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.
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Environmental Protection Agency
science advisory, peer review, risk assessment, and risk management activities. This enterprise includes the Office of Research and Development (ORD), the agency’s largest employer, as well as science activities across other key programs, regions, and cross-cutting parts of the Administrator’s office. EPA’s scientific enterprise, including ORD, has rightly been criticized for decades as precautionary, bloated, unaccountable, closed, outcome-driven, hostile to public and legislative input, and inclined to pursue political rather than purely scientific goals.
Needed Reforms: Day One Priorities
• Notify Congress that EPA will not conduct any ongoing or planned science activity for which there is not clear and current congressional authorization. This priority should be underscored in the President’s first budget request.
• The new President’s Inauguration Day regulatory review/freeze directives should avoid exceptions for EPA actions. This freeze should explicitly include quasi-regulatory actions, including assessments, determinations, standards, and guidance, that have failed to go through the notice-andcomment process and may date back years.
• Pause for review all contracts above $100,000 with a heavy focus on major external peer reviews and regulatory models.
• Call for the public to identify areas where EPA has inconsistently assessed risk, failed to use the best science, or participated in research misconduct.
• Eliminate the use of unauthorized regulatory inputs like the social cost of carbon, black box and proprietary models, and unrealistic climate scenarios, including those based on Representative Concentration Pathway (RCP) 8.5.
Personnel • Quickly nominate a reform-minded Assistant Administrator for Research and Development.
• Appoint and empower a Science Adviser reporting directly to the Administrator in addition to a substantial investment (no fewer than six senior political appointees) charged with overseeing and reforming EPA research and science activities. Qualifications for these positions should emphasize management, oversight, and execution skills Gncluding in leading state environmental agencies) as opposed to personal scientific output.