Study also shows economic benefits of implementing state’s Coastal Master Plan (Baton Rouge – March 22, 2017) Louisiana could lose as much as $3.6 billion in homes, businesses and other infrastructure over the next 50 years if the state takes no action to curb its coastal land loss crisis, according to a new study released today by the Louisiana State University (LSU) Economics & Policy Research Group. The study, “Regional Impacts of Coastal Land Loss and Louisiana’s Opportunity for Growth,” ...

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Written by Diane MacEachern

The U.S. Navy is the largest, most powerful armada on earth. But it’s no match for climate change, as a provocative new film called “Tidewater” shows.

Moreover, the U.S. Navy agrees,

“The U.S. Navy recognizes sea level rise and increasing storm surge as risks that can affect our infrastructure and readiness.“We are committed to making science-based decisions that preserve our ability to conduct our national security mission now and in the future.” -Rear Admiral Tim Gallaudet, Oceanographer and Navigator of the Navy, and Commander, Naval Meteorology and Oceanography Command

 What those decisions are depends, of course, on  how seriously citizens and elected officials along with the military take the threats climate change poses, and how well everyone works together to resolve them. “Tidewater,” which premiered at the Environmental Film Festival in Washington, D.C., is named for the Tidewater region of southeast Virginia and northeastern North Carolina. The region sits at the mouth of the Chesapeake Bay and encompasses 17 cities and municipalities, including Norfolk, Hampton, Virginia Beach, Portsmouth and Newport News. The area gets its name from the effects that changing tides have on local rivers, sounds, and the ocean. It’s flat, low land composed of tidal marshes, large expanses of swamp and the urban development that has come as cities and towns build their communities on whatever land they can reclaim from the sea.

The Navy located there to take advantage of the many ports around which to dock its ships, amass its sailors, and launch its missions. Seal Team 6, the famous commandos who took out Osama bin Laden, trained there. Tens of thousands of sailors have deployed from there to ports all over the world; 1.6 million Americans call the area home.

As a coastal community, Tidewater is experiencing the same rapid sea-level rise that’s occurring along every shoreline due to climate change, but in spades. The area is considered to be the second most vulnerable community in the U.S. to sea level rise after New Orleans. Unfortunately, it doesn’t take a hurricane like Katrina to demonstrate the region’s fragility. Sometimes streets flood when the skies are clear blue with no rain or storm in sight. People’s basements are filling with water; neighborhoods are submerging. In one effective scene from the film, the pastor of a local church described how impossible it was for his congregants to get to Mass because the inundated streets were impassible – and it wasn’t even raining. In another, a young woman is shown providing her elderly grandmother with a life vest. She doesn’t want her grandmother to drown when the floods inevitably come.

What else is at stake? In addition to roads, bridges and buildings being undermined, the electric grid fails when it gets flooded. In more than one instance, power to naval docks has gone out because the electricity system got wet. When hurricanes do strike the region, the Navy moves its ships out to sea so they won’t end up getting blown onto the land. Getting them back into port again can be almost impossible if the ports are flooded and the power is out. Retired Rear Admiral Ann Phillips is interviewed on camera expressing her concern about the national security risks the U.S. faces when these dire situations occur.

In fact, Phillips – who once commanded a destroyer squadron and an expeditionary strike group – has convened a regional Sea Level Rise Preparedness and Resilience Intergovernmental Pilot Planning Project to develop a “collaborative, whole of government and community approach” to address the impact of sea level rise across the region. She’s not ignoring her own backyard, either. The film shows her planting trees near her waterside home to help restore the wetlands that can help buffer her neighborhood against the rising tides.

“Tidewater” was produced and directed by Roger Sorkin under the auspices of the American Resilience Project. The project was founded with two goals in mind. One is to engage citizens and policymakers “in the face of environmental threats like sea level rise, extreme weather, …and electrical grid vulnerability.” The second is to harness the power of film to “inspire action and cooperation” that will lead to solutions.

Sorkin welcomed a capacity crowd to the premiere of his film, and said, “This film depoliticizes an issue that should not be political in the first place.”

In other words, whether you’re Republican or Democrat, it doesn’t matter if you’re drowning.

Acknowledging how climate change has become a political  operative, Sorkin also encouraged the audience to look to each other for solutions rather than rely strictly on the government:

“We can’t wait for our elected officials to get on board. We have to lead the way.”

READ FREE EBOOK: MILITARY VOICES ON GLOBAL WARMING 

TELL YOUR SENATOR: PROTECT OUR AIR AND OUR RESOURCES

 

Nobody raises an eyebrow when California takes steps to rein in air pollution – but what’s going on when conservative-leaning Rust Belt states such as Ohio and Pennsylvania are doing the same?

At a time when the Trump administration and Congress seek to scale back federal rules targeting methane emissions from energy production, a growing number of states that swung in favor of Trump in 2016 are heading in the opposite direction.

It reminds us that states that recognize good policy still have the power to act, regardless of who controls Washington. Ohio and Pennsylvania, now following in the footsteps of Colorado, Wyoming and California, are the latest examples of this.

Ohio: Pragmatic governor had a smart idea

States have different reasons for targeting methane leaks, even if they tend to draw the same conclusion at the end of the day: Methane mitigation is good for the environment and for companies on which tens of thousands of American jobs depend.

This was Ohio Gov. John Kasich’s pitch when he proposed common-sense steps the Buckeye State could take to rein in oil and gas pollution.

Kasich was able to avoid major opposition to the measure by pointing to environmental and political problems other states were experiencing as a result of their inaction, and by showing that it was in Ohio’s and its industry’s best interest to get ahead of the curve.

“We’re going to have to have some additional regulation to make sure that industry stays safe,” he told the Ohio Chamber of Commerce in 2014.

That year, the state required companies to reduce leaks at well sites. In February 2017, Ohio expanded these requirements to also cover compressor and transmission stations – the facilities that help push gas through the pipeline, and that account for about one-third of the industry’s total methane leakage.

The results of Ohio’s policies so far?

Companies, which must now check their equipment for gas leaks at new or modified equipment once a quarter, have complied and gone about their business. At the same time, new jobs are cropping up in a whole new industry focused on detecting and capping methane leaks.  

Pennsylvania: Public outcry prompted action

Across the state border in the Keystone State, public concern over hydraulic fracturing, or “fracking,” has already been growing for several years due to insufficient oversight.

Environmental violations at drill sites have been well-documented by the state; Pennsylvanians have been shocked by images of oil spills, leaking tanks and dead vegetation.

Not surprisingly, Pennsylvania is next in line to tackle methane waste. In January 2016, Gov. Tom Wolf announced his intent to adopt the toughest methane pollution rules in the nation.

While welcomed by many, the governor’s approach to reducing methane emissions has run into resistance in the state legislature as of late. Some politicians have apparently been swayed by misleading rhetoric about the costs of reducing gas leaks, and threats that environmental protections “kill jobs.”

All these lawmakers need to do, of course, is to peek across the border to Ohio, or call states out West that can attest that methane policies won’t hurt operators’ bottom line. They even spawn new job growth.

In fact, Pennsylvania and Ohio already count more than 40 companies that specialize in emission reduction and that provide high-paying service and manufacturing jobs to thousands of rust belt residents.

Americans don’t like waste

It’s estimated that oil and gas companies lose some $2 billion a year in product. Such waste doesn’t sit well with hardworking Americans trying to make ends meet, especially when it only costs companies about a penny per unit of produced gas to reduce such pollution. 

The 2015 Aliso Canyon disaster grew public awareness of methane leaks. And lately, opposition has been growing out West against Trump’s move to abandon an Obama-era rule aimed at reducing such leaks from drill sites on federal lands.

It raises the question of how far Trump’s policies will reach before they run into resistance – even in states that delivered him the presidency.

Trump wants to cut waste. Good, these policies do.

By Diane Regas

Barely a month after his inauguration, President Trump is proceeding with plans to dismantle protections under the Clean Air Act and Clean Water Act.  The targets include limiting pollution into streams and wetlands that flow into drinking water for a hundred million Americans, automobile fuel economy standards that cut tailpipe pollution, and performance standards under the Clean Power Plan that would boost renewable power and fight climate change.  Trump and his EPA Administrator, Scott Pruitt, have drawn up reckless plans to slash EPA’s budget—greeted with derision even by some Republicans in Congress.  With the tragic story of Flint still fresh in people’s minds, the President is betraying the demands of his own supporters — fully 64% of Trump voters want to maintain or increase spending on environmental protection.

These actions are a tragic wrong turn for the country — and not just because they threaten to roll back decades of progress on air and water pollution, and the recent steps forward on climate change.

What I especially worry about are the lost opportunities for economic growth, new jobs, and the competitiveness of American companies — at a time when China and others are stepping up.

I think we can all agree that America is great in part because of our huge capacity for innovation — from Henry Ford to Elon Musk. But sadly, the new administration fails to understand that affirmative government policy has a crucial role to play in keeping the engine of innovation healthy and humming. In fact, during my decades of working under six different EPA administrators, almost all of them Republicans, I’ve seen first-hand the ability of smart regulations to unleash the enormous power of American ingenuity and entrepreneurship.

Keeping America Great: Smart Rules Can Help The Economy And Nature Prosper
Click To Tweet

Smart rules — focused on results, not process — stimulate new ideas, create new markets and jobs, and raise living standards for all Americans. The limits imposed on pollution spewing from auto exhaust pipes not only cleaned the air and improved health, for example, they also spurred new technologies that increase fuel efficiency. As a result, Americans save money every time they pull up to the gas pump (though these benefits are threatened by the plans to roll back fuel economy standards). Similarly, protecting the ozone layer drove the development of new refrigerants, bringing higher profits for the innovative companies that paved the way to the new products.

But don’t take my word for it.

Clean states

"I refused to gamble on the energy diversity options." — Illinois Gov. Bruce Rauner

Listen instead to Bruce Rauner, the Republican governor of Illinois. Rauner recently signed a bipartisan bill that requires utilities in the state to generate 25% of their electricity from clean renewable sources like wind and solar by 2025 and to significantly boost the efficiency of energy use in homes and businesses. The mandates are good for the planet, of course, because they will cut the state’s emissions of climate change-causing greenhouse gases even more than would be required under Obama’s Clean Power Plan. And far from killing the economy, they will entice more than $10 billion in new investment dollars into the state and save people money on their electric bills. “I refused to gamble on thousands of good-paying jobs, and I refused to gamble on the energy diversity options for the people of Illinois,” Rauner told the Chicago Sun-Times. “That’s why I fought to make this bill happen.”

Clean grid

These regulations are stimulating the economy by creating high-paying jobs in construction and in manufacturing.

Or consider a seemingly arcane change in rules by the Federal Energy Regulatory Commission (FERC) about how transmission grid operators are paid to manage power fluctuations on the grid. The rule change has already spurred competition and made it cheaper (and more effective) to rely on batteries instead of ramping up gas generators — and helped fuel a whole new business in large-scale battery storage. Now, that industry is being truly kick-started by regulatory mandates, first in California, then in Oregon and Massachusetts, requiring that hundreds of megawatts of storage be added to the grid. This support in the early phase will help make battery storage competitive everywhere. These regulations are crucial weapons in the fight against climate change. But just as important, they are stimulating the economy by creating high-paying jobs in construction and in manufacturing facilities like Tesla’s battery gigafactory. As California Governor Jerry Brown says: “Regulation inspires innovation.”

Clean cars

I’ve been fortunate to personally benefit from such innovations. Pacific Gas and Electric is paying me to use my electric car as flexible power storage on their grid. PG&E and BMW have teamed up in a pilot project to test how to use plugged-in electric vehicles to meet short spikes in the supply of clean power. The utility saves money on power plants, can build-in more renewables, and will pay owners like me up to $900 over the two-year program. I’m also thrilled by the many advantages of the car itself: peppy acceleration, whisper-quiet operation, and low maintenance costs.

Clean tech

Breathtaking innovation in sensors, artificial intelligence, and advanced materials can thrive because the US creates the right environment. But an ideologically blinded attack on all government funding and regulation will create uncertainty and smother innovation that we desperately need. More than ever, we urgently need to protect the environment and slow climate change with smart investments and standards that also increase prosperity for all Americans. “The key is designing policies that point the way forward while creating a wide playing field for innovators to develop the best solutions,” says Anthony (Tony) F. Earley, Jr., Executive Chair of the Board of PG&E Corporation.

Global momentum

China is creating the world’s largest carbon emissions trading system.

Other countries understand this urgency. China is creating the world’s largest carbon emissions trading system, harnessing the power of the free market to fuel innovation and find the cheapest and best approaches to cutting carbon pollution.  In a powerful symbolic move, China just announced a competition to develop key market infrastructure — on the Friday before the National People’s Congress.

Countries like Germany, Denmark, the Netherlands, and Norway are already far ahead of us in shares of renewable power or electric cars and are reaping the resulting economic benefits from their homegrown innovations and world-leading companies. Eliminating the rules that have been successful in stimulating clean energy advances here in America will only put us further behind.

With the right smart regulations and policies, we can protect our cherished clean air and clean water and stabilize the climate. And at the same time, we will also keep America great.

This article originally appeared on Forbes.

Photo source: Grid Alternatives

By Diane Regas

Barely a month after his inauguration, President Trump is proceeding with plans to dismantle protections under the Clean Air Act and Clean Water Act.  The targets include limiting pollution into streams and wetlands that flow into drinking water for a hundred million Americans, automobile fuel economy standards that cut tailpipe pollution, and performance standards under the Clean Power Plan that would boost renewable power and fight climate change.  Trump and his EPA Administrator, Scott Pruitt, have drawn up reckless plans to slash EPA’s budget—greeted with derision even by some Republicans in Congress.  With the tragic story of Flint still fresh in people’s minds, the President is betraying the demands of his own supporters — fully 64% of Trump voters want to maintain or increase spending on environmental protection.

These actions are a tragic wrong turn for the country — and not just because they threaten to roll back decades of progress on air and water pollution, and the recent steps forward on climate change.

What I especially worry about are the lost opportunities for economic growth, new jobs, and the competitiveness of American companies — at a time when China and others are stepping up.

I think we can all agree that America is great in part because of our huge capacity for innovation — from Henry Ford to Elon Musk. But sadly, the new administration fails to understand that affirmative government policy has a crucial role to play in keeping the engine of innovation healthy and humming. In fact, during my decades of working under six different EPA administrators, almost all of them Republicans, I’ve seen first-hand the ability of smart regulations to unleash the enormous power of American ingenuity and entrepreneurship.

Keeping America Great: Smart Rules Can Help The Economy And Nature Prosper
Click To Tweet

Smart rules — focused on results, not process — stimulate new ideas, create new markets and jobs, and raise living standards for all Americans. The limits imposed on pollution spewing from auto exhaust pipes not only cleaned the air and improved health, for example, they also spurred new technologies that increase fuel efficiency. As a result, Americans save money every time they pull up to the gas pump (though these benefits are threatened by the plans to roll back fuel economy standards). Similarly, protecting the ozone layer drove the development of new refrigerants, bringing higher profits for the innovative companies that paved the way to the new products.

But don’t take my word for it.

Clean states

"I refused to gamble on the energy diversity options." — Illinois Gov. Bruce Rauner

Listen instead to Bruce Rauner, the Republican governor of Illinois. Rauner recently signed a bipartisan bill that requires utilities in the state to generate 25% of their electricity from clean renewable sources like wind and solar by 2025 and to significantly boost the efficiency of energy use in homes and businesses. The mandates are good for the planet, of course, because they will cut the state’s emissions of climate change-causing greenhouse gases even more than would be required under Obama’s Clean Power Plan. And far from killing the economy, they will entice more than $10 billion in new investment dollars into the state and save people money on their electric bills. “I refused to gamble on thousands of good-paying jobs, and I refused to gamble on the energy diversity options for the people of Illinois,” Rauner told the Chicago Sun-Times. “That’s why I fought to make this bill happen.”

Clean grid

These regulations are stimulating the economy by creating high-paying jobs in construction and in manufacturing.

Or consider a seemingly arcane change in rules by the Federal Energy Regulatory Commission (FERC) about how transmission grid operators are paid to manage power fluctuations on the grid. The rule change has already spurred competition and made it cheaper (and more effective) to rely on batteries instead of ramping up gas generators — and helped fuel a whole new business in large-scale battery storage. Now, that industry is being truly kick-started by regulatory mandates, first in California, then in Oregon and Massachusetts, requiring that hundreds of megawatts of storage be added to the grid. This support in the early phase will help make battery storage competitive everywhere. These regulations are crucial weapons in the fight against climate change. But just as important, they are stimulating the economy by creating high-paying jobs in construction and in manufacturing facilities like Tesla’s battery gigafactory. As California Governor Jerry Brown says: “Regulation inspires innovation.”

Clean cars

I’ve been fortunate to personally benefit from such innovations. Pacific Gas and Electric is paying me to use my electric car as flexible power storage on their grid. PG&E and BMW have teamed up in a pilot project to test how to use plugged-in electric vehicles to meet short spikes in the supply of clean power. The utility saves money on power plants, can build-in more renewables, and will pay owners like me up to $900 over the two-year program. I’m also thrilled by the many advantages of the car itself: peppy acceleration, whisper-quiet operation, and low maintenance costs.

Clean tech

Breathtaking innovation in sensors, artificial intelligence, and advanced materials can thrive because the US creates the right environment. But an ideologically blinded attack on all government funding and regulation will create uncertainty and smother innovation that we desperately need. More than ever, we urgently need to protect the environment and slow climate change with smart investments and standards that also increase prosperity for all Americans. “The key is designing policies that point the way forward while creating a wide playing field for innovators to develop the best solutions,” says Anthony (Tony) F. Earley, Jr., Executive Chair of the Board of PG&E Corporation.

Global momentum

China is creating the world’s largest carbon emissions trading system.

Other countries understand this urgency. China is creating the world’s largest carbon emissions trading system, harnessing the power of the free market to fuel innovation and find the cheapest and best approaches to cutting carbon pollution.  In a powerful symbolic move, China just announced a competition to develop key market infrastructure — on the Friday before the National People’s Congress.

Countries like Germany, Denmark, the Netherlands, and Norway are already far ahead of us in shares of renewable power or electric cars and are reaping the resulting economic benefits from their homegrown innovations and world-leading companies. Eliminating the rules that have been successful in stimulating clean energy advances here in America will only put us further behind.

With the right smart regulations and policies, we can protect our cherished clean air and clean water and stabilize the climate. And at the same time, we will also keep America great.

This article originally appeared on Forbes.

Photo source: Grid Alternatives

By Diane Regas

Barely a month after his inauguration, President Trump is proceeding with plans to dismantle protections under the Clean Air Act and Clean Water Act.  The targets include limiting pollution into streams and wetlands that flow into drinking water for a hundred million Americans, automobile fuel economy standards that cut tailpipe pollution, and performance standards under the Clean Power Plan that would boost renewable power and fight climate change.  Trump and his EPA Administrator, Scott Pruitt, have drawn up reckless plans to slash EPA’s budget—greeted with derision even by some Republicans in Congress.  With the tragic story of Flint still fresh in people’s minds, the President is betraying the demands of his own supporters — fully 64% of Trump voters want to maintain or increase spending on environmental protection.

These actions are a tragic wrong turn for the country — and not just because they threaten to roll back decades of progress on air and water pollution, and the recent steps forward on climate change.

What I especially worry about are the lost opportunities for economic growth, new jobs, and the competitiveness of American companies — at a time when China and others are stepping up.

I think we can all agree that America is great in part because of our huge capacity for innovation — from Henry Ford to Elon Musk. But sadly, the new administration fails to understand that affirmative government policy has a crucial role to play in keeping the engine of innovation healthy and humming. In fact, during my decades of working under six different EPA administrators, almost all of them Republicans, I’ve seen first-hand the ability of smart regulations to unleash the enormous power of American ingenuity and entrepreneurship.

Keeping America Great: Smart Rules Can Help The Economy And Nature Prosper
Click To Tweet

Smart rules — focused on results, not process — stimulate new ideas, create new markets and jobs, and raise living standards for all Americans. The limits imposed on pollution spewing from auto exhaust pipes not only cleaned the air and improved health, for example, they also spurred new technologies that increase fuel efficiency. As a result, Americans save money every time they pull up to the gas pump (though these benefits are threatened by the plans to roll back fuel economy standards). Similarly, protecting the ozone layer drove the development of new refrigerants, bringing higher profits for the innovative companies that paved the way to the new products.

But don’t take my word for it.

Clean states

"I refused to gamble on the energy diversity options." — Illinois Gov. Bruce Rauner

Listen instead to Bruce Rauner, the Republican governor of Illinois. Rauner recently signed a bipartisan bill that requires utilities in the state to generate 25% of their electricity from clean renewable sources like wind and solar by 2025 and to significantly boost the efficiency of energy use in homes and businesses. The mandates are good for the planet, of course, because they will cut the state’s emissions of climate change-causing greenhouse gases even more than would be required under Obama’s Clean Power Plan. And far from killing the economy, they will entice more than $10 billion in new investment dollars into the state and save people money on their electric bills. “I refused to gamble on thousands of good-paying jobs, and I refused to gamble on the energy diversity options for the people of Illinois,” Rauner told the Chicago Sun-Times. “That’s why I fought to make this bill happen.”

Clean grid

These regulations are stimulating the economy by creating high-paying jobs in construction and in manufacturing.

Or consider a seemingly arcane change in rules by the Federal Energy Regulatory Commission (FERC) about how transmission grid operators are paid to manage power fluctuations on the grid. The rule change has already spurred competition and made it cheaper (and more effective) to rely on batteries instead of ramping up gas generators — and helped fuel a whole new business in large-scale battery storage. Now, that industry is being truly kick-started by regulatory mandates, first in California, then in Oregon and Massachusetts, requiring that hundreds of megawatts of storage be added to the grid. This support in the early phase will help make battery storage competitive everywhere. These regulations are crucial weapons in the fight against climate change. But just as important, they are stimulating the economy by creating high-paying jobs in construction and in manufacturing facilities like Tesla’s battery gigafactory. As California Governor Jerry Brown says: “Regulation inspires innovation.”

Clean cars

I’ve been fortunate to personally benefit from such innovations. Pacific Gas and Electric is paying me to use my electric car as flexible power storage on their grid. PG&E and BMW have teamed up in a pilot project to test how to use plugged-in electric vehicles to meet short spikes in the supply of clean power. The utility saves money on power plants, can build-in more renewables, and will pay owners like me up to $900 over the two-year program. I’m also thrilled by the many advantages of the car itself: peppy acceleration, whisper-quiet operation, and low maintenance costs.

Clean tech

Breathtaking innovation in sensors, artificial intelligence, and advanced materials can thrive because the US creates the right environment. But an ideologically blinded attack on all government funding and regulation will create uncertainty and smother innovation that we desperately need. More than ever, we urgently need to protect the environment and slow climate change with smart investments and standards that also increase prosperity for all Americans. “The key is designing policies that point the way forward while creating a wide playing field for innovators to develop the best solutions,” says Anthony (Tony) F. Earley, Jr., Executive Chair of the Board of PG&E Corporation.

Global momentum

China is creating the world’s largest carbon emissions trading system.

Other countries understand this urgency. China is creating the world’s largest carbon emissions trading system, harnessing the power of the free market to fuel innovation and find the cheapest and best approaches to cutting carbon pollution.  In a powerful symbolic move, China just announced a competition to develop key market infrastructure — on the Friday before the National People’s Congress.

Countries like Germany, Denmark, the Netherlands, and Norway are already far ahead of us in shares of renewable power or electric cars and are reaping the resulting economic benefits from their homegrown innovations and world-leading companies. Eliminating the rules that have been successful in stimulating clean energy advances here in America will only put us further behind.

With the right smart regulations and policies, we can protect our cherished clean air and clean water and stabilize the climate. And at the same time, we will also keep America great.

This article originally appeared on Forbes.

Photo source: Grid Alternatives

Barely a month after his inauguration, President Trump is proceeding with plans to dismantle protections under the Clean Air Act and Clean Water Act.  The targets include limiting pollution into streams and wetlands that flow into drinking water for a hundred million Americans, automobile fuel economy standards that cut tailpipe pollution, and performance standards under […]

By Diane Regas

Barely a month after his inauguration, President Trump is proceeding with plans to dismantle protections under the Clean Air Act and Clean Water Act.  The targets include limiting pollution into streams and wetlands that flow into drinking water for a hundred million Americans, automobile fuel economy standards that cut tailpipe pollution, and performance standards under the Clean Power Plan that would boost renewable power and fight climate change.  Trump and his EPA Administrator, Scott Pruitt, have drawn up reckless plans to slash EPA’s budget—greeted with derision even by some Republicans in Congress.  With the tragic story of Flint still fresh in people’s minds, the President is betraying the demands of his own supporters — fully 64% of Trump voters want to maintain or increase spending on environmental protection.

These actions are a tragic wrong turn for the country — and not just because they threaten to roll back decades of progress on air and water pollution, and the recent steps forward on climate change.

What I especially worry about are the lost opportunities for economic growth, new jobs, and the competitiveness of American companies — at a time when China and others are stepping up.

I think we can all agree that America is great in part because of our huge capacity for innovation — from Henry Ford to Elon Musk. But sadly, the new administration fails to understand that affirmative government policy has a crucial role to play in keeping the engine of innovation healthy and humming. In fact, during my decades of working under six different EPA administrators, almost all of them Republicans, I’ve seen first-hand the ability of smart regulations to unleash the enormous power of American ingenuity and entrepreneurship.

Keeping America Great: Smart Rules Can Help The Economy And Nature Prosper
Click To Tweet

Smart rules — focused on results, not process — stimulate new ideas, create new markets and jobs, and raise living standards for all Americans. The limits imposed on pollution spewing from auto exhaust pipes not only cleaned the air and improved health, for example, they also spurred new technologies that increase fuel efficiency. As a result, Americans save money every time they pull up to the gas pump (though these benefits are threatened by the plans to roll back fuel economy standards). Similarly, protecting the ozone layer drove the development of new refrigerants, bringing higher profits for the innovative companies that paved the way to the new products.

But don’t take my word for it.

Clean states

"I refused to gamble on the energy diversity options." — Illinois Gov. Bruce Rauner

Listen instead to Bruce Rauner, the Republican governor of Illinois. Rauner recently signed a bipartisan bill that requires utilities in the state to generate 25% of their electricity from clean renewable sources like wind and solar by 2025 and to significantly boost the efficiency of energy use in homes and businesses. The mandates are good for the planet, of course, because they will cut the state’s emissions of climate change-causing greenhouse gases even more than would be required under Obama’s Clean Power Plan. And far from killing the economy, they will entice more than $10 billion in new investment dollars into the state and save people money on their electric bills. “I refused to gamble on thousands of good-paying jobs, and I refused to gamble on the energy diversity options for the people of Illinois,” Rauner told the Chicago Sun-Times. “That’s why I fought to make this bill happen.”

Clean grid

These regulations are stimulating the economy by creating high-paying jobs in construction and in manufacturing.

Or consider a seemingly arcane change in rules by the Federal Energy Regulatory Commission (FERC) about how transmission grid operators are paid to manage power fluctuations on the grid. The rule change has already spurred competition and made it cheaper (and more effective) to rely on batteries instead of ramping up gas generators — and helped fuel a whole new business in large-scale battery storage. Now, that industry is being truly kick-started by regulatory mandates, first in California, then in Oregon and Massachusetts, requiring that hundreds of megawatts of storage be added to the grid. This support in the early phase will help make battery storage competitive everywhere. These regulations are crucial weapons in the fight against climate change. But just as important, they are stimulating the economy by creating high-paying jobs in construction and in manufacturing facilities like Tesla’s battery gigafactory. As California Governor Jerry Brown says: “Regulation inspires innovation.”

Clean cars

I’ve been fortunate to personally benefit from such innovations. Pacific Gas and Electric is paying me to use my electric car as flexible power storage on their grid. PG&E and BMW have teamed up in a pilot project to test how to use plugged-in electric vehicles to meet short spikes in the supply of clean power. The utility saves money on power plants, can build-in more renewables, and will pay owners like me up to $900 over the two-year program. I’m also thrilled by the many advantages of the car itself: peppy acceleration, whisper-quiet operation, and low maintenance costs.

Clean tech

Breathtaking innovation in sensors, artificial intelligence, and advanced materials can thrive because the US creates the right environment. But an ideologically blinded attack on all government funding and regulation will create uncertainty and smother innovation that we desperately need. More than ever, we urgently need to protect the environment and slow climate change with smart investments and standards that also increase prosperity for all Americans. “The key is designing policies that point the way forward while creating a wide playing field for innovators to develop the best solutions,” says Anthony (Tony) F. Earley, Jr., Executive Chair of the Board of PG&E Corporation.

Global momentum

China is creating the world’s largest carbon emissions trading system.

Other countries understand this urgency. China is creating the world’s largest carbon emissions trading system, harnessing the power of the free market to fuel innovation and find the cheapest and best approaches to cutting carbon pollution.  In a powerful symbolic move, China just announced a competition to develop key market infrastructure — on the Friday before the National People’s Congress.

Countries like Germany, Denmark, the Netherlands, and Norway are already far ahead of us in shares of renewable power or electric cars and are reaping the resulting economic benefits from their homegrown innovations and world-leading companies. Eliminating the rules that have been successful in stimulating clean energy advances here in America will only put us further behind.

With the right smart regulations and policies, we can protect our cherished clean air and clean water and stabilize the climate. And at the same time, we will also keep America great.

This article originally appeared on Forbes.

Photo source: Grid Alternatives

By Diane Regas

Barely a month after his inauguration, President Trump is proceeding with plans to dismantle protections under the Clean Air Act and Clean Water Act.  The targets include limiting pollution into streams and wetlands that flow into drinking water for a hundred million Americans, automobile fuel economy standards that cut tailpipe pollution, and performance standards under the Clean Power Plan that would boost renewable power and fight climate change.  Trump and his EPA Administrator, Scott Pruitt, have drawn up reckless plans to slash EPA’s budget—greeted with derision even by some Republicans in Congress.  With the tragic story of Flint still fresh in people’s minds, the President is betraying the demands of his own supporters — fully 64% of Trump voters want to maintain or increase spending on environmental protection.

These actions are a tragic wrong turn for the country — and not just because they threaten to roll back decades of progress on air and water pollution, and the recent steps forward on climate change.

What I especially worry about are the lost opportunities for economic growth, new jobs, and the competitiveness of American companies — at a time when China and others are stepping up.

I think we can all agree that America is great in part because of our huge capacity for innovation — from Henry Ford to Elon Musk. But sadly, the new administration fails to understand that affirmative government policy has a crucial role to play in keeping the engine of innovation healthy and humming. In fact, during my decades of working under six different EPA administrators, almost all of them Republicans, I’ve seen first-hand the ability of smart regulations to unleash the enormous power of American ingenuity and entrepreneurship.

Keeping America Great: Smart Rules Can Help The Economy And Nature Prosper
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Smart rules — focused on results, not process — stimulate new ideas, create new markets and jobs, and raise living standards for all Americans. The limits imposed on pollution spewing from auto exhaust pipes not only cleaned the air and improved health, for example, they also spurred new technologies that increase fuel efficiency. As a result, Americans save money every time they pull up to the gas pump (though these benefits are threatened by the plans to roll back fuel economy standards). Similarly, protecting the ozone layer drove the development of new refrigerants, bringing higher profits for the innovative companies that paved the way to the new products.

But don’t take my word for it.

Clean states

"I refused to gamble on the energy diversity options." — Illinois Gov. Bruce Rauner

Listen instead to Bruce Rauner, the Republican governor of Illinois. Rauner recently signed a bipartisan bill that requires utilities in the state to generate 25% of their electricity from clean renewable sources like wind and solar by 2025 and to significantly boost the efficiency of energy use in homes and businesses. The mandates are good for the planet, of course, because they will cut the state’s emissions of climate change-causing greenhouse gases even more than would be required under Obama’s Clean Power Plan. And far from killing the economy, they will entice more than $10 billion in new investment dollars into the state and save people money on their electric bills. “I refused to gamble on thousands of good-paying jobs, and I refused to gamble on the energy diversity options for the people of Illinois,” Rauner told the Chicago Sun-Times. “That’s why I fought to make this bill happen.”

Clean grid

These regulations are stimulating the economy by creating high-paying jobs in construction and in manufacturing.

Or consider a seemingly arcane change in rules by the Federal Energy Regulatory Commission (FERC) about how transmission grid operators are paid to manage power fluctuations on the grid. The rule change has already spurred competition and made it cheaper (and more effective) to rely on batteries instead of ramping up gas generators — and helped fuel a whole new business in large-scale battery storage. Now, that industry is being truly kick-started by regulatory mandates, first in California, then in Oregon and Massachusetts, requiring that hundreds of megawatts of storage be added to the grid. This support in the early phase will help make battery storage competitive everywhere. These regulations are crucial weapons in the fight against climate change. But just as important, they are stimulating the economy by creating high-paying jobs in construction and in manufacturing facilities like Tesla’s battery gigafactory. As California Governor Jerry Brown says: “Regulation inspires innovation.”

Clean cars

I’ve been fortunate to personally benefit from such innovations. Pacific Gas and Electric is paying me to use my electric car as flexible power storage on their grid. PG&E and BMW have teamed up in a pilot project to test how to use plugged-in electric vehicles to meet short spikes in the supply of clean power. The utility saves money on power plants, can build-in more renewables, and will pay owners like me up to $900 over the two-year program. I’m also thrilled by the many advantages of the car itself: peppy acceleration, whisper-quiet operation, and low maintenance costs.

Clean tech

Breathtaking innovation in sensors, artificial intelligence, and advanced materials can thrive because the US creates the right environment. But an ideologically blinded attack on all government funding and regulation will create uncertainty and smother innovation that we desperately need. More than ever, we urgently need to protect the environment and slow climate change with smart investments and standards that also increase prosperity for all Americans. “The key is designing policies that point the way forward while creating a wide playing field for innovators to develop the best solutions,” says Anthony (Tony) F. Earley, Jr., Executive Chair of the Board of PG&E Corporation.

Global momentum

China is creating the world’s largest carbon emissions trading system.

Other countries understand this urgency. China is creating the world’s largest carbon emissions trading system, harnessing the power of the free market to fuel innovation and find the cheapest and best approaches to cutting carbon pollution.  In a powerful symbolic move, China just announced a competition to develop key market infrastructure — on the Friday before the National People’s Congress.

Countries like Germany, Denmark, the Netherlands, and Norway are already far ahead of us in shares of renewable power or electric cars and are reaping the resulting economic benefits from their homegrown innovations and world-leading companies. Eliminating the rules that have been successful in stimulating clean energy advances here in America will only put us further behind.

With the right smart regulations and policies, we can protect our cherished clean air and clean water and stabilize the climate. And at the same time, we will also keep America great.

This article originally appeared on Forbes.

Photo source: Grid Alternatives

The engineers and scientists who study the oil and gas industry’s wastewater know the term “beneficial reuse” well. It’s the seldom-used technique of taking wastewater produced from an oil or gas well, treating it, and then using it for other purposes — like watering crops (including organic crops) or feeding livestock.  It’s a rare practice […]

By Dan Mueller

The engineers and scientists who study the oil and gas industry’s wastewater know the term “beneficial reuse” well. It’s the seldom-used technique of taking wastewater produced from an oil or gas well, treating it, and then using it for other purposes — like watering crops (including organic crops) or feeding livestock.  It’s a rare practice that drought-stricken areas like California have used for a number of years, although little is known about associated health or safety risks since, usually, about 98% of wastewater is injected into disposal wells deep underground. However, as demands for water increase, and concerns about disposal wells (which have been linked to earthquakes) rise, beneficial reuse is being considered as a viable option.

But just because we can use wastewater for other purposes – does that mean we should?

Scientists researching these issues still have a lot of questions. Our recent article in World Water: Water Reuse & Desalination—a publication of the Water Environment Federation —  highlights some of the biggest knowledge gaps we still need to address in order to confidently answer that question.

A couple of the largest questions needing answers: what is in this wastewater and could it be toxic?

The oil and gas industry’s wastewater contains a vast assortment of chemicals – including constituents that are pumped into a well, chemicals already present in the fossil fuel formation, and constituents that are formed when these chemicals mix. There is not a true count of how many chemicals may be in the water (another huge question to be answered), but a review of the national chemical disclosure database FracFocus and other literature identifies more than 1,600 different chemicals potentially present.

Some advocates for beneficial reuse argue we know enough to safely treat and use the wastewater for crop irrigation. But the unfortunate reality is that our current scientific methods can only detect about a quarter of those 1,600 chemicals. And we know even less about how toxic they may be – critical toxicity information is available for less than 20% of these chemicals.

Even of the small group of chemicals in which detection methods do exist – they don’t always work. Oil and gas wastewater is extremely salty, in some cases 10 times saltier than the ocean, and testing technologies don’t always perform in such high salt content. Meaning we don’t even know how to adequately detect potentially toxic chemicals.

This kick starts a chain reaction of other unknowns. Without accurate testing, we can’t know what chemicals we could be exposed to or how toxic those chemicals might be, which means we can’t be sure that current treatment processes are effective or regulatory programs adequately protective.

Even in California where the practice of using treated oil and gas wastewater for irrigating crops has been done for years, this practice is being looked at more closely. Last year The Central Regional Water Quality Control Board convened a panel of experts  to  examine the potential adverse impacts of beneficial reuse.  The panel’s work is still ongoing, but a report authored by some of the panelists raised a number of viable concerns.

EDF is leading a number of efforts to expand the needed science. Last year we held a series of workshops with experts from across the country to assess how we can use existing technologies and tools to help narrow some of these knowledge gaps, and as a result have spurred a number of new research projects, including some we are leading to improve current wastewater testing methods.

We’re making progress, but we still have a way to go. Before policy makers start green-lighting an increase in beneficial reuse, we need to honestly acknowledge what is known, what is not,  what is of concern, and give science time to provide some answers.

The engineers and scientists who study the oil and gas industry’s wastewater know the term “beneficial reuse” well. It’s the seldom-used technique of taking wastewater produced from an oil or gas well, treating it, and then using it for other purposes — like watering crops (including organic crops) or feeding livestock.  It’s a rare practice […]

The post Scientists Question Risks of Using Oilfield Wastewater on Food Crops appeared first on Energy Exchange.

By Dan Mueller

The engineers and scientists who study the oil and gas industry’s wastewater know the term “beneficial reuse” well. It’s the seldom-used technique of taking wastewater produced from an oil or gas well, treating it, and then using it for other purposes — like watering crops (including organic crops) or feeding livestock.  It’s a rare practice that drought-stricken areas like California have used for a number of years, although little is known about associated health or safety risks since, usually, about 98% of wastewater is injected into disposal wells deep underground. However, as demands for water increase, and concerns about disposal wells (which have been linked to earthquakes) rise, beneficial reuse is being considered as a viable option.

But just because we can use wastewater for other purposes – does that mean we should?

Scientists researching these issues still have a lot of questions. Our recent article in World Water: Water Reuse & Desalination—a publication of the Water Environment Federation —  highlights some of the biggest knowledge gaps we still need to address in order to confidently answer that question.

A couple of the largest questions needing answers: what is in this wastewater and could it be toxic?

The oil and gas industry’s wastewater contains a vast assortment of chemicals – including constituents that are pumped into a well, chemicals already present in the fossil fuel formation, and constituents that are formed when these chemicals mix. There is not a true count of how many chemicals may be in the water (another huge question to be answered), but a review of the national chemical disclosure database FracFocus and other literature identifies more than 1,600 different chemicals potentially present.

Some advocates for beneficial reuse argue we know enough to safely treat and use the wastewater for crop irrigation. But the unfortunate reality is that our current scientific methods can only detect about a quarter of those 1,600 chemicals. And we know even less about how toxic they may be – critical toxicity information is available for less than 20% of these chemicals.

Even of the small group of chemicals in which detection methods do exist – they don’t always work. Oil and gas wastewater is extremely salty, in some cases 10 times saltier than the ocean, and testing technologies don’t always perform in such high salt content. Meaning we don’t even know how to adequately detect potentially toxic chemicals.

This kick starts a chain reaction of other unknowns. Without accurate testing, we can’t know what chemicals we could be exposed to or how toxic those chemicals might be, which means we can’t be sure that current treatment processes are effective or regulatory programs adequately protective.

Even in California where the practice of using treated oil and gas wastewater for irrigating crops has been done for years, this practice is being looked at more closely. Last year The Central Regional Water Quality Control Board convened a panel of experts  to  examine the potential adverse impacts of beneficial reuse.  The panel’s work is still ongoing, but a report authored by some of the panelists raised a number of viable concerns.

EDF is leading a number of efforts to expand the needed science. Last year we held a series of workshops with experts from across the country to assess how we can use existing technologies and tools to help narrow some of these knowledge gaps, and as a result have spurred a number of new research projects, including some we are leading to improve current wastewater testing methods.

We’re making progress, but we still have a way to go. Before policy makers start green-lighting an increase in beneficial reuse, we need to honestly acknowledge what is known, what is not,  what is of concern, and give science time to provide some answers.

By Tom Murray

Prosperity. We all want to attain it, yet the ways we each define it are as different as we are.

As President Trump charges through his first 100 days, there is a risky theme being pushed that a prosperous America comes with a choice between environmental protection and economic growth.

This concept is not only false, but dangerous and short sighted.

Just look at China. When I was there last year, I saw a country that, during its own industrial revolution, made decisions that had unfortunately sacrificed the environment for a short-term surge in economic prosperity. Those tradeoffs were made during a time when coal and oil provided over 90% of energy consumption, and as a result, air quality reached unhealthy standards. Now China, the world’s fastest-growing economy (IMF), is sprinting to play catch-up. In 2015, in fact, China invested $102.9 billion in renewables, making it the world’s largest investor in clean energy (the US, by contrast, invested $44.1 billion that same year). (IEEFA.org, 2017)  Earlier this year, as the Trump Administration ceded U.S. leadership, China continued to step up with a new commitment to invest over $350 billion in renewable power generation.

This concept is not only false, but dangerous and short sighted.

So I reject the idea that people have to choose between a thriving economy and clean air and water. Or that we need to choose prosperity in the short-term, but an unstable and unhealthy climate in the long-term. We should not be forced into believing false choices. Instead, we demand and deserve a healthy future where both the economy and the environment can prosper.

Environmental protection and prosperity are not at odds, says @EDFbiz @tpmurray…
Click To Tweet

Protecting the environment is being positioned by President Trump as something that stifles U.S. businesses with over-regulation. And while not all regulation is perfect, sometimes policy is necessary to round out the sharp edges of capitalism. We must ensure that we’re not just eradicating environmental regulation, but instead making informed improvements with both business and the environment in mind. Just look at California as a case in point. The state’s clean energy standards for cars, buildings and electric utilities are some of the strictest in the U.S., yet California’s jobs and overall economy continue to grow steadily.

And on a national scale, a new report from Environmental Defense Fund shows that our best line to job creation lies in the sustainability and clean energy market. Addressing climate change isn’t hampering growth, it’s driving it. Sustainability now collectively represents an estimated 4-4.5 million jobs in the U.S.  The solar industry alone is currently growing at a rate 12 times faster than the rest of the U.S. economy. Clean energy and sustainability is feeding a burgeoning pipeline of well-paying jobs across all 50 states. Jobs that cannot be outsourced I might add.

The Republican’s choice for Secretary of Energy, oil industry ally Rick Perry, said during his confirmation hearing, “the question is how we address (climate change) in a thoughtful way that doesn’t compromise economic growth.”  It’s a good question, and one that must be very thoughtfully considered by Mr. Perry. When it comes to the environment and public health, we cannot repeal safeguards without devising safer, smarter replacements that diminish economic burdens while maintaining, or even increasing, protection. We need to envision prosperity through a lens where both the environment and the economy can thrive.

Our path to prosperity must be driven by long-term economics, not short-term politics.

Rolling back environmental safeguards, pausing innovation on fuel efficiency and clean energy, and reigniting a U.S. reliance on coal and oil is short-term thinking that puts us on a dangerous path.

Business prosperity in the long-term relies on resource availability. By 2050 the world will be home to 9.5 billion consumers, all looking toward business to provide the products and services they need. This consumption drives our economy—but puts a massive burden on our planet’s resources.

This is why Google, Microsoft, Nike, Nestlé, Walmart and many others are committed to sourcing 100% of their electricity from renewable energy. This is why PepsiCo is focused on improving water use efficiency, reducing food waste and eliminating emissions from its supply chain as part of its 2025 goals. And despite the threat of environmental rollbacks and noise about pulling out of the Paris Climate Agreement, 1000 companies and investors have signed on to the Business Backs Low-Carbon USA statement, which reiterated support and intent to implement the historic Agreement to address climate change. Not because regulation demands this, but because long term prosperity requires it.

If America is to continue our longstanding tradition and commitment of leaving a better future the next generation, we must continue making decisions that align economic prosperity with environmental protection and human health. This, to me, is the most important test of business leadership.  It’s time for committed sustainability leaders to live those values, speak truth to power, and move the dialog beyond transactional, and short term campaign promises to long-term health for the economy and the planet.

By Tom Murray

Prosperity. We all want to attain it, yet the ways we each define it are as different as we are.

As President Trump charges through his first 100 days, there is a risky theme being pushed that a prosperous America comes with a choice between environmental protection and economic growth.

This concept is not only false, but dangerous and short sighted.

Just look at China. When I was there last year, I saw a country that, during its own industrial revolution, made decisions that had unfortunately sacrificed the environment for a short-term surge in economic prosperity. Those tradeoffs were made during a time when coal and oil provided over 90% of energy consumption, and as a result, air quality reached unhealthy standards. Now China, the world’s fastest-growing economy (IMF), is sprinting to play catch-up. In 2015, in fact, China invested $102.9 billion in renewables, making it the world’s largest investor in clean energy (the US, by contrast, invested $44.1 billion that same year). (IEEFA.org, 2017)  Earlier this year, as the Trump Administration ceded U.S. leadership, China continued to step up with a new commitment to invest over $350 billion in renewable power generation.

This concept is not only false, but dangerous and short sighted.

So I reject the idea that people have to choose between a thriving economy and clean air and water. Or that we need to choose prosperity in the short-term, but an unstable and unhealthy climate in the long-term. We should not be forced into believing false choices. Instead, we demand and deserve a healthy future where both the economy and the environment can prosper.

Environmental protection and prosperity are not at odds, says @EDFbiz @tpmurray…
Click To Tweet

Protecting the environment is being positioned by President Trump as something that stifles U.S. businesses with over-regulation. And while not all regulation is perfect, sometimes policy is necessary to round out the sharp edges of capitalism. We must ensure that we’re not just eradicating environmental regulation, but instead making informed improvements with both business and the environment in mind. Just look at California as a case in point. The state’s clean energy standards for cars, buildings and electric utilities are some of the strictest in the U.S., yet California’s jobs and overall economy continue to grow steadily.

And on a national scale, a new report from Environmental Defense Fund shows that our best line to job creation lies in the sustainability and clean energy market. Addressing climate change isn’t hampering growth, it’s driving it. Sustainability now collectively represents an estimated 4-4.5 million jobs in the U.S.  The solar industry alone is currently growing at a rate 12 times faster than the rest of the U.S. economy. Clean energy and sustainability is feeding a burgeoning pipeline of well-paying jobs across all 50 states. Jobs that cannot be outsourced I might add.

The Republican’s choice for Secretary of Energy, oil industry ally Rick Perry, said during his confirmation hearing, “the question is how we address (climate change) in a thoughtful way that doesn’t compromise economic growth.”  It’s a good question, and one that must be very thoughtfully considered by Mr. Perry. When it comes to the environment and public health, we cannot repeal safeguards without devising safer, smarter replacements that diminish economic burdens while maintaining, or even increasing, protection. We need to envision prosperity through a lens where both the environment and the economy can thrive.

Our path to prosperity must be driven by long-term economics, not short-term politics.

Rolling back environmental safeguards, pausing innovation on fuel efficiency and clean energy, and reigniting a U.S. reliance on coal and oil is short-term thinking that puts us on a dangerous path.

Business prosperity in the long-term relies on resource availability. By 2050 the world will be home to 9.5 billion consumers, all looking toward business to provide the products and services they need. This consumption drives our economy—but puts a massive burden on our planet’s resources.

This is why Google, Microsoft, Nike, Nestlé, Walmart and many others are committed to sourcing 100% of their electricity from renewable energy. This is why PepsiCo is focused on improving water use efficiency, reducing food waste and eliminating emissions from its supply chain as part of its 2025 goals. And despite the threat of environmental rollbacks and noise about pulling out of the Paris Climate Agreement, 1000 companies and investors have signed on to the Business Backs Low-Carbon USA statement, which reiterated support and intent to implement the historic Agreement to address climate change. Not because regulation demands this, but because long term prosperity requires it.

If America is to continue our longstanding tradition and commitment of leaving a better future the next generation, we must continue making decisions that align economic prosperity with environmental protection and human health. This, to me, is the most important test of business leadership.  It’s time for committed sustainability leaders to live those values, speak truth to power, and move the dialog beyond transactional, and short term campaign promises to long-term health for the economy and the planet.

By Richard Denison

Richard Denison, Ph.D., is a Lead Senior Scientist.  Lindsay McCormick is a Project Manager.  Jennifer McPartland, Ph.D., is a Senior Scientist.

Environmental Defense Fund (EDF) filed extensive comments yesterday on the Environmental Protection Agency’s (EPA) proposals for the two most central “framework” rules mandated by last year’s Lautenberg Act amendments to the Toxic Substances Control Act (TSCA).

Our comments address these proposed rules:

• TSCA Procedures for Prioritization of Chemicals for Risk Evaluation, the rule that sets up the process EPA will use to identify high-priority chemicals for risk evaluation and low-priority chemicals that do not require risk evaluation.
• TSCA Procedures for Chemical Risk Evaluation, the rule that sets up the process EPA will use to conduct risk evaluations on high-priority chemicals and make risk determinations as to whether or not the chemicals present unreasonable risk to human health or the environment

Both sets of comments address many different provisions of the proposed rules.  EDF indicated our strong support for many aspects of the proposals, but urged changes to a number of provisions that we cannot support as proposed.  In addition, we identified provisions we believe need to be added to EPA’s rules to be consistent with or meet the requirements of the Lautenberg Act.

EDF emphasized how vital it is for EPA to meet its June 22, 2017, statutory deadline for promulgating these rules.  Because they establish processes that will require several years to begin to yield decisions on specific chemicals, delays in promulgating them in final form so that the processes can commence in the timeframe Congress intended will only serve to undermine public confidence in the new law, counter business interests to restore confidence in the chemicals marketplace, and hamper EPA’s ability to carry out its new mandates.  This is especially the case, given EPA’s appropriate recognition in both proposed rules that it will need to initiate measures as soon as possible to ensure that sufficient information will be available to inform prioritization and risk evaluation decisions.

As discussed in more detail in the comments, EDF strongly supports EPA’s decision not to codify specific scientific policies, procedures and guidance in these rules.  To do so would not be consistent with the law and would more generally represent bad policy.  EDF also agreed with EPA’s proposal not to define in its rules complex, science policy-laden terms such as “weight of the scientific evidence,” “best available science,” and “unreasonable risk.”  These concepts are best elaborated on in guidance and policy statements and best understood in the context of specific decisions on chemical substances.

Some other highlights from each set of EDF’s comments follow.  

Prioritization:

EPA appropriately proposes a rule that:

• is procedural in nature and avoids specifying science policy issues that are better addressed in guidance and policy statements;
• provides the right level of detail on the prioritization process and does not propose an exact scoring or ranking process;
• includes a “pre-prioritization” stage to gather needed data and meet the statutory requirements of the Lautenberg Act, which EDF urges the agency to keep simple and informal;
• makes clear that chemical substances, not specific uses or subsets of uses, are to be prioritized; and
• sets a higher bar for low-priority than for high-priority designations

EDF raised concerns about several other aspects:

• EPA’s proposal to “cut off” comments on proposed low-priority designations after the public comment period, which requires several conditions to be acceptable;
• EPA’s proposal to consider substitutes in the pre-prioritization process;
• insufficient incorporation of measures to ensure public access to information EPA uses to make prioritization decisions, including Lautenberg Act requirements governing industry confidential business information (CBI) claims;
• the need to make full studies on which EPA bases prioritization decisions publicly accessible; and
• the need to incorporate the definition of “potentially exposed or susceptible subpopulations” from the statute, with the refinements EPA has made to it in its proposed risk evaluation rule.

Risk Evaluation

EPA appropriately proposes a rule that:

• is procedural in nature and avoids specifying science policy issues or defining related terms that are better addressed in guidance and policy statements;
• establishes a risk evaluation process that is compatible with reasonably available information and applicable deadlines;
• provides EPA with means by which to collect and require the development of information early and often in the “pipeline” of prioritization and risk evaluation;
• makes clear that chemical substances, not specific uses or subsets of uses, are to be subject to risk evaluations and risk determinations; and
• balances the need to consider all conditions of use of a chemical with the ability to:
  • apply different levels of analysis to different conditions of use; and
  • expedite particular conditions of use that clearly present unreasonable risk in order to expedite needed risk management;
• requires that a manufacturer requesting a risk evaluation must demonstrate there is sufficient information available for EPA to complete the risk evaluation for all conditions of use; and
• makes clear that risk determinations are policy decisions not subject to peer review.

However, EDF also raised concerns with or called for changes in several aspects of EPA’s proposal, including the need to:

• more clearly assert and utilize its authorities under amended TSCA to collect and require development of information needed to inform risk evaluations;
• establish a firm opportunity for public comment on risk evaluation scopes, and to provide more time for public comment on draft risk evaluations;
• add several conditions to its proposals that any issues not raised during public comment periods on risk evaluation scopes and draft risk evaluations could not be the basis for later objection or challenge, and close a loophole that would allow industry to get around this limitation;
• broaden the applicability of the provisions that implement Lautenberg Act requirements governing industry confidential business information (CBI) claims;
• clarify that EPA’s authority to revisit a risk determination only applies after final agency action based on the determination;
• delineate requirements for EPA consideration of third-party risk evaluations;
• clarify opportunities for public comment on industry requests for risk evaluations and EPA decisions on those requests;
• require that full studies on which EPA or third parties rely in risk evaluations be publicly accessible;
• in applying or updating guidance used to conduct risk evaluations (which should not be codified in this rule):
  • generally employ an aggregate approach to exposure assessment;
  • further integrate systematic review;
  • move away from EPA’s traditional margin-of-exposure approach for noncancer endpoints, as recommended by the National Academy of Sciences; and
  • avoid assigning greater weight to guideline studies over the peer-reviewed literature.

 

By Richard Denison

Richard Denison, Ph.D., is a Lead Senior Scientist.  Lindsay McCormick is a Project Manager.  Jennifer McPartland, Ph.D., is a Senior Scientist.

Environmental Defense Fund (EDF) filed extensive comments yesterday on the Environmental Protection Agency’s (EPA) proposals for the two most central “framework” rules mandated by last year’s Lautenberg Act amendments to the Toxic Substances Control Act (TSCA).

Our comments address these proposed rules:

• TSCA Procedures for Prioritization of Chemicals for Risk Evaluation, the rule that sets up the process EPA will use to identify high-priority chemicals for risk evaluation and low-priority chemicals that do not require risk evaluation.
• TSCA Procedures for Chemical Risk Evaluation, the rule that sets up the process EPA will use to conduct risk evaluations on high-priority chemicals and make risk determinations as to whether or not the chemicals present unreasonable risk to human health or the environment

Both sets of comments address many different provisions of the proposed rules.  EDF indicated our strong support for many aspects of the proposals, but urged changes to a number of provisions that we cannot support as proposed.  In addition, we identified provisions we believe need to be added to EPA’s rules to be consistent with or meet the requirements of the Lautenberg Act.

EDF emphasized how vital it is for EPA to meet its June 22, 2017, statutory deadline for promulgating these rules.  Because they establish processes that will require several years to begin to yield decisions on specific chemicals, delays in promulgating them in final form so that the processes can commence in the timeframe Congress intended will only serve to undermine public confidence in the new law, counter business interests to restore confidence in the chemicals marketplace, and hamper EPA’s ability to carry out its new mandates.  This is especially the case, given EPA’s appropriate recognition in both proposed rules that it will need to initiate measures as soon as possible to ensure that sufficient information will be available to inform prioritization and risk evaluation decisions.

As discussed in more detail in the comments, EDF strongly supports EPA’s decision not to codify specific scientific policies, procedures and guidance in these rules.  To do so would not be consistent with the law and would more generally represent bad policy.  EDF also agreed with EPA’s proposal not to define in its rules complex, science policy-laden terms such as “weight of the scientific evidence,” “best available science,” and “unreasonable risk.”  These concepts are best elaborated on in guidance and policy statements and best understood in the context of specific decisions on chemical substances.

Some other highlights from each set of EDF’s comments follow.  

Prioritization:

EPA appropriately proposes a rule that:

• is procedural in nature and avoids specifying science policy issues that are better addressed in guidance and policy statements;
• provides the right level of detail on the prioritization process and does not propose an exact scoring or ranking process;
• includes a “pre-prioritization” stage to gather needed data and meet the statutory requirements of the Lautenberg Act, which EDF urges the agency to keep simple and informal;
• makes clear that chemical substances, not specific uses or subsets of uses, are to be prioritized; and
• sets a higher bar for low-priority than for high-priority designations

EDF raised concerns about several other aspects:

• EPA’s proposal to “cut off” comments on proposed low-priority designations after the public comment period, which requires several conditions to be acceptable;
• EPA’s proposal to consider substitutes in the pre-prioritization process;
• insufficient incorporation of measures to ensure public access to information EPA uses to make prioritization decisions, including Lautenberg Act requirements governing industry confidential business information (CBI) claims;
• the need to make full studies on which EPA bases prioritization decisions publicly accessible; and
• the need to incorporate the definition of “potentially exposed or susceptible subpopulations” from the statute, with the refinements EPA has made to it in its proposed risk evaluation rule.

Risk Evaluation

EPA appropriately proposes a rule that:

• is procedural in nature and avoids specifying science policy issues or defining related terms that are better addressed in guidance and policy statements;
• establishes a risk evaluation process that is compatible with reasonably available information and applicable deadlines;
• provides EPA with means by which to collect and require the development of information early and often in the “pipeline” of prioritization and risk evaluation;
• makes clear that chemical substances, not specific uses or subsets of uses, are to be subject to risk evaluations and risk determinations; and
• balances the need to consider all conditions of use of a chemical with the ability to:
  • apply different levels of analysis to different conditions of use; and
  • expedite particular conditions of use that clearly present unreasonable risk in order to expedite needed risk management;
• requires that a manufacturer requesting a risk evaluation must demonstrate there is sufficient information available for EPA to complete the risk evaluation for all conditions of use; and
• makes clear that risk determinations are policy decisions not subject to peer review.

However, EDF also raised concerns with or called for changes in several aspects of EPA’s proposal, including the need to:

• more clearly assert and utilize its authorities under amended TSCA to collect and require development of information needed to inform risk evaluations;
• establish a firm opportunity for public comment on risk evaluation scopes, and to provide more time for public comment on draft risk evaluations;
• add several conditions to its proposals that any issues not raised during public comment periods on risk evaluation scopes and draft risk evaluations could not be the basis for later objection or challenge, and close a loophole that would allow industry to get around this limitation;
• broaden the applicability of the provisions that implement Lautenberg Act requirements governing industry confidential business information (CBI) claims;
• clarify that EPA’s authority to revisit a risk determination only applies after final agency action based on the determination;
• delineate requirements for EPA consideration of third-party risk evaluations;
• clarify opportunities for public comment on industry requests for risk evaluations and EPA decisions on those requests;
• require that full studies on which EPA or third parties rely in risk evaluations be publicly accessible;
• in applying or updating guidance used to conduct risk evaluations (which should not be codified in this rule):
  • generally employ an aggregate approach to exposure assessment;
  • further integrate systematic review;
  • move away from EPA’s traditional margin-of-exposure approach for noncancer endpoints, as recommended by the National Academy of Sciences; and
  • avoid assigning greater weight to guideline studies over the peer-reviewed literature.

 

By Richard Denison

Richard Denison, Ph.D., is a Lead Senior Scientist.  Lindsay McCormick is a Project Manager.  Jennifer McPartland, Ph.D., is a Senior Scientist.

Environmental Defense Fund (EDF) filed extensive comments yesterday on the Environmental Protection Agency’s (EPA) proposals for the two most central “framework” rules mandated by last year’s Lautenberg Act amendments to the Toxic Substances Control Act (TSCA).

Our comments address these proposed rules:

• TSCA Procedures for Prioritization of Chemicals for Risk Evaluation, the rule that sets up the process EPA will use to identify high-priority chemicals for risk evaluation and low-priority chemicals that do not require risk evaluation.
• TSCA Procedures for Chemical Risk Evaluation, the rule that sets up the process EPA will use to conduct risk evaluations on high-priority chemicals and make risk determinations as to whether or not the chemicals present unreasonable risk to human health or the environment

Both sets of comments address many different provisions of the proposed rules.  EDF indicated our strong support for many aspects of the proposals, but urged changes to a number of provisions that we cannot support as proposed.  In addition, we identified provisions we believe need to be added to EPA’s rules to be consistent with or meet the requirements of the Lautenberg Act.

EDF emphasized how vital it is for EPA to meet its June 22, 2017, statutory deadline for promulgating these rules.  Because they establish processes that will require several years to begin to yield decisions on specific chemicals, delays in promulgating them in final form so that the processes can commence in the timeframe Congress intended will only serve to undermine public confidence in the new law, counter business interests to restore confidence in the chemicals marketplace, and hamper EPA’s ability to carry out its new mandates.  This is especially the case, given EPA’s appropriate recognition in both proposed rules that it will need to initiate measures as soon as possible to ensure that sufficient information will be available to inform prioritization and risk evaluation decisions.

As discussed in more detail in the comments, EDF strongly supports EPA’s decision not to codify specific scientific policies, procedures and guidance in these rules.  To do so would not be consistent with the law and would more generally represent bad policy.  EDF also agreed with EPA’s proposal not to define in its rules complex, science policy-laden terms such as “weight of the scientific evidence,” “best available science,” and “unreasonable risk.”  These concepts are best elaborated on in guidance and policy statements and best understood in the context of specific decisions on chemical substances.

Some other highlights from each set of EDF’s comments follow.  

Prioritization:

EPA appropriately proposes a rule that:

• is procedural in nature and avoids specifying science policy issues that are better addressed in guidance and policy statements;
• provides the right level of detail on the prioritization process and does not propose an exact scoring or ranking process;
• includes a “pre-prioritization” stage to gather needed data and meet the statutory requirements of the Lautenberg Act, which EDF urges the agency to keep simple and informal;
• makes clear that chemical substances, not specific uses or subsets of uses, are to be prioritized; and
• sets a higher bar for low-priority than for high-priority designations

EDF raised concerns about several other aspects:

• EPA’s proposal to “cut off” comments on proposed low-priority designations after the public comment period, which requires several conditions to be acceptable;
• EPA’s proposal to consider substitutes in the pre-prioritization process;
• insufficient incorporation of measures to ensure public access to information EPA uses to make prioritization decisions, including Lautenberg Act requirements governing industry confidential business information (CBI) claims;
• the need to make full studies on which EPA bases prioritization decisions publicly accessible; and
• the need to incorporate the definition of “potentially exposed or susceptible subpopulations” from the statute, with the refinements EPA has made to it in its proposed risk evaluation rule.

Risk Evaluation

EPA appropriately proposes a rule that:

• is procedural in nature and avoids specifying science policy issues or defining related terms that are better addressed in guidance and policy statements;
• establishes a risk evaluation process that is compatible with reasonably available information and applicable deadlines;
• provides EPA with means by which to collect and require the development of information early and often in the “pipeline” of prioritization and risk evaluation;
• makes clear that chemical substances, not specific uses or subsets of uses, are to be subject to risk evaluations and risk determinations; and
• balances the need to consider all conditions of use of a chemical with the ability to:
  • apply different levels of analysis to different conditions of use; and
  • expedite particular conditions of use that clearly present unreasonable risk in order to expedite needed risk management;
• requires that a manufacturer requesting a risk evaluation must demonstrate there is sufficient information available for EPA to complete the risk evaluation for all conditions of use; and
• makes clear that risk determinations are policy decisions not subject to peer review.

However, EDF also raised concerns with or called for changes in several aspects of EPA’s proposal, including the need to:

• more clearly assert and utilize its authorities under amended TSCA to collect and require development of information needed to inform risk evaluations;
• establish a firm opportunity for public comment on risk evaluation scopes, and to provide more time for public comment on draft risk evaluations;
• add several conditions to its proposals that any issues not raised during public comment periods on risk evaluation scopes and draft risk evaluations could not be the basis for later objection or challenge, and close a loophole that would allow industry to get around this limitation;
• broaden the applicability of the provisions that implement Lautenberg Act requirements governing industry confidential business information (CBI) claims;
• clarify that EPA’s authority to revisit a risk determination only applies after final agency action based on the determination;
• delineate requirements for EPA consideration of third-party risk evaluations;
• clarify opportunities for public comment on industry requests for risk evaluations and EPA decisions on those requests;
• require that full studies on which EPA or third parties rely in risk evaluations be publicly accessible;
• in applying or updating guidance used to conduct risk evaluations (which should not be codified in this rule):
  • generally employ an aggregate approach to exposure assessment;
  • further integrate systematic review;
  • move away from EPA’s traditional margin-of-exposure approach for noncancer endpoints, as recommended by the National Academy of Sciences; and
  • avoid assigning greater weight to guideline studies over the peer-reviewed literature.