When you think about who is going to be hit the hardest by pollution, whether it’s conventional air water and soil pollution or climate change, it is very often low-income communities and communities of color. The undercutting of these kinds of protections is going to have a disproportionate impact on these very same communities.
See this page in the PDF
Environmental Protection Agency
regulatory review (before options are selected); causality of health effects; low-dose risk estimation (linear no-threshold analysis); and employment loss analysis.
Personnel
The majority of the political appointee team must be assembled, vetted, and ready to deploy before Day One. To the extent provided by the Federal Vacancies Reform Act,” appointees in consideration for Senate-confirmed positions (excluding the Administrator) should be prepared to serve as a Deputy or Principal Deputy to get into the agency on Day One while their nomination and affiliated confirmation processes proceeds. In addition to a deputy slated for the Assistant Administrator role, each office will need a political chief of staff, senior advisers designated to run suboffices, and energized assistants. Teams should be balanced with technical knowledge, legal expertise, and political exposure. Ideally, they should also be geographically diverse. Appointee positions should also extend to all the regional offices and specialty labs.
OFFICE OF AIR AND RADIATION (OAR)
OAR develops national programs, policies, and regulations to control air pollution and radiation exposure. In recent decades, OAR and its statutory responsibilities under the Clean Air Act have been reimagined in an attempt to expand the reach of the federal government. The U.S. Supreme Court has stopped and stricken several actions from OAR under liberal Administrations, citing a lack of requisite legal support. A reformed OAR should focus on EPA’s mission of limiting and minimizing criteria and hazardous air pollutants in partnership with the states.
Cross-Cutting Reforms. OAR consists of four suboffices with two located in Washington, D.C.; one in Ann Arbor, Michigan; and one at Research Triangle Park in Raleigh, North Carolina. The following reforms should be implemented across all OAR offices:
• Issue arule to ensure consistent and transparent consideration of costs.
• When doing cost-benefit analysis, use appropriate discount rates, focus
on the benefits of reducing the pollutant targeted by Congress, identify
“co-benefits” separately, and acknowledge the uncertainties involved in quantifying benefits.
• Review and revise Reasonably Available Control Technology (RACT) cost guidance to ensure that calculations are accurate and reflect the actual regulatory burden, including costs of air rules implementation and compliance.