casac
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see SAB
see secret sci
see PM2.5 partic holo
enstrom, wheeler, milloy
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Reset or Purge? Trump EPA Dismisses Agency Science Advisers - Inside Climate News
Reset or Purge? Trump EPA Dismisses Agency Science Advisers
BY MARIANNE LAVELLE
Critics fear the unusual clean sweep of panels is meant to ease the planned rollback of climate and environmental policy.
All members of the Environmental Protection Agency’s boards of outside advisers on science and clean air were dismissed in a letter emailed late Tuesday, an unusual step the Trump administration said was aimed at depoliticizing the panels.
Panel members expressed disappointment and confusion at the assertion in the letter signed by James Payne, a career EPA attorney Trump installed as acting administrator. Critics charged the Trump administration with politicizing the process by eliminating the current independent advisers and clearing the way for them to be replaced with hand-picked appointees.
“This is not about good governance, this is about rigging the system for polluters; corruption at the expense of the American people,” said Sen. Sheldon Whitehouse of Rhode Island, the ranking Democrat on the Committee on Environment and Public Works.
Similar efforts to remake science advisory panels came during the first Trump administration, with EPA leaders changing the eligibility rules for serving on boards. The result was fewer university researchers on the panels and more industry consultants and scientists who were supportive of Trump’s deregulatory efforts, like University of Alabama in Huntsville atmospheric scientist John Christy, taking seats.
A number of the now-dismissed panel members had two to three years remaining in their terms. It was not immediately clear who would be appointed as replacements on the advisory panels, both of which are required under federal law. Trump’s choice to head up the Environmental Protection Agency, former New York Congressman Lee Zeldin, won Senate confirmation on Wednesday, the day after the dismissals.
An EPA spokesperson said the move was in line with the agency’s purpose.
“EPA is working to update the Science Advisory Board (SAB) and Clean Air Scientific Advisory Committee (CASAC) to ensure that the agency receives scientific advice consistent with its legal obligations to advance our core mission,” the spokesperson said in an email. “The decision to reset these federal advisory committees emphasizes the importance of SAB and CASAC to EPA’s mission of protecting human health and the environment and seeks to reverse the politicization of SAB and CASAC made by the previous Administration.”
The dismissed chairs of both of the boards disputed that characterization.
“I was not appointed as a political appointee, but as a scientist that studies air pollution and health,” said Jeremy Sarnat, a professor at Emory University’s Rollins School of Public Health who had only begun serving as chair of the CASAC in October. He said the Clean Air Act, passed on a bipartisan basis more than 50 years ago and implemented under administrations of both parties, had been “one of the most successful public policies that has ever been enacted globally,” in part because of procedures that require the agency to rely on the best science.
“I know that so many other facets of American life and society have been politicized, and I hope that the CASAC and the advisory boards can remain above that and that the new administrator will adhere to the principles and practices, which have really worked so well for decades,” Sarnat said.
Kimberly Jones, an engineering professor and associate provost at Howard University, who has served as chair of the Science Advisory Board since 2023, said she was disappointed in the administration’s decision.
“It does seem to signal a shift in the decades-old accepted facts about how science should occur,” Jones said. “We should not be writing or interpreting science to meet anybody’s objectives. We should be independent, doing our best job to evaluate the science as scientists. This seems to go counter to that understanding.”
Although EPA’s science advisers are not decision-makers, their advice becomes important when the agency’s policy decisions face legal challenges. EPA’s 2024 decision to strengthen the National Ambient Air Quality Standard for fine particulate matter, for example, was bolstered because it was in line with the advice the agency received from the CASAC. Conversely, weak ozone standards passed during the first Trump administration were successfully challenged in court in 2021, in part because the EPA had received contrary recommendations from outside advisers.
It is not the first time there has been a clean sweep of scientific advisers. Biden’s EPA chief, Michael Regan, installed a new slate at CASAC when he took office in 2021 based on the findings by the GAO and others that the selection process had become compromised.
H. Christopher Frey, an associate dean at North Carolina State University who served as head of EPA’s Office of Research and Development during the Biden administration, said the circumstances are entirely different now. “This is really just a flat-out purge of the current membership,” he said.
Frey said the Trump administration seemed to be following the conservative policy platform Project 2025, which called for “resetting science advisory boards” at EPA.
“The administration seems to be wanting to promote loyalty and compliance with its policy agenda, but that’s not the mission of a science advisory board,” Frey said. “So if that’s the goal, it’s an inappropriate interference in an external, independent expert advisory board, and it’s also just setting more precedent for this to happen every time.”
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good sum PM2.5 and secret sci BS:
https://insideclimatenews.org/news/28052020/contrarian-science-james-enstrom-epa-climate-change/
no lnx many
How a Contrarian Scientist Helped Trump’s EPA Defy Mainstream Science
James Enstrom’s work on particle pollution’s health effects contradicts the findings of dozens of studies, but that hasn’t stopped the agency from relying on it.
By Marianne Lavelle
May 28, 2020
In March 2017, a scientist named James Enstrom rattled many public health experts by publishing a study concluding that there was no link between fine soot air pollution and premature death.
The finding was drastically at odds with the consensus of medical researchers and with the evidence from nearly three decades of previous research.
But it was in line with arguments that Enstrom, a physicist-turned-epidemiologist, had been making for years. His dissent had played an essential role in his ascendance as a folk hero to far-right conservatives who oppose most environmental protection policies in the United States, especially those put in place by the Obama administration.
Enstrom argued that his analysis refuted one of the most influential papers in environmental health science: a 1995 study by the American Cancer Society showing that fine particulate matter pollution—or PM 2.5, as it is known—is associated with early death. PM 2.5 is produced primarily through the burning of oil, coal and wood.
Enstrom, 76, said he based his study on long-hidden cancer society data from an inside source whom he did not name. Throughout the article, which appeared in the journal Dose-Response, he took jabs at institutions that he believed had long marginalized him, including the cancer society (ACS), leading scientific journals, the U.S. Environmental Protection Agency and other health researchers, who, he wrote, “need to promptly address my findings.” He hinted at scientific malfeasance and suggested that there was a conspiracy of silence against minority views like his.
Big-name journals, Enstrom wrote in the article, were biased against publishing results showing no association between air pollution and mortality, adding that seven other peer-reviewed scientific journals had rejected his study. In an unusual footnote, he also included a link to the rejection letters.
Over the next months, Enstrom’s paper drew fierce criticism. The cancer society said it could not confirm his data’s authenticity. The scientists whose work he had critiqued—including some of the world’s renowned experts in air pollution health science—published a withering point-by-point take-down of Enstrom’s methods and analysis.
But in at least one realm, his paper won acceptance. Eight weeks before the study was published, President Donald Trump took office. And in an administration disdainful of scientific consensus and intent on dismantling restraints on the fossil fuel industry, Enstrom found a receptive audience.
When, last month, EPA Administrator Andrew Wheeler announced the agency’s decision that it would not raise the standards for air pollution because the science of PM 2.5 was too uncertain to justify doing so, he was relying in part on Enstrom’s work. Enstrom’s research was among the studies cited by Wheeler’s hand-picked committee of science advisers to raise doubts about the PM 2.5 consensus.
More broadly, Enstrom’s work has helped provide the underpinning for the Trump administration’s wide-ranging assault on environmental protection policy, from its retreat on climate change to its current effort to restrict the type of science used by the EPA by disqualifying studies that critics say are some of the most important in human health science.
In a way, Enstrom’s journey from outsider to influencer is the story of the Trump administration’s monumental campaign to remake the rules of scientific evidence, and how that effort could shape U.S. environmental protection for years to come.
“These are changes that could have very major impacts on human health and on the environment itself,” said Bernard Goldstein, dean emeritus of the University of Pittsburgh Graduate School of Health. “All of the laws we passed that cleaned up the environment so well—even with the challenges we still have—these have all been science-based. Well, if you knock the science out of the process, you can base the decisions on politics.”
Goldstein, who served as EPA’s assistant administrator for research and development under President Ronald Reagan, recently wrote that the leadership of the scandal-ridden agency in the early Reagan years “did nothing that even came close to the assault on the independence and expertise of the scientific advisory processes carried out by Wheeler and his predecessor, Scott Pruitt.”
‘Everything’s Been Turned on its Head’
Critics often call the Trump administration “anti-science,” but in fact, its retreat on climate change and public health and safety has only been possible with the help of science—the work of contrarians like Enstrom who have devoted themselves to challenging the mainstream consensus.
Trump’s appointees have found justification for their actions in the work and ideas of this stable of scientists, most of them industry aligned, who for years have provided ammunition to foes of federal regulation.
These contrarians have helped make the case in agencies, in Congress and in the courts, for coal, oil and other industries intent on maintaining their way of doing business in the face of increasing attention to the threats posed by climate change, and the growing imperative for cleaner air and cleaner energy.
President Trump has made clear decisions to upend environmental policy, like withdrawing from the Paris climate accord, but he has also made more subtle moves, like the purging of experts from science advisory committees, limiting the science that can be used by the EPA and the relying on contrarian studies like Enstrom’s work on PM 2.5. Credit: NICHOLAS KAMM/AFP/Getty Images
Fossil fuel companies were losing ground in this battle when Trump entered the White House: The Obama administration’s actions on global warming seemed as if they might presage the industry’s last stand. To change course, the Trump administration has sought to change fundamentally how science is evaluated in environmental decision-making.
Trump’s grand moves to upend environmental policy, like withdrawing from the Paris climate accord, are well known. But his legacy may be sealed more deeply in scores of arcane changes deep in the bureaucratic process, like the purging of experts from science advisory committees; the overhaul of cost-benefit analyses; the effort to limit the science that can be used by the EPA; and the reliance on contrarian studies like Enstrom’s work on PM 2.5.
“Everything’s been turned on its head by EPA, so that the consultants are considered the good guys and the academics are all biased,” said Goldstein.
Carol Browner, board chairwoman of the League of Conservation Voters, who was EPA administrator under President Bill Clinton and climate adviser to President Barack Obama, puts it this way: “What they’re doing in this whole line of insidious actions is to dismantle and fundamentally change how the agency does its business.”
A Plan to Discredit Pollution Science
A number of the actions have been aimed at neutralizing the power of one of the most important findings in environmental health science: The science showing that air pollution kills.
In the 1990s, two large, long-term studies, by the American Cancer Society and Harvard researchers, showed that breathing higher levels of PM 2.5—microscopic particles 2.5 microns in diameter or less that spew into the air when something is burned—was associated with premature death.
Virtually everyone is exposed to the PM 2.5 because it is produced by the burning of coal, oil and wood.
[PM 2.5 Explainer infograpic]
Groups allied with the fossil fuel and tobacco industries led an effort to discredit the science, but a reanalysis of the data by the Boston-based Health Effects Institute (HEI), a nonprofit research organization funded by the EPA and the auto industry, affirmed the findings. Since then, dozens of studies, including more than 30 long-term human health studies in North America, have documented the link between PM 2.5 and premature death.
Based on the science, Clinton enacted the first national air quality standards on PM 2.5 in 1997.
Even more important, the large-scale studies of PM 2.5 allowed policy makers to quantify the benefits of cleaner air in a way that had not been possible before. The EPA, after peer-reviewing the science, began using the number of lives saved from reduced PM 2.5 exposure in the cost-benefit analysis it was required to perform to justify new cuts in pollution from cars, trucks and power plants.
In 2011, the EPA estimated that the benefits yielded by U.S. air pollution rules from 1990 to 2020 at $2 trillion, a figure that outweighed the costs of the regulation by 30-to-1, savings primarily attributable to reduced PM 2.5. In addition, the Clean Power Plan, Obama’s signature climate initiative, was to result in PM 2.5 reductions that would account for up to 60 percent of the plan’s projected $34 billion to $54 billion in benefits, far outweighing its $8.4 billion in costs.
That lopsided calculus stood in the way of what Trump said was his plan to “quickly, very quickly” end U.S. climate policy and other restraints on the oil and coal industries. This was well understood by appointees like Wheeler, a former coal industry lobbyist, and William Wehrum, Trump EPA’s assistant administrator for air pollution policy until 2019.
In 2014, Wehrum, a former industry lawyer, led an unsuccessful lawsuit seeking to overturn the Obama EPA’s PM 2.5 standards, by invoking the work of contrarian scientists like Enstrom. But a federal court disagreed. “Petitioners simply have not identified any way in which EPA jumped the rails of reasonableness in examining the science,” wrote then-U.S. District Judge Brett Kavanaugh.
Still, that loss pointed to an avenue for a future attack on PM 2.5 science. And soon after taking office, Trump’s appointees followed that path, overhauling EPA’s science advisory boards and replacing every member of its legally mandatedClean Air Science Advisory Committee or CASAC,which had sided with the mainstream consensus on PM 2.5.
By last year, the reshaped CASAC made clear that it had a far different view of the risks posed by PM 2.5. In a key review, the committee not only disputed EPA’s staff scientists on the need to act on new evidence of PM 2.5 health risks, the CASAC members were divided on the long-standing consensus that PM 2.5 caused premature death.
One of the studies the committee cited in its final report raising doubts about the science on PM 2.5 was Enstrom’s 2017 research report. It had taken a long time for Enstrom to have his work recognized, and he expressed his satisfaction when he called into a public teleconference of a CASAC meeting last December.
“This is a tremendous group, and I don’t believe it’s ever been done better in the 50-year history of EPA,” Enstrom said of the committee.
A Turning Point
In the Trump era, Enstrom may be a scientific influencer, but he has spent much of the last two decades as an outsider vocal about feeling unfairly maligned.
The point in his life when mainstream scientists turned against him, he believes, came 17 years ago, when he published a paper in the British Medical Journal challenging the scientific consensus that second-hand tobacco smoke causes heart disease and cancer.
The American Cancer Society condemned the study, funded by the tobacco industry through its now-defunct Center for Indoor Air Research, saying it misrepresented the cancer society’s data. The data Enstrom based his research on was from an early ACS long-term study group, whose members were recruited in the 1950s. But at that time, smoking was so ubiquitous that it was impossible to conduct a valid study comparing people who’d been exposed to second-hand smoke with people who hadn’t, the ACS argued in rebutting Enstrom’s study.
[ cf The Anti-Scientists series]
A host of other scientists also joined in: The medical journal published 10 letters disputing Enstrom’s method, findings and the conflict of interest they said was created by the industry sponsorship.
But Enstrom insisted that the work was sound. “This was peer-reviewed, and there’s not been one error identified in my paper,” he said in an interview with InsideClimate News.
As for the conflict of interest, Enstrom said he saw no difference between his acceptance of funding from a group controlled by tobacco executives and the practice of accepting research money from state cigarette tax funds and tobacco legal settlement money, as his scientist critics had. Both, he said, “originated with” the tobacco industry.
In Enstrom’s eyes, he was the target of relentless persecution, smears that had all but obscured the early achievements of his career.
“Up until 2003, I basically had a third of a century where I had a perfect record of integrity,” said Enstrom. Since then, he said, “my entire career has been under attack and the attack has never let up.”
‘If I Didn’t Fight I Could Have Disappeared’
Enstrom grew up in a middle class home in southern California, part of a wave of aspiring young Cold War-era scientists inspired by stories of the physicist Albert Einstein and Russia’s launch of Sputnik, the first manmade satellite.
Enstrom’s father, Elmer, was a courtroom clerk who longed to argue cases instead of swear in witnesses. Elmer Enstrom taught himself law and passed the California bar at 41, eventually serving as a U.S. Magistrate Judge in San Diego. But he became best known for his pro bono legal work in retirement, representing residents who were fighting court-ordered busing in the San Diego public schools.
The younger Enstrom said he learned the value of perseverance from his father’s example.
As a student at Harvey Mudd College in Claremont,California, a then-new institution aiming to nurture the technological talent the United States needed for the space race, Enstrom was co-valedictorian of the class of 1965. He went on to obtain a Ph.D. in physics at Stanford, where his dissertation adviser was Melvin Schwartz, who later won the Nobel Prize. Enstrom’s post-doctoral work at what is now known as Lawrence Berkeley National Laboratory was carried out under another luminary, Luis W. Alvarez, also a Nobelist and a veteran of the Manhattan Project.
Physics, Enstrom recalled recently, was “exciting, exhilarating, because you’re on the very forefront of science.” But his studies left him unfulfilled.
“If you’re doing elementary particle physics, you’re basically doing something that’s not really that understandable to most people,” he said.
Through a college friend, Enstrom met Lester Breslow, California’s top health official in the 1960s, who promoted a healthy diet and abstention from smoking as key to a long life. Enstrom became so drawn to the study of human health that he switched fields, working with Breslow, the dean of public health at the University of California, Los Angeles, for many years on a multi-part study on the longevity of Mormons, work supported by the American Cancer Society.
But Enstrom, who obtained a master’s degree in epidemiology, was not on a tenure track at UCLA, and he relied on grant money to maintain his research position.
Over the next years, after public health advocates began blasting his work as suspect, Enstrom struck back. He accused those who questioned his integrity of liberal bias, and repeatedly clashed with his previous sponsors, colleagues, other scientists and government officials.
Among those Enstrom said were biased was a colleague, John Froines, a professor in UCLA’s environmental health sciences department. Froines was a science adviser to California regulators, and had supported strong air pollution rules.
Politically, the two men could not have been further apart. While Enstrom spent the Vietnam War studying in a defense-related field,Froines was one of the “Chicago Seven,” anti-war activists arrested during the riots outside of the Democratic National Convention in 1968.
In 2009, Enstrom helped initiate a lawsuit by a conservative legal group charging that Froines had overstayed his tenure on California’s air pollution science review panel. Amid the controversy, Froines was temporarily removed from the board, but later reinstated. Froines, contacted by email, declined comment for this story.
In 2010, UCLA gave Enstrom notice that he was being terminated. His research, the university said, was “not aligned” with the school’s academic mission and his research output and ability to secure continued funding did not meet the department’s minimum requirements.
Enstrom sued UCLA, charging that his termination, which came after a confidential vote by his department’s faculty, was in retaliation for his activism and his “whistleblowing” regarding Froines.
The case was eventually settled, with UCLA denying Enstrom’s allegations. UCLA “vigorously supports the principles of academic freedom,” the university said in an emailed statement. “Enstrom’s presence as a researcher for decades, despite his minority positions defending diesel emissions and tobacco, demonstrates that fact.” In the settlement, UCLA paid Enstrom $140,000 and gave him continued access to university resources, as well as permission to use the title “retired researcher.”
Enstrom told UCLA’s student newspaper, The Daily Bruin, that he was not entirely satisfied with the settlement, but thought it was the best compromise that could have been reached in the case.
“I am a good scientist, a very honest scientist,” Enstrom said. “If I didn’t fight I could have disappeared.”
A War Over PM 2.5
For Enstrom, a major battleground has always been his home state of California, which historically has led the way in U.S. air pollution regulation. Thousands of pages documenting his advocacy against air pollution regulations are collected at the website of the Scientific Integrity Institute, a nonprofit organization he founded in Los Angeles.
In the 1990s, while he was still at UCLA, he began consulting for the tobacco industry, a role that would lead eventually to his study on second-hand smoking and his rift with the American Cancer Society.
Around the same time, Enstrom was contacted by Frederick Lipfert, a consultant for the industry-funded Electric Power Research Institute, who had seen Enstrom’s work with the early ACS research cohort.
Lipfert asked if Enstrom could delve into the cancer society data to explore a question of crucial importance to the operators of the nation’s power plants, more than half of which were fired by coal at the time: Were the invisible particles that their operations released into the air deadly?
With that, Enstrom joined the war over PM 2.5.
The buildings of downtown Los Angeles are partially obscured by smog at midday on Nov. 5, 2019. Credit: Mario Tama/Getty Images
The buildings of downtown Los Angeles are partially obscured by smog at midday on Nov. 5, 2019. Credit: Mario Tama/Getty Images
He soon became a one-man exemplar of the wide-ranging and high-stakes conflict over the pollutant. He testified before California state regulators, advised a Congressional committee, and filed a lawsuit over the makeup of EPA’s science advisory boards.
In 2005, Enstrom published a study funded by the Electric Power Research Institute that found no association between PM 2.5 and premature death in Californians from 1983 to 2002. That finding again put him at odds with the cancer society because it purported to shed doubt on the ACS’s influential PM 2.5 work. It had the flavor of personal payback, as well: A co-author of the cancer society’s PM 2.5 study was Michael Thun, then ACS’s vice president for research, the same scientist who had condemned Enstrom’s tobacco research two years earlier.
But at the time, Enstrom’s findings did not gain traction with government regulators.
For the EPA, the decisive flaw in Enstrom’s study was his reliance on county-level air pollution data. Rates of premature death in lightly polluted rural areas could skew the rates in heavily polluted cities in the same county, especially in a state like California, with some of the largest counties in the nation.
The original ACS study in 1995 also had inexact exposure estimates, based on urban census tracts that in some cases encompassed several counties. But the ACS researchers had recently published a follow-up study that used smaller zip code areas in Los Angeles and found an even stronger association between PM 2.5 and deadly health effects. The correlation between the pollutant and harmful health effects also was holding up in research that had begun to use satellite remote sensing to pinpoint PM 2.5 pollution levels in the vicinity of individual people’s homes.
So regulators gave little weight to Enstrom’s study in comparison with the original Harvard and ACS studies; the reanalysis of that data; the cancer society’s follow-ups; as well as research on the effects of PM 2.5 carried out in other places, using different groups of subjects and different methodologies. These studies were augmented by work in lab animals that provided evidence of how PM 2.5 can disturb the cardiovascular system. In 2009, the EPA concluded that a broad body of evidence affirmed PM 2.5’s deadly toll.
“The evidence that combustion-related fine particle pollution contributes to both respiratory and cardiovascular diseases is just pretty compelling,” said C. Arden Pope, an economist at Brigham Young University and a co-author of both the original Harvard and ACS studies and follow-up studies.
“There are probably no two studies in environmental health that have been more independently reanalyzed,” Pope said. “They have been scrutinized in really remarkable ways and have held up.”
A Campaign Against ‘Secret Science’
Enstrom, however, was convinced that the findings of the Harvard and ACS studies were biased and politically motivated, carried out by scientists who favored more U.S. government regulation.
“What I’m watching is the descent of epidemiology from what used to be a legitimate public health science into just pure activism,” he said.
The legal battle with UCLA had earned Enstrom stature on the right. The libertarian publication Reason Magazine produced an online video on his mistreatment at the hands of what it called “the Green Regulation Machine.” The conservative American Freedom Alliance honored Enstrom as a “Hero of Conscience,” along with his wife, Marta Villanea, an administrative law judge, who supported him throughout his trials.
“All I did is what a good wife should do,” Villanea said in her acceptance speech.
Enstrom joined the board of trustees of the American Council on Science and Health, an industry and Libertarian-funded group that describes itself as a “a pro-science consumer advocacy organization,” although critics note that its advocacy invariably takes the form of battling government regulation.
Enstrom also became a science advisor to the Heartland Institute, the conservative think tank that has long supported and promoted work that disputes the science on climate change.
Steve Milloy, a former tobacco and coal industry adviser who had been leading attacks on PM 2.5 science from the beginning, said that Enstrom brought to the fight a “personal story of persecution.”
“It’s hard for people to understand what’s going on unless you’ve been really intimately involved in this saga, and Jim has been,” said Milloy. “He’s actually had his career damaged by it, and so he feels it very personally.”
Milloy, working with a fossil fuel-industry funded legal advocacy group, represented Enstrom in a lawsuit against EPA in 2016, alleging bias in the choice of scientists who served on its scientific advisory boards.
Enstrom also began advising U.S. Rep. Lamar Smith (R-Texas), who after becoming chairman of the House Science Committee in 2013 took up the cause of discrediting the science on PM 2.5.
Smith derided the ACS and Harvard studies as “secret science,” adopting a line of attack launched two decades earlier by industry foes of regulation who characterized the studies’ routine protections of patients’ confidential medical data as nefarious.
Smith pelted the EPA with subpoenas seeking the raw data, and continued his efforts even after he was reminded that the studies had already been re-analyzed. However, he said he knew one legitimate researcher whose request for access to the raw data had been turned down by the American Cancer Society: James Enstrom.
The EPA ultimately complied with Smith’s subpoena, but Smith did nothing further with the data. Instead, he sponsored a “secret science” bill seeking to bar the EPA in the future from relying on studies that used confidential data in regulatory decision-making. Critics said it would bar the public health agency from using some of the most important human health science. The legislation, first introduced in 2014, passed three times in the GOP-led House, but was never taken up by the closely divided Senate.
By the time of the last vote in March 2017, however, Trump was in the White House, and the prospects for Smith’s proposal suddenly improved.
The Trump administration was in a position both to enact limits on the EPA’s use of mainstream science and to give more weight to contrarian work of scientists like Enstrom, who had just published his new study challenging the foundations of PM 2.5 science.
Enstrom’s ‘Odd Man Out’ Study
Enstrom’s study almost wasn’t published. “I have never read a paper that so willfully ignored the breadth of scientific evidence and attacked a specific study/group of investigators,” said a reviewer for the New England Journal of Medicine, one of the scientific journals that rejected the manuscript.
But Enstrom finally got the paper in print by reaching out to Edward Calabrese, a toxicologist at the University of Massachusetts, who had submitted a letter in support of Enstrom during his fight with UCLA.
Calabrese was a founder of the International Dose Response Society, an organization that holds that exposure to low doses of toxic agents can be beneficial—a position embraced by many industry groups and rejected by many advocates of strong environmental protection policies.
He was also the editor of the society’s journal, Dose-Response. Aware of the controversy Enstrom’s study would stir, Calabrese agreed to publish, but warned Enstrom he would give the authors Enstrom challenged a chance to respond. “I said you’ll have to take your whacks by the people you’re going to hit, and they’re formidable people,” Calabrese recalled.
In fact, the authors of the original ACS study and the Health Effects Institute (HEI) reanalysis soon published a detailed response, citing a litany of problems they had identified in Enstrom’s work.
The most significant fault, they wrote, was Enstrom’s use of old, county-level PM 2.5 readings instead of employing newer methods now widely used to estimate exposure more precisely. The authors of the critique had just published their latest follow-up study of the ACS cohort, using seven different methods of estimating pollution, including satellite remote sensing, and finding even more significant associations between PM 2.5 exposure and premature death.
Enstrom rejected the critiques of his study—in fact, in an interview last year, he refused to accept that the substance of his work had been called into question at all.
“This is an old tactic that’s used by people who don’t want to address fundamental issues,” Enstrom said. “Instead of addressing what I did, they use the tactic of looking at what I didn’t do, and which they know I can’t do. It’s a miracle that I was able to do what I did do, because of all the efforts to stop me, and the fact that this data is not available outside their little clique.”
Changing the Rules
Enstrom’s study was well-timed to figure into U.S. air pollution policy decision-making. As Trump took office, the EPA was already launching its re-assessment of the state of current science on PM 2.5, as the law requires the agency to do every few years for key pollutants to ensure that Clean Air Act regulations are adequate.
This time around, there was major new science on PM 2.5 to consider, including one of the largest studies ever, a Harvard analysis of the health records of 60 million Medicare recipients. It indicated that lowering PM 2.5 pollution nationwide by just 1 microgram per cubic meter would save 12,000 American lives annually. The research found the risk of premature death for African Americans in the study was three times as great as that for the general population.
But how the EPA weighed the science was affected profoundly by the changes made at the agency by Trump’s team, who borrowed the ideas and rhetoric that industry foes of regulation had honed in the 25-year battle over PM 2.5. Several members of Trump’s transition team, including Milloy, were longtime warriors in the campaign to discredit the science.
Trump’s first EPA Administrator, Scott Pruitt, accelerated the schedule for considering the adequacy of the national PM 2.5 science by two years, so that the review could be concluded by the end of Trump’s first term in office. And in the name of “sound science” and “independence,” Pruitt barred recipients of EPA grants from serving on agency science advisory boards. Since the EPA is one of the largest funders of environmental science, the move had the effect of knocking prominent experts off the committees.
To replace them, Pruitt and his successor, Wheeler, named industry-friendly state regulators and consultants for regulated industries, who faced no similar conflict-of-interest bar. Wheeler eliminated altogether a separate 20-person expert panel on particulate matter. It was precisely the sort of overhaul that Milloy and Enstrom had sought in their 2016 lawsuit against the EPA.
The agency’s rank and file was still staffed with scientists who predated Trump, and they gave Enstrom’s paper little weight when they considered it against the bulk of evidence on PM 2.5. The staff scientists cited more than 2,600 scientific studies in a nearly 2,000-page analysis finalized on Dec. 31, 2019. It affirmed the EPA’s long-standing conclusion that PM 2.5 was a cause of early death. In a separate analysis, EPA staff recommended a stricter national standard for fine particulate matter pollution.
But the Trump administration’s revamped six-member Clean Air Science Advisory Committee saw things differently. Chaired by statistician Louis Anthony Cox, a Denver consultant for the American Petroleum Institute and other industry groups, the CASAC urged that the agency require a much higher burden of proof for assessing pollution’s health harms.
Enstrom’s 2005 study was included in the list of studies that the committee said raised doubt about the link between PM 2.5 and premature death. And one CASAC member, Sabine Lange, a toxicologist for the Texas Commission on Environmental Quality, wrote in a separate attachment that Enstrom’s 2017 study could be an effective challenge to the seminal American Cancer Society research.
“The Enstrom study had a finer resolution, so one would guess that it had less exposure error and therefore possibly a greater effect estimate, or one with narrower confidence intervals,” she wrote.
Last month, when the EPA announced it would not strengthen the pollution standard, Wheeler cited the committee’s report and the doubts about the PM 2.5 science to justify the decision. “We’ve identified a lot of uncertainties,” he said.
Currently, Wheeler is moving forward with an initiative to change how the agency weighs science in the future. The proposal, called “Strengthening Transparency in Regulatory Science,” is essentially the idea that Smith attempted to move through Congress three years ago, barring the EPA from basing decisions on studies that rely on patients’ confidential medical data, as the original ACS and Harvard Six Cities PM 2.5 studies did.
A wide array of health, medical and science organizations oppose Wheeler’s decision not to raise the PM 2.5 standard decision. On April 14, 19 health and medical organizations, led by the American Lung Association, said in a statement that the Trump EPA had employed a “deeply flawed” process and ignored “powerful, overwhelming evidence” that the current PM 2.5 standard is inadequate.
Scientists and health organizations are also fighting the so-called “transparency” rule—critics say even the name has an Orwellian ring to it, because the proposed regulation is not transparent about its purpose.
The public comment period on the proposed rule ended May 18, while the deadline for the public to weigh in on the PM 2.5 standard is June 29. “The way I see it, now, all the pieces are falling into place” in the Trump administration’s plan for weakened regulation, said Gretchen Goldman, research director for the Union of Concerned Scientists’ Center for Science and Democracy.
She said the purge of the science advisory boards, the appointments of industry consultants to the advisory committee and other changes to the process have helped obscure the strong scientific consensus around the risks of PM 2.5, while elevating the importance of the work of scientists like Enstrom.
“These contrarian scientists really have the ear of the EPA in ways they never had before,” Goldman said. “People like Enstrom provide the appearance of an independent scientist weighing in, and It all works together to get where we are—a rule that does not protect health with an adequate margin of safety.”
H. Christopher Frey, a professor of environmental engineering at North Carolina State University, who was a member of the particulate matter expert panel that Wheeler disbanded, said that the changes made under the Trump administration amounted to a rigging of the process. “If I wanted to design a science review that would have a predetermined outcome favorable to the regulated industries, I would get rid of the real experts,” he said.
Members of the disbanded panel, in fact, felt so strongly about the issue that they met on their own and submitted a report to EPA endorsing the agency staff’s finding that the PM 2.5 standard needed to be strengthened.
Frey said Enstrom’s argument—that his study has refuted the 1995 ACS study, and therefore, the EPA’s PM 2.5 standard should be withdrawn—reveals a fundamental misunderstanding of the process.
“The standards are not set based on a single study, and they’re not withdrawn based on a single study,” Frey said. “It’s the overall body of evidence that is important.”
‘A Journey Almost Impossible to Comprehend’
Enstrom said recently that although he thinks there is no need for a PM 2.5 standard at all, he is gratified by Wheeler’s decision to maintain the current standard and to move forward with the “transparency” rule.
“It shows the value of persistence in terms of believing in honest science and trying to penetrate what seems like an impenetrable wall of dishonesty and deception,” he said. His struggle to be recognized, he added, was “a journey that is almost impossible to comprehend. It’s just been incredibly contentious and for what purpose I’m not sure I know, other than just deliberate power, power and ego.”
During a recent phone interview, Enstrom detoured frequently into speculation about “the other side” in the air pollution science debate.
He complained that air pollution studies authored by “activist Canadians” should not be the basis for U.S. environmental regulations. And he noted that a Chinese businessman’s family foundation has helped fund the Harvard T.H. Chan School of Public Health and that Chinese doctoral students were co-authors on the school’s air pollution studies.
“Do you see any of these Harvard people going over to China or central Africa where you do have air pollution problems?” Enstrom asked. “No. Their only goal is to force more regulation on Americans.”
Enstrom expressed particular outrage about a pre-publication study recently released by a Harvard group that found PM 2.5 levels in the United States to be associated with higher death rates from Covid-19. (The researchers have since revised their findings to reflect a lower, but still significant, association). Enstrom has published his own calculations of the pandemic’s effects in the conservative Heritage Foundation’s publication, The Daily Signal. Averaging counts of total mortality in the United States by the Centers for Disease Control and Prevention for the five weeks ending April 4, early in the pandemic, he concluded that deaths were no higher than expected. And based on those numbers, Enstrom wrote, “It’s possible that the lethality of Covid-19 is no greater than that of the seasonal flu.”
Since then, the CDC’s weekly death counts have been as much as 36 percent higher than expected, and the agency estimates that Covid-19 is at least 10 times more deadly than the flu. Enstrom said he remains convinced that the impact in the U.S. is limited geographically, primarily to New York, and that public officials have overreacted. Although the loss of life was significant in the flu pandemic of 1917-1918, Enstrom said, “The country dealt with it. It was terrible, but it was not something to shut down the entire economy.”
Recently, Enstrom has sent personal emails to scientists and public interest groups who have criticized the Trump administration’s review of PM 2.5 science, asking them to discuss his evidence that “there is NO causal relationship between PM 2.5 and total mortality in the U.S.”
So far, he lamented recently, no one has responded.
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https://theintercept.com/**2020/09**/19/wildfires-trump-election-epa-environment/
sharon lerner
as WILDFIRES DESTROY millions of acres in California, Oregon, and Washington, and an unprecedented series of hurricanes cause historic flooding in the South, leaving parts of the region uninhabitable, the Trump administration has been racing to reverse rules designed to prevent exactly these kinds of climate disasters.
Throughout his presidency, Donald Trump has presided over the rollback of more environmental rules and regulations than any other president. The result has been that, even as climate change is on track to soon force millions of Americans from their homes and eventually heat the Earth to temperatures not seen for 34 million years, the leader of the country that bears more responsibility for the climate change than any other has doubled down on the decimation of efforts meant to combat both pollution and the climate crisis.
“The Trump administration is the first in the history of the agency to devote itself so relentlessly to a rollback agenda without even a pretense of meaningfully reducing environmental pollution,” said John Walke, an attorney and senior adviser to the NRDC Action Fund.
starting with his choice of Scott Pruitt, a climate denier whose rise through Oklahoma politics was fueled by the oil and gas industry, to lead the Environmental Protection Agency, Trump has has signaled his disregard for the climate and public health throughout his time in office. While Trump has called climate change a “Chinese hoax” and a “con,” federal agencies under him have taken countless actions — from the removal of information about climate change on the EPA website to the decision to withdraw from the Paris climate agreement;the retooling of models used by the U.S. Geological Survey; and the cancellationof NASA’s carbon monitoring program — that set back the effort to address the climate crisis, and ultimately endanger the environment.
In recent months, the pace of these assaults has quickened. The frenzied efforts of federal agencies during the last months before a presidential election are often referred to as “midnight regulation.” But the work the Trump administration has recently been hurrying to complete would be more accurately described as “midnight deregulation.”
A sign with the words “Trump Digs Coal” can be seen on a factory building in a coal mining area in Hazleton, Penn., on Feb. 2, 2017.
Photo: Maren Hennemuth/Picture Alliance/Getty Images
Protections Obliterated
As soon as he entered office, Trump began the environmental reversals that will likely be the most enduring legacy of his administration. In March 2017, the Environmental Protection Agency signaled that it would not complete the planned ban of a neurotoxic pesticide called chlorpyrifos. The decision came after consulting closely with industry groups and after the Dow Chemical Company, which makes the pesticide, donated $1 million to the Trump inaugural committee. The Trump EPA has since completed dozens of other environmental rollbacks, including gutting the Clean Water Act; weakening restrictions on facilities that emit toxic air pollution; scrapping a rule that required mining companies to set aside money to cover the costs of cleaning up pollution; rewriting the National Environmental Policy Act so that it no longer requires government to consider the cumulative environmental impacts of major federal projects on communities; and ensuring that the coal industry is now able to dump mining waste in streams.
Among the recently finalized actions that will have devastating and long-lasting climate consequences are the rescinding of limits on methane emissions during oil and gas production and processing. Methane is a climate pollutant that traps over 80 times more heat than carbon dioxide in a 20-year period, and the U.S. is already releasing way too much of it. The rollback of methane rules, which was finalized in August — and opposed by many of the major oil companies that will be affected by it — is specifically designed to ignore climate considerations and is expected to increase the amount of the greenhouse gas released each year by 4.5 million metric tons. The additional pollution released will have the same impact as 100 coal-fired power plants each year, according to the Environmental Defense Fund, which is suing the administration over the rule.
The EPA’s weakening of fuel economy standards for cars and light trucks, which was finalized in March while most people were focused on the coronavirus pandemic, will also speed climate change and lead to more catastrophic weather events and wildfires. The change, which reduces fuel efficiency for these vehicles by 27 percent, is expected to result in at least 867 million metric tons of additional carbon dioxide pollution, the equivalent of the annual emissions from 216 coal plants.
The EPA has also reversed its policy of requiring businesses to inspect for leaks from refrigerators and air conditioners. The revision to the regulations, which was finalized in February, affects the release of hydrofluorocarbons, chemicals that can cause hundreds of times more warming than carbon dioxide and often leak from cooling equipment. According to the agency’s own science, the new rulewill result in an increase of greenhouse gas emissions that has the same warming potential as 2.9 metric tons of carbon dioxide each year.
Meanwhile, the Department of Interior finalized its plan to open up Alaska’s Arctic National Wildlife Refuge to oil drilling, a move that environmentalists expect to not only be devastating to the 700 species of plants and animals that live there but also greatly increase carbon emissions. In 2018, the Federal Energy Regulatory Commission limited its consideration of greenhouse gas emissions from natural gas projects. And, through an executive order, Trump weakened regulations that were put in place to mitigate flooding from sea-level rise.
Perhaps most devastating is the loss of the Clean Power Plan. That Obama-era plan was designed to reduce climate pollution by more than 400 million tons by 2030. Instead, Trump replaced it with the far weaker Affordable Clean Energy Rule in 2019.
Deadly Consequences
In many cases, this deregulation will have a measurable human toll. Changes to the Mercury and Air Toxics Standards, which the EPA made in April, undermined limits on mercury and other toxic air pollution coming from coal-fired power plants that were put in place in 2011. Those regulations had prevented between 4,000 and 11,000 premature deaths each year, according to the agency’s own calculations. But under Trump, the EPA has decided that it is no longer necessary to regulate this pollutant, which causes brain damage in developing fetuses and increases heart attacks in adults.
If it stands, the methane rollback, which is being challenged by environmentalists, will also result in illness and death. In addition to hastening climate change,methane turns into ozone, which causes chronic diseases, including respiratory damage, cancer, asthma, and heart disease. Fence-line communities, which are disproportionately made up of people of color, including the more than 1 million African Americans who livewithin a half-mile of an oil and gas facility, will be among the hardest hit by the pollution. And the replacement of the Clean Power Plan is expected to lead to thousands of deaths.
With less than seven weeks until the election, and the wildfires and flooding continuing to spread along with the recognition that they are part of a larger climate apocalypse, the Trump administration is still scrambling to finish the deadly destruction of some of the rules and processes that were put in place to protect human health.
Among other hugely consequential rules still hanging in the balance are the standards for particulate matter and ozone, both of which stem from power plants. Since 1977, the law has required that a Clean Air Scientific Advisory Committee, orCASAC, made up of independent scientists help set the standards. While the committee still exists, the Trump EPA has gutted it, removing many of the independent scientists from it and all of the epidemiologists, and instead stacked it with industry-friendly experts. CASAC is now headed byLouis Anthony “Tony” Cox Jr., an industry consultant who disputes well-established science showing that particulate matter kills by increasing rates of heart and lung disease. He has worked for Exxon Mobil, the American Chemistry Council, and the American Petroleum Institute.
EPA administrator Andrew Wheeler fired a panel of scientists that historically advised CASAC on particulate matter — which includes dust, dirt, soot, and smoke — and dispensed with a panel of ozone experts in what he claimed was an effort to “streamline” the standard-setting process. The result is that the EPA is now trying to finalize the current standards for both particulate matter and ozone, which independent scientists say are not protective of health. Although weather affects ozone levels, the proposed standard doesn’t consider the effects of climate change.
Maintaining the standards for the air pollutants, both of which result from power plant emissions, is a “sop to the oil and gas industry” that will prove deadly, according to Bernie Goldstein, a physician who served as chair of CASAC and a Reagan-appointed EPA assistant administrator who is now a member of the Environmental Protection Network.Already more than 100,000 people in the U.S. die because of air pollution, including particulate matter and ozone. “More people will die because the pollutant standards aren’t high enough,” said Goldstein.
Goldstein is particularly concerned about the increased vulnerability to these air pollutants during the coronavirus pandemic — something the EPA did not factor into its standard-setting process, even though it issued its proposal after the pandemic began. “The idea that something that violently attacks the heart and lungs the way Covid-19 does will interact with air pollutants that also attack the heart and lungs is a no-brainer,” he said.
Trump is working with the Agriculture Secretary Sonny Perdue to expand logging in Alaska’s Tongass National Forest, removing decades-old protections from the 10 million acres that absorb more carbon than any other national forest. And the administration is attempting, through the Department of the Interior, to fast-track the environmental reviews of oil and gas drilling projects, including the Mountain Valley natural gas pipeline and a natural gas terminal in Oregon.
Also among the unfinished business at EPA is the rollback of 2015 protections that protect farm workers and agricultural communities from pesticide exposure. If the Trump administration succeeds with its change, farm workers — who are overwhelmingly Latino and already dozens of times more likely to be poisoned by pesticides than non-farm workers — will face even greater exposure.
And the EPA is taking the last steps to finalize its “Strengthening Transparency in Regulatory Science” rule, which would limit the use of independent science in the agency’s decision-making by employing a strategy first devised by tobacco companies. The proposal was sent to the White House regulatory review office earlier this week, and Wheeler said he hopes to finalize it by the end of the year.
Meanwhile, the administration is still at work on two proposed rules affecting the Endangered Species Act: One will open up designation of critical habitat to challenges by industry, and the other will institute changes in the interpretation of the Migratory Bird Treaty Act, pushed by the oil and gas industry, that “will result in the deaths of many birds,” according to Noah Greenwald, endangered species director at the Center for Biological Diversity.
The Trump administration has already been “devastating for endangered species,” according to Greenwald. “It’s been a terrible waste of four years at a time when we don’t have four years,” he said. “While scientists around the world have been raising alarms about the extinction crisis, they’re rushing to finalize these rules.”
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A melted pro-Trump sign remains at a burned residence during the Bear fire, in the Berry Creek area of unincorporated Butte County, Calif., on Sept. 14, 2020.
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Reversing the Damage
The Center for Biological Diversity is just one of the environmental organizations that have been using the courts to challenge the Trump rollbacks.Overwhelmingly, these suits have succeeded. Only 12 out of 81 lawsuits related to environment, energy, and natural resources deregulation were decided in the Trump administration’s favoras of August 31, according to the Institute of Policy Integrity at New York University School of Law.
If Trump loses the election, a Democratic administration could fairly easily resolve many of the suits that are still pending. “Biden could quickly signal that he won’t defend Trump rollbacks in court,”said William Buzbee, a professor of law at Georgetown University Law Center. “Administrative law is flexible and always gives a future president the ability to reverse the damage of his predecessor.” A Biden administration could also simply reverse the Trump administration’s withdrawal from the Paris climate agreement — a move that won’t be finalized until a day after the election and will take a new president 30 days to reenter.
Depending on the date of the rollback, if Biden is elected and there is also a Democratic majority in both the House and Senate, some of the changes could be reversed through a law called the Congressional Review Act.
But other damage inflicted by the Trump administration on environmental protections will take longer to reverse. Some finalized rules will require years of formal rule-making to change. And there will be no way to revive the Clean Power Plan. “It is pretty close to dead,” Thomas McGarity, professor at the University of Texas at Austin School of Law, said of the centerpiece of the Obama administration’s climate initiative. “If the next administration wants to do something on climate change and they try to do it administratively they’re going to have to start over.”
Some of the harm that Trump has inflicted by disputing established climate science and rolling back desperately needed climate protections is irreparable. “It will be impossible make up for the four years spent ignoring and worsening the climate crisis,” said Buzbee. “The amount of additional CO2 and methane in the atmosphere will linger for decades if not centuries. That loading into the Earth’s atmosphere cannot be recovered and that time cannot be recovered.”
The climate reversals have irrevocably undercut the international effort to address the most pressing issue of our time. “Climate change is in the end a trust game,” said Buzbee. “Nations constraining their own polluters have to trust that others will step up and also do their part. But by stepping back, the U.S. has lost credibility.”
Buzbee, who judges Trump as already “the worst president for the environment in U.S history,” predicts that the environmental impact of a second Trump term would be immeasurably more destructive. “They’d have the time to finish and defend all the first-term rollbacks,” he said. “I’m not sure the EPA and the major environmental statutes could withstand the onslaught.”
While the administration is racing to complete its rollbacks, the Sunrise Movement has sent its members door-to-door to convey the stakes of the election to voters. “Our movement is talking to hundreds of thousands of young people in swing states across the country to communicate the opportunity we have to organize and mobilize under a Biden admin,” said Stephen O’Hanlon, a co-founder of the Sunrise Movement. “Biden wasn’t the first choice of many young people, but he is the clear choice.”
Activist and writer Bill McKibben has put a finer point on the environmental consequences of unseating Trump. “This is going to be the most important election for the next few million years,” McKibben tweeted on Tuesday, sending out a video of the president once again denying climate science even while being briefed on the fires that have killed dozens of people and destroyed millions of acres of land.
EPA Spokesperson James Hewittprovided the following comment in response to an inquiry from The Intercept:
This story is pushing a false narrative that isn’t rooted in fact. Under this EPA, air pollution in this country has fallen 7 percent, we’ve delisted 61 Superfund sites, invested $40 billion in water infrastructure, collected more in criminal and civil penalties than the Obama Administration did in their first term, and are finalizing a final Lead & Copper rule. All regulatory decisions are grounded in science and our legal statutes unlike the last administration.
Environmental experts took issue with all of the claims in the EPA’s response. Asked about the air pollution reductions, Elena Craft, senior director of climate and health at the Environmental Defense Fund, said she was unclear of any measure by which air pollution has fallen by 7 percent and added that “I can’t think of a single action that this administration has done that would result in a reduction of emissions.”
While the EPA has delisted many Superfund sites, it also has the largest backlog of unfunded construction projects at Superfund sites in 15 years. According to Betsy Southerland, who retired after 30 years of working for the EPA, the agency is trying to take credit for work done under previous administrations. “Delisting is just a paperwork exercise documenting that a project was completed in previous years,” she said. “This administration has the worst record of any previous in terms of the number of projects that were ready for construction that they did not fund. Rather than request the funding needed for these sites, they actually asked for cuts in the Superfund budget every year.”
Southerland also said that the agency’s touting of the lead and copper rule was disingenuous: “The proposed lead rule did not lower the concentration that would trigger lead pipe replacement. And they slowed the required rate of replacing lead pipes.”
As for the penalties, EPA’s own data shows that in fiscal 2019, the agency conducted the smallest number of inspections of polluters in at least 18 years,with about half the number of inspections conducted a decade earlier.A 2019 report from The Environmental Integrity Project documents these trends and shows that the number of criminal environmental cases opened and polluters charged fell sharply under Trump.
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update
https://cei.org/content/cei-comments-epas-proposed-review-national-ambient-air-quality-standards-particulate-matter
CEI Comments on EPA's Proposed Review of the National Ambient Air Quality Standards for Particulate Matter
Docket ID No. EPA-HQ-OAR-2015-0072
Marlo Lewis, Jr. • June 29, 2020
Thank you for the opportunity to comment on EPA’s review of the national ambient air quality standards (NAAQS) for particulate matter (PM).[[1]](https://cei.org/content/cei-comments-epas-proposed-review-national-ambient-air-quality-standards-particulate-matter#_ftn1)
EPA proposes to retain the existing PM standards without revision. EPA’s proposal is consistent with the advice of the agency’s Clean Air Scientific Advisory Committee (CASAC) on the primary 24-hour PM2.5 standard, the primary PM10 standard, and the secondary standards. However, not all CASAC members agree with EPA’s proposal to retain the annual primary PM2.5 standard. That proposal, moreover, is strongly opposed by many blue state politicians, progressive punditry, and, for want of a better term, the Regulatory Industrial Complex.[[2]](https://cei.org/content/cei-comments-epas-proposed-review-national-ambient-air-quality-standards-particulate-matter#_ftn2)
Accordingly, this letter addresses only EPA’s proposal to retain the annual primary PM2.5 standard. The Competitive Enterprise Institute (CEI) strongly supports EPA’s proposed decision not to tighten the standard.
Summary of Argument...
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https://desmog.co.uk/2020/05/18/epa-clean-air-committee-cox-harvard-air-pollution-covid
The head of a federal committee tasked with advising the Environmental Protection Agency (EPA) on air quality science recently disparaged a new Harvard study examining the link between air pollution and coronavirus fatalities across the country. The EPA adviser’s critical remarks appear consistent with his track record of disregarding robust science on air pollution and health risks in his consulting work for industry clients such as tobacco and fossil fuel interests.
Dr. Louis Anthony (Tony) Cox Jr., who is chair of EPA’s Clean Air Scientific Advisory Committee, criticized a preliminary study from the HarvardT.H. Chan School of Public Health in comments made to the Washington Examiner. Cox — who previously produced his own study on air pollution and health risks that was funded and edited by the American Petroleum Institute — questioned the validity of the Harvard study, which was released publicly in early April but has yet to undergo formal peer review.
The study, which links the type of fine particulate air pollution produced by cars and power plants to higher COVID-19 mortality rates, has been submitted for review and publication to the New England Journal of Medicine.
“It was rushed out without being properly vetted,” Cox said. He called the study a “bogus piece of analysis” and “technically unsound.” According to Cox, the study is “fundamentally flawed” and “has sensational policy implications, none of which are trustworthy.”
That study found that even small increases in fine particulate matter (PM2.5) exposure is associated with a statistically significant increase in the COVID-19 death rate. It is the first study to examine the link between long-term particulate matter exposure and coronavirus risks in the U.S., and the results are consistent with other peer-reviewed studies finding a correlation between COVID fatalities and air pollution in Europe and, most recently, a preliminary analysis in Louisiana's Cancer Alley. ...[twt]
Harvard study has already garnered attention in Democratic policy circles. A trio of Democratic Representatives cited it in a letter expressing concerns over an EPA policy to relax environmental compliance obligations during the pandemic. Massachusetts Attorney General Maura Healey’s office also cited it in a recent brief on environmental injustice and coronavirus.
Democractic presidential candidate Joe Biden referenced the study in an online fact sheet about his plan for a “clean energy revolution and environmental justice.” And in April the study authors discussed their findings with members of the House Select Committee on the Climate Crisis.
According to H. Christopher Frey, who has studied air pollution for over 30 years and chaired EPA’s Clean Air Scientific Advisory Committee from 2012 to 2015, the Harvard study linking fine particulate matter exposure and worsened coronavirus outcomes “is no doubt the first of more to come.” He said the Harvard researchers behind this study previously published epidemiological research showing the harmful effects of human exposure to fine particles, which is part of a robust science indicating deadly impacts of fine particulate (or particle) air pollution.
“What is lost in the media coverage of the recent Harvard study is the strong causal link between human exposure to fine particles — before, during, and after the pandemic — and premature death,” Frey told DeSmog via email. “There is strong evidence, based on multiple peer-reviewed studies that span a wide range of locations, population demographics, housing characteristics, and so on, that exposure to fine particles at levels below the current air quality standards causes premature death and numerous disease outcomes.”
But for Cox, who now leads the EPA advisory committee that Frey formerly chaired, the Harvard study’s findings are not convincing. “I would have zero confidence in the published results of this study because its interpretation, design, and analysis are fundamentally flawed,” he told the Washington Examiner.
“The statistical models developed by the Harvard team ignore crucial real-world interactions among risk factors, such as that PM2.5 cannot kill people where there are no people to kill,” Cox explained to DeSmog. He said the models also “omit crucial information and demographic variables” that could help explain reported associations. “For example, the model omits a variable, the 'rural-urban continuum,' that could help examine whether the reported association between PM2.5 and COVID-19 mortality risk is explained by the fact that both are higher in more crowded areas,” he said.
Francesca Dominici, Harvard biostatistician and senior author of the COVID study, defended Cox's critiques to the Washington Examiner, saying the team took into account potential confounding variables such as population density and separately analyzed urban and rural counties, with “very similar” results.
A group of 10 agriculture and biofuels organizations called out Cox’s dismissive comments in a May 8 letter to EPA Administrator Andrew Wheeler, a former coal industry lobbyist.
“The Harvard School of Public Health has done work with EPA for years. It is shocking to see the Clean Air Scientific Advisory Committee be so dismissive of such a highly respected independent party,” a spokesman for the group said in a press release. The letter also points to Cox’s close association with the American Petroleum Institute, with the letter describing him as “the proverbial ‘fox in charge of the chicken coop.’”
Longtime Industry Consultant
Tony Cox is a statistician focusing on risk analysis and is president of Denver-based consulting firm Cox Associates. He has a long history of consulting work on behalf of corporate clients including in the tobacco, fossil fuel, and chemical industries. His industry ties include work in service of tobacco giant Phillip Morris and trade associations such as the American Chemistry Council, National Mining Association, and the American Petroleum Institute (API).
Cox “has a history of attacking established research on the health risks of air pollution,” according to E&E News, and his approach has been to emphasize scientific uncertainty and to question standard risk assessment. He has published studies, for example, that question the relationship between levels of fine particulate matter (PM2.5) and mortality rates.
one of those studies, published in 2017 in the journal Critical Reviews in Toxicology, was not only sponsored, but also copy-edited, by API, a major oil and gas industry trade group. According to E&E News, “Cox denied that API influenced his work and said the organization did not suggest any substantive changes.” Cox has done other research backed by API into air pollution and health risks, as well as the carcinogenic risks of benzene, a chemical in gasoline.
When asked whether his past industry funding sources could affect his research approach and stance on health risks of air pollution, Cox said the short answer is no. He defended hisadherence to what he calls “sound science**” that demands a “more exacting” analysis and higher burden of proof compared to the traditional weight-of-evidence approach. “I believe that adhering to principles and methods of sound science, which leave no room for what funding sources believe or want, serves both science and the public interest far better than other approaches, and will continue to apply that approach in reaching conclusions,” Cox told DeSmog.
Studies show that industry-funded research may bias results and tends to produce more favorable results for its backers, in areas from psychology to medicine to sugar and obesity.
Cox acknowledged that his approach has been “met with enormous backlash.” Frey said Cox's treatment of air pollution risk assessment is “disregarding the law.”
“The Clean Air Act requires that EPA set air quality standards that protect public health with an adequate margin of safety. The standards should be set based not just on known, but also anticipated, adverse effects,” Frey explained. “With Dr. Cox leading the way, the current [Clean Air Scientific Advisory Committee] has imposed a burden of proof for evidence of adverse effects far beyond that required by the Clean Air Act.”
The U.S. Chamber of Commerce nominated Cox to chair EPA’s Clean Air Scientific Advisory Committee, and former EPA head Scott Pruitt ushered Cox into that role as part of a move that replaced many of the independent scientists on the agency’s Science Advisory Board with industry-affiliated experts.
Purging Independent Scientists From EPA Advisory Board
As noted in 2017, Cox was one of three nominees to the Clean Air Scientific Advisory Committee that raised red flags. The other two were S. Stanley Young, who is affiliated with climate science–denying Heartland Institute, and Deane Waldman, who directs the Koch, Exxon, and tobacco industry-funded Texas Public Policy Foundation’s Public Health Center. Cox became chair of the committee and both he and Young were put onto EPA’s Science Advisory Board.
Senators Tom Carper (D-DE) and Sheldon Whitehouse (D-RI) raised concerns about these two ultimate appointments in a January 9, 2018 letter to then-EPA Administrator Pruitt. “Specifically, it appears that public commenters warned that Drs. Louis Anthony (Tony) Cox, Jr. (a researcher for the petroleum industry) and S. Stanley Young (a researcher for the pharmaceutical and petroleum industry) may have financial conflicts of interest, may risk an appearance of impartiality, and may lack the scientific expertise necessary to serve on one or more Federal Advisory Committees,” they wrote.
The senators also expressed concern with Pruitt’s decision to bar scientists who received EPA grant funding from serving on EPA advisory committees and to instead appoint individuals with clear ties to regulated industries.
“We are concerned that some of the newly-appointed members of these nonpartisan scientific advisory committees and boards may have financial and ethical conflicts of interests,” they wrote. “In addition, some of these individuals may not possess the appropriate level of scientific expertise or credentials. This underscores our concern that your actions to replace many highly-qualified members of these committees — including the unprecedented action to remove any scientist who was a recipient of EPA grants from eligibility — has led to Federal Advisory Committees that are not balanced in viewpoints, and to the appointment of committee members who are either not qualified or not impartial. This approach undermines the process of providing sound, science-based advice that EPA can use as a basis for environmental regulations that are aimed at protecting human health and the environment.”
A federal court recently ruled that the EPA cannot prohibit its grant recipients from serving on its advisory panels.
EPA’s Science Advisory Board generally does have some industry-affiliated scientists — they made up 40 percent of the board under President Obama — but under Trump they have come to dominate the agency’s science board, comprising 68 percent of the members.
As Reveal News explained in 2017, “Pruitt transformed the board from a panel of the nation’s top environmental experts to one dominated by industry-funded scientists and state government officials who have fought federal regulations.”
'Sidelining Science'
In mid-April, just a week after the Harvard study came out, EPA posted a proposed decision to retain the current regulatory standards for fine particle pollution, a decision that ignored evidence showing that strengthening the standards would save lives.
“Leaving the standards alone is a threat to public health, because thousands of premature deaths each year could be prevented by a more stringent science-based standard that meets the legal requirements of the Clean Air Act,” Frey told DeSmog.
Gina McCarthy, president of the Natural Resources Defense Council and former EPA Administrator under the Obama administration, called EPA’s decision to retain the particle pollution (soot) standards “indefensible.”
“EPA’s own scientists say more than 12,000 lives could be saved every year by strengthening the national limits for soot,” she said in a statement. ...
[twt]
but as Frey explained, Trump’s EPA appears to have little interest in heeding the science.
“EPA political appointees are ignoring, disregarding, and sidelining science in pursuit of their ideological agenda of regulatory rollback,” he said.
“Mr. Wheeler’s proposal to retain the current fine particle standards is a floundering example of red herrings, strawmen, and other logical fallacies,” Frey added. “The danger is that the courts may not be able to sort this out and, even if they do, it will take time during which Americans will continue to suffer under an inadequate standard.”
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https://www.desmogblog.com/2020/05/05/epa-decides-reject-latest-science-endanger-public-health-and-ignore-law-keeping-outdated-fine-particle-air-pollution
no lnx many
EPA Decides to Reject the Latest Science, Endanger Public Health and Ignore the Law by Keeping an Outdated Fine Particle Air Pollution Standard
By Guest • Tuesday, May 5, 2020
By H. Christopher Frey, North Carolina State University
The COVID-19 pandemic and economic shutdown have temporarily produced clearer skies across the U.S. Meanwhile, however, the U.S. Environmental Protection Agency has been busy finding reasons not to pursue long-lasting air quality gains.
On April 30, 2020, the agency published a proposed new rule that retains current National Ambient Air Quality Standards for Particulate Matter without any revisions. It took this action after a five-year review process, in which scientific evidence showed unequivocally that these standards are not adequate to protect public health.
I have studied air pollution and air quality for over 30 years, and have been directly involved for a decade with EPA’s reviews of scientific findings on air pollution. This includes serving on the agency’s Clean Air Scientific Advisory Committee, or CASAC, and on 10 specialized panels focused on individual pollutants.
As I have written previously, the Trump administration has watered down the role of science in what is supposed to be a science-based process of setting national air quality standards. This new proposal — which I expect will be challenged in court when finalized — is the result.
Recent studies indicate that reducing PM2.5 standards below current levels could avert thousands of premature deaths.
Fine Particle Air Pollution Is Deadly
Fine particles, known as PM2.5 because they measure 2.5 microns or less in diameter, can penetrate deeply into the lungs and bloodstream. EPA staff scientists have reaffirmed that daily and annual exposure to PM2.5 causes premature death and a variety of illnesses.
Scientists have known this for decades, but since the national standard was last revised in 2012, new studies have strengthened these findings. They include an epidemiologic study with the largest ever number of subjects and several that include PM2.5 concentrations well below the current standard.
EPA’s scientific staff estimates, based on multiple epidemiologic studies, that currently an average of 13,500 to 51,300 people die prematurely each year from breathing fine particles. Although these numbers are uncertain, the likelihood of thousands of deaths per year would typically spur regulators to tighten existing standards. However, EPA’s current political leadership disagrees.
EPA Administrator Andrew Wheeler, a former coal industry lobbyist, has asserted that uncertainty around recent studies suggesting that current PM2.5 standards don’t adequately protect public health justifies retaining the current standard. AP Photo/J. Scott Applewhite
What the Law Requires
The Clean Air Act directs the EPA to set air quality standards based on an accurate and thorough review of the latest science. This function is performed by CASAC, which I chaired from 2012 to 2015.
CASAC has seven members, which isn’t enough to provide the breadth, depth and diversity of expertise, experience and perspectives needed for these complex reviews. Recognizing this, for four decades the EPA has augmented the committee by convening expert review panels for each pollutant. They include scientists with extensive knowledge of epidemiology, toxicology, medicine, air quality, exposure, risk, statistics and other fields. I served on the 20-member CASAC PM Review Panel that was appointed in 2015 to help CASAC review the PM2.5 standard.
EPA Administrator Andrew Wheeler disbanded that panel in October 2018. Wheeler also continued a makeover of CASAC, started by his predecessor, Scott Pruitt, that removed leading researchers from the committee. Now CASAC has no epidemiologists — a key discipline for assessing PM2.5 health effects.
What Our Expert Panel Recommended
Realizing that EPA would not otherwise get the science advice it needs, the disbanded PM review panel reconvened itself in October 2019. We found that current fine particle standards are not protective of public health.
The studies published since 2012 demonstrating that exposure to fine particles causes premature death at concentrations below current standards were key to our decision. We advised the EPA that the annual standard should be reduced from its current level of 12 micrograms per cubic meter to a range of between 10 and 8 micrograms per cubic meter.
For the 24-hour standard, which regulates short-term air quality spikes, we recommended reducing the limit from the current level of 35 micrograms per cubic meter to between 30 and 25 micrograms per cubic meter. These scientific findings were based on multiple epidemiologic studies, augmented with evidence from controlled experiments with animals and humans.
Failing to Protect the Public
Administrator Wheeler claims that recent studies since the last time the standards were revised “do not provide a basis for revising the standards.” Wheeler acknowledges that studies based on long-term exposures below the current standards show “associations” between air quality and premature death. However, he argues that this research does not show a causal relationship. Yet, based on the overall body of evidence, he acknowledges that “a causal relationship exists between long-term PM2.5 exposure and total mortality.” In my view, his rationale is illogical and is inconsistent with the evidence.
The Clean Air Act requires regulators to set standards that will provide an “adequate margin of safety.” This means that they should be stringent enough to protect sensitive populations, such as older adults, people with preexisting cardiovascular or respiratory diseases and children with asthma.
The EPA proposal acknowledges that these groups exist, but does not specify how it will protect them from PM2.5 in the air. Wheeler is also silent regarding the role of racial and ethnic differences in exposure and risk, even though a federal court called EPA to task in 2009 for not specifically addressing at-risk groups.
Preliminary evidence suggests that exposure to particles worsens the effects of COVID-19. While this finding needs peer review and additional study, existing evidence of risk for sensitive populations shows the need for a more protective standard.
EPA currently faces lawsuits for multiple instances in which it has either sought to weaken, or failed to strengthen, air pollution regulations. They include rolling back motor vehicle greenhouse gas emission standards, failing to implement stringent rules limiting interstate air pollution and repealing the Obama administration’s Clean Power Plan to limit carbon emissions from power plants. Unless EPA modifies its position on particle air quality to address the law and the science, I expect that this regulation too will end up in court.
H. Christopher Frey is Glenn E. Futrell Distinguished University Professor of Environmental Engineering at North Carolina State University.
This article is republished from The Conversation under a Creative Commons license. Read the original article.
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17. Louis Anthony Cox is a well-published statistician/risk expert, but with a long history of corporate “product defense.” Unlike some of the others, he displays technical competence, but employed in the service of doubt.
David Michaels in *Triumph of Doubt*(2020) (review) discusses Cox with whom he often had direct interactions, p.133-134 (silica), 224-225, and 270. For example, on p. 224-225 he writes:
“The Trump Administration's choice to chair the Clean air Scientific Advisory committee was Louis Anttony (Tony) Cox, a long-time industry consultant who clings to uncommon opinions, like lowering ozone and the belief that PM2.5 exposures would not improve public health. Cox was well-known at the Labor Department for his testiomony on behalf of the National Mining Association, predictably claiming that the government's risk assesment on respirable coal dust was flawed.”
Jie Jenny Zou and Chris Young wrote, “Wave of climate lawsuits threatens the future of Big Oil” in 2017:
“But the all-expenses-paid event hosted by George Mason University’s Law & Economics Center in Arlington, Virginia, served another purpose: It was the first of several seminars designed to promote 'skepticism' of scientific evidence among likely candidates for the 140-plus federal judgeships President Trump will fill over the next four years.
The lone science instructor was Louis Anthony Cox Jr., a risk analyst with deep industry ties whose recent appointment as chair of the U.S. Environmental Protection Agency’s Clean Air Scientific Advisory Committee drew condemnation in public-health circles. Since 1988, Cox has consulted for the American Petroleum Institute, a lobby group that spent millions to dispute the cancer-causing properties of benzene, an ingredient in gasoline, and is now working to discredit the science on smog-causing ozone. He’s also testified on behalf of the chemical industry and done research for tobacco giant Philip Morris.
For a $4,000 honorarium, Cox delivered two closed-door lectures at George Mason: “a primer on the scientific method,” followed by a session aimed at “understanding what science can and cannot do.” Included in his presentation were slides urging judges to be wary of EPA science on fine particles — a pollutant he has been researching for API. “
See also “EPA swaps top science advisers with industry allies” (2017), for more information on Cox.
Harvard School of Public Health published: “EPA may limit review of evidence on air pollution and health risks”:
“The paper, published on March 21, 2019, noted that the EPA’s Clean Air Scientific Advisory Committee (CASAC)has recently recommended that the EPA limit the types of epidemiological studies used to assess the health risks of air pollution … CASAC is currently headed by Louis Anthony Cox Jr., a Denver-based risk assessment consultant who has worked for the oil, chemical, and healthcare industries. Cox said in December that his panel wasn’t convinced by the EPA’s 1,800-page assessment of small particle air pollution, which cited more than 2,800 research papers on the subject and was authored by more than 50 of the world’s leading experts on air pollution — and reviewed by dozens more, according to a March 21, 2019 Los Angeles Times article. That assessment concluded that even low levels of exposure to particulate matter can lead to illness and death. Cox accused the authors of that assessment of being subjective in their conclusions and using bad science, according to the Times.” [emphasis added]
An Industry Documents Library search finds 57 documents, including interactions with Shell Oil and expert-witnessing for Philip Morris.
- Mark Regnerus's work and criticisms of his methods are not ones I've studied, although it is not clear what expertise he really brings to improving science. Dorothy Bishop wrote:
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whoohoo
https://www.ecowatch.com/scientists-epa-panel-air-pollution-2640669910.html
A group of 20 scientists charged with reviewing the nation's air quality standards plans to convene and to issue a report on the country's air pollution regulations, even though the Environmental Protection Agency (EPA) disbanded their panel.
In a move that is consistent with the administration's skepticism towards science and expertise, the EPA administrator, Andrew Wheeler, disbanded the Particulate Matter Review Panel, part of the Clean Air Scientific Advisory Committee, in October 2018, as The Hill reported.
When he disbanded the group, Wheeler claimed that the group — made up of some of the nation's top scientists assigned to review the impact of soot and other microscopic air pollutants on human health — took too long to perform its task, according to Bloomberg Environment.
Now, in a seemingly unprecedented maneuver, the scientists will meet in Arlington, Virginia Oct. 10-11, one year after they were disbanded, to issue a report on whether or not the current federal particulate matter standard is sufficient, according to Reuters.
The group, which now calls itself the Independent Particulate Matter Review Panel wants to make sure there is a documented record of scientific consensus that reaches the EPA decision-makers.
"I'm proud to say that being disbanded is not an obstacle for our panel," said Chris Frey of North Carolina State University who chairs the panel to the NC State press office. "If anything, being told that we were unilaterally terminated has redoubled my determination to discharge the public service to which I originally agreed."
Even though Wheeler is a former coal-industry lobbyist, Frey is hopeful that he will consider the independent panel's recommendations.
"As a group, this panel has more experts, more breadth, depth and diversity of expertise than the chartered Clean Air Scientific Advisory Committee," Frey said, as E&E News reported.
Like Frey, most of the members of the independent panel come from universities and all are unpaid for serving on the panel.
"This is the first time in the history of EPA where the credibility of the agency's science review process has been so compromised that an independent panel of experts has recognized the need for and will be conducting a comprehensive review," said Chris Zarba, who will help lead the effort and once served as director of the EPA's Science Advisory Board, another board that provides scientific advice to the agency, The Hill reported.
The Union of Concerned Scientists will host the panel since it was troubled that the EPA is operating without the scientific expertise it needs to ensure a particulate standard based on the best available science.
"Reconvening a disbanded pollutant review panel breaks new ground," said Gretchen Goldman, a research director at the Union for Concerned Scientists, to The Hill. "Nothing like this has ever been done before. Indeed, nothing like this has ever been necessary. But we live in unprecedented times."
[docs]
The EPA, however, disagrees with the idea that it is without scientific expertise or that it writes regulations without considering science.
"EPA is committed to scientific integrity and transparency," EPA spokeswoman Corry Schiermeyer said in an emailed statement when asked about the start-up of the independent panel, as Reuters reported. "EPA always welcomes comments from the public and it is not uncommon for special interest groups and coalitions to organize, meet and develop comments for submission to the record. EPA will continue to take into consideration these comments that meet our scientific standards."
Frey, for his part hopes the EPA will consider the independent panel's work.
"We will place our written report into the docket for this review cycle, which obligates EPA to look at our findings and advice," he said to NC State. "We would like for our findings and advice to be considered by EPA staff as they revise the draft Integrated Science Assessment and draft Policy Assessment into final documents, and by the administrator in making a decision regarding whether to retain or revise the existing standards."
RELATED ARTICLES AROUND THE WEB
- E.P.A. to Disband a Key Scientific Review Panel on Air Pollution ... ›
- Scientists booted from EPA panel form their own group | TheHill ›
- EPA Science Panel Casts Doubt On Air Pollution Dangers : NPR ›
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https://insideclimatenews.org/news/15032019/air-pollution-trump-epa-science-advisers-health-risk-fossil-fuel-chemical-tobacco-industry
For two years, the Trump administration has been planting seeds of change in the Environmental Protection Agency—installing allies of regulated industries onto its elite panels of science advisers. That effort now has borne fruit in dramatic fashion.
The EPA's new science advisers, sweeping aside decades of research on the grave health risks of fine particle air pollution, have launched a drive to force the agency to give greater weight to a handful of contrarian studies that dispute the harmful effects of soot.
Particulate matter is the pollution caused by combustion, a mixture of solid and liquid droplets that forms in the burning of fossil fuels or wood. The health risks of particulate matter have been an underpinning of the EPA's cost-benefit analysis of a number of air pollution regulations, including those meant to address climate change, like the Obama administration's Clean Air Act.
The science is well-established—the World Health Organizationestimates that there are 4.2 million premature deaths a year due to fine particle pollution, making it one of the leading environmental health risks globally. But allies of the fossil fuel industry have vigorously disputed the validity of fine particle pollution studies since they first emerged in the 1990s.
Significantly, the health damages from particle and other pollution coming from the combustion of fossil fuels have also been used by the EPA to justify controls on carbon dioxide, the main greenhouse gas. Controlling climate change has important co-benefits, the agency has reasoned. The Trump administration and its industry allies oppose this logic.
More Weight for 'Discordant' Claims?
The latest scientific dispute centers around the EPA's draft assessment of the science on particulate matter (PM), a comprehensive review that the agency is required by law to conduct every few years to update the state of the science on several key pollutants. EPA released its draft review last fall.
It affirmed the agency's previous findings that the science points consistently and overwhelmingly to a "causal relationship" between PM pollution and premature deaths. The assessment concludes the greatest risk is due to particles less than 2.5 microns in width, and that PM2.5 is associated with a range of cardiovascular and respiratory effects.
For the first time, the EPA concluded that the evidence was strong enough to show a "likely" causal relationship between long-term PM2.5 exposure and cancer, as well as nervous system effects. The EPA concluded, as it has in the past, that there is evidence of health risks even at extremely low levels of PM exposure.
Now, in a harshly worded draft review, the Trump administration's science advisors are blasting those findings as based on "unverifiable opinions" and lacking in scientific support.
The advisers are members of a seven-member panel called the Clean Air Science Advisory Committee. Although it is clear the members are not unified in their critique—individual members attached separate letters—the document calls for "substantial revisions" to EPA's assessment of PM, including giving more weight to what it called the "discordant" evidence among the 2,800 published studies cited in the EPA's 1,900-page science assessment.
"Substantial discordant and conflicting evidence remains ignored or unresolved," the Trump administration-appointed CASAC wrote, "leading to repeated assertions that the literature shows consistent and coherent positive associations when in fact it shows a mixture of positive and negative results."
When asked for comment on the critique, a spokesperson for the EPA said by email: "We appreciate the work of the CASAC and we will review the report."
Who Are New Committee Members Listening To?
The CASAC, now chaired by Louis Anthony "Tony" Cox, Jr., a Denver-based consultant, offers a few examples of the studies it wants to see the EPA give more weight to. Among them are studies that are authored, in fact, by Cox himself—whose clients have included theAmerican Petroleum Institute, the tobacco industry and the chemical industry.
Other studies mentioned by the CASAC are by S. Stanley Young, a former pharmaceutical industry statistician based in Raleigh, N.C., who is an adviser to the HeartlandInstitute, a conservative think tank that has led a years-long campaign to discredit climate science. Young is now also an EPA science adviser.
The CASAC also pointed to the work of James Enstrom, a Los Angeles epidemiologist who for years has questioned the health risks of particulate matter. A former tobacco industry researcher, Enstrom was a plaintiff in a 2016 lawsuit brought by the fossil fuel industry-funded Energy and Environment Legal Institute that challenged the makeup of the previous CASAC.
Many of the environmental scientists who were appointed to EPA's advisory panels had received funding from EPA at some point in their careers, which the Enstrom suit said was a conflict of interest. In 2017, Trump's first EPA administrator, Scott Pruitt, made the same argument when he replaced scientific experts from the existing science advisory boards with new appointees—including a number of industry allies and consultants, like Cox and Young.
'CASAC Itself Lacks Necessary Expertise'
One scientist who was among those removed from the CASAC last year, H. Christopher Frey, an environmental engineer at the University of North Carolina, said the harsh science critique from the Trump administration-appointed committee comes amid "numerous major changes to the [air quality standards] review process that collectively undermine its quality, integrity and credibility."
"Most astonishing is the arrogant and insulting tone of this letter toward EPA scientific staff," Frey, a former chairman of the CASAC, said in an email to InsideClimate News. Frey dismissed as "patently absurd" the document's assertion that the EPA's approach on particulate matter was unscientific. "The statement is ironic given that the CASAC itself lacks necessary expertise," he said.
In fact, the CASAC recommended that it be given access to additional technical expertise in order to complete its review of EPA science on particulate matter. Two members of the CASAC called for the EPA to reconstitute a 20-member special review panel on particulate matter that EPA Administrator Andrew Wheeler disbanded in October, just prior to the start of the peer review. That panel included experts in the science of particulate matter and health effects—expertise that is now missing on the CASAC. Although much of the science on the health risks of particulate matter is from large human studies, there are no epidemiologists on the current CASAC.
In one striking passage of its draft peer review, the CASAC said it is unable to reach consensus on the link between particulate matter and mortality—the "causality determination of mortality from PM2.5 exposure." Some members "are of the opinion that, although uncertainties remain, the evidence supporting the causal relationship between PM2.5 exposure and mortality is robust, diverse, and convincing," the document said. But other committee members think EPA should provide a better justification for its determination that there is a causal relationship between PM exposure and premature death.
Daniel Greenbaum, president of the Boston-based Health Effects Institute (HEI), a research institute that has conducted major studies on air pollution, said that he was surprised at that passage.
"Given that there is more than a decade worth of work now looking at the epidemiology, the toxicology, and a number of other things to see whether or not PM can contribute to mortality, there's pretty robust literature that says that," said Greenbaum. HEI has offered its own critiques of some aspects of EPA's assessment—for example, it does not agree with EPA's conclusion on nervous system effects. But HEI does not dispute EPA's fundamental conclusion on mortality risk. "By most standards, people would say that the evidence has strengthened over the last 20 years," Greenbaum said.
But Greenbaum noted that the committee's review document is only a draft. The CASAC has set a conference call for March 28 to discuss the document and the next steps before submitting its final recommendations to Wheeler.
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