By Gretchen Goldman, Union of Concerned Scientists
Trump administration officials at the US Environmental Protection Agency have made several moves that undermine the longstanding process that the agency uses to ensure that independent science informs ambient air pollution standards.
For decades, under both democratic and republican administrations, the EPA has used the best available science and science advice to set air pollution standards at levels that protect public health with an adequate margin of safety, as the Clean Air Act requires. But now that process is under threat. Below is a timeline of actions the Trump administration has taken that upend this time-tested and science-based process for setting health-based air pollution standards.
31 October 2017: Pruitt Memo on Grants and Advisory Committees
Then-EPA Administrator Scott Pruitt issues a memorandum banning scientists with current EPA research grants from serving on science advisory committees, while permitting individuals from regulated industries to continue to serve. The move forced several scientists on EPA’s seven science advisory committees to either step down or give up grants they were awarded in order to continuing serving.
12 April 2018: Presidential Memorandum on NAAQS
Presidential Memorandum orders the EPA to make sweeping changes to implementation of the National Ambient Air Quality Standards (NAAQS), including requiring science advisors to consider non-scientific information, restricting the science that can be used in decisionmaking, and shifting responsibility to the states without increasing their resources.
9 May 2018: Pruitt Memo on NAAQS Process
Then-EPA Administrator Scott Pruitt follows the president’s memorandum with his own, articulating details of how he will implement the orders at the agency. The Pruitt Memo announces that EPA will follow an expedited timeline for review of the National Ambient Air Quality Standards for particulate matter and ozone, and that the kinds of scientific information EPA can use in its ambient air pollutant standard policy decisions may be restricted.
10 October 2018: PM Panel Disbanded
EPA leaders disband the Particulate Matter Review Panel and announce they will not convene an Ozone Review Panel, bodies of independent expertise that have informed air pollution standard reviews for decades. At the same time, EPA leaders replace the members of its Clean Air Scientific Advisory Committee (CASAC) largely from academic institutions with those from state and local regulatory agencies, led by an industry consultant.
11 April 2019: CASAC Lacks the Needed Expertise
In an unprecedented move, CASAC sends a letter to EPA Administrator Andrew Wheeleracknowledging that the seven-member group needs additional expertise to adequately advise the agency on the particulate matter ambient air quality standard.
5 September 2019: PM Policy Assessment Released
The EPA Draft Policy Assessment for Particulate Matter is released. The document is inclusive of the risk assessment (which has been a separate document in recent history) and considers the agency’s Integrated Science Assessment, which characterizes the state of the science on particulate matter and health and welfare effects. The Policy Assessment recommends that in order to protect public health with an adequate margin of safety, as the Clean Air Act requires, the primary fine particulate matter standard should stay the same or be tightened.
13 September 2019: Consultants Appointed
Rather than appoint a Particulate Matter Review Panel as CASAC and the broader scientific community have asked, EPA leaders appoint a group of consultants to supplement the seven-member CASAC in its review of the particulate matter standards. The consultants will be available for a highly controlled Q&A process, where committee members’ questions must be asked by the committee and answered by the consultants in advance of CASAC’s meeting. Unlike the Particulate Matter Review Panel, the consultants will not be able to engage with the committee or with each other in real time and will not be able to deliberate on topics outside of the narrow questions they are posed.
18 September 2019: CASAC Meeting Structure Announced
The CASAC meeting to discuss the Policy Assessment for the Particulate Matter National Ambient Air Quality Standards review is set for October 24 in North Carolina. In an atypical move, the meeting will detach public comments as a separate teleconference two days prior. One challenge with this structure is that public commenters may not have access to the committee members pre-meeting comments and agency briefing material. If all materials are not available by October 22, this would limit the ability of the public to make informed comments to CASAC and the EPA in their discussion of the particulate matter standards.
The administration intends to finish the ambient standard reviews for both particulate matter and ozone by the end of 2020. Stay tuned for new developments as EPA leaders strive to meet this tight timeline.