By Gretchen Goldman, Union of Concerned Scientists
Yesterday, the EPA Clean Air Scientific Advisory Committee (CASAC) had a teleconference to discuss their recommendations to the administration on the agency’s assessment of the science on particulate matter (PM) and health. The meeting continued the ongoing push and pull between the EPA, its science advisors, and the committee chair Dr. Tony Cox.
The committee was meeting to finalize a letter they will jointly send to the EPA recommending changes to its draft science assessment on the state of particulates and health, a key document that informs the EPA’s (statutorily required to be science-based) decision on the level of particulate matter that protects public health. (More background and information on the state of play in my Scientific American piece here.) Here’s five top takeaways from the meeting:
1. CASAC admits it doesn’t have the needed expertise
The committee finally agreed on what was obvious to everyone else: They need more expertise. Since EPA leaders dismissed the particulate matter review panel last October and selected a new set of CASAC members that don’t include key expertise like epidemiology, it has been abundantly clear that the current seven-member CASAC is insufficient to review the hefty and wide-ranging scope of the EPA’s science assessment. I, and many other scientists, made this point in public comments at the December meeting. And a letter signed by 206 air quality in public health experts asked the administration to reinstate the panel. Members of CASAC themselves echoed these concerns but in December the chair pressed forward, ignoring them. This time, he conceded they needed more expertise and the group agreed to put language in their final letter that asks for a reconvening of the particulate matter review panel or one with comparable expertise, plus a few additional expertise areas they indicate needing.
This new consensus is important. The committee now has disagreed with EPA Administrator Andrew Wheeler who told Congress earlier this year that the panel had the needed expertise to conduct the review. In response to a question from Senator Carper asking about the dismissal of the PM panel, Administrator Wheeler said, “I believe the current CASAC has the experience and expertise needed to serve in this capacity as well as to complete the reviews for the particulate matter and ozone NAAQS.” The committee now admits they do not, raising questions about whether the EPA will be able to obtain the best available science advice necessary to set a science-based PM standard that protects public health, as the Clean Air Act requires.
2. CASAC members pushed back on the chair
While at the December meeting the Chair was able to override most disagreements raised by others, in this meeting CASAC members were more willing to speak up and disagree with the Chair on letter contents. As a result, many of the most damaging elements of the draft letter that the Chair released on March 7th were removed. The draft letter had uncharacteristically strong critiques for how the EPA conducted its science assessment calling the robustly lengthy and exhaustively referenced document “unverifiable opinion” and accusing the EPA of not following the scientific method. The committee has thankfully agreed to strike this language. It is less clear if committee members were able to push back on all of the problematic language in the letter, but the final draft should be substantially less hostile to EPA’s science assessment than the version Cox drafted.
3. The scientific community stood up
The broader scientific community is not sitting this one out. Last week I released a paper in Sciencewith Harvard data scientist and air pollution and health effects expert Francesca Dominici. The paper took on Cox directly for his fringe ideas about how the EPA should approach assessing links between air pollution and health outcomes like early death and respiratory disease. Many other top experts in the field gave in-person comments or submitted written comments criticizing the process and scientific approach being taken by CASAC chair. There were also organizational comments from the Health Effects Institute and the International Society for Environmental Epidemiology, as well as a letter signed by 17 members of the dismissed PM review panel. These critical comments build on public comments submitted and delivered at CASAC’s December meeting, including comments from former CASAC members and former PM review panel members, and former ozone review panel members. In short, the top experts in air pollution and health are in strong unified opposition to the approach being taken by Dr. Cox and this meeting made that abundantly clear.
4. The chair has not moderated his fringe views
Dr. Cox was criticized in my Science piece and elsewhere for his views far outside the mainstream scientific community on air pollution and health. While Dr. Cox expressed surprise with this characterization, mentioning my Science piece explicitly, he did not moderate his views throughout the meeting, noting that he is “appalled” with the lack of evidence for the connection between particulate matter and early death, a relationship that scientists have studied and confirmed in many studies, over many years, in many locations around the world, using different study designs.
5. The process is broken
The (well-designed, in my opinion) process for developing air pollution standards is now broken for this PM standard update. This started long before the current CASAC was appointed. Last spring in his “Back to Basics” memo, former EPA Administrator Pruitt made clear he intended to expedite the process for updating the particulate matter and ozone standards and create conditions that made it harder for robust science advice to inform National Ambient Air Quality Standards. Pruitt and now Administrator Wheeler made good on that promise by tearing down the scientific supports that ensure a robust scientific process with ample opportunities for public input.
EPA is now in a tough spot. It would be difficult in any event to complete a PM review by 2020 as the administration intends. Doing so was made more difficult by the administration nixing the PM review panel. It is now made even more difficult by CASAC’s intention to ask for the panel to be reinstated, a move that would surely mean more public meetings, document drafts, and a general delay in the process.
Alternatively, the administration could move forward, ignoring CASAC’s request for more expertise but in doing so, they are almost certainly setting themselves up for legal challenges. If CASAC itself acknowledges they don’t have the scientific expertise to conduct a science-based review, how can the administration claim to have set a science-based standard? Based on yesterday’s discussion, there are likely to be some elements of the final letter that still conflict with the broader scientific community’s opinion on EPA’s approach, despite pushback from several committee members and nearly all public comments. We will see what the final letter to the administration from CASAC looks like, but one thing is for certain, this process is broken.