Over the past two months, EPN submitted two sets of formal comments on proposed rulemakings and a set of comments on a draft chemical risk evaluation, provided written and oral testimonies to an EPA advisory committee and board, and continued to be a trusted source of information to reporters.
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.
Highlights:
EPN submitted a third set of comments on the chemical Pigment Violet 29 (PV29), as well as written and oral comments on three additional draft chemical risk evaluations for 1,4-Dioxane, HBCD, and 1-Bromopropane (1-BP) to the Science Advisory Committee on Chemicals. EPN also submitted more detailed comments on 1,4-Dioxane and HBCD.
EPN submitted written and oral testimony to the EPA Science Advisory Board on the issue of personally identifying information and confidential business information, as it is proposed under the censored science rule. EPN also drafted comments to the Council on Environmental Quality on the draft National Environmental Policy Act (NEPA) guidance for climate changing greenhouse gas emissions.
EPN submitted comments to EPA on the Region 4 North Carolina State Implementation Plan (SIP) alternative interpretation and submitted comments on the proposed perchlorate drinking water standard.
EPN’s members were featured in dozens of media outlets and authored numerous op-eds.
EPN member Roy Gamse, former Deputy Assistant Administrator for Planning and Evaluation and Acting Assistant Administrator for Planning and Management, is quoted in this article about scientists pushing back against a Trump Administration proposal that would block EPA from relying on studies that don’t make their underlying data public.
EPN members Dr. Bernard Goldstein, former chair, EPA Clean Air Scientific Advisory Committee, and former EPA Assistant Administrator for Research and Development, and Roy Gamse, former Deputy Assistant Administrator for Planning and Evaluation and Acting Assistant Administrator for Planning and Management, are quoted in this article about the Science Advisory Board’s role in consulting with EPA on its Censored Science proposal and the serious practical and ethical problems that arise from it.
This article discusses and quotes EPN’s comments objecting to draft guidance issued by the Council on Environmental Quality to assist federal agencies in considering greenhouse gas emissions when they evaluate federal actions, like the construction of roads and pipelines, under NEPA.
EPN Comments on EPA Region 4 North Carolina SIP Alternative Interpretation
In response to EPA Region 4’s proposal for an alternative interpretation of the North Carolina SIP, EPN concluded that the proposal failed to justify why it is warranted, lacks a legal or technical justification that the revision would protect public health, and fails to show that it is consistent with the Clean Air Act.
EPN Comments on EPA’s Proposed Drinking Water Regulation for Perchlorate
In response to EPA's proposed drinking water regulation for perchlorate, EPN produced comments highlighting the shortcomings of the proposal and strongly recommended submitting a new proposal that addresses these issues and excludes the option to withdraw from the 2011 determination to regulate perchlorate.
In addition to the news articles above, EPN members contributed to a range of articles on topics such as the Clean Power Plan, changes to the Federal Advisory Committees Act, Trump’s speech on his environmental record, attacks on science, a variety of air issues, methane, and the Safe Affordable Fuel-Efficient Vehicle rule. EPN members have also penned their own op-eds on greenhouse gas emissions and NEPA, as well as budget issues concerning states.
EPN member Jeff Alson, former EPA Senior Engineer and Policy Advisor, Office of Transportation and Air Quality, is quoted in this article about how automakers’ voluntary deal with California could be a model for voluntary environmental initiatives in other sectors, but would not be as protective as federal policies backed by enforcement or oversight.
EPN member Janet McCabe, former EPA Acting Assistant Administrator, Office of Air and Radiation, was interviewed for this special about the devastating impacts of Trump’s deregulation campaign.
EPN member Cynthia Giles, former EPA Assistant Administrator, Office of Enforcement and Compliance Assurance, wrote this op-ed about the Trump Administration encouraging federal agencies to downplay and dismiss the risks of climate change in regulations and policies. For example, the White House Council on Environmental Quality’s (CEQ) draft guidance on how federal agencies should consider climate when they evaluate federal actions under the National Environmental Policy Act (NEPA) makes no mention of “climate change.”
EPN member Trish Koman, former Senior Environmental Scientist, Program Manager and Supervisor in EPA’s Office of Transportation and Air Quality, was quoted in this article about emissions from school buses and their disproportionate impact on sensitive populations such as young children.
Christopher Zarba, EPN member and former Director, EPA Science Advisory Board, was quoted in this article about a report from the Government Accountability Office (GAO) that found that EPA ignored several ethics rules and administrative procedures when overhauling its science advisory panels. This article ran in numerous other publications, including ABC, US News, and The Telegram.
David Coursen, EPN member and former EPA Office of General Counsel, wrote this op-ed about the Trump Administration’s attacks on state-level environmental protection efforts, from proposed budget cuts for brownfield programs to potential rescindment of waivers that allow states to set standards that are more stringent than at the federal level.
