By Michael Halpern, Union of Concerned Scientists
The EPA’s own Science Advisory Board (SAB)—two-thirds of which was appointed by the Trump administration—is the latest group of scientists to come out swinging against a proposal to restrict the use of science in agency decisions. The SAB’s draft analysis was released on New Year’s Eve as one of four documents that panned several recent anti-science and anti-environmental proposals. The advisors also challenged EPA’s work on water protection, fuel efficiency, and mercury pollution.
The EPA recently doubled down on its “restricted science” proposal, making it worse and more expansive despite universal opposition from mainstream scientific organizations. EPA leaders, including Administrator Andrew Wheeler, consistently rebuffed advice from scientists on the proposal, but SAB analyzed it anyway.
The scientists, in unusually strong language, pick apart every major component of the EPA’s “restricted science” proposal, echoing two years of analysis from many other scientists and organizations including UCS since the proposal was announced. Among the highlights:
- The proposal heavily politicizes science. The proposed rule could be viewed as a “license to politicize the scientific evaluation required under the statute based on administratively determined criteria for what is practicable.”
- The proposal could allow EPA to exclude vast amounts of information from consideration as it makes decisions. Broad implementation of the proposal “would be enormously expensive and time consuming at best and can be expected to result in the exclusion of much of the scientific literature from consideration.”
- The proposal is a solution in search of a problem. “There is no justification in the Proposed Rule for why the EPA finds that exiting procedures and norms utilized across the U.S. scientific community, including the federal government, are inadequate.”
- The proposal is so vague that its impact cannot be fully assessed. “Considerations that should inform the Proposed Rule have been omitted from the proposal or presented without analysis…it is not possible at this time to define the implications of the rule with confidence.”
- The proposal could impede scientific research inside EPA. “Some additional requirements of the Proposed Rule may not add transparency and even make some kinds of research more difficult..”
- Giving the administrator the authority to include or exclude specific studies could further politicize science. “A case-by-case waiver may exacerbate concerns about inappropriate exclusion of scientifically important studies.”
Even in draft form, this letter from the agency’s own external advisors should be the final blow for a deeply flawed effort by the EPA to place unreasonable and unwarranted restrictions on the science used to inform decisions. Hopefully, Administrator Wheeler will announce publicly that the proposal will be shelved.
Unfortunately, Wheeler’s recent decision to further exert control over Science Advisory Board reviews was almost certainly a direct response to his advisors choosing to review this rule and shows how unwilling the administrator is to consider the critical feedback the agency so sorely needs.
While we await EPA’s next move, the SAB will meet publicly later this month to discuss all four reports and finalize its recommendations. The proposal to restrict the use of science will be discussed on January 21. This two page PDF includes information on how to participate in these meetings, and provide public comments or written statements.