ICYMI : TCEQ Criticism of EPA Air Pollution Science

Washington DC – In case you missed it, the Texas Commission on Environmental Quality (TCEQ) recently commented on the Environmental Protection Agency’s proposal to lower the National Ambient Air Quality Standards (NAAQS) for fine particulate matter (PM2.5). Science, Space, and Technology Committee Chairman Ralph Hall (R-TX) issued the following statement today on the TCEQ comments:

“These comments echo concerns raised by Members of the Committee on Science, Space, and Technology over EPA’s reliance on cherry-picked data, problematic regulatory cost-benefit analysis, and a lack of independence among the Agency’s supposedly objective science advisors.  I strongly encourage the Agency to heed Texas’ recommendations and criticisms.”

TCEQ’s comments included:

• “…it appears that the EPA did not consider all of the available scientific evidence or adequately weigh the significant limitations and uncertainties in using observational epidemiological studies to set the proposed NAAQS. Furthermore, the conclusion to lower the NAAQS is based on two faulty assumptions: (1) that exposure to PM2.5 at relevant environmental concentrations causes premature mortality; and (2) that the relationship between PM2.5 exposure and the purported effect on mortality is linear with no threshold. Neither of these assumptions is borne out by the available epidemiologic or toxicological data.”

• “In presenting the studies that support lowering the standard, the data has been ‘cherry picked’ to show only positive associations (regardless of their statistical significance) and to exclude evidence that does not support the policy decision to lower the NAAQS.”

• “There appears to be double counting of benefits across multiple rules…. Including PM2.5 co-benefits in other [Regulatory Impact Analyses] not only results in double-counting of benefits but also prevents meaningful reductions in regulatory burdens while still meeting air quality objectives.”

• A review of the membership of the Clean Air Science Advisory Committee (CASAC) “…indicates that most members are affiliated with academic institutions and receive EPA funding. This information raises significant concerns regarding conflict of interest within the CASAC as well as undermining the goal of independent peer review of EPA rulemakings and associated analyses.”

• “Members of the Science Advisory Board and CASAC should not include the authors of studies utilized in that specific assessment, nor should they be current recipients of EPA funding, as this represents a significant conflict of interest…. If such individuals are to be consulted, equal weight should be given to scientists representing a wide variety of backgrounds and points of view, e.g. local or state governments.”

For Additional Information: Committee on Science, Space, and Technology hearings on EPA’s Clean Air Act science include:
EPA’s Impact on Jobs and Energy Affordability: Understanding the Real Costs and Benefits of Environmental Regulations (June 6, 2012)
Fostering Quality Science at EPA: Perspectives on Common Sense Reform – Day II (February 3, 2012)
Fostering Quality Science at EPA: Perspectives on Common Sense Reform (November 30, 2011)
Quality Science for Quality Air (October 4, 2011)
Out of Thin Air: EPA's Cross-State Air Pollution Rule (September 15, 2011)