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EPA Science Advisory Board Input

June 6, 2019

As part of EPA’s June 5-6 meeting of the Chartered Science Advisory Board (SAB), we submitted both oral and written input on several issues, including the Clean Water Rule, power-sector emissions of air toxics, vehicle emissions standards, and the Science Transparency Rule.

EPA and the Army Corps of Engineers are proposing to replace the 2015 Clean Water Rule with a new rule that would harm many waterways by removing critical federal protections. In our letter, we urge the SAB to consider the full benefits of wetlands and review the errors in the agencies’ economic analysis in the new rule. We submitted to the SAB our previously filed comments as well as an expert report by Peter Howard and Jeffrey Shrader.

To aid in SAB’s review of the Mercury and Air Toxics Standards Reconsideration, we provided our previously filed comments as well as a relevant Minnesota Law Review article by Richard Revesz and Kimberly Castle. These documents explain how EPA, in proposing to withdraw a prior finding that it is “appropriate and necessary” to regulate power-sector emissions of mercury and other “air toxics” under the Clean Air Act, has failed to provide a reasoned explanation for its change of course.

We also addressed the Trump administration’s proposal to dramatically weaken federal emissions standards for cars and light trucks. Federal emissions standards have been enormously successful at reducing greenhouse gas pollution and lowering fuel costs for consumers. Our letter to the SAB on this topic attaches our previously filed comments, which describe the flaws in the National Highway Traffic Safety Administration’s models that support the proposal.

Policy Integrity legal fellow Madison Condon attended the meeting to present oral comments on the Science Transparency Rule, which would bar regulators from relying on scientific studies that fail to meet proposed data availability standards. In practice, this rule will impede informed rule-makings and make it harder to design beneficial regulatory action.

Filed under Climate Change and Energy Policy, Environmental Health, Public Comments, Jobs and Regulation