Authors H. Christopher ("Chris") Frey
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1/9. There are many problems with this rule. Pruitt/Wheeler threw out EPA's own established procedures to short-circuit the science review: changes to the review process since 2017 undermined its quality, credibility, and integrity.
2/9. Pruitt/Wheeler kicked all 7 members off the Clean Air Scientific Advisory Committee, and replaced them under a policy found to be arbitrary and capricious by the U.S. district court of SDNY. The repopulated CASAC has the appearance of lack of impartiality.
3/9. Wheeler refused to form a CASAC Ozone Review Panel 3 months after EPA issued a call for nominations for such a panel, thereby depriving CASAC of the breadth, depth, and diversity of expertise, experience and perspectives needed for ozone NAAQS Review.
4/9. The Ozone review process was truncated and accelerated, leading to inadequate scientific review, and inappropriate commingling of science and policy reviews. Fewer opportunities for public comment created a less transparent NAAQS scientific review process
5/9. As professional malpractice, the stripped down and reconstituted CASAC offered advice outside of its expertise, particularly with regard to epidemiology (there were zero epidemiologists on CASAC). The CASAC chair imposed a burden of proof contrary to that of the CAA.
#EPA's status quo rule to leave its current ground-level ozone standard in place cleared #OIRA review yesterday after just two weeks. An agency announcement is coming this afternoon. #AirPollution pic.twitter.com/lIGAQBBgkL
— Sean Reilly (@SeanatGreenwire) December 23, 2020
2/9. Pruitt/Wheeler kicked all 7 members off the Clean Air Scientific Advisory Committee, and replaced them under a policy found to be arbitrary and capricious by the U.S. district court of SDNY. The repopulated CASAC has the appearance of lack of impartiality.
3/9. Wheeler refused to form a CASAC Ozone Review Panel 3 months after EPA issued a call for nominations for such a panel, thereby depriving CASAC of the breadth, depth, and diversity of expertise, experience and perspectives needed for ozone NAAQS Review.
4/9. The Ozone review process was truncated and accelerated, leading to inadequate scientific review, and inappropriate commingling of science and policy reviews. Fewer opportunities for public comment created a less transparent NAAQS scientific review process
5/9. As professional malpractice, the stripped down and reconstituted CASAC offered advice outside of its expertise, particularly with regard to epidemiology (there were zero epidemiologists on CASAC). The CASAC chair imposed a burden of proof contrary to that of the CAA.