EPN In Action November-December 2020

Welcome to your EPN in Action Newsletter

The Environmental Protection Network was launched in January 2017 to harness the expertise of former EPA career staff and confirmation-level appointees from multiple administrations to provide an informed and rigorous defense against efforts to undermine the protection of public health and the environment.

  • EPN member Roy Gamse presented personal testimony on EPA’s Revised “Guidelines for Preparing Economic Analyses” during a meeting of the Science Advisory Board.

  • EPN created a side-by-side comparison of the FY2020 enacted budget, the FY2021 House bill, and the FY2021 Senate proposed bill.

  • EPN submitted comments in response to the Department of Transportation’s proposed significant changes to implementation regulations of the National Environmental Policy Act.

  • EPN commented on EPA’s proposed regulations that would allow certain genetically modified plant-incorporated protectants to be exempt from Federal Insecticide, Fungicide, and Rodenticide Act registration and Federal Food, Drug, and Cosmetic Act requirements.

  • EPN requested a comment extension and submitted comments on the supplemental analysis conducted under the Toxic Substances Control Act (TSCA) on the draft risk evaluation for 1,4-dioxane.

  • EPN sent a letter to EPA Administrator Wheeler reiterating its concerns about the agency’s final risk evaluation of trichloroethylene conducted under TSCA.

  • EPN submitted comments on the revised draft risk evaluation of the chemical Pigment Violet 29 conducted under TSCA.

EPN’s Work on Cost Benefit Analysis, Budget, and NEPA

EPN Member Presents Testimony on SAB Peer Review of EPA’s Revised Guidelines for Preparing Economic Analyses

EPN member Roy Gamse, former EPA Deputy Assistant Administrator for Planning and Evaluation and Acting Assistant Administrator for Planning and Management, presented personal testimony on the importance of ancillary benefits and costs during a public meeting of EPA's Science Advisory Board (SAB) to review the draft SAB peer review of EPA’s revised "Guidelines for Preparing Economic Analyses."

EPN Submits Comments on DOT Proposal for Significant Changes to NEPA Regulations

EPN submitted comments on the Department of Transportation's (DOT's) proposed significant changes to the implementation of the National Environmental Policy Act (NEPA) regulations, which conform to the Council on Environmental Quality NEPA implementation changes that became effective in September 2020. EPN opposed both proposals due to inconsistencies with NEPA law, congressional intent, and years of practice.

Cost Benefit Analysis and Budget in the News

New Trump Rule Aims to Limit Tough Clean Air Measures Under Biden

December 9, 2020 / by

Coral Davenport /

The New York Times

Roy Gamse, EPN member and former EPA Deputy Associate Administrator for Policy, was quoted in this article concerning EPA’s decision to finalize a rule that would alter how the agency calculates the costs and benefits of air rules. Roy was also quoted in articles by Reuters, DeSmogBlog, Gizmodo, Common Dreams, Inside EPA, and EcoWatch.

Trump Admin Plows Ahead on Fiscal 2022 Budget

November 11, 2020 / by

Kelsey Brugger /

E&E News

Dave Coursen, EPN member and former attorney, EPA Office of General Counsel, was quoted in this article about the Trump administration’s continued work on the FY22 budget.

EPN’s Work on Toxics and Pesticides

EPN Comments on Proposed Exemptions of Certain Genetically Modified Plant-Incorporated Protectants

EPN commented on EPA's proposed regulations to allow certain genetically modified plant-incorporated protectants (PIPs) to be exempt from Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) registration and Federal Food, Drug, and Cosmetic Act (FFDCA) requirements. EPN found possible sources of risk to human health and the environment in potentially exempted products and urged EPA to add conditions based on economic and social considerations to any exemption rule before finalized.

EPN Requests a Comment Extension for Supplemental Analysis of 1,4-Dioxane

EPN sent a letter to EPA requesting an extension of the comment period for the draft supplemental risk evaluation for 1,4-dioxane. Due to the significant issues raised by a major expansion in scope of the original evaluation, a 60-day comment period was recommended to produce the most comprehensive comments.

EPN Submits Comments on 1,4-Dioxane Supplemental Analysis

EPN submitted comments on EPA's supplemental analysis to the draft risk evaluation for 1,4-dioxane under the reformed Toxic Substances Control Act (TSCA). As in previous comments, EPN urged EPA to adequately evaluate whether conditions of use present an unreasonable risk of cancer or noncancer effects, as well as to assess risks to the general population from contaminated drinking water supplies.

EPN Raises Concerns about Final TSCA Risk Evaluation of Trichloroethylene

EPN sent a letter to EPA about the unreasonable health risks associated with the chemical trichlorethylene (TCE). EPN urged Administrator Wheeler to take immediate regulatory action and utilize the most sensitive endpoint in its risk evaluation to set standards that will adequately protect human health.

EPN Submits Comments on Revised Draft Risk Evaluation of PV29

EPN submitted comments on a revised draft risk evaluation of the chemical Pigment Violet 29 (PV29), which is primarily used as a colorant in inks, paints, coatings, and plastics. EPN raised concerns with inadequate data and deficiencies in determining risk to human health and a concurrent peer review, which lacked peer reviewers who have critically needed expertise in inhalation toxicology and did not provide time for public comments to be taken into consideration.

EPN Member Op-Eds

EPN members penned their own op-eds on climate and water, enforcement, and EPA’s 50th anniversary.

Steps to Cool the Climate will Improve Water Quality, too

December 9, 2020 / by

Jeff Peterson /

The Hill

Jeff Peterson, EPN member and former Senior Policy Advisor, EPA Office of Water, wrote this op-ed about how climate change mitigation can improve the health of U.S. water bodies and increase drinking water quality.

Reversing Rollbacks in the Post Trump-Era is not Enough

December 7, 2020 / by

David Coursen /

The Hill

David Coursen, EPN member and former attorney, EPA Office of General Counsel, penned this op-ed regarding the crucial need for increased spending on criminal enforcement to uphold the Biden administration’s environmental agenda.

The EPA at 50: It’s Time to Correct Inequities and Think Big

December 3, 2020 / by

Michelle Roos /

Bloomberg

Michelle Roos, EPN Executive Director, wrote an op-ed published in Bloomberg discussing “Resetting the Course of EPA” in the context of EPA’s 50th anniversary. 

Examples of EPN in the News

In addition to the articles above, EPN members contributed to a range of articles on topics such as climate change and climate science, the finalized lead and copper rule, rebuilding science at EPA, the censored science rule, and risk evaluations under TSCA.

The Resistance: In the President’s Relentless War on Climate Science, They Fought Back

December 27, 2020 / by

Marianne Lavelle /

Inside Climate News

EPN members Jeff Alson (former Senior Engineer and Policy Adviser, EPA Office of Transportation and Air Quality), Dan Costa (former National Program Director, EPA Air, Climate, and Energy Research Program, Office of Research and Development), Tom Sinks (former Director, EPA Office of the Science Advisor), and Chris Zarba (former Director, EPA Science Advisory Board) were quoted and EPN was mentioned in this article concerning the current administration’s combative relationship with science at EPA.

EPA Finalizes New Lead and Copper Rules for Drinking Water

December 23, 2020 / by

Adisa Hargett-Robinson /

ABC News

Mustafa Santiago Ali, EPN member and former Senior Advisor for Environmental Justice and Community Revitalization and Assistant Associate Administrator for Environmental Justice, was quoted in this article regarding EPA’s recently finalized Lead and Copper Rule. Mustafa was also quoted in a similar article in The Hill.

Can Joe Biden Rebuild the Ravaged US Environmental Protection Agency?

December 16, 2020 / by

Jeff Tollefson /

Nature

EPN members Bob Kavlock, former Acting Assistant Administrator, EPA Office of Research and Development and EPA Deputy Assistant Administrator for Science, and Chris Zarba, former Director, EPA Science Advisory Board, were quoted in this article about the damage sustained to EPA under the current administration and what will be required to build back its capacity.


E.P.A.’s Final Deregulatory Rush Runs Into Open Staff Resistance

November 27, 2020 / by

Lisa Friedman /

The New York Times

EPN members Tom Sinks (former Director, EPA Office of the Science Advisor), Tom Burke (former Science Advisor and Deputy Assistant Administrator, EPA Office of Research and Development), Judith Enck (former Regional Administrator for EPA Region 2), and Chris Zarba (former Director, EPA Science Advisory Board) were quoted in this article regarding staff resistance to the potential finalization of EPA’s “censored science” rule.

To Achieve His Climate Goals, Joe Biden Needs to Bring Scientists Back

November 12 / by

Justine Calma /

The Verge

EPN members Dan Costa (former National Program Director, EPA Air, Climate, and Energy Research Program, Office of Research and Development), Vijay Limay (Physical Scientist, Air Monitoring and Analysis Section, Air and Radiation Division, EPA Region 5), and Chris Zarba (former Director, EPA Science Advisory Board), are quoted and Mustafa Santiago Ali (former Senior Advisor for Environmental Justice and Community Revitalization and Assistant Associate Administrator for Environmental Justice) is mentioned in this article on the need to reintegrate science into the federal government for the incoming Biden administration to implement its climate change agenda.

Biden Administration Expected to Increase Scrutiny of TSCA Risk Evaluations, New Chemicals

November 11, 2020 / by

Terry Hyland /

Chemical Watch

EPN members Betsy Southerland (Director of the Office of Science and Technology in EPA’s Office of Water) and Bob Sussman, former EPA Deputy Administrator, were quoted in this article regarding Toxic Substances Control Act (TSCA) policies under an incoming Biden administration.

Read all recent EPN In the News items here