The EPA’s Science Advisory Board (SAB) met earlier this month in DC to discuss a range of issues, but perhaps most prominently, to discuss whether any of Pruitt’s deregulatory actions from 2017 had scientific issues warranting SAB review. Also on the agenda was whether the SAB should have a chance to review the merits of the EPA’s restricted science proposal before it moved any farther in the rulemaking process. At the end of the meeting, the SAB members agreed (almost unanimously) that they would write to Pruitt and tell him that they did indeed want to review five spring and fall 2017 regulatory agenda items, including the glider truck rule and the Clean Power Plan, and the restricted science proposal.
It appears that the SAB has written two letters to the administrator, sent on Thursday, June 21. These two letters cover the spring and fall deregulatory agendas and closely track with what the committee discussed at their meeting. Almost one week later, and notably absent from the letters sent is anything related to the lengthy discussions that were had on Pruitt’s restricted science proposal.
Since there was some disagreement in exactly what this letter should recommend, with more seasoned SAB members arguing that the EPA should defer all action on the rule until SAB reviews and several Pruitt-appointed members pushing for review in tandem with the normal comment period process, perhaps this letter is delayed because those discussions are still being hashed out over phone calls and emails. But every moment that the SAB is not weighing in on this proposal is a missed opportunity, as the public comment window shrinks and the regulatory finish line approaches. The feedback that the SAB could be providing the EPA would touch upon issues like:
- How data restrictions could have impacts on regulatory programs at the agency, thus affecting regulatory costs and benefits with long-term implications.
- How much of the confidential human subject data can and should not ever be made public for legal and ethical reasons.
- How reanalyses of data, like the Harvard Six Cities study, can be done rigorously without public access to data and models.
- How advisory committees like the SAB and the EPA’s Clean Air Scientific Advisory Committee are already set up to do much of the peer review of studies that EPA might use in regulatory decisions.
The EPA has already skirted all input from the scientific community in crafting this harebrained proposal, which is why SAB review as soon as possible is imperative. And the first step is getting Administrator Pruitt to charge them with conducting that review, by asking through this letter that has yet to be sent.
While we wait to see what the SAB officially asks of Administrator Pruitt on this topic, you can join the scientific community and other members of the public who will be standing up for science at the public hearing in DC on July 17 by signing up here or submit a comment to the EPA by August 17 here.