Many critics of government regulation argue that it reduces economic growth by making it more expensive for businesses to operate. But there is a strong counterargument that a clean environment is consistent with long-term economic prosperity. Here’s a compelling example: Since 1980, U.S. gross domestic product has grown by 165 percent, while emissions of six common air pollutants decreased by 67 percent – thanks largely to government regulation.
Science is a critical foundation of effective regulation. I have studied air pollution and air quality for over 30 years, and have been directly involved for a decade with the U.S. Environmental Protection Agency’s reviews of scientific findings on air pollution.
Under the Clean Air Act, EPA is required to conduct regular reviews of national air quality standards for major pollutants, and to revise those standards if the latest science indicates that they are not adequately protecting public health. It is now reviewing standards for ozone and particulate matter – the two most significant air pollution regulations on the books.
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Emissions from cars, trucks and power plants react in sunlight to form excessive amounts of ozone in the lower atmosphere. Fine particles are produced from many sources, including fossil fuel combustion.
These pollutants harm the public generally and at-risk groups in particular, including children, the elderly, outdoor workers and people with asthma. Health impacts include respiratory, cardiovascular and other diseases and premature death. Today more than 124 million Americans live in areas with breathable ozone above health protective levels, and over 23 million live in areas with high levels of fine particles.
The Clean Air Act requires EPA to carry out a periodic “thorough review” of the “latest scientific knowledge” underpinning regulations for major air pollutants. In this process, an “independent scientific review committee” must assess existing standards and recommend revised or new ones as appropriate. This is job of the Clean Air Scientific Advisory Committtee (CASAC).
The committee has seven members, appointed by the EPA administrator. But air pollution standards draw on many scientific disciplines, including air quality, epidemiology, toxicology, medicine, biostatistics, ecology, climate and risk assessment. For four decades EPA has organized panels of additional experts to help CASAC review the latest research.
This process properly established the science for health-protective air quality standards – until now.
Former EPA Administrator Scott Pruitt changed the rules for appointments to CASAC. He said appointments should be based on geographic diversity and affiliation with state, local and tribal governments, and called for more member turnover.
Pruitt also barred scholars who had received EPA research grants from serving on the committee. But often these are precisely the highly respected scientific leaders that CASAC needs. The federal government has long recognized that holding a research grant does not infringe on a scientist’s “ability to offer independent scientific advice.” In contrast, Pruitt allowed people who received funding from regulated industries to serve on CASAC.
In October, acting Administrator Andrew Wheeler followed through on Pruitt’s directive by replacing five CASAC members. The committee now includes one researcher, staff from one federal and four state agencies and an industry consultant. It lacks scientific horsepower compared to prior years. Wheeler also did away with panels of additional experts.
Pruitt also called for shortening the time for CASAC’s work and commingling reviews of science and policy that were previously kept separate.
Until now, these reviews took an average of three years. They focused on three major EPA staff reports that summarized scientific findings on health effects, established the scientific basis for quantifying health risk, and identified potential options for retaining, revising or rescinding the current standard or setting a new one. These steps were carefully designed to clearly establish the science before making judgments about policy.
EPA recently announced the schedule for its next review of the ozone standard. The agency wants CASAC’s input in one year, which will require the committee to assess policy options before finalizing the science and force it to hold fewer public meetings. I expect it to be a rushed process that inappropriately intermixes science and policy and elbows out the public.
Studies show that air pollution still kills thousands of Americans every year. Given this toll, I do not believe CASAC or the public should accept changes that undermine the quality, credibility and integrity of the scientific basis for air quality standards.