Note: It is best to personalize or modify the wording (without changing its meaning). You do not need to be a scientist to submit your comments, but say so, if you are.
(As someone trained in scientific analysis, I understand that) transparency is not a key test of the quality and legitimacy of a scientific study. By proposing that EPA use only data that passes a “transparency” test, the Agency uses political, rather than scientific logic for limiting the use of the best science. The proposal would bar many kinds of important scientific evidence from consideration, resulting in weaker science and greater real harm to Americans’ health.
EPA’s decisions should be based on all of the best available science. EPA does this by using studies that have been peer reviewed, the key underpinning of the modern scientific method and the gold standard in determining scientific legitimacy. The “independent review” cited as EPA’s goal in the proposal is unnecessary and duplicative of the scientific peer review process. It would be an overstepping of the federal government’s role to establish a different and arbitrary set of standards for determining accepted science than is used by the scientific community.
In fact, EPA is already extremely transparent, giving scientific experts access to studies and conducting hours of discussion about the technical aspects of those studies. The public has full access to those discussions. Even though some underlying data cannot and should not be made public, EPA already collects and reviews volumes of such data while appropriately protecting them from public disclosure.
Implementing EPA’s proposal would be unrealistically expensive. The Congressional Budget Office estimated that a similar measure introduced in Congress last year, HR 1430, would cost $250M a year to implement. The process for removing confidential personal and business information before making it public would be virtually impossible, especially in light of smaller Agency budgets.
If EPA does not use the best available science, it will not be carrying out the mission given to it by congress to protect Americans and the environment.
Script for Members of Congress:
I have sent the attached comments to the EPA regarding its proposal to restrict the science the Agency can use to develop regulatory safeguards, Docket # EPA-HQ-OA-2018-0259. I ask for your support to publicly denounce plans to weaken science at EPA and to use your authority to hold EPA accountable to its mission. Thank you.
(1) Send comments to EPA to oppose restrictions on the Agency’s use of science.
Submit your comments at Regulations.gov using this link by August 16. EPA is required to publish responses to public comments. By raising the issues in your comments you are requiring the Agency to address these issues and potentially providing support for a future suit against EPA.
(2) Share your comments with your members of congress
- Senator Dianne Feinstein: (415) 393-0707, (310) 914-7300, (202) 224-3841, or email.
- Senator Kamala Harris: (415) 355-9041, (213) 894-5000, (202) 224-3553, or email.
Find your Representative:
- Rep. Mark DeSaulnier - 11th district: (510) 620-1000, (202) 225-2095, or email.
- Rep. Nancy Pelosi - 12th district: (415) 556-4862, (202) 225-4965, or email.
- Rep. Barbara Lee - 13th district: (510) 763-0370, (202) 225-2661, or email.
- Rep. Jackie Speier - 14th district: (650) 342-0300, (202) 225-3531, or email.
- Rep. Eric Swalwell - 15th district: 510-370-3322, 202-225-5065, or email.
Science is the foundation of everything EPA does. This proposal is the latest of several efforts by the Trump administration and congressional republicans to tie EPA’s hands and weaken EPA’s ability to set limits on pollution. Under the cynical guise of transparency, the proposal would prevent EPA from using important and legitimate science in its decision-making if the associated underlying data is not publicly available for independent evaluation. The proposal is purposefully designed to result in weaker science and environmental protection.
EPA uses scientific studies to set limits on air pollution, water pollution, pesticide use and other toxic and hazardous substances. Many studies rely on private personal information used in medical research or legally-protected confidential business information. The fact that the underlying data cannot be made public does not impact the validity of the results of these peer-reviewed studies. (Peer review is the process of having multiple independent scientific experts in the same field review and critique a scientific study.) EPA is, in fact, already extremely transparent, as cited in the script above.
The proposal is straight from the tobacco and climate denial playbook. According to Scientific American magazine, “In a 1996 memo out of R. J. Reynolds Tobacco Company, industry consultant (and later part of the Trump administration’s landing team at EPA), Chris Horner, laid out the “secret science” strategy as a way to fend off tobacco regulations as the science increasingly showed the harms of secondhand smoke. The goal, he wrote, was ‘to construct explicit procedural hurdles the agency must follow in issuing scientific reports.’ This has never been about transparency in science-based decision making.” Instead, it is a tactic for both weakening and delaying EPA’s decisions, while giving more influence to industry.
This proposal follows a new internal EPA policy on science transparency. If implemented, the proposal would carry more legal weight and be more difficult to undo.