By Gretchen Goldman, Union of Concerned Scientists
On Thursday, November 29, the EPA’s Clean Air Scientific Advisory Committee (CASAC) will meet(via phone) for the first time since the recent upheaval in its membership. The agenda? To discuss the Integrated Review Plan for updating the ozone standard. And recently ousted scientists have something to say about it.
A science-based process to protect people from ozone pollution
Ozone is one of the last remaining ambient air pollutants we don’t have under full control. Many places in the US have struggled to meet the federal standard designed to protect public health and ozone pollution at current levels affects millions of Americans, particularly those with lung diseases like asthma. Thankfully, we’ve long had a science-based process to ensure we can set an ozone standard that protects public health. The process has always allowed for robust scientific assessmentand public input, and importantly, clear separation between the science and the policy. For more background, I’ve written about this process and the history of the ozone standard here.
A Compromised CASAC and an expedited process
But under the Trump administration, this process has changed. In October, the Trump administration replaced the CASAC’s independent scientists hailing mostly from academic institutions with individuals from local and state agencies. The new seven-member committee now includes only one member primarily from an academic institution, a stark shift from CASAC’s long history of being comprised primarily of academic researchers who publish regularly in the field of air pollution and health effects. The difference is dramatic.
In the same announcement, the administration announced it would not convene an ozone review panel—the group of experts that have informed ambient air pollution standards for four decades. The ozone Integrated Review Plan released this November revealed the EPA’s plan to update the standard will now also be streamlined in other ways that compromise the level of scientific and public input. The schedule is greatly expedited compared to past updates to the ozone standard. The agency also indicated it would be streamlining the scientific and policy assessment documents that inform the EPA administrator’s decision on the final standard.
An ozone standard protective of public health?
Together, these changes are likely to mean less science feeding into the process of updating the ozone standard. Given the pervasiveness and serious health impacts of ozone pollution, this is concerning. When EPA last updated the ozone standard in 2015, it set the standard at 70 ppb. This was the upper limit of what the independent scientists on CASAC recommended to the EPA administrator. CASAC recommended a standard of 60-70 ppb but noted that a standard of 70 ppb might not adequately protect vulnerable groups liked children, the elderly and those with lung diseases, as the Clean Air Act requires.
In other words, scientists considered the current ozone standard only minimally protective. As a result, we cannot afford to walk back this standard. If the Trump administration sets a standard looser than 70 ppb, we can be certain that it won’t have followed the science on ozone and health, it won’t be consistent with the advice of scientific experts, and it certainly won’t protect public health.
Scientists aren’t happy about this new process. This week, 19 former members of the ozone review panel, many of them former CASAC as well, penned a letter criticizing the new EPA process. The scientists write that the changes to the ozone review are “collectively harmful to the quality, credibility, and integrity of the scientific review process and CASAC as an advisory body” and provide 30 recommendations for what the current CASAC should do to ensure the appropriate science-based process is followed.
I too have thoughts. Below is the public comment I will deliver at the CASAC ozone meeting:
Thank you for the opportunity to comment. I am the research director at the Center for Science and Democracy at the Union of Concerned Scientists. On behalf of more than half a million citizens and scientists, we advocate for the use of science for a healthy planet and a safer world. The Center for Science and Democracy works to advance the roles of science and public participation in policy decision-making. We have never advocated for an ambient air quality standard different from the CASAC recommendation, only to ensure the proper process is followed and scientific advice is heeded.
With respect to the ozone standard update, I am concerned about this process. The greatly expedited schedule and document merging proposed in the draft Integrated Review Plan are likely to limit the ability of the EPA and its Clean Air Scientific Advisory Committee (CASAC) to follow a science-informed process that leads to ozone standards protective of public health and welfare. Typically, the process of EPA staff, CASAC, and the ozone review panel compiling, reviewing, and revising the Integrated Science Assessment, Risk and Exposure Assessment, and Policy Analysis requires far more time than this schedule allows.
Additionally, the expedited timeline with fewer drafts and fewer public meetings will mean fewer opportunities for public input. Some 124 million Americans live in areas with ozone pollution levels that exceed the current standard, with serious public health consequences for many, including those with lung diseases such as asthma, children, and the elderly. The public deserves sufficient opportunity to weigh in on a regulation with such far-reaching impacts.
The effects of this expedited timeline document skimming are compounded by the agency’s failure to convene an ozone review panel. In past reviews of the ground-level ozone standard, the panel has provided vital expert input and necessary peer review of the wide-ranging fields represented in the Integrated Science Assessment. Indeed, for more than four decades, such expertise has helped ensure EPA leadership is presented with the best available science on the effects of criteria pollutants on health and the environment. These panels provide the needed range of perspectives on critical science and science policy issues.
It would be challenging for any seven-member CASAC to compensate for this lapse of expert input. Moreover, because the current CASAC lacks experts in key fields, such as epidemiology, it is difficult to imagine that the EPA’s science assessment will receive the robust scientific review that is necessary.
The expedited time frame and merged documents, combined with gaps in expertise on CASAC and the lack of review panel and public input opportunities, are likely to undermine the ability of the EPA to set a science-based standard for ozone, protective of public health with an adequate margin of safety, as required by the Clean Air Act.
I urge you to reconsider the decision not to convene an ozone review panel. As you hear in these comments, many qualified scientists are willing to volunteer their time and expertise for such a task, as they always have since the EPA began setting ambient air quality standards decades ago. An ozone review panel would help ensure that the EPA can make decisions based on solid scientific assessment.
I urge you to follow a careful, robust process to assess the current state of the science on ozone and health, regardless of whether it meets the arbitrarily aggressive timeline laid out in the Integrated Review Plan. And I urge you to ensure there are sufficient opportunities for public input for a pollutant standard that will affect more than a third of the nation’s population. The EPA’s mission, the Clean Air Act and broad public opinion compel you to make a decision that protects the public health.
The current CASAC should use its authority to recommend that the EPA follow a science-based process that protects public health. At Thursday’s meeting we will hear their thoughts.