UCS Blog - CSD (text only)

A Poisonous Frog in the Barrow: Department of Justice Actions Undermine Public Health and Safety

Photo: Quartl/CC BY-SA 3.0 (Wikimedia)

In my opinion, the quote of the week last week came from Chicago Tribune reporter Steve Chapman, who wrote, “Trying to point out the mistakes, transgressions and failures of the Trump administration is like trying to load frogs into a wheelbarrow. For every one you get, a dozen get away.” A particularly poisonous frog that the Administration just hatched is a seemingly obscure change in Department of Justice policy with regard to civil lawsuits brought by the government to enforce our fundamental laws.

The Justice Department has now said that their attorneys “may not use noncompliance with guidance documents as a basis for proving violations of applicable law.”

Agency guidance

The fundamental task of every federal “mission” agency (e.g. EPA, NOAA, US Fish and Wildlife Service, etc.) is it implement the statutes that Congress has passed and that have become the law of the land. Pollution protections are put in place pursuant to the Clean Air Act, or Clean Water Act or another statute. And the same goes for environmental protections, worker safety rules, fair labor standards and on and on. Suffice it to say that nothing happens when Congress passes a law until one or more agencies and their state, tribal and local partners implement and enforce it.

I doubt many people are shocked when I say that Congress is not always clear on exactly how implementing of the law should be carried out. Most legislation is a negotiated solution to a difficult societal challenge. Whether one likes the solution or not is beside the point. There are still many issues that need to be clarified. It is common practice for agencies to issue guidance documents that essentially say, “this is how we intend to interpret our task under the law.” Without question, such guidance doesn’t have the force and effect of law, but it does what the name implies, guide agency actions, the public, and regulated industry.

Here is a concrete example from my time working at NOAA. Congress passed revisions to the Fishery Management and Conservation Act (FCMA), in fact several times. Each time Congress would instruct the agency to “end overfishing” or “minimize unwanted bycatch” (the catch that is incidental to fishing and is usually thrown away for various reasons), or “take the needs of communities dependent on fishing into account.” Those are important tasks that reflect societal choices that Congress has made on behalf of the nation. But what do they mean in practice?  NOAA Fisheries issued guidance essentially informing the public how the agency would interpret these congressional mandates in its regulatory and enforcement actions. And, these guidance documents were shaped by scientific information as well as guiding future scientific analyses and monitoring of the nation’s fisheries.

And after the guidance is issued or revised, fishery management plans, fishery enforcement actions and, yes, civil lawsuits use the guidance, as does the public, to make clear the agency’s interpretation of the law. In large part, guidance documents are critical to government transparency across a huge range of issues from natural resource management such as fisheries to civil rights, consumer protection and public health and safety.

What’s changed?

By directing Justice Department divisions and attorneys not to use agency guidance documents as a basis for enforcing the law, the Department has not clarified anything. Quite the opposite.

Many of the guidance documents that agencies have developed are in response to requests for clarification by industry, state, tribal or local agencies or the public. For example, the EPA has a large number of guidance documents related to the Clean Air Act that clarify how testing for air pollution should be done. Another is on requirements for response and enforcement during an air pollution emergency. A third is on the data requirements for states to report Clean Air Act violations. In each of these cases and many more, the guidance is intended to provide greater clarity and more specific standards than the language of the statute. But if the Justice Department won’t use these documents in bringing cases, the alternative is not less or simpler regulation, is it unclear or unenforceable rules.

This is a fair boon to attorneys defending regulated industry because it is another barrier to enforcement of public interest laws. Those barriers to enforcement signal an ongoing tilt of the playing field, toward industry—and particularly bad actors in industry—and away from the public. And ironically this was done by….wait for it….guidance from the Justice Department.

Photo: Quartl/CC BY-SA 3.0 (Wikimedia)

The Science of Voting Rights + An Interview with Matt Dunlap

Photo: Denise Cross Photography/Flickr

My first podcast with UCS has been posted this week, where we talk about the science of representation and the role that science plays in election law and voting rights. This was recorded before the new Pennsylvania Congressional map was released, so we don’t get into those details, but we do discuss gerrymandering, scientific standards for measuring it, and how science informs us about the consequences of choosing electoral institutions.  You can listen to the podcast here:

When Maine Secretary of State Matthew Dunlap agreed to serve on President Trump’s “Election Integrity” commission, election scholars, myself included, roundly criticized him for legitimizing a nakedly partisan attempt to indulge the President’s fantasies about why he failed to win the popular vote. It was clear from President Trump’s campaign trail rhetoric, and its partisan membership, that the Commission would be used as a vehicle to nullify the National Voter Registration Act and restrict voting access across the country.

But on December 22nd, 2017, when a federal judge ordered Commission Chair Kris Kobach to hand over records about correspondence that was concealed from Mr. Dunlap as a member, it was the beginning of the end.  By early January, the White House acknowledged defeat: “Rather than engage in endless legal battles at taxpayer expense, today President Donald J. Trump signed an executive order to dissolve the Commission, and has asked the Department of Homeland Security to review these issues and determine next courses of action.”

Mr. Dunlap’s pursuit of transparency is a crucial example of how a commitment to science-based policy and integrity can protect citizens from government agencies betraying the public interest. In early February, I sat down with Dunlap for an extended interview. We discussed his decision to serve, his experience as a member of the Commission, and the events that led to his lawsuit against the Commission. Below is part of our interview.

 

https://blog.ucsusa.org/wp-content/uploads/Dunlap-Blog-Embedd.mp3

 

In the future, we will also share our conversation with Dunlap about his role as top election official in the first U.S. state to adopt Ranked Choice Voting (RCV), which will make its debut in the Maine June primary.

There Are Better Things in France for Trump to Emulate Than a Military Parade

President Trump and French President Emmanuel Macron review French troops during the Bastille Day parade in Paris last July.

 

President Trump was so impressed by the military parade he saw in Paris on Bastille Day last July that he ordered the Pentagon to plan a bigger one for Washington, D.C.

“It was one of the greatest parades I’ve ever seen,” Trump told reporters when he met with French President Emmanuel Macron in New York in September for the opening of the UN General Assembly. “It was two hours on the button, and it was military might, and I think a tremendous thing for France and for the spirit of France. We’re going to have to try to top it.”

Of course Trump wants to top it. All things Trump are always “huge,” from his inauguration day crowd to his nuclear button to his tax cut. But if the president really wants to outdo France, below are some tremendous French things that the United States would do well to emulate.

The French are safer

After the mass shooting last week at a Florida high school, Trump tweeted his “prayers and condolences” to the victims’ families. His initial comments also focused on mental health, not guns, despite the fact that early last year he signed a bill revoking an Obama-era rule that made it harder for mentally ill people to buy firearms.

The French, by contrast, do a lot more than offer empty platitudes: They have stringent gun laws. French citizens who want to buy a gun have to apply for a hunting or sporting license, which requires a psychological evaluation and, if acquired, must be renewed every five years. Gun sales, meanwhile, are tightly regulated and require official background checks.

Stricter controls definitely make a difference: France has significantly fewer guns in civilian hands and fewer gun-related deaths per capita than the United States.

In 2013, for example, there were an estimated 10 million guns, both legal and illegal, in France, which at the time had a population of 66 million. That year, 1,750 people were killed by firearms, amounting to 2.65 deaths per 100,000 people.

By contrast, the United States, with a population of 316.2 million in 2013, had an estimated 357 million guns in circulation—more than one gun per person. That year, there were 33,636 US gun deaths, or 10.64 deaths per 100,000—four times the rate in France.

They’re healthier, too

White House doctor Ronny Jackson assured Americans in January that President Trump is in “excellent health.” Given the results of Trump’s physical exam, that’s debatable, but the health of the US health care system is not. It’s in bad shape, especially when compared with France’s.

France’s public-private hybrid health care system is consistently rated among the best in the world. Last year, for example, France placed 18th in the health category in the Legatum Institute’s annual Prosperity Index, which ranks 149 countries on health outcomes, economic performance, education quality, and six other categories. The United States health care system, meanwhile, came in 30th.

Like every other industrialized nation besides the United States, France has universal health coverage. All French citizens are covered by the government’s Assurance Maladie, and most also have private insurance through their job or the private market. The government sets prices for appointments and procedures and reimburses them at 70 percent. It’s similar to Medicare and Medicaid, but because the system covers the entire population, the French government has more leverage to keep prices low.

The United States spends more than twice per capita on health care than France, but French babies have a better chance of staying alive and living longer than American newborns. France’s infant mortality rate, according to 2015 World Health Organization (WHO) data, is 3.2 deaths per 1,000 live births. At 5.7 deaths per 1,000 live births, US infant mortality is higher than in any comparable industrialized democracy. And at the end of life, France boasted a combined male and female life expectancy of 82.4 years, putting it in 9th place in a 2015 WHO survey. The United States, by contrast, ranked 31st, with a combined life expectancy of 79.3 years.

They eat better

France’s obesity rate is 15.3 percent, slightly better than the 15.9 percent for the entire European Union. By contrast, nearly 38 percent of American adults are obese, including President Trump, who apparently fudged his height to avoid being classified that way.

French and US stats on food and farming tell a similar disparate story. In 2017, France ranked No. 1 for the second year in a row in the Food Sustainability Index, which grades 34 countries worldwide in three categories: food loss and waste, nutrition policies, and sustainable agriculture. It bested every other country in reducing food waste and came in fourth in nutrition on the strength of its programs that promote healthy diets. In the sustainable agriculture category, it placed third, largely due to a national agro-ecology program that, among other things, is encouraging farmers to cut their pesticide use in half by 2025 and rotate their crops to increase soil fertility.

The United States, conversely, ranked 21st overall, mainly because of policies that cultivate bad eating habits and destructive industrial farming practices. The fact that Americans consume high levels of meat, saturated fat and sugar placed the United States 24th in the nutrition category. Only Australians eat more meat than Americans, but not by much, and US sugar consumption is the highest among all of countries in the study. The result? More than 40 percent of American children are overweight, the most in any of the countries surveyed.

At 31st out of 34, the US ranking for sustainable agriculture is even more worrisome. Only India, Tunisia and the United Arab Emirates ranked lower. The low US score is attributable to a number of factors, including livestock production, which strains water resources and emits methane, and the fact that a tiny fraction of agricultural land is devoted to organic farming while nearly a quarter is used for biofuel production and animal feed.

They make education more affordable

France starts children off with free, universal preschool at écoles maternelles. With 100 percent preschool enrollment for 3- to 5-year-olds, the country ranked first among developed countries in 2014, according to the Organization for Economic Co-operation and Development (OECD), an international association.

The United States, where some states offer preschool programs from age 4 but most offer nothing at all, ranked 36 out of the 40 nations OECD surveyed. In 2015, only about a third of American 3-year-olds and 60 percent of 4-year-olds were enrolled in preschool programs, according to the National Center for Education Statistics.

Most schools of higher education in France, meanwhile, are state-subsidized, which keeps tuition relatively low, even by European standards.

In 2007, the average public university in France charged $234 per year (189 euros) for a bachelor’s degree, $321 for a master’s degree, $487 for a doctorate, and $757 for an engineering degree. The average bachelor’s degree takes three to four years, so students spend $702 to $936 for their entire undergraduate education. There are pricier options, but compared to the cost of higher education in the United States, they are still a bargain.

The United States is home to the most prestigious colleges and universities in the world, but they are also among the most expensive. The average cost of tuition and fees for the 2017–2018 school year was $34,740 at private colleges, $9,970 for state residents at public colleges, and $25,620 for out-of-state residents attending public universities, according to the College Board.

The high cost of a college diploma saddles American grads with debt that can dog them for much of their adult life. Currently there are more than 44 million borrowers with more than $1.4 trillion in student loan debt, which after home mortgages is the highest consumer debt category in the United States. For the class of 2016, the average student loan debt was $37,172.

They treat workers better

The national minimum wage in France is 9.88 euros an hour, the equivalent of $12.25 an hour in the United States. The US national minimum wage is $7.25 an hour, although some states and municipalities now require as much as $15.

The official work week in France is 35 hours, so a French employee making minimum wage would gross the equivalent of $22,297 a year and is entitled to health care coverage, a minimum of five weeks paid vacation and 11 national holidays, as many as 90 days paid time off, and a maximum of three years of medical leave pay, which is covered by the state social security system. Maternity leave, which is at least six weeks before childbirth and 10 weeks afterward, is paid.

Most minimum wage employees in the United States working 40 hours a week gross $15,080 a year. Employers with more than 50 employees are required to offer health care benefits or pay a penalty, and most provide only two weeks paid vacation along with 10 federal holidays. Employers with 50 or more employees also are required to grant up to 12 weeks of unpaid maternity (or adoption) leave or family sick leave.

At the other end of the pay scale, US CEOs make considerably more than their counterparts in other industrialized countries when compared to what average workers earn. In 2014, the ratio between CEO and average worker pay in the United States was 354 to 1, meaning that for every dollar an employee got paid, the head of the company made $354, far outpacing the 148 to 1 ratio in Switzerland, the country with the second highest pay gap. In France, the ratio was 104 to 1.

They’re downplaying the role of nuclear weapons

France, which has always maintained a much smaller nuclear force than the United States, currently has a total of 300 warheads deployed on submarines and bombers. In the 1990s, it eliminated its land-based missiles and signed and ratified the Comprehensive Test Ban Treaty (CTBT).

The United States, conversely, has some 1,590 deployed strategic nuclear warheads on submarines, bombers and land-based intercontinental ballistic missiles (ICBMs), as well as 2,390 redeployable warheads currently stored in a “hedge” stockpile, some 500 smaller deployed and stockpiled tactical (battlefield) warheads, and an estimated 2,300 retired warheads slated for dismantlement. The United States signed the CTBT the same time France did, but 22 years later, the US Senate has still not ratified it.

ICBMs pose a big problem. The United States keeps them on hair-trigger alert, which dramatically increases the chance of an accidental, erroneous or unauthorized launch in response to a false alarm, a much more likely scenario than an actual attack. A number of retired generals and former high-level government officials have called for taking ICBMs off high-alert status, while others have called for scrapping them altogether. Under the Trump administration, taking ICBMs off hair-trigger alert or retiring them are highly unlikely possibilities, and the Pentagon’s recently released Nuclear Posture Review lowers the threshold for nuclear use.

They do a better job protecting the environment

Two recent studies ranked France way ahead of the United States when it comes to environmental protection. In the aforementioned Legatum Prosperity Index, France placed 4th out of the 149 nations surveyed. The United States was 34th. The second study, published annually by the Bertelsmann Foundation’s Sustainable Governance Indicators program, rated US environmental policies 39th out of 41 countries, mainly because of the US government’s inability to seriously address climate change. France, on the other hand, ranked 12th, largely because of its leadership in international climate diplomacy.

France’s climate leadership is evidenced by its binding commitment as a signatory to the Paris climate agreement to reduce its domestic emissions by at least 40 percent below 1990 levels by 2030. By contrast, the Trump administration announced it was pulling out of the accord (which it cannot officially do until November 5, 2020—the day after the next presidential election) and made it clear it has no intention of honoring the US national pledge.

As part of its plan to meet its Paris accord targets, the French government announced last July that it will ban the sale of gasoline- and diesel-powered vehicles by 2040, and French automakers are already doing their part. Peugeot, Citroën and Renault ranked first, second and fourth on a 2017 list of large car manufacturers with the lowest carbon emissions, and Renault started selling battery-powered cars in 2011.

The Trump administration, conversely, wants to weaken fuel economy standards. The National Highway Traffic Safety Commission is now considering permitting an average fleetwide standard of 36.7 miles per gallon (mpg) by 2026, considerably less than the 46.6 mpg requirement imposed by the Obama administration with the auto industry’s consent. According to an Environmental Protection Agency analysis, such a rollback would mean cars and light trucks would emit at least a half a billion more tons of carbon pollution and consume an extra 50 billion gallons of fuel over their lifetimes.

They hold cleaner elections

Unlike the US system of legalized bribery, French campaign finance laws keep special interest money out of politics. French citizens can contribute as much as $5,750 (4,600 euros) to one or more candidates for a specific election, but corporations, unions and advocacy groups are not allowed to donate to political campaigns or parties. In addition, the government has placed limits on campaign expenditures pegged to the office level. Electoral campaigns are relatively brief, and national television and radio stations air political ads free of charge for all candidates during the three months preceding an election. All paid political ads during that time are prohibited. Citizens are automatically registered to vote when they reach the age of 18, and elections are held on a Sunday to make it easier for people to vote.

Restraining corporate influence in elections is one of the key reasons France outpaces the United States in many of the categories cited above. While special interests—from the gun lobby to industrial polluters to Wall Street—keep US politicians on a tight leash, French elected officials are freer to represent the interests of their constituents, not the narrow interests of deep-pocketed campaign contributors and unregulated super PACs.

So, Mr. President, instead of spending as much as $50 million on parade displaying overpriced military hardware, how about trying to top some of these much more significant French accomplishments? America has proven time and time again that it can outperform the rest of the world, but history has also shown that it takes leadership to do it.

Dave Cooke, Marcia DeLonge, Joshua Goldman, Chanelle Kacy-Dunlap, Rachel Licker and David Wright provided research assistance for this essay.

 

 

 

White House

And Then They Came for the Social Scientists

Drug overdose deaths in 2016 most likely exceeded 63,000. Most of these deaths (about 42,200) are due to the family of painkillers known as opioids, which includes legally prescribed medications used to treat pain such as oxycodone and hydrocodone. To put into perspective how alarming this number is:  approximately 41,000 Americans die annually from breast cancer, more than 43,000 died due to HIV/AIDS during the peak of the epidemic in 1995, and approximately 40,000 Americans died from gun-related injuries during the peak of this issue in 1993.

In October 2017, President Trump declared the opioid crisis a public health emergency. The President’s Commission on Combating Drug Addiction issued its final report a week later with more than 50 recommendations to solve America’s opioid crisis. But public experts say that the Trump administration is failing to act on these recommendations. “You don’t call it an emergency and sit around do nothing about it,” said Dr. Andrew Kolodny, executive director of Physicians for Responsible Opioid Prescribing. “The doing something should be a plan from the agencies … and it should be seeking money from Congress.”

Social scientists and their expertise will be required to solve many of America’s public health issues, including the opioid crisis. To more fully understanding the linkages between our DNA and a person’s predisposition to addiction, to investigating the social externalities that may result in one seeking out opioids, social scientists are needed to research these issues. Social science also is needed to help solve other important public health issues in the US such as the country’s high number of mass shootings and other gun-related deaths, especially those associated with racism. While the Trump administration’s war on science has been well-documented on issues such as climate change, there are now some signals that this administration may ramp up attacks on social science.

Evidence-based treatments targeted

“The therapies that you use have to be evidence-based, otherwise you don’t know if they actually work and you want to do what is best for you clients to help them” Dr. Danya Goodman, a Boston-based psychologist who has worked with veterans with histories of trauma and substance abuse at the Boston VA, told me on the phone when I asked her about the importance of science in her practice. “Psychologists rely on science—to help us determine the difference between practices supported by anecdotes versus data.”

Dr. Goodman also noted that when every minute of your time is being focused on clients, like at a community mental health center, you may not have the time or resources to fully review the peer-reviewed literature to assess what therapies or programs are most effective for treating your clients. This is one of the reasons why the federal government made accessible a database to help these busy practitioners find effective, proven, evidence-based programs that work to both prevent and treat substance abuse and other behavioral health problems. The database is known as the National Registry of Evidence-Based Programs and Practices (NREPP) and is housed by the Substance Abuse and Mental Health Services Administration (SAMHSA) within the department of Health and Human Services. NREPP was established to screen different therapy practices and programs to determine which are effective and which are not effective.

During December, 2017 the Trump administration ended the NREPP contract, which means that the database will no longer be updated, at least for now. SAMHSA has said that future work on NREPP would be moved “in-house,” but many are questioning if the work will truly continue, and the agency has yet to announce a plan on how it will continue updating NREPP. Maybe this is part of the Administration’s push to ban words such as “evidence-based” across federal agencies?

Key social science research on gun violence restricted

Even after the occurrence of another mass shooting at Stoneman Douglas High School in Broward County, Florida, government research on gun violence is still not allowed. Scientists at the Centers for Disease Control and Prevention (CDC) have been banned from studying gun violence since 1996 due to an amendment on a spending bill that prevents the CDC from using money to “advocate or promote gun control.”

Social scientists have suggested that gun violence would decline in the US if we understood more about it. Some social science research priorities were pointed out by a National Academies of Sciences, Engineering, and Medicine report, including: what motivates people to acquire guns? What groups and sub-groups are more at risk of being victimized? Which prevention strategies and interventions work to curb gun violence, and for whom do they work?

There are so many important research questions that demand exploration; yet, our government scientists are barred from studying them even though they have pleaded to do so.

Experts on substance abuse sidelined

White House counselor Kellyanne Conway was chosen to lead the President’s opioids agenda. With President Trump choosing one of his senior advisors to lead the charge on the opioid crisis, some viewed this as the President taking this issue seriously. But Conway seems to be keeping out the government’s own experts from any of the White House’s discussions on the matter. More specifically, the administration is excluding career staffers from the Office of National Drug Control Policy (ONDCP)—the office that has guided drug policy since President Reagan was in office. “It’s fair to say the ONDCP has pretty much been systematically excluded from key decisions about opioids and the strategy moving forward,” said a former Trump administration staffer.

The exclusion of experts at the table may not be a surprise given that the Trump administration has consistently sidelined experts from advisory committees, or that they are expected to target ONDCP for massive budget cuts, or that the senior most official in the administration leading US drug policy for a while was a 24-year-old Trump campaign staffer who had no professional experience in developing or implementing drug policy, let alone leading a federal government agency.

All talk, no action

The Trump administration has been all talk and no action on important public health and social science issues. It is rumored that the Trump administration planned to air a Super Bowl ad to bring attention to the opioid crisis, but this didn’t happen. The administration also has produced a report with many recommendations aimed at ending the opioid crisis, yet has failed to act on them. Many congressional members have offered their thoughts and prayers to victims of mass shootings, but haven’t acted to solve this public health crisis.

I asked Dr. Goodman if the halting of NREPP, the Trump administration’s inaction on the opioid crisis, and preventing social science experts from providing input or doing research may send a message to the social science community that their work is not valued. “I think this administration is attacking all science, and generally has a distaste for truth.” She let out an exasperated sigh before continuing, “These attacks on social science are just another example of that and, unfortunately, they will undermine those people who are less fortunate in the US.”

 

 

Pennsylvania’s New Congressional Map is Fair, But Reveals Fundamental Tradeoffs in Institutional Choice

Earlier this week, the Pennsylvania Supreme Court released its much-awaited Congressional redistricting plan to replace a 2012 Republican-drawn plan which it recently ruled to be an unconstitutional partisan gerrymander. The new plan is unquestionably more fair, ensuring at least two more seats for Democratic voters who currently hold only 5 of Pennsylvania’s 18 seats, despite composing about half of the statewide electorate. However, the new plan, and others proposed over the last week, reveal a fundamental limitation of our electoral system that should concern not just the Democratic Party, but anyone concerned about political equality.

All of the non-partisan plans submitted would have been an improvement over the GOP gerrymander, but the Pennsylvania court’s requirements for the new plan included incompatible design principles. Analysis of the plans hints at a future where a majority of voters may routinely be denied a majority of seats in competitive swing states.

New PA map

Figure 1: Pennsylvania’s new Congressional map: fairness wins

The new plan creates 8 districts won by Hillary Clinton in 2016 and 10 won by Donald Trump, though Democrats could pick up as many as 11 seats in 2018 if everything goes their way.  It is clear that Nathaniel Persily, who designed the map, explicitly prioritized fairness in the design. Nevertheless, most initial estimates, while based on incomplete data, suggest that the plan still slightly favors the Republican Party.  That is, at a 50% vote split, GOP voters have a better chance of winning 10 of 18 seats, compared to Democratic voters. Why?

As Sam Wang, director of the Princeton Gerrymandering Project, showed in a weekend analysis, most of the submitted plans yielded 6 to 8 safe seats for Democrats, 9 safe Republican seats, and more seats that lean to Republicans over Democrats. Arguably the fairest plans were those submitted by Adele Schneider and Stephen Wolf at Daily Kos, which had the two parties likely to split nine seats, and restrained partisan asymmetry (measured in terms of partisan bias) to just under statistical significance.

The crucial dynamic at play is the interaction between incompatible design principles. The court explicitly wanted a plan that cut across fewer country and municipal boundaries, with geographically compact, single-seat districts, that nevertheless treat individual voters equally, regardless of which party they vote for.

In our 2016 book Gerrymandering in America, my co-authors Anthony J. McGann, Charles Anthony Smith, Alex Keena and I demonstrated that it is generally easy to create fair districting plans, but that there are trade-offs between principles. While there is a tendency to think of the concentration of Democrats in dense, urban populations as a “natural” geographic disadvantage in districting, it is important to keep in mind that there is nothing “natural” about compactness, boundary-crossing, or the use of single-seat districts. These are political choices with political consequences.

Figure 2: Redistricting Chicago-Style

For example, the 2011 Illinois state legislature, controlled by the Democratic Party, was able to draw an unbiased plan (though not one that benefited them), but at a cost of drawing some odd looking, non-compact districts. I think of this as a “Chicago-style” plan, as Congressional districts spread out from Chicago, like slices of deep-dish pizza, to incorporate more conservative suburbs into the densely Democratic city districts. This illustrates the trade-off between the geographic goal of compactness and the individual goal of political equality.

Figure 3: Philly-Chicago-style: Less compact districts yield 8 safe Dem seats, 2 lean Dem seats, 4 lean R seats, 4 safe R seats.  Do these districts look more like pizza slices or cheesesteaks?

I tried to replicate this in Philadelphia using Dave’s Redistricting App, but still could only produce a map with 8 safe Dem seats and 2 Dem-leaning seats (though with more tossups). Even without prioritizing compactness, it is difficult to assure that the party winning a majority of the vote will receive a majority of the seats. And here is the rub: if urban Democrats become increasingly segregated with increased partisan polarization, it is not just compactness that creates a fundamental restraint on how fair a plan can be. It is not just urban Democrats who waste votes under urban-rural polarization, it is all minority voters, Republicans in cities as well as rural Democrats, who still typically make up 30-35% of rural voters.

Figure 4: Multi-Seat Districts in PA; Blue (2R/3D), Yellow (2R/2D/1?), Red (2R/1D), Green (2R/3D)

Our reliance on single-seat districts puts limits on our ability to remedy discriminatory districting of any kind. To see the effect of this institutional choice, consider the possibility of multi-seat districts in Pennsylvania. I designed a plan using three 5-seat districts and one 3-seat district. The large, red district reflects the three seats allocated in the most rural part of the state. Assume that an electoral formula is used to allocate seats to party candidates proportionately. Further, assume that the Republican and Democratic parties would not have any additional competition (a risky assumption, but that’s a separate story).

The “eastern” district next to Philadelphia would lean slightly Democratic (average party vote 54% Dem, 46% GOP) while the “western” district with Pittsburgh likely yield two seats to each party, with a toss-up seat. Overall results would more proportional, and more likely to respect statewide majority rule. Further, parties would have an incentive to compete for votes throughout the entire state. In terms of racial dynamics, the Philadelphia district is approximately 25% African-American and 8% Hispanic, such that racial bloc voting would likely produce multiple racial minority seats (a candidate with 20% of the vote is guaranteed a seat). The western district, with Pittsburgh and other racially diverse cities in South Pennsylvania, would also have a good shot at electing a candidate strongly supported by people of color.

The importance of district boundary locations also begins to fade, as they are less consequential in shaping electoral outcomes. Three 6-seat districts in Pennsylvania could be designed to send equal numbers of candidates from both parties, and a single, 18-seat district would guarantee majority rule and political equality with only one district boundary, the state.

If the current trend of urban-rural partisan polarization continues, even a clear standard against unconstitutional gerrymandering and strict enforcement of voting rights may not be enough to protect majority rule and political equality. For all the work that we are putting into fixing our single-seat system, its inherent limitations could actually become more apparent.

Court To Decide Fate Of EPA’s Chemical Disaster Rule

Photo: US Department of Energy

Union of Concerned Scientists (UCS) is plaintiff in a lawsuit challenging a 20-month delay EPA Administrator Pruitt put on standards designed to prevent accidents at facilities that use or store hazardous chemicals. On March 16, the U.S. Court of Appeals for the D.C. Circuit is scheduled to hold a public oral hearing on this case, which pits environmental justice communities, scientists, public health advocates, and others against the EPA – whose very mission is to protect public health.

Why we need updated chemical safety regulations

As my colleagues Yogin and Kathy have detailed, chemical-related accidents happen like clockwork. Over 2,000 incidents were reported between 2004 and 2013, and lives were lost. Over 17,000 people were injured and 59 people were killed during this period, and over 400,000 people experienced evacuations or shelter-in place orders because of a chemical-related accident at a facility covered by the rules delayed by EPA.

For years, community groups, environmental organizations, and labor groups lobbied for stronger chemical disaster prevention rules. In 2013, President Obama finally issued an Executive Order directing federal agencies to enhance chemical facility safety. EPA then undertook a multi-year effort of stakeholder engagement and requests for information in the run-up to a proposed rule. After receiving comments from the regulated industry, advocacy groups, and other stakeholders, a rule was finalized in January . The updated rule, which modernized the EPA’s Risk Management Program, was scheduled to go into effect March 14, 2017, though some of the provisions were scheduled to phase in over time, some as far out as 2022, which gave the covered facilities some flexibility in figuring out how to comply with the updated requirements. Upon entering office, Administrator Pruitt put this rule on hold until February 2019, almost 2 years later than the rule was supposed to go into effect. This decision prompted the legal challenge from UCS and others.

Smoke and flames rise from the flooded Arkema chemical plant in Crosby, Texas, after two trailers of highly unstable compounds blew up. First responders filed a lawsuit saying they weren’t properly warned of risks while responding to an Arkema facility explosion after Hurricane Harvey. Image via: Associated Press / WSJ.

What’s next for the EPA risk management program

There are heavy hitters on both sides of this case. The plaintiffs are a coalition of scientists, fenceline communities, public health advocates, the United Steelworkers (North America’s largest industrial labor union) the EPA, and the DOJ. The case will likely hinge on a judicial interpretation of whether EPA has the authority to delay rules as long as they wish, or whether the agency must adhere to the Clean Air Act’s directive that any reconsideration of a rule “shall not postpone the effectiveness” of the rule for longer than three months (emphasis added).

Interested in more of the legal theory? Read the excellent brief filed by our council Earthjustice here, or let me know if you would like a more in-depth debrief. Stay tuned for the result. The safety of many communities across the country will hinge on it.

CDC Scientists Plea to Congress: Let Us Research Gun Violence

This past Wednesday, our nation bore witness as another gun-related tragedy unfolded, this time at a high school. Seventeen people were shot and killed, more than two dozen others wounded at Stoneman Douglas High School in Broward County, Florida after a heavily armed, former student of the school brazenly opened fire on unsuspecting, innocent teachers and pupils. There have been 290 school shootings since 2013, 1,333 mass shootings since 2014, and 56,755 deaths by guns since 2014– yet our government does not deem gun violence to be a public health concern worth researching. We must support scientists to do the necessary work that would shed light on how to protect the public. How many firearm casualties must there be to justify use of federal investment for research into the safety of this country’s residents?

Government scientists understand the value in studying gun violence, but we won’t allow them to do their jobs. As my colleague mentioned yesterday, a policy rider that has been including in spending bills since 1996 effectively bans the Centers for Disease Control and Prevention (CDC) from researching gun violence. The so called the Dickey amendment has not definitively outlawed research on gun violence and safety, but Congress “coincidentally” removed funding from the CDC to the exact amount it once spent on that research. This sends the message to CDC scientists that such research is strongly discouraged, deprioritized, and ultimately, it is not conducted.

Scientists Survey: Scientists Feel Restricted on Gun Research

Scientists are still feeling the effects of that decision two-decades later. In 2015, the Center for Science and Democracy (CSD) at UCS, long committed to protecting scientific integrity at federal agencies, conducted a survey of federal scientists, including scientists at the CDC. The purpose of the survey was to ascertain how scientists felt about the state of scientific integrity at their respective agencies, and to glean how effective science-based agencies were at meeting their missions. Several scientists at the CDC voiced their concerns about Congress and interest groups like the National Rifle Association (NRA) interfering in their work – especially related to gun violence research. Here are a few of the most poignant comments from CDC scientists:

  • “The integrity of the scientific work would be improved if the National Rifle Association did not prevent CDC from doing more research on gun violence in the U.S.”
  • “…I am not aware of the instances where internal processes for CDC’s decisions and other activities have been inappropriately affected by influence from industry or related interest groups. Yet, it is fresh in my memory that due to the influence from the congress CDC has not been able to engage in research on guns. In my view the widespread availability of guns is a major public health issue of the U.S. The congressional influence has limited CDC’s capacity to address this issue, and I strongly hope the ‘ban’ be lifted in the future.”
  • “The main concern I have is about Congressional interference in scientific and epidemiological studies that relate to gun violence (i.e., cutting the funding for this type of research). This is a clear example of political interests preventing the advance of public health knowledge and practice.”

Earlier this week, CSD launched the most recent iteration of the scientist survey, adding scientists from 12 more agencies and bureaus to the list. It will be interesting to see if CDC respondents will have more or less to add on the issue of gun research this time around. Their (anonymous) input will be extremely useful for helping shape recommendations for agencies on scientific integrity, and potentially a good tool to push Congress toward finally allowing scientists to study how are nation might address this growing public health threat.

Yesterday, Secretary of Health and Human Services Alex Azar kind of opened the door on lifting the research ban at CDC (which is a part of his agency), by telling Rep. Kathy Castor in a congressional hearing that he believes the “poison-pill” policy rider doesn’t prevent CDC scientists from doing their job. When asked if he would be more “proactive” on gun violence research at the CDC, Secretary Azar said that the agency will. Hopefully, congressional appropriators will see the secretary’s comments and remove this anti-science policy rider in the next spending agreement and CDC scientists will see an on-the-ground change where the agency leadership will encourage research on this public health crisis. You can bet that UCS will be looking to hold Secretary Azar and other administration leaders accountable and hold them to this commitment.

The families of victims need more than thoughts and prayers; they need action. They need policies. They need gun reform based on scientific research. And to do that, as policymakers have said themselves, we need data to ensure the most effective measures are taken.

Cara Loughran. Alyssa Alhadeff. Scott Beigel. Nicholas Dworet. Aaron Feis. Jaime Guttenberg. Chris Hixon. Peter Wang. Alaina Petty. Luke Hoyer. Carmen Schentrup. Joaquin Olivier. Meadow Pollack. Gina Montalto. Martin Duque. Alex Schachter. Helena Ramsay.

These are real people, just as the victims of every senseless act of gun violence are. They are not just statistics. Let’s have a moment of silence to reflect on their lives, their untimely deaths – but let’s not remain silent on pushing for gun violence safety research and science-based policies that can follow.

Science For Justice: A New Blog Series

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

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

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

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

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

 

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

Congress must address gun violence safety

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

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

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

This is unacceptable. This has always been unacceptable.

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

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

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

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

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

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

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

— Alex Moe (@AlexNBCNews) February 15, 2018

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The good, the bad, and the ugly

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

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

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

On the chopping block

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

Cuts to EPA enforcement and compliance programs could also mean:

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

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

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

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

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

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

How these cuts make America great is beyond me.

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

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

Poison pills—those ugly riders

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

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

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

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

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

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

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

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

Photo: USFWS

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

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

Congress’s poison arrows

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

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

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

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

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

 

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

Photo: USFWS

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

Photo: Anna Scott

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

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

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

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

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

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

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

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

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

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

 

ExxonMobil’s Climate Disinformation Campaign is Still Alive and Well

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

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

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

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

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

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

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

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

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

ExxonMobil’s Echo Chamber

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

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

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

What did the company get for that money?

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

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

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

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

ExxonMobil Spreads its Money Around

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

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

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

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

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

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

Inhofe Upstaged

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

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

“I guess not,” Whitehouse replied.

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

Science Alert to EPA Chief Pruitt: Pollution Kills People

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

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

Let’s dig into the details.

Less MACT means more HAPS

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

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

All eyes on IRIS

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

And then there’s TSCA

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

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

Pollution control is good for the economy and public health

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

What the science says—a global look

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

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

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

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

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

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

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

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

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

What the science says—a look at our kids

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

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

EPA, please follow the science

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

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

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

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

UCS is Surveying Federal Scientists Working Under the Trump Administration

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

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

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

Surveying scientists—a history

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

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

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

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

Giving scientists a voice

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

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

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

Trump Administration Raids Workers’ Tip Jars, Buries Data Showing That’s a Horrible Idea

In December the Trump administration proposed a new rule that specifically allows employers to control and distribute tip income as they see fit, taking away control of tip money from the employees—food servers, baristas, and many other hardworking people—who earned it.

Now it has come to light that the Department of Labor, which proposed the rule, has provided yet another example of the Trump administration following its science motto: “If the data don’t tell you what you want to hear, bury the data.” In this case, by suppressing data and analysis from their own staff showing the economic impacts of this rule.

People are always hurt by such an approach, and the casualties this time are the people who serve restaurant meals for minimum wage or less.

“Tip pooling”—banned for good reason

Last fall, the department halted a rule put in place in 2011 that banned the practice of “tip pooling” in restaurants and other businesses. The idea of the original rule was to ensure that when patrons add tips to their bills, that money is controlled by employees, not restaurant owners or managers. This is important because in many states, servers are exempt from the legal minimum wage—making as little as $2.13/hour in some states—so their incomes rely heavily on tips. But the Trump administration not only rescinded the pooling ban, it went further in December, proposing a new rule specifically allowing employers to control and distribute tip income as they see fit.

It has created a lot of controversy to say the least. Hundreds of thousands of tipped workers, the vast majority women,  may lose as much as $5.8 billion in income if the rule is finalized. Our allies at the Restaurant Opportunities Center United have warned that opening the door to tip theft would also exacerbate sexual harassment in an industry already rife with it, as it would give employers extraordinary power over their workers’ tips.

Suppressing the evidence

As a matter of human rights and fairness this is an important issue, but is it a science issue too?  Unfortunately, yes. That’s because, in the course of overturning this worker protection, the Trump administration suppressed data and analysis from their own staff showing the economic impact of the reversal. That impact comes from transferring income away from waitstaff to a broader set of workers, or to employers who directly retain some of the money.

Public policy decisions like these are supposed to be based on the best data and analyses available and the decision itself must be weighed and justified based on that evidence. And the public must have access to that information when the department takes comments on the proposed rule.

In this case, Labor Department analysts compiled data on the economic effects of the rule change, but according to Bloomberg, political appointees at the Labor Department later ordered the staff to change the analysis to appear more supportive of their proposal to allow tip-pooling. When changes to the data and analysis were still not sufficient to show the proposal favorably, the administration just buried the report altogether.  Not only does that misinform the public and industry, it also manipulates the decision process itself and “tips” it in favor of the administration (pun intended).

Unfortunately, this action to sideline science in order to allow politics and influence to rule the day is not unique to the Department of Labor, but is rife throughout this administration. In this case, the attorneys general of 17 states are warning that the administration’s failure to release its data on tip pooling is illegal under federal rulemaking law.

We need to push back with our elected representatives and demand the rule be withdrawn. This administration, like any other, may have policies it wants to advance, but they must do the scientific analyses straight up and allow the public to have a voice.  Misinforming the public shouldn’t be an acceptable tactic for pushing ahead with public policies that hurt everyday hard-working people.

Demolishing Public Protections to Build Trump’s Wall

Photo: Denver Gingerich/CC BY-SA 2.0 (Wikimedia)

From Hadrian’s Wall, to the Great Wall of China, the Wall of the North and many more , political walls have been built to discourage or control immigration, White Walkers, and ideologies at state borders since ancient times (though this is certainly not an endorsement). They have been built from stone, earth, wood, and steel, but one thing they all have in common—they are an ineffective strategy for border control, with other damaging side effects.

Still, the Department of Homeland Security (DHS) recently announced that they have waived 25 federal laws in order to expedite the construction of the US-Mexico border wall. Aside from being a humanitarian nightmare, this move stands to threaten the environment, wildlife, and culturally and historically significant public lands surrounding it—and the people whose lives and heritage depend upon these resources. The waiver will apply to the 20-mile vicinity east of the Santa Teresa, New Mexico port of entry, where existing vehicle barriers will be converted into a steel and concrete bollard wall.

Among the many statutes being set aside for construction are federal heavyweights like the National Environmental Policy Act (NEPA), the Magna Carta of federal environmental law, and the Endangered Species Act (ESA). The waiving of NEPA, ESA and other laws by the Secretary of Homeland Security, allowed under the REAL ID Act of 2005, is a huge power grab though not entirely unprecedented: the DHS has exercised the waiver requirement seven times prior to this, five times under President Bush from 2005-2008 and two times already in 2017. Waiving protective statutes, however, should be considered with caution and not wielded as a weapon for political gain. These laws were designed to ensure public health and environmental protection using science-based rules. Together, these safeguards have kept people safe and kept our nation beautiful. By exploiting waivers like this, the administration is throwing away the progress we’ve made in developing science-based laws for the public’s benefit.

For example, Santa Teresa, NM lies in the cultural and natural resource-rich Chihuahuan Desert near the Rio Grande. Disruptions from wall construction will put pressure on this delicate ecosystem, which is already threatened by climate change, agricultural expansion, and population growth. Waiving these acts shows a blatant disregard for public health and culturally important, irreplaceable sites and resources, and impinges on the rights and freedoms of tribal communities to preserve their heritage.

Here are all the different (evidence-based) laws that the wall will trample over:

Environment
  • National Environmental Policy Act—This will allow the administration to forgo an environmental impact assessment on the project.
  • Clean Water Act – This will allow the administration to escape regulation of pollutants discharged into US waters, deflecting requirements for water quality standards.
  • Resource Conservation and Recovery Act—The monitoring and enforcement of solid and hazardous waste generation, transportation, treatment, storage, and disposal standards will be overlooked, meaning this safeguard will be laid to waste (pun intended).
  • Comprehensive Environmental Response, Compensation, and Liability Act (Superfund)—A complement to RCRA (above), CERCLA “authorizes the President to respond to releases of hazardous substances into the environment”. Waiving this statute takes the administration off the hook for reporting and cleaning up releases of hazardous substances during construction activities.
  • Safe Drinking Water Act—This will remove requirements for monitoring contaminants in public water systems, as well as waiving the responsibility for notifying the public of contamination to the water systems.
  • Clean Air Act—Enforcement of air emissions standards from stationary and mobile sources will not be required for the construction project, potentially allowing for unmitigated emissions of hazardous air pollutants.
  • Noise Control Act—This will allow the administration to construct their wall without reducing excess noise pollution from transportation vehicles, equipment, and machinery.
Wildlife
  • Endangered Species Act—This waiver will remove administration requirements to consider the special protections of imperiled species and ecosystems in the proposed construction site.
  • Migratory Bird Treaty Act—This will allow for the harming, possession, purchase, sale, bartering, transport, export, and import of any migratory bird, nest, or eggs of migratory birds without the requirement of a federally issued permit.
  • Migratory Bird Conservation Act—This will allow for the purchase or rental of land (or water) in migratory bird habitat without consultation and approval by the Migratory Bird Conservation Commission (MBCC).
  • National Fish and Wildlife Act of 1956—Protections of fisheries and wildlife resources would be waived for the border wall construction. For example, collection of data on the availability and abundance of all wildlife (not just endangered) in the construction area would no longer be required.
  • Fish and Wildlife Coordination Act—This would relieve the requirements for federal agencies to conduct assessments on effects of sewage, waste, and other pollutants on wildlife.
  • Eagle Protection Act—This will allow for the harming, possession, purchase, sale, bartering, transport, export, and import of any bald (or golden) eagles, nest, or eggs of bald (or golden) eagles without the requirement of a federally issued permit.
Land rights
  • Farmland Protection Policy Act—This would allow the administration to construct their wall without requiring them to minimize impact to farmland (and forest land, pastureland, cropland, or other non-urban built-up land).
  • Federal Land Policy and Management Act—This Act establishes the procedures whereby the Bureau of Land Management manages public lands to accommodate multiple uses (for example: livestock grazing, mineral extraction, logging, fishing, hunting, conservation of historical and cultural resources), which won’t need to be adhered to for border wall construction purposes.
Cultural preservation and national heritage
  • National Historic Preservation Act—This will allow the administration to ignore the effects of federally funded projects on historic properties and artifacts.
  • Archaeological Resources Protection Act—This will allow the administration to excavate or remove archeological resources on federal or tribal lands without a permit.
  • Paleontological Resources Preservation Act—This will allow the administration to dismiss protections for non-renewable paleontological resources on federal lands.
  • Federal Cave Resources Protection Act of 1988—The waiver will allow for a lack of specific statutory protections for significant caves that are “an invaluable and irreplaceable part of the nation’s natural heritage.”
  • Archaeological and Historic Preservation Act—Also waived away are requirements for preservation of historical and archaeological data that might be lost or destroyed by federal projects or activities.
  • Native American Graves Protection and Repatriation Act—This will allow for the administration to construct their wall without regard for Native American burial sites. Moreover, consultations with tribes when archaeological investigations encounter or discover Native American cultural items on federal or tribal lands will not be required.
  • American Indian Religious Freedom Act—This will allow the administration to disregard protections of the religious cultural rights and practices of American Indian peoples, particularly by removing access to sacred sites and objects.
  • Antiquities Act—This Act provides protection for any cultural or natural resource, generally. The waiver, much like that of the Archaeological Resources Protection Act, will remove the permitting requirement for excavation activities.
  • Historic Sites, Buildings, and Antiquities Act—This will allow the administration to forego a survey of any historic and archaeologic sites, buildings, and objects existing at the site of construction.
Transparency in rulemaking
  • Administrative Procedure Act—sets requirements for publishing notices of proposed and final rulemaking in the Federal Register, opportunities for public comment on proposed rulemaking, and requires a 30-day delayed effective date.

Actions like this will not only succeed in straining US relations with Mexico, but also open the door to further dismissal of important science-based protections, particularly in the name of immigration reform. In fact, President Trump announced last week in his State of the Union address his plan to update US infrastructure—which will surely include gutting environmental protections in favor of corporate polluters, and at the expense of resources vital to nearby communities and wildlife.

Photo: Denver Gingerich/CC BY-SA 2.0 (Wikimedia)

Conflicts of Interest in the Trump Administration: The Cases of Alex Azar and Brenda Fitzgerald

Alex Azar, secretary of Health and Human Services. Photo: Wikimedia

It is slim relief that Brenda Fitzgerald was forced to resign last week as director of the Centers for Disease Control and Prevention. Her final offense in her very short and immoral tenure was investing in tobacco stocks after being appointed in July, according to a Politico report. Before being appointed by the Trump administration, the former Georgia health commissioner had long invested in cigarette companies whose products kill 480,000 Americans a year and 6 million worldwide, according to her own agency.

She was further compromised by investments in drug, insurance, and health diagnostic firms that posed conflicts in dealing with cancer, opioids, and dissemination of health information. She told the New York Times that she was considering renewing CDC ties with Coca-Cola. In Georgia, she was a cheerleader for Coca-Cola’s physical fitness programs. The world’s largest soda company, based in Atlanta, was exposed in 2015 for funding scientists who said America’s obesity crisis was all about exercise, not the excess empty calories from sugary drinks. As documented by the Union of Concerned Scientists, Coca-Cola was following an all-too-common tactic of the corporate disinformation playbook—hiring scientists to produce results that obscure a product’s harm.

But her departure hardly guarantees that we can count on the CDC to protect the nation’s health. For the moment, the acting director is Anne Schuchat, a respected infectious disease expert, known for leading domestic and global response teams against flu viruses in the US and infectious diseases in Africa and China, including Ebola and SARS. A member of the National Academy of Medicine and a rear admiral in the United States Public Health Service, her disease detective work was the model for a lead character Kate Winslet played in the movie “Contagion.”

The ethical conundrum of Alex Azar

It is rare for acting directors, even if immortalized by actresses, to win a full appointment. So who comes next bears serious watching, especially since Alex Azar is the new secretary of Health and Human Services (HHS), the department that oversees the CDC, and he himself is an ethical conundrum.

Azar, a lawyer who clerked for the late conservative Supreme Court Justice Antonin Scalia, and was on George W. Bush’s legal team for the 2000 Florida recount, became general counsel at HHS and ultimately deputy secretary of the department. He left in 2007 to become the top lobbyist for the Eli Lilly pharmaceutical giant and worked his way to the presidency of the company in 2012.

When President Trump nominated him in November to replace Tom Price, who abused taxpayer dollars by traveling by private jet, the president tweeted Azar “will be a star for better healthcare and lower drug prices.” When Azar was sworn in on January 29, Trump, who has repeatedly said that drug companies get away with “murder,” said prices would now “come rocketing down.”

From drug company CEO to people’s champion on drug prices? Unlikely.

There is no evidence to remotely suggest that Azar, the first pharmaceutical executive ever to head HHS, according to the Washington Post, will miraculously transform from drug company CEO into the people’s champion on drug prices. In July, the Indianapolis Business Journal reported that in the last 20 years, while the price of milk went up 23 percent, the cost of a Dodge minivan rose 21 percent and general inflation was 32 percent, the price of Lilly’s insulin drugs Humalog and Humulin skyrocketed by 1,157 percent and nearly 800 percent respectively. A vial of Humalog that cost $21 in 1996 cost $274.70 last summer.

Lilly is a defendant along with global diabetes drug titans Novo Nordisk and Sanofi in a class action price-fixing lawsuit filed last year in federal court in Massachusetts. According to the lawsuit, Lilly’s Humulin shot up 325 percent from just 2010 to 2015, a period covering Azar’s first three years at the helm. Several news stories and guest columns last year featured the difficulty many American diabetics have in affording insulin. One out of every eight American adults has diabetes, and the lower the socioeconomic status, the higher the incidence of the disease.

According to the CDC, diabetes was listed as any cause of death on a quarter million US death certificates in 2015, and the annual direct and indirect cost of diabetes to the nation is a quarter billion dollars. Several small studies over the last two decades have shown that high percentages of patients admitted to hospitals with life threatening diabetic ketoacidosis became sick after discontinuing insulin therapy because it was unaffordable.

Lilly blamed the rise in drug prices to other parts of the health care system, but it refused to disclose to the Indianapolis Business Journal its net prices. Lilly ranks 132nd in the Fortune 500 with profits last year of $2.7 billion.

Keeping a watchful eye

Pressed in his Senate confirmation hearings on drug pricing, Azar acknowledged they were high but offered no major solutions, having opposed the Affordable Care Act and saying the government should not have a heavy hand in negotiating drug prices. As average Americans struggle with diabetes drug costs, Azar made $3.6 million in his last year at Lilly in salary and severance. He also sold off $3.4 million in Lilly stock, according to the Associated Press.

Azar’s light hand on out-of control drug prices merits a very watchful eye over both HHS and CDC. We need to make sure that our government officials, especially those making decisions about access to health care, advocacy against diseases, and scientific research aren’t beholden to profitable companies producing drugs, cigarettes, soda, or other health-related products or services. Before her departure, Fitzgerald came under fire when the Washington Post reported that certain words were being banned from budget requests, such as “evidence based” and “diversity.”

Trump says that under Azar, drug prices will come rocketing down. In actuality, the watch is on to see if Azar instead is another incoming missile from Trump against federal protection of the nation’s health.

Rigor and Transparency as an Antidote to Politicization at EPA’s Integrated Risk Information System

Tina Bahadori, Director of EPA’s National Center for Environmental Assessment (NCEA), and Kristina Thayer, Director of EPA’s Integrated Risk Information System (IRIS), speak about recent improvements to the IRIS program at Thursday’s workshop.

A National Academy of Sciences (NAS) study committee charged with reviewing advances made to the EPA’s National Center for Environment Assessment and its Integrated Risk Information System (IRIS) program met at the NAS headquarters in DC this week. Over a day and a half, IRIS presented the full slate of activities that the program has been engaging in to modernize and improve the ways that the program is completing its hazard assessment and dose response evaluations.

IRIS assessments on environmental contaminants represent the gold standard for chemical toxicity reviews at the federal, state, and local level, and even internationally. These reviews provide a science basis for many of the standards set by U.S. environmental statues, including the Clean Air Act, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) also known as Superfund, Clean Water Act, Resource Conservation and Recovery Act (RCRA), The Toxic Substances Control Act (TSCA), and the Safe Water Drinking Act. IRIS is crucial in helping the agency meet its mission to protect human health and the environment. However, because of this program’s critical role in standard setting for federal and state policy, it is often targeted by industry for criticism and even calls to alter its mission or strike the program altogether.

During Thursday’s meeting, IRIS staff expressed concerns about the ability for IRIS to do the work at timelines expected due to staff attrition (now down to just 30 staffers) and lack of funding for external contractors to help with its workload, all while trying to meet Administrator Pruitt’s priority for increased efficiency. Over the course of four information sessions and a poster session, IRIS staff systematically addressed the ways in which the program has made targeted improvements to its processes as NAS recommended in its last review of the program in 2014. Layers upon layers of internal and external peer review and public engagement have been built into the review process using new tools and state-of-the-art methods.

The NAS meeting offered opportunities for public comment at several points throughout the meeting, and there were a series of comments communicating the value that this program offers, from a nonprofit organization that relies on IRIS assessments as it works to remediate superfund sites in New Jersey, to the plight of La Place, Louisiana community members living near a facility emitting chloroprene, a likely carcinogen as determined by IRIS. We cannot afford to have the work of this program diminished or politicized in any way.

My comment in support of the independence and integrity of the IRIS office is below.

Good afternoon, I would like to thank this National Academies study committee for the opportunity to provide this comment today. My name is Genna Reed. I am the science and policy analyst at the Center for Science and Democracy at the Union of Concerned Scientists. The Center for Science and Democracy at UCS advocates for improved transparency and integrity in our democratic institutions, especially those making science-based public policy decisions.

The EPA IRIS program provides a critical scientific service to the public, offering a public searchable database with scientific analyses that inform the decisions that protect us from environmental contaminants.[1] This office is not just important for federal policymaking, but IRIS assessments and associated toxicity values are used by state environmental and public health agencies, as well as community groups, to assess local risks from facilities producing chemicals across the country. This incredibly valuable program must be preserved and protected to conduct its scientific work without political interference. The EPA’s authority to determine the risks posed by hazardous chemicals should not be compromised by interference from other federal agencies or industry stakeholders with vested interests in decision outcomes.

This office has been targeted for political interference in the past. A 2009 U.S. Government Accountability Office (GAO) report found several examples of interference from EPA political appointees, the Office of Management and Budget (OMB), or other agencies to delay or weaken IRIS assessments, including decade-long review processes for naphthalene, formaldehyde, and RDX.[2]  A fall 2017 hearing held by the House Committee on Science, Space, and Technology about the integrity of IRIS failed to invite any IRIS staff to talk about the progress of the office.[3] This year, there have even been attempts to defund the program through the appropriations process.[4] Time and time again, the chemical industry has targeted IRIS because new assessments may lead to more stringent standards set based on the best available science on a chemical. Now there is the potential for the IRIS program to move under the jurisdiction of the TSCA program, which would limit the ability of the office to develop risk assessments for a range of industrial chemicals, instead forcing focus solely on those under TSCA’s authority.[5]

IRIS assessments and their staff provide institutional knowledge and assistance not only to risk assessors within the EPA and its regional offices, but also to public health practitioners in state and local governments. It is critical that the career staff scientists that comprise the IRIS office are supported so that they can continue to be a resource for individuals making regulatory decisions about these chemicals. This will allow for federal, state, and local decisions to be based on the best available science, using best methods for systematically evaluating that science. IRIS must continue to be housed in the Office of Research and Development as opposed to the policy office at the Office of Chemical Safety and Pollution Prevention because IRIS represents a scientific database that should be prepared by scientific experts. There is not room for political considerations in the work that IRIS staff do. The EPA’s scientific integrity policy explicitly protects the agency’s scientists and their work from political interference or personal motivations,[6] thus NAS should consider what a potential restructuring of the program would mean for its ability to conduct scientific work free from interference.

NAS has acknowledged some of IRIS’ challenges in the past, including room for improvement in transparency in communicating risks and decision points to the public and standardizing assessments, updating methodologies, and regularly training employees. Its most recent report in 2014 found that IRIS had made impressive strides toward implementing their previous recommendations.[7] The EPA Science Advisory Board found similar results after reviewing IRIS progress. In a September 2017 letter from the chair of the EPA’s Science Advisory Board (SAB), the Board commended the agency for its swift improvements to the IRIS program.[8]

At a time when the agency’s staff is shrinking[9] and science advisors are being underutilized,[10] the EPA needs its robust scientific staff to continue the work that has sustained stringent standards at the federal level and beyond. The healthy functioning of the IRIS program will ensure that we continue to have the data to set health-protective limits for hazardous chemicals and ensure public trust that the EPA has our best interests in mind.

Thank you.

 

 

[1] Integrated Risk Information System (IRIS). Online at https://cfpub.epa.gov/ncea/iris_drafts/simple_list.cfm, accessed January 30, 2018.

[2] United States Government Accountability Office. Low Productivity and New Interagency Review Process Limit the Usefulness and Credibility of EPA’s Integrated Risk Information System. Report to the Chairman, Committee on Environment and Public Works, U.S. Senate. Report No. GAO-08-440; March 2008. Online at http://www.gao.gov/new.items/d08440.pdf, accessed January 30, 2018.

[3] United States House of Representatives Committee on Science, Space, and Technology, Joint Subcommittee on Environment and Subcommittee on Oversight. 2017. Examining the Scientific and Operational Integrity of EPA’s IRIS Program, Hearing, September 7. Online at https://science.house.gov/legislation/hearings/joint-subcommittee-environment-and-subcommittee-oversight-hearing-examining, accessed January 30, 2018.

[4] Erickson, B.E., C. Hogue, J. Morrison. 2017. Trump EPA to shed chemical programs, grants. Chemical and Engineering News. Online at https://cen.acs.org/articles/95/i17/Trump-EPA-shed-chemical-programs.html, accessed January 30, 2018.

[5] United States Senate Committee on Appropriations. 2017. Summary: FY2018 Interior, Environment Appropriations Chairman’s Mark Released, November 20. Online at www.appropriations.senate.gov/news/minority/summary-fy2018-interior-environment-appropriations-chairmans-mark-released, accessed January 30, 2018.

[6] U.S. Environmental Protection Agency (EPA). 2014. U.S. Environmental Protection Agency Scientific Integrity Policy. Online at www.epa.gov/sites/production/files/2014-02/documents/scientific_integrity_policy_2012.pdf, accessed January 30, 2018.

[7] National Research Council. 2014. Review of EPA’s Integrated Risk Information System (IRIS) Process. Washington, DC: The National Academies Press. doi:10.17226/18764.

[8] Thorne, P.S. 2017. Letter to EPA Administrator E. Scott Pruitt, September 1. Online at https://yosemite.epa.gov/sab/sabproduct.nsf/0/A9A9ACCE42B6AA0E8525818E004CC597/$File/EPA-SAB-17-008.pdf, accessed January 30, 2018.

[9] Friedman, L., M. Affo, and D. Kravitz. 2017. E.P.A. Officials, Disheartened by Agency’s Direction, Are Leaving in Droves. New York Times, December 22. Online at www.nytimes.com/2017/12/22/climate/epa-buyouts-pruitt.html, accessed January 31, 2018.

[10] Reed, G., S. Shulman, P. Hansel, and G. Goldman. 2018. Abandoning Science Advice: One Year In, the Trump Administration is Sidelining Science Advisory Committees. Cambridge, MA: Union of Concerned Scientists. Online at www.ucsusa.org/sites/default/files/attach/2018/01/abandoning-science-advice-full-report.pdf, accessed January 31, 2018.

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