This week I’m at the EPA Clean Air Scientific Advisory Committee (CASAC) meeting in North Carolina and an expected but disappointing outcome has just occurred: The committee has failed to reach consensus recommendations for the EPA head on the particulate matter (PM) standards, thus putting the nail in the coffin on any hope of official and robust scientific advice reaching the Administrator’s desk. This is unprecedented. It is a big deal for EPA, for the courts, and for the nation’s health.
An assault on the science-based NAAQS process
As I’ve documented throughout this process, the Trump Administration has been undercutting the EPA’s process for developing the National Ambient Air Quality Standards (NAAQS) since it took office, expediting timelines, eliminating draft documents, removing independent scientists from CASAC, nixing the PM Review Panel, and adding ad hoc consultants in a highly controlled and narrow process. Even CASAC itself admitted it didn’t have the expertise to complete the review.
It was anyway challenging to envision how robust science advice could emerge from this process; nonetheless, I had hope. I had hope because it would be so easy for the remaining seven-member committee to do the right thing because someone else had already done it for them. The Independent Particulate Matter Review Panel that was dismissed last year reconvened, conducted their own review of the PM Policy Assessment, and issued their own recommendations to the Administrator. Their comprehensive report was hand-delivered to the committee at their meeting in October. All that CASAC needed to do was parrot their recommendations.
CASAC splits on the PM review
Instead, we see a split committee. In their letter to the administrator, members of CASAC could not come to agreement—not only on what range of standard levels is supported by the science, but even the more basic question of whether or not the current standards are adequate. This is literally a yes or no question and the committee couldn’t agree.
This is an eyebrow-raising moment. To be clear, scientists, of course, frequently disagree. Historically, members of CASAC would have robust discussions with the pollutant review panel, and their discrepancies in scientific judgment would be reflected in their individual comments to the Administrator. But they’ve always been able to have a coherent recommendation to an administrator on where to set the standards. This CASAC has failed to do that. As a result, the Administrator—and Americans at large—have been deprived of the robust science advice that is so desperately needed (and legally required) on this particulate pollution review.
This failure of a process with an illegitimate committee could have big consequences on the health of the nation. Some 23 million Americans live in places that exceed the current particulate pollution standards. And the Independent Particulate Matter Review Panel concluded those standards aren’t adequate to protect public health. As a result, many more people are likely at risk of adverse health effects. But rather than addressing that risk and working to protect people from harmful particulate pollution, several EPA science advisors have chosen to ignore what the Independent Panel calls “New and compelling evidence that health effects are occurring in areas that already meet or are well below the current standards.” This willful ignorance of scientific evidence will place many more people in harm’s way, despite readily available science and a policy process in place to protect people.
EPA Administrator Wheeler: An informed decision?
The committee will finalize its letter in the coming weeks. Next, EPA Administrator Andrew Wheeler will have decisions to make. He will have access to three relevant stacks of paper:
- The CASAC letter without any consensus recommendations (this version with forthcoming revisions)
- The thorough and detailed science and policy documents developed by EPA scientists, and
- The Report of the Independent Particulate Matter Review Panel
Both the EPA documents and the report of the Independent Panel—along with a fraction of members on CASAC—tell the Administrator that the PM standards are inadequate. It is only some members of CASAC informing him otherwise. As a result, it should be clear to Administrator Wheeler where the science lies. His job is to use the best available science to carry out the EPA’s mission of protecting public health. I hope he’s up to the task.