UCS Blog - The Equation (text only)

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

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

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

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

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

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

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

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

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

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

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

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

¿Usted qué puede hacer?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

This time, they heard it.

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

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

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

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

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

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

Photo: Gage Skidmore/Flickr

The limbo king of record worsts has notched another low.

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

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

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

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

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

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

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

Oh, how low that man can go.

Mr. Pruitt goes to market

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

The marketplace? Which marketplace?

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

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

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

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

But still.

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

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

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

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

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

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

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

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

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

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

Looking up, looking ahead

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

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

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

Gage Skidmore/Flickr

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

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

You can’t renegotiate a Faustian bargain

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

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

What the industry has asked for thus far

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

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

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

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

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

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

What the industry should be asking of the President

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

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

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

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

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

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

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

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

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

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

Past progress and approaches to pricing 

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

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

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

And now a unified proposal from a broad coalition 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Chlorpyrifos clearance only the beginning

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

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

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

A fleeting victory for science

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

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

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

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

A Dining Bald eagle in Conowingo, Maryland eating fish.

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

Specter of silent spring

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

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

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

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

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

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

In southern Nevada doing some rare plants surveys.

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

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

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

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

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

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

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

 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

ExxonMobil refinery in Baton Rouge, LA.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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



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

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

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

Wikipedia

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

Photo: Pesticide Action Network

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

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

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

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

Understanding the EPA’s Science and Technology account

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Stand up for science at the EPA

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

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

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

Pesticide Action Network

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

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

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

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

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

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

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

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

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

Take action

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

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

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

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

Photo: skynesher/iStockphoto

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

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

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

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

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

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

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

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

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

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

Attacks on science hit locally

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

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

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

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

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

What Happened During the Hasty White House Review of EPA’s Science Restriction Rule?

We already know that the production of Administrator Scott Pruitt’s rule to restrict science at the EPA was purely political, but it’s possible that there’s a whole new layer of politics that went on at the White House level as well.

Source: reginfo.gov

On Thursday April 19, the White House Office of Management and Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA) received a draft proposed rule from the EPA titled “Strengthening Transparency and Validity in Regulatory Science.” It was signed promptly by Administrator Pruitt on Tuesday. At first, the OMB’s website showed its review completion on Wednesday (meaning that Pruitt had signed the document before it was cleared by the White House), but then later in the week OMB backdated its review completion date to Monday. That means that not only is there likely some funny business going in between the EPA and OIRA, but OIRA had four days (and little more than one to two full work days) to review a proposed rule that would dramatically impact the way that EPA uses science in future rulemakings.

In just a couple days of OIRA review, a UCS analysis of the rule before and after review shows that it grew by four pages and was narrowed to include rules considered to be “significant regulatory actions” and those with dose response data and models that underlie “pivotal regulatory science.” While the docket does not currently include details on who made those changes, if OIRA staff was responsible for changing the scientific basis of this rule, there is certainly reason to be concerned. White House review under Executive Order 12866 is supposed to be limited to cost benefit analysis and overlap with other agencies and should in no way change the scientific content of the agency’s work. Interference from the White House in this area doubles down on the already implicit affront to scientific integrity at EPA that this rule represents.

We compared the start and conclusion documents from OIRA’s EO 128666 review of EPA’s science restriction policy and noticed that post-review changes (those in blue) included narrowing its scope to cover the dose response data and models underlying “pivotal regulatory science.” Source: regulations.gov

 

The policy post-OIRA review also included definitions for “dose response data and models” and “pivotal regulatory science.” Source: regulations.gov

Not only are there questions about OIRA’s role in changing the content of the rule, but the rule’s mad dash through White House review is not normal even by Administrator Pruitt’s standards. OIRA review of proposed rulemakings, required under President Bill Clinton’s Executive Order 12866, is supposed to take under 90 days with the possibility to extend to 120 days if it is absolutely needed. If we operate under the assumption that a 90-day review is an adequate amount of time for OIRA to review a rule, make sure the costs and benefits have been thoroughly analyzed, allow time for interagency review and meetings with stakeholders, and then suggest changes to the agency, exactly how inadequate is a 1 to 2 day review? According to OIRA’s regulatory review data, since the time that Pruitt has been at EPA, the agency has reviewed 41 rules that were not economically significant (including the policy in question). The average review time for those rules? 52 days. In fact, only 6 other rules have gone through review in less than a week at the EPA in this period, several of which were addendums to rules (like definitions, delays, or stays).

So what’s the problem with such a quick turnaround from the White House?

UCS has in the past taken issue with extensive delays in OIRA review, especially under the Obama administration, that have held up important science-based public health protections in regulatory limbo. While an overly long OIRA review period bogs down the regulatory process, a dramatically swift review process may allow rules to be proposed without the proper analysis to back it up. This is precisely what we’re now seeing with the EPA’s proposal to restrict science. In it, the EPA claims it’s not an economically significant rule, citing no analysis on the potential costs and benefits of the rule. It calls for a system to make scientific data publicly available but cites no existent database that would be able to handle all of EPA’s “pivotal regulatory science.” It does not include protections for privacy for confidential business information and it gives the EPA administrator the ability to waive rules from the requirements on a case by case basis. And finally, it reveals just how feeble the rule is by posing 25 substantive questions (almost four pages-worth) to commenters for them to answer in 30 days— the shortest comment period window possible for a rule.

UCS has submitted a comment to the EPA asking for an extension to this woefully insufficient comment period for such a sweeping rule and we are joined by many other organizations who are doing the same. House Science Committee Ranking Member Eddie Bernice Johnson and Energy & Commerce Environment Subcommittee Ranking Member Tonko were joined by 63 democratic colleagues on a letter calling for a 90-day comment period because “regardless of viewpoint, there is agreement that the proposed rule would be a significant change in how the agency considers science in policymaking.” It is imperative that Administrator Pruitt heeds this call to ensure all stakeholders have a chance to meaningfully participate in this process, which has been bungled in a variety of ways since this rule began as just a twinkle in Lamar Smith’s eye.

Photo: Matthew Platt/CC BY-SA (Flickr)

What is the Connection Between New Mobility and Transportation Equity?

My name is Richard Ezike, and I work at the interface between new mobility and transportation equity. When I talk about “new mobility” in my research, I refer to what is arguably the most disruptive technology in transportation in the last century: the autonomous vehicle (AV). Already these cars are being tested on America’s roadways in Chandler, Arizona; Pittsburgh, Pennsylvania; and Silicon Valley, Companies like Uber, Lyft, Waymo, Ford, and General Motors are investing billions of dollars to bring this technology quickly to market. These companies are touting widespread adoption in less than 5-10 years.

However, more discussion is needed on the impacts of these cars on transportation equity because this nexus is often ignored in the spaces where AVs are being debated and discussed. The million-dollar question is: Will AVs help or hurt the mobility of low-income people and people of color? The pursuit to tackle that question has led me here to the Union of Concerned Scientists (UCS).

My project works to address this question from two angles. First, we are working with a transportation consulting firm to study the potential impact of self-driving technology on access, equity, congestion, and transit utilization in the DC Metro Area, where I personally live and work.  They are using a travel demand model developed by the area metropolitan planning organization (MPO), the National Capital Region Transportation Planning Board, to predict the impacts of vehicle miles traveled, vehicle trips, and transit trips by AVs in 2040. By modifying the inputs to the model, we can simulate the impacts of self-driving cars on the future transportation network performance. The detailed nature of the model allows us insight into specific neighborhoods that may gain or lose under a variety of future scenarios.

Second, we are engaging stakeholders to learn their thoughts and concerns about AVs. To date, I have interviewed over 40 stakeholders including local government officials, car dealers, community leaders, and policy makers. I have asked them about the potential impacts of AVs on traffic, labor, the environment, and the economy. In early 2019, we plan to convene stakeholders to discuss our research findings, get feedback, and generate policy recommendations to share with local leaders and community groups.

Using this two-pronged approach will provide our community with both technical and community-based knowledge that will assist in the planning of how AVs can be deployed safely and equitably.

Defining transportation equity

Historically, members from disadvantaged groups (low-income residents, minorities, children, persons with disabilities, and older adults) have experienced the most negative impacts of the transportation system. These groups have lower car ownership levels, the longest commute times and the highest costs for transportation. These same groups also live near inadequate infrastructure, which results in unsafe conditions for cycling and walking and therefore an increased number of fatalities involving pedestrians and cyclists.

Low-income and minority communities are also more likely to be located near highways and other transportation facilities that produce local air pollution; to suffer from negative health effects such as asthma; and to have the least accessibility to key destinations such as parks, hospitals, and grocery stores selling healthy food. Addressing these issues requires a dedicated effort to address equity in the transportation system to provide equal access for all people.

Equity is defined as the fairness, impartiality, and justness of outcomes, including how positive and negative impacts are distributed. Within transportation and infrastructure, the decisions made in the planning stages can significantly affect the level of equity achieved in communities.

Depending on how it is deployed, autonomous vehicle technology could improve transportation inequities; but without guidance, the same detrimental effects to disadvantaged groups may only get worse. Moreover, solving these problems is not a purely technical challenge, but requires meaningful engagement and input from communities with a stake in the outcomes, so they can have a voice in the way their city is developed. Historically, public engagement has been a secondary consideration, although many MPOs are stepping up their efforts. Based on work by Dr. Alex Karner, effective engagement can be broken into three steps:

  1. Identify current unmet needs from the communities this requires engaging with community groups to learn how MPOs can best serve residents.
  2. Provide funds to assist community groups in engagement – Engagement can be time consuming and expensive, and often community groups do not have the bandwidth in time or in funding for outreach. Therefore, the MPOs should provide resources to assist. Karner suggested raising money through state taxes or allocating from available transportation funds
  3. Measure progress of outreach using relevant metrics – MPOs must track how effectively they are engaging communities. They need to know how many people they talked with and if they understood the material being discussed. By tracking that information, MPOs will know if their message is getting across.

Through the duration of my fellowship I have had the opportunity to interview several stakeholders to learn about how they see autonomous vehicles impacting equity. Across the board, there is a definite interest in how the broad impacts of AVs will manifest themselves in society, and at UCS my research will help to bring these various groups together. My engagement with these groups is helping to identify unmet needs, identify relevant metrics from stakeholders, and stress the importance of safe and equitable AV deployment. 

Why new mobility and equity must function together

I have talked with transit advocates who are concerned about the impacts on transit agency jobs and public transit options in general, as they are concerned that AVs will replace public transit but may not meet the needs of transit dependent communities while eliminating thousands of transit worker jobs.

I have spoken to business owners who believe the benefits of autonomous vehicles, such as increased access to the transportation system for the disabled and senior citizens, outweigh any potential pitfalls.  I have heard varying viewpoints from several local government officials from very concerned to “we have not thought about AVs yet,” and some state departments of transportation are taking a hands-off approach.

These discussions reiterate that the paradigm shift is happening. Autonomous car technology is here, and billions of dollars are being spent to put these cars on the roads as fast as possible. However, the conversations that are most needed –potential impacts on transportation equity and accessibility, the effects on public transit, and the environmental considerations – are not happening quickly enough. They need to happen more often, and soon. Through my fellowship at UCS, I aim to increase this awareness and provide new research, analysis and recommendations to advance equitable transportation outcomes.

Regulators Should Think Twice Before Handing Out Pollution Credits for Self-Driving Cars

A new report out by Securing America’s Future Energy (SAFE) suggests that automakers should get credits towards meeting emission and fuel economy standards for connected and automated vehicles (AVs) and related advanced driver assist systems—technologies that may or may not save any fuel. Doing so would not only increase pollution and fuel use, but would seriously undermine the integrity and enforceability of regulations that have delivered enormous benefits to our environment, our pocketbooks, and our national security.  The tens of thousands of traffic related fatalities every year in the U.S. demands that automakers and regulators must continue to make our cars safer.  But trying to encourage greater deployment of safety technologies by undermining pollution standards is the wrong approach.

Here’s why regulators should reject giving emissions credits to manufacturers for deploying safety and self-driving technologies.

Including emissions credits for safety and self-driving technologies in 2022-2025 vehicle standards would be a windfall for automakers, resulting in less deployment of proven efficiency technologies and more pollution.

There are more questions than answers about the potential impacts of various safety technologies and self-driving capabilities on vehicle and overall transportation system emissions, which I’ll get into more below.  But for now, let’s just take a big leap of faith and assume that some safety technologies actually do lower an individual vehicle’s emissions.

One example is adaptive cruise control.  This technology automatically adapts a vehicle’s speed to keep a safe distance from a vehicle ahead and theoretically could perform more efficiently than a human driver.  It is widely available and featured on vehicles like the Toyota Camry, Honda Accord and Ford Fusion.  One study examined this technology and found changes in efficiency could range from +3 to -5 percent during various types of driving. While there is some evidence that under certain conditions there might be a slight fuel economy benefit from this technology when it is in use, that same evidence indicates that increased fuel use and emissions are also possible.

In another recent study of self-driving cars, researchers found that while eco-driving capabilities could potentially provide savings, the increase in electric power demand, added weight, and aerodynamic impacts of sensors and computers would increase fuel use and emissions.  Both of these examples demonstrate the importance of testing and verifying any assumed change in emissions from the deployment of safety and self-driving technology as emissions reductions are anything but certain.

But even if credible testing and data were available, giving off-cycle credits for this technology within existing standards would be a giveaway to the auto industry.

Why? Adaptive cruise control is already being deployed on millions of cars – 1 in 5 new vehicles produced for the US market in model year 2017 were equipped with adaptive cruise control. Automatic emergency braking is another example, where automakers have already made commitments to make it standard on nearly all cars by 2022. Giving credits for these technologies would be a windfall for manufacturers and result in less deployment of proven fuel efficiency technologies.

The ICCT also identified this issue of providing credits for tech deployment that is already occurring in their review of the current off-cycle credit program and concluded that the program greatly reduces the deployment of other efficiency technology. They also identified the lack of empirical evidence to validate claimed fuel economy and emissions benefits from several technologies already included in the program as another big problem. And currently there is little empirical data to validate any efficiency benefits of safety and self-driving technologies.

Providing credits for emissions and fuel consumption impacts that are difficult to measure and not directly related to a vehicle – like possible impacts on traffic congestion—would increase pollution and undermine the standards.

Expanding the off-cycle program for safety technologies that might directly impact a vehicle’s emissions is just the tip of the iceberg.   The off-cycle credit program, like the vehicle standards in general, is limited to emissions directly related to the performance of a vehicle. But some automakers, and SAFE, are interested in allowing credits based on potential changes in emissions from the transportation system as whole. For example, automakers could earn credits toward compliance with vehicle standards for some future changes in traffic congestion that might result from the deployment of improved vehicle safety technologies. This would be a major change to the per-vehicle basis of the fuel economy regulations that were established in the 1970’s.

There are several serious problems with including speculative, indirect emissions impacts in existing vehicle standards.

1. Providing credits for emissions reductions that may or may not ever happen in the future will increase pollution in the short term and may never result in emission reductions in the long term

We only need to look back at the flex fuel vehicle (FFV) loophole to find an example of this kind of failed policy. Automakers were given fuel economy credits for selling cars capable of running on fuel that is 85 percent ethanol (known as E85), under the theory that this would help drive E85 to market and we would use less oil. Several automakers used it as a compliance strategy and avoided investing in other fuel efficiency technologies. But the cars almost never actually used E85, which means instead of getting more efficient vehicles, we got more oil use. The increased fuel consumption resulting from the FFV loophole is estimated to be in the billions of gallons.

Crediting future emissions reductions based on hopes and dreams has been tried before and doesn’t work.

2. Ignoring the potential negative impacts from self-driving technologies is a HUGE problem.

Self-driving cars have the potential for both positive AND negative impacts on pollution and energy use.

The biggest X-factor is how drivers will respond to these new technologies, which make vehicles safer, but also makes them easier to drive (or not drive at all as the case may be). A paper by Wadud et. al examined a range of direct and indirect impacts self-driving vehicles could potentially have on emissions.  And there are several possibilities, some of which could reduce emissions while others could increase emissions dramatically (see figure).   Increased emissions could result from higher highways speeds enabled by increased vehicle safety, increased vehicle size or features as drivers expect more features in their vehicles while their car drives them around, and most importantly, increases in the amount of vehicle travel overall.  Combined, these effects could increase emissions by more than 100% according to the study.

Automated vehicles could have both positive and negative impacts on energy consumption and emissions. Wadud et al.

We’ve already experienced increased highway speeds as vehicles have become safer with seatbelts, air bags and a host of other safety technologies.  And it’s not hard to imagine increases in vehicle miles traveled as cars take over the task of driving so we can do other things.  Just think about for a minute—what different choices might you make if you didn’t have to drive your own car?  Living farther from work or taking that extra trip during Friday rush hour might not seem so bad anymore when you can read a book or watch a movie while your car chauffeurs you to wherever you want to go.

Based on the current scientific literature, SAFE’s estimate of potential efficiency improvements from automated vehicles is misleading at best. Their analysis ignores any possible disbenefits, like increased vehicle travel, even while specifically acknowledging AVs “can also give drivers one thing of tremendous value to most Americans – an increase in personal or productive time”. The analysis also uses the upper range of efficiency benefits from a handful of studies estimated over limited driving situations, and inappropriately applies them to all driving.  The conclusion that a handful of safety technologies could reduce emissions 18-25%  across the entire vehicle fleet is not supported by current evidence, ignores any other effects of self-driving cars, and is not a sound basis for policymaking decisions.

My point isn’t that we should prevent self-driving technology and the many potential benefits it could deliver if done responsibly.

But vehicle standards aimed at reducing emissions and fuel consumption shouldn’t include credits for potential positive changes to transportation system emissions while ignoring the negative ones.

3. Finally, regulatory enforceability and accountability—the key to the success of today’s vehicle standards—would be severely undermined

The effectiveness of vehicle standards, any standards for that matter, is having effective enforcement which ensures regulated entities are all participating on a level playing field and that the actual benefits of the standards are realized.  We’ve seen the importance of enforcement over the decades as automakers have been held accountable for the performance of their products. Think ‘VW diesel scandal’ for one, and the numerous examples of erroneous fuel economy labels (Ford and Hyundai-Kia to name just two). These enforcement actions have one important thing in common: regulators were able to perform tests on the vehicles to determine if they were performing as the automakers claimed, and demonstrate that they were not.

Current vehicle standards are robust because they are predicated on direct emissions and fuel savings benefits that are verifiable on a vehicle level. An automaker makes a car, it’s tested, and they are held accountable for the results. How might a regulator, or an automaker, test and verify the congestion impacts of an individual Cadillac STS with Super Cruise?

Providing credits to automakers for emission reduction benefits that cannot be verified or attributed to an individual manufacturer, nevermind an individual vehicle make or model would be a massive change in approach to the program introduced through a mechanism – the off-cycle credit provisions – which was never intended to be more than small part of automaker compliance.

Where’s our insurance policy?

SAFE makes the case that giving away credits to automakers now, even without proof that these technologies reduce fuel use and emissions, is worth it because it would allow EPA and NHTSA to run a research program to understand the impacts on fuel economy of self-driving technology. But why should we accept increased pollution for collecting information? A better path forward for regulators is to indicate their intention to consider the direct vehicle emissions and fuel economy impacts of safety and self-driving technology in setting post-2025 vehicle standards and implement a testing program now to collect the necessary data to see whether giving credits for these technologies is appropriate. This would motivate automakers to do their own testing and to work with EPA and NHTSA to develop appropriate test procedures for ensuring the claimed benefits are actually occurring.

If safety and self-driving technology off-cycle credits are a proposed solution to the current impasse over 2022-2025 vehicle standards between federal regulators, the auto industry, and California, then we all need to be clear about the costs. They would provide windfall credits to auto companies for something they are already doing, while stalling deployment of proven efficiency technologies and increasing emissions.  If indirect changes in transportation system emissions and fuel consumption are included, such as some theoretical impacts on congestion sometime in the future that may or may not happen, the move would risk undermining the foundation of the standards themselves.

We should not be forced to make a choice between improving vehicle safety and reducing emissions. We need to protect the public from vehicle crashes and protect the public from pollution. If there is proven safety technology that is saving lives, automakers should deploy it and safety regulators should require it. But moving from a regulatory structure that is built on verifiable and enforceable emission reductions to one that is based on speculation and indirect impacts is a dangerous move that should be avoided.

 

The Health and Safety of America’s Workers Is at Risk

Saturday, April 28, may have seemed like just another Saturday. Some of us likely slept a little later and then got on to those household chores and tasks we couldn’t get to during the week. Some of us enjoyed some leisure time with family and friends. Many of us got up and went to work—maybe even to a second or third job.

But April 28 is not just another day. Here in the US and around the world, it’s Workers’ Memorial Day—the day each year that recognizes, commemorates and honors workers who have suffered and died of work-related injuries and illnesses. It is also a day to renew the fight for safe workplaces. Because too many workers lose their lives, their health, their livelihoods or their ability to fully engage in the routine activities of daily living because of hazards, exposures and unsafe conditions at work.

Unless you know someone who was killed or seriously injured on the job, you probably don’t give workplace safety much thought. Perhaps you think work-related deaths, injuries and illnesses are infrequent, or only affect workers in demonstrably risky jobs—like mining or construction. The actual statistics, however, tell a different story. (For a more detailed and visual look, see this Bureau of Labor Statistics [BLS] charts package.)

Fatalities: In 2016 the number of recorded fatal work injuries was 5,190. On average, that’s 14 people dying every day. In the United States. It’s also 7 percent more than the number of fatal injuries reported in 2015 and the highest since 2008. Most of these deaths were the result of events involving transportation, workplace violence, falls, equipment, toxic exposures, and explosions. And the 2016 data reveal increases in all but one of these event categories. That’s not going in the right direction.

Non-fatal cases: According to the BLS, private industry employers reported 2.9 million non-fatal workplace injuries and illnesses in 2016, nearly one third of which were serious enough to result in days away from work—the median being 8 days. For public sector workers, state and local governments reported another 752,600 non-fatal injuries and illnesses for 2016.

Costs: And then there’s the enormous economic toll that these events exact on workers, their families and their employers. According to 2017 Liberty Mutual Workplace Safety Index, the most serious workplace injuries cost US companies nearly $60 billion per year.

But that’s just a drop in the bucket. The National Safety Council estimates the larger economic costs of fatal and non-fatal work injuries in 2015 at $142.5 billion. Lost time estimates are similarly staggering: 99 million production days lost in 2015 due to work injuries (65 million of which occurred in 2015), with 50 million estimated days lost in future years due to on-the-job deaths and permanently disabling injuries that occurred in 2015.

And even these costs don’t come close to revealing the true burden, as they do not include the costs of care and losses due to occupational illness and disease. A noteworthy and widely cited 2011 study estimated the number of fatal and non-fatal occupational illnesses in 2007 at more than 53,000 and nearly 427,000, respectively, with cost estimates of $46 billion and $12 billion, respectively.

Who foots the bill and bears these enormous costs? Primarily injured workers, their families, and tax-payer supported safety net programs. Workers’ compensation programs cover only a fraction. See more here and here.

The other part of the story

As sobering as these data and statistics are, they tell only part of the story; the true burden of occupational injury and illness is far higher. Numerous studies find significant under-reporting of workplace injuries and illnesses (see hereherehereherehere). Reporting of occupational disease is particularly fraught, as many if not most physicians are not trained to recognize or even inquire about the hazards and exposures their patients may have encountered on their jobs.

Nor do the statistics reveal the horror, loss, pain, and suffering these injuries and diseases entail. In the words of Dr. Irving Selikoff, a tireless physician advocate for worker health and safety, “Statistics are people with the tears wiped away.”

Just imagine having to deal with the knowledge that a loved one was suffocated in a trench collapse; asphyxiated by chemical fumes; shot during a workplace robbery; seriously injured while working with a violent patient or client; killed or injured from a fall or a scaffolding collapse; or living with an amputation caused by an unguarded machine.

Or the heartache of watching a loved one who literally can’t catch a breath because of work-related respiratory disease. Or is incapacitated by a serious musculoskeletal injury. Or has contracted hepatitis B or HIV because of exposure to a blood-borne pathogen at work.

And here’s the kicker: virtually all work-related injuries and illnesses are preventable. There’s no shortage of proven technologies, strategies and approaches to preventing them. From redesign, substitution and engineering solutions that eliminate or otherwise control hazards and exposures to safety management systems, worker training programs, protective equipment, and medical screening and surveillance programs, there are multiple paths to prevention. And, as a former assistant secretary of labor for occupational safety and health, David Michaels, recently wrote in Harvard Business Review, safety management and operational excellence are intimately linked.

Historic progress now at risk

The Good News: It’s important to note and remember that workplace health and safety in the US is a lot better than it used to be before Congress enacted the Occupational Safety and Health Act of 1970, and even since 2000. This progress has resulted large measure from the struggles of labor unions and working people, along with the efforts of federal and state agencies. Workplace fatalities and injuries have declined significantly, and exposures to toxic chemicals have been reduced.

It is also a testament to the effectiveness of health and safety regulations and science-based research. We can thank the Occupational Safety and Health Administration (OSHA), the Mine Safety and Health Administration (MSHA), and the National Institute for Occupational Safety and Health (NIOSH) for many of these protections and safeguards. We must also acknowledge and thank the persistence, energy, and efforts of the workers, unions, researchers, and advocates that have pushed these agencies along the way.

The Red Flags: There are numerous indications that this progress will be slowed or even reversed by a Trump administration intent on rolling back public protections and prioritizing industry interests over the public interest. For example:

  • Right off the bat, the president issued his two-for-one executive order requiring agencies to rescind two regulations for each new one they propose. So, to enact new worker health and safety protections, two others would have to go.
  • OSHA has delayed implementation or enforcement of several worker protection rules that address serious health risks and were years in the making—i.e., silica, the cause of an irreversible and debilitating lung disease, and beryllium, a carcinogen and also the source of a devastating lung disease.
  • OSHA has left five advisory and committees to languish—the Advisory Committee on Construction Safety and Health; the Whistleblower Protection Advisory Committee; the National Advisory Committee on Occupational Safety and Health; the Federal Advisory Council; and the Maritime Advisory Committee—thus depriving the agency of advice from independent experts and key stakeholders.  Earlier this week, a number of groups, including the Union of Concerned Scientists, sent a letter to Secretary of Labor Acosta asking him to stop sidelining the advice of independent experts.
  • President Trump signed a resolution that permanently removed the ability of OSHA to cite employers with a pattern of record keeping violations related to workplace injuries and illnesses. Yes, permanentlybecause it was passed under the Congressional Review ActAnd Secretary Acosta recently seemed hesitant to commit not to rescind OSHA’s rule to improve electronic recordkeeping of work-related injuries and illnesses.
  • Having failed in efforts to cut some worker health and safety protections and research in his FY18 budget proposal, the president is going at it again with his FY19 proposal. He is calling for the elimination of the US Chemical Safety and Hazard Investigation Board and OSHA’s worker safety and health training program, Susan Harwood Training Grants. There is, however, a tiny bit of good news for workers in President Trump’s proposed budget for OSHA; it includes a small (2.4 percent) increase for enforcement, as well as a 4.2 percent increase for compliance assistance. Of note, employers much prefer compliance assistance over enforcement activities.
  • The president’s budget also proposes to cut research by 40 percent at the National Institute for Occupational Safety and Health (NIOSH)—the only federal agency solely devoted to research on worker health and safety—and eliminate the agency’s educational research centers, agriculture, forestry and fishing research centers and external research programs.
  • He has also proposed taking NIOSH out of CDC, perhaps combining it later with various parts of the National Institutes of Health. Never mind that NIOSH was established by statute as an entity by the Occupational Safety and Health Act of 1970.
  • The Mine Safety and Health Administration (MSHA) has also jumped on the regulatory reform bandwagon. The agency has indicated its intent to review and evaluate its regulations protecting coal miners from black lung disease. This at a time when NIOSH has identified the largest cluster of black lung disease ever reported.
  • EPA actions are also putting workers at risk. Late last year, the EPA announced that it will revise crucial protections for more than two million farmworkers and pesticide applicators, including reconsidering the minimum age requirements for applying these toxic chemicals. Earlier in the year, the agency overruled its own scientists when it decided not to ban the pesticide chlorpyrifos, thus perpetuating its serious risk to farmworkers, not to mention their children and users of rural drinking water. And the agency has delayed implementation of its Risk Management Plan rule to prevent chemical accidents for nearly two years.
  • The Department of Interior is following up on an order from President Trump to re-evaluate regulations put into place by the Obama administration in the aftermath of the Deepwater Horizon accident in 2010, which killed 11 offshore workers and created the largest marine oil spill in United States’ drilling history.
  • And then there’s a new proposal at the US Department of Agriculture that seeks to privatize the pork inspection system and remove any maximum limits on line speeds in pig slaughter plants. Meat packing workers in pork slaughter houses already have higher injury and illness rates than the national average. Increasing line speeds only increases their risk.
Remember and renew

The Trump administration makes no bones about its (de)regulatory agenda. The president boasts about cutting public safeguards and protections, and his agency heads are falling right in line. Our working men and women are the economic backbone of our nation. They produce the goods and services we all enjoy, depend on, and often take for granted. They are our loved ones, our friends, and our colleagues. They deserve to come home from work safe and healthy.

Worker Memorial Day is a time to pause and remember workers who have given and lost so much in the course of doing their jobs. It is also a time to renew our vigilance and be ready to use our voices, votes and collective power to demand and defend rules, standards, policies and science-based safeguards that protect our loved ones at work. Let’s hold our elected leaders and their appointees accountable for the actions they take—or don’t take—to protect this most precious national resource.

This post originally appeared in Scientific American.

How Important is it for Self-Driving Cars to be Electric?

A Waymo self-driving car on the road in Mountain View, CA, making a left turn. CC-BY-2.0 (Wikicommons).

The rapid development of self-driving technology has raised many important questions such as the safety of automated vehicles (AVs) and how they could radically alter transportation systems. These are critical questions, but AVs also have the potential to result in significant changes to the global warming emissions from personal transportation.

An interesting recent study from the University of Michigan and Ford Motor Company lays out the details of the likely changes in emissions from using an AV system on both electric and gasoline cars. The main takeaway from the study is that adding AV equipment to a car adds weight, aerodynamic drag, and electrical power consumption that leads to increased fuel consumption. There is the potential to offset emissions from more efficient driving by connected and automated vehicles, but by far the largest impact on emissions is the choice of fuel: gasoline versus electricity.

Direct emissions versus behavioral and usage changes

Switching from human control to fully automated driving will have direct effects on emissions as well as changes to the amount we use vehicles. Direct emissions changes include reductions in efficiency from factors like increased drag from sensor equipment and the power consumption of required computing and communications equipment. Positive direct impacts could include more efficient driving, such as smooth and precise acceleration control in an automated system.

Automation will also change how we use cars and how much we use them, indirectly affecting emissions, though the effect of AVs on these indirect emissions is much more speculative. While some changes, like “right-sizing’ (for example, having smaller one or two occupant cars available for solo trips), could decrease emissions, many of the usage changes considered would increase vehicle usage and therefore emissions. Making long distance driving easier or more productive could encourage people to live farther from their jobs. Having fully automated vehicles will mean more people can use a car. The elderly, blind, youth, and people with disabilities could switch from transit to a car, or simply add trips that would not have been able to happen otherwise. While many of these uses of AVs would be beneficial, it’s important to understand the potential emissions from AVs and how we could minimize the total contribution of global warming pollution from personal transportation.

That’s why this new study is important: it lets us at least estimate the direct, short-term implications of AV technologies on emissions. While it doesn’t examine the potential impacts of driving more, it does shed light on the direct effects of adding these new features to cars.

AV equipment increases fuel consumption, especially for gasoline vehicles

Focusing on the physical changes to the vehicle, the addition of self-driving and sensor equipment has three major changes to the fuel consumption (and therefore emissions) of the AV. First, the additional weight of the equipment decreases efficiency. Second, AVs that have sensor equipment like cameras and LiDAR (laser-based imaging) often require side bulges and roof-mounted equipment pods. Like a conventional cargo rack, these additions are detrimental to fuel economy as they increase the vehicle’s aerodynamic drag. Lastly, the sensors and computing equipment that enable self-driving require additional electrical power beyond a conventional vehicle. For a gasoline car, this means added load on the engine to power an alternator (and therefore higher gasoline consumption), while a battery electric car will have reduced overall driving efficiency (and therefore shorter range between recharges).

Waymo’s AV minivan adds sensors and computing systems that increase weight, drag, and electrical power consumption. This model was used as an example of a ‘large’ sized AV system in the referenced study. Image source: Waymo

The researchers from Michigan and Ford examined three sizes of AV systems that could be added to vehicles: an AV system with sensors like a Tesla Model S, a medium-sized system with smaller external sensors similar to a Ford AV prototype, and finally a large AV system modeled after Waymo’s modified Chrysler Pacifica AV. While all AV systems have a negative impact on fuel consumption and emissions, the largest impact is seen in the increased drag from the large AV system.

AV systems can increase global warming emission attributed to driving. The largest impact is seen on larger AV systems due to drag from the sensor units.

Improved driving behavior and other savings from AVs are possible in the long run

The study also points out the possibility of fuel savings from having self-driving and connected cars. These savings could come from several sources. For example, AVs could have more efficient acceleration and braking (“eco-driving”), especially if they are communicating with other cars to anticipate speed changes in traffic. AVs could also communicate with infrastructure like traffic signals to reduce idling and stop-and-go driving. On highways, groups of connected AVs could drive much closer together than a human driver could. This ‘platooning’ technology can increase fuel efficiency by reducing aerodynamic resistance, similar to the drafting that competitive cyclists and NASCAR drivers use to save energy. There is also a potential for AV technology to increase fuel consumption because cars could potentially drive safely on the highway at higher speeds and high speeds reduce efficiency.

These factors are currently harder to quantify than the impact of the AV equipment, and some of the potential benefits require having most or all cars on the road be at least connected, if not fully automated. For example, platooning would require multiple AVs traveling on the same roadway at the same time, which would require a critical mass of AVs to be deployed. The researchers in this study estimate a potential emissions savings on average of 14 percent from these technologies if fully implemented. However, they do not consider changes to vehicles that are already producing some of these benefits, such as improved aerodynamics (which gives some of the same benefits as platooning) or stop-start systems (which already act to reduce some of the adverse impacts of stop-and-go traffic and intersections).

Early AV models are more likely to have higher emissions

The study also considered the impact of the much more power-hungry equipment used in early developmental AV systems. For example, early prototypes have been reported to require in excess of 2,000 W of power, mostly for on-board computing. Increased computer power requirements in these early prototypes, for example going from the from these early AVs (see table). This is especially true for the less-efficient gasoline-engine driven vehicles, where increased electric power requirements would increase emissions over 60 grams CO2 equivalent per mile.  That’s equal to reducing the fuel economy of a 35MPG car to 29MPG, or like adding the emissions from running 10-25 iMac computers using a gasoline generator for every car. Since early AVs will not have enough numbers on the road to take advantage of platooning and connected vehicle savings, it is very likely that in the near-term AVs will contribute higher net emissions than a conventionally driven vehicle using the same fuel.

 

Emissions from AV system’s electricity use. Baseline system is 200W computer system, prototype uses 2,000W computing system. AV system size Baseline AV system, battery electric vehicle (gCO2eq/mi) Baseline AV system, gasoline vehicle (gCO2eq/mi) Prototype AV system, battery electric vehicle (gCO2eq/mi) Prototype AV system, gasoline vehicle (gCO2eq/mi) small 3.0 8.0 25.9 70.3 medium 3.2 8.6 26.1 71.0 large 4.3 11.8 27.3 74.1

 

Switching from gasoline to electricity is by far the most important factor in reducing emissions

 

The choice of fuel (gasoline versus electricity) is the most important choice for reducing emissions. Emissions estimates based on Ford Focus gasoline and battery-electric models and includes ‘well-to-wheel’ emissions for fuel production, distribution, and use in the vehicle. Emissions related to vehicle or AV system production are not included in this chart.

The most important determinant of direct emissions from vehicles is not the AV system, but is the choice of gasoline or electricity. Choosing a electric vehicle instead of the gasoline version for this analysis reduces global warming emissions from 20 to over 80 percent, depending on the emissions from electricity generation. The addition of AV equipment only increases this difference, making it clear that electric drive is required to have AVs that maximize emissions reductions.

What will the future hold? Some AV companies, like Waymo (spun off from Google) and Cruise Automation (partnered with General Motors) are using EVs and have plans to continue using electric drive in their AVs. Other companies have been less progressive, such as Ford announcing that they anticipate using gasoline-only hybrids for their AVs. If AVs have the transformative effect on mobility and safety that many predict, it will be vital to encourage the use of cleaner electricity instead of gasoline in these future vehicles.

 

 

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