA and the species it covers. In collaboration with other scientists from across the country, our collective efforts helped raise awareness of riders and amendments meant to weaken important ESA protections, and I am thrilled to say that many of these provisions were rejected by Congress in the end. To me, this victory reinforced how important our voices as scientists and science-supporters are, and how diving into the politics of science to contribute our expertise and opinions can truly have an impact. We should not feel helpless in these challenging times when we have so much power in collaboration.

So, what does the ESA mean to me? It means opportunities for research, and a chance to take lessons learned from one species’ survival story and apply them to other complex conservation problems. It means collaboration, among people that may not otherwise ever share a meeting. It means support, for those species awarded protections they might desperately need to stabilize and grow, ensuring we maintain our biodiversity on this planet. And it means hope, that a small toad only living along a single ten-mile stretch of road, or a bird that performs one of the most beautiful mating displays I’ve ever witnessed, can rise up from the threat of extinction, all because of the collective efforts of a community.

As scientists, please join me in signing this letter telling Congress to protect science and the Endangered Species Act, because our collective voices are louder and can do more than any one of us alone.


Cody Ernst-Brock is currently finishing her M.S. at the University of Nevada, Reno in the Natural Resources and Environmental Science program. Her research centers on analyses of restoration projects implemented across the state, often in sensitive sage-grouse, pygmy rabbit, and mule deer habitat. She hopes to continue her work in conservation and restoration post-graduation, preferably in a capacity that allows her to travel. In her free time she enjoys exploring her home in the foothills of the Sierra Nevada Mountains, where you can find her mountain biking, kayaking, and swimming in Lake Tahoe.

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.

How Would a Flawed 2020 Census Affect You? I Talked with Someone Who Knows

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Not to be outdone by other Secretaries who are gaining a lot more public attention, on March 26, Commerce Secretary Wilbur Ross said “Hold my beer…” then announced that he was going along with Attorney General Jeff Sessions’ request to add a question about citizenship to the 2020 Census. The decision was announced despite concerns about the threat of a population undercount voiced by previous Census directors, the scientific and voting rights communities, and leaders in the public and private sectors.

Most people understand the threat of an undercount for the primary purpose for which the U.S. Census was designed: the apportionment of seats to the U.S. House of Representatives. The first Census, mandated by the Constitution and engineered by James Madison and Thomas Jefferson, also included some demographic questions, but it was the total population data that Jefferson used to apportion seats, of about 30,000 persons per seat.

According to estimates from Election Data Services, the 2020 Census data will impact over a dozen states by changing their Congressional delegations. As the table below shows, under current population projections, and with the size of the House capped at 435, seven states look to gain at least one seat, and Texas and Florida could gain more. Nine states would lose seats, based on relative population changes.

States Gaining Districts (7) States Losing Districts (8 or 9) Arizona +1 (from 9 to 10) Alabama -1 (from 7 to 6) Colorado +1 (from 7 to 8) Illinois -1 (from 18 to 17) Florida +2 (from 27 to 29) Michigan -1 (from 14 to 13) Montana even or +1 (from At-large to 2) Minnesota -1 or even (from 8 to 7 or no change) North Carolina +1 (from 13 to 14) New York -1 (from 27 to 26) Oregon +1 (from 5 to 6) Ohio -1 (from 16 to 15) Texas +2 or +3 (from 36 to 38 or 39) Pennsylvania -1 (from 18 to 17) Rhode Island -1 (from 2 to 1) West Virginia -1 (from 3 to 2)

Apportionment is obviously very consequential for democratic representation (and partisan control of Congress), but there are additional, economic consequences of an undercount that are less well understood.

Andrew Reamer, Research Professor at George Washington University, has analyzed the fiscal impact of Census undercounts to states, and is producing a series of reports, Counting Dollars for 2020: The Role of the Decennial Census in the Geographic Distribution of Federal Funds. In this series, Reamer breaks down the various types of programs that receive federal funds, and estimates what per capita and overall costs would result from undercount estimates.

For example, in a recent analysis of five Health and Human Service programs that rely on the Federal Medical Assistance Percentage (FMAP) funding formula, Reamer showed how an additional 1% population undercount for Texas in 2010 would have resulted in a nearly $300 million loss in funding for these programs. That’s more than $1000 per person.

In upcoming reports, Reamer is working to analyze approximately 300 programs and $800 billion of funding that could be affected by a Census undercount. Moreover, he pointed out that there would be losses in both the public and private sectors that would be very difficult to quantify, given the importance of Census data that is linked to so many organizational decisions throughout the U.S. economy.

For example, consider all of the geographically specific demographic data linked to the identification of medically underserved areas, used to allocate support for medical programs, including physician training and funding for doctors to serve specific services. Errors in Census data, which are used to weight and design the sampling surveys that provide medical supply and demand information, could have far-reaching rippling effects throughout the economy.

“An accurate Decennial Census has a substantial impact on how the American economy functions,” noted Reamer, to “identify business opportunities, determine where to locate, and what to sell.” In addition to all of the market segmentation analysis that public-facing companies like Target and Walmart rely on to understand population characteristics and anticipate consumption patterns, businesses rely on Census-derived information (information that is not taken directly from the Census, but that builds on the basic population data provided by the Census) to make employment decisions, in order to invest in places with people who have the skills that they need to operate.

Small businesses use Census-derived data to make location and purchasing decisions, even if they don’t know it. Market analysis vendors repackage and augment this data when they provide consumer reports, consumer ratings, and the like to private and media clients. In short, there are very few areas of social or economic organization that are not impacted by the quality of Census data.

Professor Reamer’s next report will be a more complete listing of all federal financial assistance programs that rely on Census-derived data, hopefully released early this summer. You can follow the series at the George Washington Institute of Public Policy.

2°C or not 2°C? Unanswered Questions in ExxonMobil’s and Chevron’s Climate Risk Reports

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ExxonMobil refinery in Baton Rouge, LA.

Heading into their annual meetings at the end of this month, both ExxonMobil and Chevron have published reports in response to investor demands that they disclose their plans for a world in which global temperature increase is kept well below two degrees Celsius (2°C) above pre-industrial levels—the target set in the Paris Climate Agreement. Mounting mainstream expectations for better corporate climate risk disclosure have been reflected in shareholder resolutions and the recommendations of the Task Force on Climate-Related Financial Disclosure (TCFD).

Should ExxonMobil and Chevron shareholders be satisfied with these reports? No—and there are indications that some are not. I took a look at these reports, consulted with other UCS experts, and identified four big questions left unanswered.

1) When will they get serious about the Paris Climate Agreement temperature targets?

Both ExxonMobil and Chevron seem to bet against the world achieving the Paris Climate Agreement goal of keeping global temperature increase well below 2°C over pre-industrial times—and striving to limit warming to 1.5°C.

A former ExxonMobil executive recently criticized the reports for “assum[ing] that governments won’t succeed in meeting their Paris Agreement commitments, resulting in financial outlooks that leave them free to sell all their fossil fuel assets.”

ExxonMobil admits that the emissions trajectory of its Outlook for Energy (which does not extend to 2100) “closely approximates in shape” an emissions profile of the Intergovernmental Panel on Climate Change (IPCC) that “would result in an average global temperature increase of approximately 2.4 °C by 2100 from the industrial age.”

ExxonMobil’s “2018 Energy and Carbon Summary: Positioning for a Lower-Carbon Energy Future” presents a false choice between curbing climate change and solving other pressing problems, warning that “Inefficient approaches to address the risks of climate change can divert resources and detract from society’s ability to address other important priorities” such as poverty, education, health, and security.

Like ExxonMobil, Chevron also emphasizes potential conflicts rather than synergies between climate solutions and other societal goals: “As we work to address climate change, we must create solutions that balance environmental objectives with global economic growth and our aspirations for a better quality of life for people across the world.”

Under new CEO Michael Wirth, Chevron seems to be sticking with the same old business plan. Its report, “Climate Change Resilience – A Framework for Decision Making,” states that “Chevron’s views on the future energy mix are generally aligned with prominent third-party projections like the IEA’s [International Energy Agency’s] NPS [New Policies Scenario].” The NPS takes into account Nationally Determined Contributions (NDCs) under the Paris Agreement—with modifications such as the announced U.S. withdrawal—commitments that are acknowledged to fall far short of what is needed to meet the agreement’s global temperature goals.

Does Chevron urge greater ambition to keep global warming well below 2°C and transform our energy system? Um, no. Far from it. Instead, the company dismisses the notion of a peak in oil demand as unlikely on the basis that “a series of critical demand-reducing factors would need to occur simultaneously, apply across the entire slate of oil products and move at an unprecedented pace. Such a confluence of events in the next two decades would represent a historic and unprecedented revolution.” Wasn’t the Paris Agreement intended to spark just such a revolution?

2) Why do they bank on burning like there’s no tomorrow?

In UCS’s 2016 Climate Accountability Scorecard, both ExxonMobil and Chevron scored “poor” in the area of Planning for a World Free From Carbon Pollution. Look for a Scorecard update later this year.

If fossil fuel companies support achieving net-zero carbon emissions by shortly after mid-century, they should commit to reaching net-zero with their own emissions, right?

Wrong. Neither ExxonMobil nor Chevron seems to envision much disruption to the business of extracting, refining, and marketing fossil fuels.

In response to a 2018 shareholder proposal, Chevron goes so far as to “… disagree with the premise… that future diversification of energy sources requires all energy producers to curtail production of fossil fuel resources and/or to diversify their portfolios proportionately. A decrease in overall fossil fuel emissions is not inconsistent with continued or increased fossil fuel production by the most efficient producers. We believe Chevron is a capable and efficient energy producer, well positioned to participate in meeting future energy demand regardless of other energy sources that may become competitive.” (Unfortunately for Chevron, its competitors seem to have a similar “Survivor: Fossil Fuel Industry” mentality about 2°C scenario planning.)

Meanwhile, ExxonMobil anticipates that over 90 percent of its year-end 2016 proved reserves will have been produced by 2040, and believes “these reserves face little risk.” The company expects to sink substantial cash into developing the remaining 10 percent over the next couple of decades, such that “the production of these reserves will likely remain economic” even under a 2°C scenario.

Still, both ExxonMobil and Chevron admit that some of their assets may not be profitable to develop in a world where temperature increase is kept well below 2°C:

  • ExxonMobil allows that “some higher-cost assets, which could be impacted by many factors including future climate policy, may not be developed,” but estimates that these assets account for less than 5 percent of the company’s total property value.
  • In a sidebar headlined “The ‘stranded assets’ theory,” Chevron acknowledges the possibility that not all oil and gas assets will get produced. In a discussion of stress-testing its portfolio against the IEA’s Sustainable Development Scenario, Chevron tacitly admits that several of its projects may not be profitable in a low-price environment, noting that they will generate cash but not necessarily earnings.
3) How about transparency we can use?

Both ExxonMobil and Chevron talk a good game about transparency in these reports. ExxonMobil shares more information about its energy forecasts; Chevron focuses more on strategy and includes some asset-level disclosure.

However, it is difficult to extract and compare the assumptions underlying both reports. For example, although ExxonMobil and Chevron are both defendants in lawsuits by a dozen communities seeking to hold them accountable for climate damages and adaptation, ExxonMobil’s report fails to acknowledge the rise of climate liability litigation as a potential risk to its business. (Chevron acknowledges the lawsuits but dismisses them as “factually and legally without merit”).

Greater transparency on metrics such as emissions along the supply chain, internal use of carbon prices, and investments in low-carbon technology research and development is necessary in order to make meaningful comparisons among different fossil fuel companies’ 2°C scenario plans, and to assess each company’s progress toward its stated commitments. (Read my colleague Jeremy Martin’s blog about why improved transparency along the oil and gas supply chain matters).

As issuing 2°C reports becomes the norm for companies across the oil and gas sector, investors must demand comprehensive, consistent, and comparable disclosures. Standard-setters like Task Force on Climate-Related Financial Disclosures (TCFD), CDP (formerly Carbon Disclosure Project), and the Sustainability Accounting Standards Board (SASB) have a role to play—and so do regulators like the Securities and Exchange Commission (SEC).

4) What’s behind the PR Fanfare about Low-Carbon Investments?

Both ExxonMobil and Chevron fail to set targets for reducing heat-trapping emissions—a glaring omission in any fossil fuel company’s consideration of its plans for a low-carbon world. They also fail to identify opportunities to play a leading part in the clean energy economy.

Chevron emphasizes “flexible investment strategies” and claims that “setting targets, such as investing a predetermined percentage of renewables within our asset base, could limit our ability to select the most profitable energy development opportunities.”

ExxonMobil is laughably lacking in ambition with regard to renewables, highlighting its role as a supplier of lubricants for wind turbines. As my colleague John Rogers (no stranger to wind turbines) observed,

While lubrication is important, in the context of ExxonMobil’s anti-climate activities, this seems akin to taking credit for a skyscraper project because you supplied the signs for the restroom doors… while simultaneously taking a jackhammer to the building’s foundations under cover of night.

Both companies tout their investments in low-carbon research and development—sums that are a pittance in comparison with their spending on oil and gas exploration and infrastructure. For example (thanks to my colleague Nicole Pinko for number-crunching):

  • ExxonMobil reports spending more than $8 billion since 2000 to develop and deploy higher-efficiency and lower-emission energy solutions across its operations—less than 2 percent of its capital and exploration expenditures during the same timeframe.
  • Chevron says it has invested more than $75 million in carbon capture and storage (CCS) research and development over the past decade—well under 1 percent of its capital and exploration spending during that time. The company also reports $1.1 billion of investment in two projects—Quest in Canada and Gorgon in Australia—that include CCS. Impressive? Not compared with Chevron’s $20+ billion annually in capital and exploration spending over the past couple of decades.

ExxonMobil’s and Chevron’s climate risk reports are by no means their only vehicles for misleading PR about their roles in a clean energy economy. Watch UCS scientists Dr. Gretchen Goldman and Dr. Astrid Caldas react to recent fossil fuel industry ads. Learn more > 

 ExxonMobil’s and Chevron’s climate risk reports illuminate the far-reaching risks of these companies’ reliance on ever-increasing sales of fossil fuel products. Now is the time for consumers, investors, public prosecutors, policy makers, and others to demand answers to the above questions, and insist that major fossil energy producers use their enormous resources and technical capacity to make real plans for a 2°C world.

UCS will be at the ExxonMobil and Chevron annual meetings at the end of May, highlighting these gaps and following up on these outstanding questions. Look for upcoming blogs delving further into major fossil fuel companies’ reporting and disclosures, incorporating insights from several of my UCS colleagues.


How Trump’s Proposed Cuts to the EPA’s Science and Technology Budget Endanger Our Health and Safety

UCS Blog - The Equation (text only) -

Photo: Pesticide Action Network

Most people have a vague understanding of what our nation’s Environmental Protection Agency (EPA) does. Some people may have memories of killer smog and rivers on fire and how badly our air and water were contaminated in the not-so-distant past. They may know that the agency is somehow responsible for ensuring that our air and water are clean, that our land and treasured natural resources are protected, and that our health is not damaged by toxic chemicals and pollutants. 

Because the environment is a critical determinant of human health, the EPA is really a public health agency, with environment in its name. And science plays a fundamental and essential role in its ability of to fulfill its responsibilities to the American public.

With hearings and debates on the fiscal year (FY) 2019 federal budget getting underway in Congress, we are once again working to defend the budget of the EPA against attacks from the Trump administration and some in Congress. We are paying particular attention to the science and technology (S&T) component of the EPA budget because of the fundamental role that science plays across the agency in its mission to protect our health and the health of our environment.

Rather than cutting the resources for critical programs, our leaders should be boosting investment in them.  Here’s why.

Understanding the EPA’s Science and Technology account

The S&T account: It may sound esoteric and parsing this budget component can certainly be daunting. But what it covers and the benefits it brings us are easy to understand. Essentially, the S&T account funds science-based research throughout the agency.

Here’s just a snapshot of the programs, activities, and research and development efforts that fall under this EPA budget category—along with some info on what the Trump administration is proposing for them in FY19. These budget proposals are chilling and, if implemented, would certainly hamper the EPA’s ability to fulfill its mission.

Proposed Budget for EPA Science and Technology Account (Dollars in Thousands)*

Clean air:  Know someone with asthma, heart, or respiratory disease?  The S&T account is critical to their health. It supports EPA efforts and activities to monitor air quality levels, estimate population exposure to air pollutants, examine the effects of air pollution on public health, track progress in improving air quality and reducing associated risks, and provide models, tools, and technical guidance to states. The EPA is our nation’s primary source of atmospheric data on acid deposition, regional ground-level ozone, and other forms of particulate and gaseous pollutants that put our families and communities at risk.

And that pollution from cars, trucks, buses, nonroad vehicles (such as farm and construction equipment)—and the fuels that power them? The S&T budget is critical to developing and implementing standards to control their harmful emissions, as well as evaluating new control technologies. It allows the EPA to provide information and tools to states, local, and tribal agencies, as well as communities, to reduce air toxics emissions and risks specific to their local areas.

The S&T budget also supports our National Vehicle and Fuel Emissions Testing Laboratory—a state of the art facility and national resource in Ann Arbor, Michigan that conducts the research and testing needed to develop and ensure compliance with tailpipe emissions standardsthe safeguards that control and protect us from breathing in harmful chemical and particulate pollutants from transportation sources. And remember the news that Volkswagen and  Audi were cheating on their US emissions tests by installing software in their  diesel cars?  It was our national Vehicles Lab that confirmed it and then recalled the offending vehicles.

Recent analysis has shown that the public will reap clean air benefits to the tune of $2 trillion (that’s trillion with a T) by the year 2020, compared to estimated costs of $65 billion in the same time period. Given that clean air is absolutely essential to our health and EPA efforts around clean air have been one of EPA’s biggest public health success stories, it’s pure folly to entertain cuts to these efforts. To keep them robust and up-to-date, increases in funding make much more sense. But President Trump has proposed cutting $30,845,000 from EPA S&T programs that focus on clean air. That’s 27% cut from the final budget passed in FY18. That certainly won’t help us breathe any easier!

Indoor Air: The administration is proposing to eliminate two indoor air programs funded by the S&T account and shift the responsibility of protecting families from exposure to indoor air pollutants back to the states. These include the radon program and the program to reduce risks from indoor air. Radon is a known human carcinogen and a significant cause of lung cancer, even at low exposure levels.

Other indoor air contaminants also pose health risks, and the EPA has been conducting and coordinating research on indoor air quality, doing field testing, and providing information and technical support to states and localities. As the EPA seeks to increasingly shift responsibility back to the states, it’s reasonable to question if the states will have the resources and capacity to address radon and other indoor air pollution in residents’ homes and living spaces and adequately help protect them from the associated health effects.

Given the public health significance of indoor air pollution and the fact that we spend the vast amount of our lifetimes indoors, what we really need to see is increased funding to support research and technology to reduce the health risks to our children, our families, and our communities.

Emergency Response Preparedness:  When emergencies and disasters strike, we expect our federal agencies to be ready to respond. Through its Homeland Security sub-budgets, the S&T account at the EPA ensures that the agency (and thus we the affected public) will have the science, analyses, sampling, and measurement capacity needed to respond to radiological or nuclear incidents, to oil and hazardous substance emergencies, to terrorist and cyber threats, and to all-hazard events on our nation’s critical water infrastructure.

The EPA is responsible for remediating contaminated environments affected by industrial accidents, natural disasters, and terrorist attacks. The S&T budget supports the research needed to fill the critical gaps in the EPA’s ability to carry out these responsibilities and help communities prepare for, absorb, and recover from disasters.

Given the many serious chemical emergencies experienced by our communities in just the past few yearslike explosions at oil refineries and chemical plantsalong with the health impacts, social disruption, and property damage caused by these events and by the increasing ferocity of extreme weather events like hurricanes, wildfires, and floods it is critical to ensure that the agency has the funding it needs to help us prepare, respond, and recover effectively when disaster strikes.

Pesticides: By design, pesticides are meant to killpests. But they are dangerous neurotoxins that can and do kill and sicken people as well. A 2012 study of human exposure to pesticides in the US reported an average of 130,136 calls to poison control centers from 2006 to 2010, with an average of 20,116 cases (17.8%) treated in health care facilities annually. The Agency for Health Care Quality and Research reported an annual average of 7385 emergency room visits during 2006 to 2008, and 1419 annual hospitalizations during 2005 to 2009. Between February 2016 and February 2017, 2,577 pesticide exposure incidents were reported by the National Pesticide Information Center.

The EPA is responsible for registering and re-evaluating pesticides to protect consumers, pesticide users, and workers who apply them, as well as children and other sensitive populations. The agency’s Chemical Safety, Pollution Prevention and Pesticide program relies on the science and analytical capability of two of its laboratories to evaluate possible adverse effects of pesticide use and determine the risks they pose to public health. EPA pesticide programs also use the latest science and conduct risk assessments to determine the risks that pesticides pose to human health and ecological effects on plants, animals, and ecosystems that are not the targets of the pesticide. The agency also has responsibilities under the Endangered Species Act related to pesticide use. Despite all this, the administration is proposing to cut the EPA pesticide licensing program by 15%.

Research: While most if not all of the above mentioned programs include analytical components, EPA’s S&T account specifically identifies several budget categories as research. These include:

  • Air and Energy Research provides scientific information to EPA programs and regional offices. This line item supports the analysis and publication of research to disseminate EPA research findings on air quality, emissions, and health impacts across all 50 states. It is the scientific cornerstone on EPA efforts to identify and recommend action to reduce air pollution, including the health disparities of air pollutants, and to protect the health and well-being of the American public.Our communities, local and state officials, public health agencies, and health care institutions rely on the findings of this research to stay informed and take necessary action. In this year’s proposed budget, down by a whopping 66%.
  • Chemical Safety and Sustainability Research evaluates how the use and disposal of thousands of chemicals, both existing and under development, might affect public health and the environment. This research provides the fundamental information, tools, and methods needed to make better-informed and more timely decisions about the chemicals in use in the USincluding those used in our homes, schools, and workplaces and that find their way into our consumer products, household items, water, and food.It also supports the Integrated Risk Information System (IRIS), the gold-standard of toxicity reviews that provides critical and impartial information on cancer and non-cancer health risksindependent of its use by EPA programs and regional offices. In FY18, the administration proposed eliminating IRIS, but Congress did not agree and provided IRIS with level funding. In its FY19 proposal, the administration plans to “review” IRIS, including moving from traditional IRIS assessments to “fit-for-purpose” products to ensure risk assessments remains responsive to stakeholders/partners. This modification will surely be welcome news to the agency’s industry stakeholders; not so much for their public, community, and public health stakeholders.In this year’s proposed budget, the chemical safety and sustainability research line is down 33%.
  • Safe and Sustainable Water Resources Research provides the robust research and scientific analysis needed to inform policy making under the Safe Drinking Water Act and Clean Water Act. This is the essential research needed to ensure that the water in our lakes, streams, and rivers are healthy and safe enough to drink, to fish, and to enjoy for swimming and boating. The program develops analytical methods for detecting emerging contaminants, and develops sampling protocols and risk models to help states and communities protecting human health from well-known contaminants, like lead in drinking water. One needs only to reference Flint to understand the critical importance of this research program.
  • Sustainable Communities Research supports regulatory activities and provides on-demand technical support for federal, tribal and state-led cleanup activities and during emergencies. It conducts health, environmental engineering, and ecological research, translating their findings into planning and analysis tools for communities to improve environmental and health outcomes. For example, program researchers found a way to estimate how drinking water, food, dust, soil, and air contribute to the lead levels in the blood of infants and young children. Communities take note: The administration proposes to cut this research program by 60%.
Our national labs

EPA’s Office of Research and Development (ORD), supported by the S&T Account, supports three national labs and four national centers located in 14 facilities across the country. The experts in these labs and centers are the linchpins of research and development efforts that inform the EPA programs and efforts described above. They are also members of their local communities, maybe even your neighbors.  Locations include: Ada, OK; Athens, GA; Chapel Hill, NC, Cincinnati, OH; Corvallis, OR; Duluth, MN; Edison, NH; Grosse Ile, MI; Gulf Breeze, FL; Las Vegas, NV (soon to be shuttered); Narragansett, RI; Newport, OR; Research Triangle Park, NC; and Washington, DC.

Despite the centrality of ORD research to our public health, environmental quality, and emergency preparedness, President Trump has proposed cutting its FY19 budget by 46% and staffing levels by 37% compared to the FY18 annualized continuing resolution budget. Ask yourself: Does this ensure that EPA has the robust and necessary resources and expertise to meet the scientific challenges of the future? To me, this looks more like a giant step backwards.

From Alaska and Hawaii to the lower 48: cause for concern

No matter where you call home in this vast and beautiful country, we can likely all agree that our health, our communities, our air, land, water, our treasured landmarks, and our critical environmental resources need safeguarding and protecting. The song says, “This land is our land.” We need to remember that “this EPA is our EPA”we the people are meant to be the primary beneficiaries of its mission. Not the regulated industry.

Air pollution remains a significant risk for cancer, cardiovascular disease, respiratory illness, and premature death across the country. More than half of all Americans166 million peoplelive in counties where people are exposed to unhealthful levels of air pollution. Fairbanks, Alaska was ranked #1 for annual particulate pollution out of 187 metropolitan areas and #4 for 24-hour particulate pollution out of 201 metropolitan areas. Los Angeles – Long Beach, CA ranked #1 for high ozone days out of 227 metropolitan areas, #7 for 24-hour particle pollution out of 201 metropolitan areas, and #4 for annual particle pollution out of 187 metropolitan areas.

A series of maps from UCS shows locations of facilities with reduced pollution control requirements and shows the potential emissions increases by congressional district.

And the recent EPA decision to strip away a key component of the agency’s “once in, always in” (OIAI) air pollution protection policy could result in increased emissions of toxic pollutants from major industrial sources in essentially every state. The Union of Concerned Scientists has produced an interactive map of industrial facilities with reduced pollution control requirements and potential emission increases by congressional district. A double whammy when coupled with the proposed cuts in EPA clean air programs and research.

Oh, and don’t get me started on EPA’s new proposal to restrict the science going into its decision-making. Actually, the science community has sounded the alarm loud and clearhere, here, and here.

Stand up for science at the EPA

The EPA is a critical component of our nation’s efforts to protect our health and the quality of the environment on which it depends. Without a robust scientific enterprise, it is hard to imagine how EPA can address the problems we are facing today, let alone the known and unknown threats we will be facing tomorrow.

The current administration’s proposal for resourcing science and technology at EPA reflects dangerous short-term thinking. Now is the time to weigh in and ask your legislators to oppose any cuts to the EPA S&T budget and to support an increase in funding for the critical scientific research and staff needed to protect and advance our health now and into the future.

Call your legislators today at 202-224-3121, and ask them to protect—and invest—in science at the EPA

Pesticide Action Network

EPA Eliminates Vital Protection to Keep Air Clean of Toxics, Threatening Our Health

UCS Blog - The Equation (text only) -

1973 EPA photo of a smokestack of the DuPont chemical plant on the Houston Ship Channel.

For decades, the Clean Air Act has protected us from the dangerous health effects of hazardous air pollutants (HAPs). Many of these are toxic, since breathing or otherwise ingesting them can cause cancer, as well as respiratory and degenerative neurological diseases that can lead to death. Some, like chlorine and clorhydric acid, can inflame the lungs and airways. Workplace exposure to styrene, a solvent frequently used to manufacture plastics and synthetic rubber, is linked to degenerative diseases like multiple sclerosis and others similar to Parkinson’s Disease. Thanks to strong federal rules that protect us from 187 toxic air pollutants, the EPA estimates that we have avoided emitting 1.5 million tons of these pollutants every year since 1990.

But the EPA, recently—and quietly—eliminated these protections. To the already long list of EPA actions that have undermined public protections and the extensive conflicts of interest of many of the agency’s political appointees, we can now add a new assault on our health and environment: the withdrawal of a long-standing policy known as “once in, always in” (OIAI). The change was made with no public comment and a muted announcement of a “reinterpretation” of the law. Eliminating OIAI will allow major sources of hazardous air pollutants like mining smelters and petrochemical manufacturing to discontinue the use of the maximum achievable control technologies (known as “MACT”) to control toxic air emissions.

In a previous post before UCS completed our analysis of potential impacts, I warned that the rule change would increase cancer-causing toxic air pollutant emissions. My colleague Dr. Gretchen Goldman also explained how environmental justice (EJ) communities—typically low-income communities of color already overburdened with environmental hazards in their neighborhoods—would be the most affected by this rule change. Sure enough, in our study we did in fact find that many of the communities where there are already high levels of toxic contamination will become even more exposed.

Let’s take the communities of Galena Park and Manchester along the shipping channel in Houston, TX as an example. Together with our partners—residents of these communities and activists of the EJ organization TEJAS, we showed some time ago that their health and livelihoods are already under assault due to the clustering of multiple industrial facilities that emit large quantities of toxic air pollutants. Legislative District 29 (TX-29), where these communities are located, currently has 15 facilities that have kept emissions under 25 tons per year through the use of MACT; eleven of these facilities could emit an additional 205 tons per year of toxic air pollutants as a result of the EPA’s new policy, which represents an increase of nearly 70 percent!

Some major sources of hazardous air pollutants such as the Deer Park chemical manufacturing in Houston, TX (a subsidiary of OxyChem), could increase its emissions of hazardous air pollutants from 0.64 to nearly 25 tons per year if it stops using MACT to control emissions.

The EPA’s new guidance will affect states very differently because some states have their own stringent toxic emissions limits, while others follow federal guidelines. The 21 states that only follow federal guidelines will likely be most affected by the new guidance as shown in our web feature. But all states rely on the federal designation to some degree so this problem will occur across the country.

How can you find out how impacted your area may be? You can check out a map we created showing how many facilities in your congressional district could increase toxic emissions. For example, if you click on Montana’s At-Large congressional district, a pop-up window will reveal that 9 out of 17 MACT-subject facilities in the district could emit 212 tons per year of hazardous pollutants, and that the state does not have any additional protections in place to limit toxics. If you scroll the pop-up a bit further down, you will find the name and office phone number of that district’s congressional representative. We encourage you to contact your congressional representative and ask them how they will demand that the EPA and your state’s environmental agency will protect public health from this dangerous new change.

Take action

There are many ways you can speak up about the concerns you have about the potential for the facilities in your community to release hazardous air pollutants due to this reduction in public protections.

  • If you live in a state where toxic air pollution might increase, push your state legislators to enact stronger state-level laws to protect your community from toxic air pollutants. Below are some ways to engage – consult these tips on communicating with policymakers.
  • Inquire with your state air agency how your area might be affected by the changes to the “once in, always in” mandate. Find your state agency on the EPA site.
  • Utilize the media to bring attention to the issue. Write a letter to the editor, Op-Ed, or meet with local journalists or editorial boards about your concerns. See these tips on best practices.
  • Directly contact the company that operates the facility near you, and ask them to commit to maintaining their classification and use of MACT technology and requirements. Follow up if you don’t hear back in a week and utilize their response (or lack thereof) to hold them accountable for their actions, and/or to show the media, your policymakers, and the public what they are saying.
  • Tell EPA Administrator Scott Pruitt to do his job of carrying out the EPA’s mission of protecting public health and the environment by rescinding the new guidance.
    • Tweet at EPA Administrator Scott Pruitt, the EPA, and tag your members of congress.

Want to receive the latest information on federal attacks to our health, safety, and environmental protections, and customized opportunities for you to push back and advocate for science? If you’re a scientist or technical expert, you can do so by joining the Science Network’s watchdogging initiative. If you’re an advocate within your local community, join the cadre of Science Champions.

Science — The Hidden Gem at the Heart of the EPA and Why You Should Support It

UCS Blog - The Equation (text only) -

Photo: skynesher/iStockphoto

The role of science in EPA decision-making might, in the vocabulary of former President George W. Bush, be the most “misunderestimated” part of the EPA’s job. Although their work is the foundation of virtually every EPA decision—from regulatory protections to reviews of new chemicals to Superfund cleanups—agency scientists have labored for years under the radar. Career and political professionals appreciate and routinely rely on their work, but their invaluable contributions remain largely invisible.

Not any longer. Scott Pruitt’s obvious distaste for science has pushed EPA science into the headlines. We’ve gone from a norm in which a top-ranking EPA science policy figure was on virtual speed dial to the administrator to a Pruitt-era multi-faceted attack on the scientists themselves. Initially Pruitt ignored them, then tried to defund them, and is now attempting to hobble their work.

An attempt to slash the EPA’s Science and Technology Account

Let’s start with the 2019 Trump/Pruitt proposed budget, which is virtually identical to their 2018 proposal that was fortunately soundly rejected by the Congress. The 2019 budget would cut the EPA’s Science and Technology budget by 49%. The specifics—all programs funded by the S&T Account that President Trump proposes cutting—illustrate the insult to the health and safety of the American public.

  • A 67% cut to the “Air and Energy” account that looks at how air pollution damages our health and well-being. This is essential information as the EPA decides which pollutants must be reduced and at what levels, and prepares the country to respond to climate change. The Trump budget would ax these programs despite analysis showing that since 1990 the American public has reaped clean air benefits to the tune of $2 trillion compared to estimated costs of $65 billion. Need one good example? This program helps advance the development and use of lower-cost, portable, and user-friendly monitoring devices individuals can use in their own communities to find out what they and their families are breathing. Why cripple one of the EPA’s biggest public health success stories when we actually need to be investing more in our clean air?
  • A 37% cut in “Safe and Sustainable Water Resources” to protect the lakes, streams, and rivers across our country from which we get drinking water and where we fish, swim, and boat. This research is an essential part of making sure water bodies are healthy, that valuable water isn’t overwhelmed by pollution from factories and other industrial processes. You only have to look at the role of EPA scientists in monitoring and evaluating algae blooms in Toledo, Ohio that endangered drinking water for millions of people, or Flint, Michigan’s problems with lead in drinking water to understand why this account should be funded at even greater levels than it is today.
  • A 61% cut in “Research on Sustainable Communities.” Cities and states across the country rely on the research and planning tools developed in this program as they go about their jobs assuring good environmental and health outcomes. This research also develops and demonstrates new and improved techniques for environmental protection. For example, program researchers found a way to estimate how drinking water, food, dust, soil and air contribute to blood lead levels in infants and young children.
  • A 34% cut in “Research on Chemical Safety and Sustainability” to evaluate how thousands of chemicals, existing and under development, might affect people’s health and the environment. This research allows the EPA to develop the scientific knowledge, tools and models to conduct integrated, timely, and efficient chemical evaluations. Getting a bit wonky here—because I was personally involved in this effort and watched it grow from a concept to being the international leader in innovating approaches to chemical hazard: this account supports the EPA’s work in computational toxicology, which in turn helps the EPA take on the herculean task assigned it by the 2016 Lautenberg amendments to the bipartisan Toxic Substances Control Act to analyze possibly thousands of chemicals for potential risk. The tool integrates knowledge from biology, biotechnology, chemistry, and computer science to identify important biological processes that may be disrupted by the chemicals and thereby sets priorities for their review based on potential human health risks. Risking that program should be a non-starter.
  • Completely eliminating Science to Achieve Results (STAR) Grants that support outside researchers for cutting edge work in all of the areas above.
Political takeover of science

Scott Pruitt’s most recent attack on science at the EPA is a back-door attempt to institutionalize a very damaging idea that has failed to be enacted by Congress over multiple years. Pruitt is trying to railroad through a regulation that would throw out scientific studies used in setting EPA rules and other requirements unless the raw data on which the studies are based are made publicly available.

Why is this a terrible idea and threatening to public health? For five decades, EPA’s regulatory protections have relied on many thousands of health-related studies of pollutants, including epidemiological, human, and animal studies. Many examine the relationship between concentrations of various pollutants and their impacts on people’s health.

The raw data on which these studies are based often includes names, dates of birth and death, health, lifestyle information, and subjects’ locations—data that is personally damaging if released and has almost nothing to do with public understanding or the validity of the study’s results. Ethical and legal considerations rightly keep scientists from releasing such personal data. Restricting the use of the data cuts two ways, as often it is submitted by industry in support of its activities as well by groups that are arguing for more stringent regulatory controls. There are certainly ways to confirm independently the validity of the studies as has been done with two keystone air quality studies by the Health Effects Institute (HEI), an organization jointly funded by EPA and the industry.

The Pruitt proposal creates other problems as well: so much time has passed since the leading studies of the impacts of air pollution were compiled in the early 1990s that it would be logistically difficult to retrieve and redact all of the underlying data; this would effectively prevent the use of the most authoritative data available on the impacts of air pollution.

Put in plainer language, Pruitt’s latest attack on science is not good for anyone—industry or the general public.

Attacks on science hit locally

There are many practical, local examples of why cutting science funding is so pernicious and bad for everyone. The EPA, for example, plays a role in the cleanup of Anchorage, Alaska’s Elmendorf Air Force Base and for that had the assistance of another federal body, the Agency for Toxic Substances and Disease Registry (ATSDR), which examined blood samples taken from residents at the base. ATSDR concluded on the basis of science that lead exposure there did not pose a health hazard. There is no way to make such determinations without science and data, in this case medical data such as blood sample test results, which are critical in drawing valid conclusions as to whether regulated facilities, such as Superfund cleanup sites, cause health effects in nearby communities.

Another notable example is the remote native village of Kivalina in Northwestern Alaska, which is downstream from Red Dog Mine. Unsurprisingly, Kivalina residents are worried about how mining activities might threaten their health by contaminating subsistence foods from their hunting and gathering activities. Personal medical data taken from Kivalina residents was analyzed to determine that Kivalina residents and their food are unlikely to be at risk. The same form of analysis of environmental impacts has been used at other sites such as the long-running cleanup efforts of asbestos contamination in Libby, Montana.

The EPA’s seminal achievements over almost 50 years include removing lead from gasoline; reducing acid rain to improve water quality; reducing second-hand smoke exposure; improving vehicle efficiency and emission controls; and encouraging a shift to rethinking of wastes as materials.

Evaluating and acting on science—the best available science—and having the funding to ensure science expertise is on tap at the EPA is the linchpin to any one of these. Congress and the American public should tell Pruitt to back off from his attacks on EPA science and make sure the agency has the funding it needs to do its job.

Robert Kavlock is the former Acting Assistant Administrator for the EPA Office of Research and Development and an EPA Science Advisor (retired). He is currently a member of the Environmental Protection Network, a nonprofit organization of EPA alumni working to protect the agency’s progress toward clean air, water, land and climate protections.


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