By Genna Reed, Union of Concerned Scientists
The Trump Administration doubled down on its overhaul of the EPA’s Board of Scientific Counselors (BOSC) this week, notifying members whose terms would be ending in 2017 and early 2018 that their terms will not be renewed and cancelling subcommittee meetings for the rest of the year. This means that just 3 out of 18 executive committee members and 11 out of 49 subcommittee members will remain, with just 10 days to reapply to their positions.
This will stall the work of the committee, which was set to begin looking at the EPA’s Office of Research and Development’s (ORD) plans for the next five years. According to the Board’s chair, Deborah Swackhamer, it’s an inauspicious sign of what’s to come for other advisory committees with members whose terms are coming to an end, like many members of EPA’s Science Advisory Board.
Scientific advisory process is already open, inclusive, and diverse
Scientific advisory committees, like BOSC, provide independent advice to the federal government, allowing agencies to seek outside expertise on critical issues. The EPA has seven advisory committees that are scientific or technical in nature, including the Science Advisory Board (SAB), the FIFRA Scientific Advisory Panel (SAP), the Board of Scientific Counselors, the Clean Air Scientific Advisory Committee (CASAC), the Chemical Safety Advisory Committee, the Environmental Laboratory Advisory Board, and the Human Studies Review Board.
Most recent membership includes a wide range of expertise, of scientists from a variety of backgrounds whose affiliations range from an academic setting to the private sector.
As appropriate, a diversity of expertise is represented on these advisory committees, the work of which ranges from reviewing epidemiological studies on a particular pesticide to advising the EPA on a contentious scientific review, like fracking impacts on drinking water.
Advisory committees should be made up of a balance of expertise, not just because it’s required under the Federal Advisory Committee Act but because it promotes a breadth of opinions, an opportunity for creative solutions to complex problems, and challenges members to come to a consensus on certain charge questions.
The EPA’s advisory committees are also very transparent. All members serving on these committees must sign ethics forms, disclose funding from the past two years, and be prepared to submit a waiver to the administrator if there is a clear conflict of interest explaining how it will be mitigated.
This is about science advice, not politics
A representative from the American Chemistry Council told the Washington Post that the emptying out of BOSC was welcome and would address their “concerns in the past that EPA advisory boards did not include a diversity of views and therefore frequently presented a biased perspective on issues before them.” But this criticism doesn’t make sense for the BOSC. Its executive committee is composed of scientists with diverse research expertise, equipped to give advice on ORD’s research agenda without making policy prescriptions where a bias would come into play.
I want to reiterate something that the BOSC’s chair repeated several times in a hearing before the House Science Committee in May. She told members of congress that “robust science, not politics, should form the bedrock” of environmental policies and that all of the members who could have been renewed for a second term had been fully qualified, vetted, and ORD-recommended.
There was no justification for their dismissal. Swackhamer was rightfully offended by the implication that BOSC members would display allegiance to the administration under which they are appointed, telling the Star Tribune that, “I resent the fact that we are considered biased because were appointed during [President Barack] Obama’s tenure,” she said. “I would behave the same way if I were appointed by Pruitt.”
Independent science advisors should be judged based on their qualifications to make scientific recommendations, which don’t change just because there’s a new EPA administrator. Now instead of working to help ORD decide how in the world they will deal with likely cuts to several of its research programs, BOSC will be incapacitated for at least the next year, which according to one of the subcommittee members who resigned last month, Peter B. Meyer, will mean that “guidance to shape the coming agenda will be lost so cost-effectiveness of research will suffer, as will science.”
Of all of the EPA’s advisory committees, BOSC is the last one I would expect to be caught up in a political fight. And I’m still worried about the future of EPA’s other important science advisory committees. Let’s remember that the SAB often works on policy-relevant issues, and its current nomination process is already stalled this year.
Every year since 2007, the EPA has put out a call for nominations around the same time in April. Except this year, that call never came, despite there being 15 slots opening up this September that need to be filled. Likewise, CASAC’s chair’s term is ending in September and the EPA has so far done nothing to recruit for her replacement, even though without her the committee will be unable to function. EPA staff has reported that Pruitt has a draft notice for nominations on his desk, but he hasn’t issued it yet. Without CASAC’s chair, the committee will be unable to issue recommendations on soot and sulfur oxides that the EPA relies on for further air quality rulemaking.
The crucial role of independent science advice
Delaying the work of these advisory committees is another example of this administration’s apparent philosophy of death by delay. The inability of CASAC to continue advising the EPA on its National Ambient Air Quality Standards means that the EPA will go without independent scientific advice on the six criteria pollutants of ozone, particulates, carbon monoxide, sulfur dioxide, nitrogen oxides, and lead. Changes to BOSC means that ORD will have less input on how to make cost-effective changes to its research programs while encouraging important scientific development. And if the SAB gets treatment similar to BOSC, SAB’s ongoing work to review EPA’s water quality criteria to protect aquatic life and to peer review EPA’s toxicological assessments of several chemicals, including ethyl tert-butyl ether will languish.
We must protect federal advisory committees, for they are the objective body that every agency needs in order to take on some of the most difficult questions facing our country today. The work that these advisory committees do feeds into the crucial research conducted by and the safeguards issued by the EPA. Advisory committee members volunteering their valuable time to public service to advise agencies on how best to protect us and the environment are unsung heroes. We should acknowledge and praise them more often.
It’s a shame that Administrator Pruitt is doing the opposite: actively working to offend committee members by questioning their objectivity under a new administration and devaluing their work by shifting committee composition and cancelling committee meetings. Gutting our government’s capacity for independent science advice is an attack on science. We will be keeping a watchful eye on the appointment of new BOSC committee members to make sure that scientific expertise and research experience, not political views, are the basis for qualification.