The EPA Cut Science Out of Air Pollution Standard-Setting. We’re Putting It Back.

September 26, 2019 | 1:00 am
Genna Reed
Gretchen Goldman
Former Contributor

EPA leaders have now irreparably damaged the agency’s process for setting health-based air pollution standards. That’s why scientists are taking matters into their own hands. To ensure that independent science informs the particulate matter standards and beyond, the very particulate matter review panel that EPA Administrator Wheeler disbanded last year will reconvene.

Convening the scientists the Trump administration dismissed

In Washington DC on October 10-11—exactly one year to the day since the particulate matter review panel was disbanded—its members will meet again. The Independent Particulate Matter Review Panel, which self-organized days after being disbanded, includes 20 of the experts set to inform the next particulate matter standard before they were cut off. Notably, this group has more than double the number of experts currently reviewing the EPA standards, since EPA leaders disbanded the panel last October. It was one of the administration’s first moves that derailed the longstanding EPA process for ensuring that independence science informs ambient air pollution standards. The Independent Panel has already advised EPA twice since December regarding the science of particulate matter air quality.

Hosted by the Union of Concerned Scientists, the independent panel will come together to do what the EPA has thus far failed to: Conduct a full review of the EPA’s assessment of the science, with a breadth of experts from the most important scientific disciplines. They will deliberate on what we know and don’t know about particulate matter’s link to human health and welfare effects. And importantly, they will discuss the policy question at the heart of it all: Given the current science, what level of pollution will protect public health with an adequate margin of safety—the question that the Clean Air Act mandates EPA to answer and use to set pollution standards.

The panelists have undergone an ethics review to ensure that the panel is independent. In fact, the ethics review is being conducted by the very same (now retired) EPA staff member who cleared the panel’s ethics review before it was disbanded. (Chris Zarba was the EPA Scientific Advisory Board Staff Director until last year and is now working with the Environmental Protection Network). UCS is hosting the meeting, but the panelists’ deliberations will be independent, the panel will publicly report its advice directly to EPA, and panelists are accepting no honoraria for the meeting.  (For the record, UCS doesn’t take positions on ambient air quality standards and criteria, only advocates that independent science advice be followed.)

We will ensure the process tracks as closely as possible to what the EPA should be doing to ensure independent science informs air pollution standards. Contrary to EPA’s plans for its upcoming Clean Air Scientific Advisory Committee meeting, we will include a public comment period within the meeting in order to ensure the public has an opportunity to inform the EPA process. The meeting will be held in Washington, DC, will be open the public, and will be livestreamed. Additional meeting details can be found on the event’s website.

The nation deserves a process that ensures science and public input inform the air pollution standards that affect us all. We are going to make it happen.

A need for independent science

For decades—under both Republican and Democratic administrations—the EPA has followed a long-standing science-based process for setting health-based ambient air pollution standards. This process has reliably ensured the nation’s ambient air pollution standards protect public health and welfare. The process has worked remarkably well over the years, even in the face of outside pressures to set weaker standards than the science suggests.

But the Trump Administration has taken a wrecking ball to this process (Full timeline here). First, then-EPA Administrator Scott Pruitt announced the process would be abbreviated, with faster timelines, less review, and shorter documents than have been necessary in the past to ensure science-based standards. Then the administration nixed the Particulate Matter Review Panel and failed to convene an Ozone Review Panel. These pollutant-specific review panels have for decades augmented the seven-member Clean Air Scientific Advisory Committee to ensure leading experts on a given pollutant had a seat at the standard-setting table. This process ensured that the latest science could be accurately incorporated into EPA decisions that affect public health, with panels consisting of 10-20 people, largely from academic institutions, who largely donate their time and expertise to inform the agency. And it is a bargain for taxpayers. They deliberate in public and can fully engage with the seven-member committee to ensure sufficient expertise to have robust discussion of the many scientific disciplines and technical issues involved in reviewing the standards.

After EPA disbanded the Particulate Matter Review Panel, CASAC members told EPA they needed it back but Administrator Wheeler refused to listen. To save face and avoid having to reconvene the panel they themselves disbanded, the administration came out with a laughable workaround. This summer, the administration announced it would hire a “pool” of consultants that could be individually contacted on key questions science advisors asked them. The selection of these consultants was made by the Administrator with no public review of the selections.  It appears that this highly controlled written Q&A will allow little to no discussion between the committee and consultants, and no interface with the public.

But the who and how of the consultant pool is lacking. The breadth of expertise on the consultant list does not go far enough to enhance the expertise that CASAC is missing (and has acknowledged they need) and the list leans toward individuals who consult for industry rather than top academic experts who regularly publish in the field. In an unusual move, the October 24 CASAC meeting will also detach the public comment period in a separate teleconference two days prior.

This is a far cry from the open discussion that typically occurs among the science advisors, the review panel, and the public. We cannot allow such a sham process to proceed unanswered. The public’s health is at risk.

Holding EPA leaders accountable to science-based standards

Reconvening a disbanded pollutant review panel breaks new ground. Nothing like this has ever been done before. Indeed, nothing like this has ever been necessary. But we live in unprecedented times. The stakes are high. Particulate matter is responsible for more death and sickness than any other air pollutant in the US. If the EPA fails to set a standard that aligns with our scientific understanding of particulates and health, then the public’s health is at risk. Americans deserve to have a standard that protects them from the harmful effects of particle pollution. And we cannot get there unless robust science advice informs the EPA administrator’s decision. The Trump EPA has proven it cannot be trusted with this responsibility. That’s why we’re stepping up.

Please join us on October 10-11 in Washington, DC as we break new ground and give the EPA the independent science advice it so desperately needs. If you’d like to sign up to give in-person public comment on October 10 or written comment before the meeting, please email [email protected].