Getting the framework right for the new TSCA: EDF comments filed on key EPA proposed rules

7 years 6 months ago

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:

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.

 

Richard Denison

Farmers and environmentalists want the same thing

7 years 6 months ago

I’m spending time on this year’s National Ag Day thinking back gratefully to a recent meeting I had with farmers. I was attending the annual farm exchange program offered through the California Agricultural Leadership Foundation, which facilitates learning opportunities on California farms. This year’s program brought together state environmental policy professionals and growers from the Central […]

The post Farmers and environmentalists want the same thing first appeared on Growing Returns.
Rebecca Haynes

Farmers and environmentalists want the same thing

7 years 6 months ago

By Rebecca Haynes

I’m spending time on this year’s National Ag Day thinking back gratefully to a recent meeting I had with farmers.

I was attending the annual farm exchange program offered through the California Agricultural Leadership Foundation, which facilitates learning opportunities on California farms. This year’s program brought together state environmental policy professionals and growers from the Central Coast, an epicenter for growing the nation’s specialty crops, such as lettuce, broccoli, and strawberries. My aim was “to see sustainability through the eyes of farmers.” We toured various agricultural operations, had thoughtful discussions, and stayed with host families in the local farm community.

My host was Erin Amaral, who manages 1,170 acres of vineyards near San Luis Obispo. Erin and I got along immediately – and our conversations kept coming back to one central tenet: farmers and environmentalists want the same things.

Farmers and environmentalists want the same thing, via @rebeccalhaynes…
Click To Tweet

Shared interests

Erin told me about growing up on her father’s Central Valley almond orchard and how she developed an interest in sustainable farming during college. I too became interested in agriculture’s potential to protect the environment during college. We both carried that interest over into our careers – and during my stay, we shared a profound appreciation for the beauty of the vineyard landscape.

Erin strives to make her vineyard as sustainable as possible. A specialist in pest control, she and her colleagues at Pacific Vineyard pioneered a sustainable way to lower the population of mealybugs, a particularly noxious pest that transmits plant viruses, in their vineyards. Over time, this innovative solution allowed them to completely eliminate the use of high risk pesticides with toxic ingredients. They’ve also reduced their use of herbicides by implementing vine tillage, a process that destroys weeds with blades rather than chemicals.

Erin and her colleagues are careful stewards of their natural resources, conserving water and planting cover crops to prevent soil erosion.

Shared agendas

Public perception tends to pit environmentalists and farmers against each other. But over the four days of this meeting, no disagreements took place. Instead of creating conflict, we formed friendships.

At EDF, I work on creating protocols and market mechanisms to reward growers who implement sustainable agricultural practices, such as preserving grasslands and applying fertilizer more efficiently. These methods allow growers to create carbon offsets that can be sold into carbon markets. My colleagues and I are also working to scale up private investments into agricultural carbon offset projects, in part to guarantee payments for growers that implement these practices. Erin agreed with me on the importance of creating secure, low-risk financial incentives to scale up sustainable practices on farmlands.

We all want healthy food produced in ways that preserve land and natural resources. We all want farms to preserve the quality of their soil so that they can generate high crop yields for generations into the future. We all want to keep pollutants out of waterways and out of the air. Loving the land and loving the earth are the same.

Related:

There's good reason to end the agriculture versus the environment fight >>

Farmers' voices are essential to figuring out sustainability. Let's listen up. >>

Impact investors eye bigger allocations to sustainable agriculture >>

Rebecca Haynes

Farmers and environmentalists want the same thing

7 years 6 months ago

By Rebecca Haynes

I’m spending time on this year’s National Ag Day thinking back gratefully to a recent meeting I had with farmers.

I was attending the annual farm exchange program offered through the California Agricultural Leadership Foundation, which facilitates learning opportunities on California farms. This year’s program brought together state environmental policy professionals and growers from the Central Coast, an epicenter for growing the nation’s specialty crops, such as lettuce, broccoli, and strawberries. My aim was “to see sustainability through the eyes of farmers.” We toured various agricultural operations, had thoughtful discussions, and stayed with host families in the local farm community.

My host was Erin Amaral, who manages 1,170 acres of vineyards near San Luis Obispo. Erin and I got along immediately – and our conversations kept coming back to one central tenet: farmers and environmentalists want the same things.

Farmers and environmentalists want the same thing, via @rebeccalhaynes…
Click To Tweet

Shared interests

Erin told me about growing up on her father’s Central Valley almond orchard and how she developed an interest in sustainable farming during college. I too became interested in agriculture’s potential to protect the environment during college. We both carried that interest over into our careers – and during my stay, we shared a profound appreciation for the beauty of the vineyard landscape.

Erin strives to make her vineyard as sustainable as possible. A specialist in pest control, she and her colleagues at Pacific Vineyard pioneered a sustainable way to lower the population of mealybugs, a particularly noxious pest that transmits plant viruses, in their vineyards. Over time, this innovative solution allowed them to completely eliminate the use of high risk pesticides with toxic ingredients. They’ve also reduced their use of herbicides by implementing vine tillage, a process that destroys weeds with blades rather than chemicals.

Erin and her colleagues are careful stewards of their natural resources, conserving water and planting cover crops to prevent soil erosion.

Shared agendas

Public perception tends to pit environmentalists and farmers against each other. But over the four days of this meeting, no disagreements took place. Instead of creating conflict, we formed friendships.

At EDF, I work on creating protocols and market mechanisms to reward growers who implement sustainable agricultural practices, such as preserving grasslands and applying fertilizer more efficiently. These methods allow growers to create carbon offsets that can be sold into carbon markets. My colleagues and I are also working to scale up private investments into agricultural carbon offset projects, in part to guarantee payments for growers that implement these practices. Erin agreed with me on the importance of creating secure, low-risk financial incentives to scale up sustainable practices on farmlands.

We all want healthy food produced in ways that preserve land and natural resources. We all want farms to preserve the quality of their soil so that they can generate high crop yields for generations into the future. We all want to keep pollutants out of waterways and out of the air. Loving the land and loving the earth are the same.

Related:

There's good reason to end the agriculture versus the environment fight >>

Farmers' voices are essential to figuring out sustainability. Let's listen up. >>

Impact investors eye bigger allocations to sustainable agriculture >>

Rebecca Haynes

Barrier Islands: A Critical Restoration Project for People and Birds

7 years 6 months ago

Managing Barrier Islands to Maximize their Benefits to Birds Originally posted here in Audubon Louisiana News on March 20, 2017. Restoration of Louisiana barrier islands and shorelines is not only vital to the health of coastal Louisiana, but also to hundreds of thousands of nesting birds. Those that lay their eggs on the sand, called beach-nesting birds, are among the fastest group of declining birds in North America, and they rely on this critical habitat for survival. Over the last ...

Read The Full Story

The post Barrier Islands: A Critical Restoration Project for People and Birds appeared first on Restore the Mississippi River Delta.

efalgoust

Barrier Islands: A Critical Restoration Project for People and Birds

7 years 6 months ago

Managing Barrier Islands to Maximize their Benefits to Birds Originally posted here in Audubon Louisiana News on March 20, 2017. Restoration of Louisiana barrier islands and shorelines is not only vital to the health of coastal Louisiana, but also to hundreds of thousands of nesting birds. Those that lay their eggs on the sand, called beach-nesting birds, are among the fastest group of declining birds in North America, and they rely on this critical habitat for survival. Over the last ...

Read The Full Story

The post Barrier Islands: A Critical Restoration Project for People and Birds appeared first on Restore the Mississippi River Delta.

efalgoust

Barrier Islands: A Critical Restoration Project for People and Birds

7 years 6 months ago

Managing Barrier Islands to Maximize their Benefits to Birds Originally posted here in Audubon Louisiana News on March 20, 2017. Restoration of Louisiana barrier islands and shorelines is not only vital to the health of coastal Louisiana, but also to hundreds of thousands of nesting birds. Those that lay their eggs on the sand, called beach-nesting birds, are among the fastest group of declining birds in North America, and they rely on this critical habitat for survival. Over the last ...

Read The Full Story

The post Barrier Islands: A Critical Restoration Project for People and Birds appeared first on Restore the Mississippi River Delta.

efalgoust

From row crops to rainforests: how agriculture affects us all

7 years 6 months ago

By Katie Anderson

Happy Agriculture Day! Whether you have a special interest in agriculture or not, we’re guessing that—as a human being—you probably have an interest in food

But, on this Agriculture Day, we want to recognize and celebrate the farmers and ranchers while acknowledging the fact that we all play a part in the growing of food. In just a few decades, there will be two billion more people to feed on the planet. As a global community our challenge is to feed this growing population sustainably without depleting the soil, polluting our water and worsening global warming.

The statistics are eye opening. Global food production accounts for:

  • 33% of the world’s GHG emissions
  • 70% of the world’s water consumption
  • 80% of deforestation worldwide
  • 50% of global top soil loss

What’s behind these huge numbers? When we look deeper, the problem looks different depending upon which side of the equator you’re on. From row crops to rainforests, here’s a snapshot of what’s happening, both in terms of the problem and the solution:

Domestic Agriculture                         

When we think about how we will feed an additional 2 billion people, improving yields will be critical to meet demand. Fertilizer is an essential nutrient that will help to increase the yields we need. But with less than half of nutrients applied each season being actually absorbed by crops, the unused fertilizer is bad for the planet:

  • US food production accounts for 75% of nitrous oxide emissions and has contributed to the pollution of nearly 40% of US drinking water supply;
  • Excess fertilizer and pollution is washing off of farm fields and into water ways degrading coastal ecosystems and causing algae blooms.

At the same time, this also hurts farmers financially. Fertilizer represents their single biggest input cost, so when nearly $420 million in fertilizer washes off Midwestern farm fields and into the Gulf of Mexico every year, it’s tough to remain profitable.

Eating food has hidden costs: the power of partnership in reducing the impact of our food supply…
Click To Tweet

EDF’s work* with  Walmart, Smithfield Foods, Campbell’s Soup, Land O’ Lakes and other food companies is proving that efficient fertilizer use reduces supply chain emissions and saves money. It just needs to happen more: when food companies, retailers, and other supply chain actors send the demand for scientifically based and economically viable strategies for using fertilizer more efficiently, sustainable practices will expand and far less impact will be placed on the environment.

Agriculture and Deforestation

Agriculture is the largest single cause of deforestation. Everyday forest lands in Brazil and other tropical countries are burned down to grow crops or to create cattle pastures for beef production. The exploitation of the tropical forests for the big four agricultural commodities, palm oil, beef, soy, and pulp and paper, contributes significantly to climate change.

Deforestation accounts for about 15% of global carbon emissions annually. Hundreds of major consumer goods companies have committed to eliminating deforestation from their supply chains.

The challenge is twofold: how to increase agricultural production in these topical regions to support the livelihoods of local communities and growing global consumer needs, while fulfilling companies’ zero-deforestation commitments to reduce carbon emissions?

The solution lies in multi-stakeholder engagement. Brazil’s experience shows that collaboration between companies, government agencies and local communities within a region can successfully reduce deforestation while maintaining robust growth in production. The country successfully reduced Amazon deforestation by about 75% from 2005 to 2013.

Katie Anderson, Project Manager, EDF+Business

When executed properly, these jurisdictional approaches provide win-win-win opportunities. Companies have a new way to meet zero deforestation commitments in supply chains by sourcing from lower risk areas and reduce the risk that deforestation will spread to other suppliers. Governments have additional support to improve policies and productivity in their regions. Farmers have the needed incentives and assistance to increase sustainability and profitability on their lands.

Partnership is the key

So it’s clear: our food has costs beyond our wallets, in the form of greenhouse gases, water quality, water scarcity, biodiversity, and other important impacts that we don’t see each day when we sit down at the table.

But the good news is, there’s a lot of movement—or potential for movement— across the food supply chains, from retailers to growers to consumers, to promote sustainable practices on a multitude of food and agriculture issues.

Theresa Erhlich, Project Coordinator, Supply Chain

To tackle these costs, everyone along the food chain needs to realize that there is no free lunch (pun very much intended):

  • At EDF, we are working in collaboration with farmers, companies, governments, and other NGO’s to address these issues and reduce the impact of our food supply chains.
  • Companies (including: food companies, retailers and other supply chain actors) need to consistently send the demand signal to farmers that they want less deforestation and more efficient fertilizer use.
  • Consumers play an important role by sending our own demand signal for more sustainably produced food by thanking the companies leading the way in sustainability through shopping power.

So today take a moment think about where our food is comes from, and the hard work and energy that went into its approaches to feed people and protect our planet.

* EDF takes no money from our corporate partners—we are funded solely through grants, donations and membership. 

Katie Anderson

From row crops to rainforests: how agriculture affects us all

7 years 6 months ago

By Katie Anderson

Happy Agriculture Day! Whether you have a special interest in agriculture or not, we’re guessing that—as a human being—you probably have an interest in food

But, on this Agriculture Day, we want to recognize and celebrate the farmers and ranchers while acknowledging the fact that we all play a part in the growing of food. In just a few decades, there will be two billion more people to feed on the planet. As a global community our challenge is to feed this growing population sustainably without depleting the soil, polluting our water and worsening global warming.

The statistics are eye opening. Global food production accounts for:

  • 33% of the world’s GHG emissions
  • 70% of the world’s water consumption
  • 80% of deforestation worldwide
  • 50% of global top soil loss

What’s behind these huge numbers? When we look deeper, the problem looks different depending upon which side of the equator you’re on. From row crops to rainforests, here’s a snapshot of what’s happening, both in terms of the problem and the solution:

Domestic Agriculture                         

When we think about how we will feed an additional 2 billion people, improving yields will be critical to meet demand. Fertilizer is an essential nutrient that will help to increase the yields we need. But with less than half of nutrients applied each season being actually absorbed by crops, the unused fertilizer is bad for the planet:

  • US food production accounts for 75% of nitrous oxide emissions and has contributed to the pollution of nearly 40% of US drinking water supply;
  • Excess fertilizer and pollution is washing off of farm fields and into water ways degrading coastal ecosystems and causing algae blooms.

At the same time, this also hurts farmers financially. Fertilizer represents their single biggest input cost, so when nearly $420 million in fertilizer washes off Midwestern farm fields and into the Gulf of Mexico every year, it’s tough to remain profitable.

Eating food has hidden costs: the power of partnership in reducing the impact of our food supply…
Click To Tweet

EDF’s work* with  Walmart, Smithfield Foods, Campbell’s Soup, Land O’ Lakes and other food companies is proving that efficient fertilizer use reduces supply chain emissions and saves money. It just needs to happen more: when food companies, retailers, and other supply chain actors send the demand for scientifically based and economically viable strategies for using fertilizer more efficiently, sustainable practices will expand and far less impact will be placed on the environment.

Agriculture and Deforestation

Agriculture is the largest single cause of deforestation. Everyday forest lands in Brazil and other tropical countries are burned down to grow crops or to create cattle pastures for beef production. The exploitation of the tropical forests for the big four agricultural commodities, palm oil, beef, soy, and pulp and paper, contributes significantly to climate change.

Deforestation accounts for about 15% of global carbon emissions annually. Hundreds of major consumer goods companies have committed to eliminating deforestation from their supply chains.

The challenge is twofold: how to increase agricultural production in these topical regions to support the livelihoods of local communities and growing global consumer needs, while fulfilling companies’ zero-deforestation commitments to reduce carbon emissions?

The solution lies in multi-stakeholder engagement. Brazil’s experience shows that collaboration between companies, government agencies and local communities within a region can successfully reduce deforestation while maintaining robust growth in production. The country successfully reduced Amazon deforestation by about 75% from 2005 to 2013.

Katie Anderson, Project Manager, EDF+Business

When executed properly, these jurisdictional approaches provide win-win-win opportunities. Companies have a new way to meet zero deforestation commitments in supply chains by sourcing from lower risk areas and reduce the risk that deforestation will spread to other suppliers. Governments have additional support to improve policies and productivity in their regions. Farmers have the needed incentives and assistance to increase sustainability and profitability on their lands.

Partnership is the key

So it’s clear: our food has costs beyond our wallets, in the form of greenhouse gases, water quality, water scarcity, biodiversity, and other important impacts that we don’t see each day when we sit down at the table.

But the good news is, there’s a lot of movement—or potential for movement— across the food supply chains, from retailers to growers to consumers, to promote sustainable practices on a multitude of food and agriculture issues.

Theresa Erhlich, Project Coordinator, Supply Chain

To tackle these costs, everyone along the food chain needs to realize that there is no free lunch (pun very much intended):

  • At EDF, we are working in collaboration with farmers, companies, governments, and other NGO’s to address these issues and reduce the impact of our food supply chains.
  • Companies (including: food companies, retailers and other supply chain actors) need to consistently send the demand signal to farmers that they want less deforestation and more efficient fertilizer use.
  • Consumers play an important role by sending our own demand signal for more sustainably produced food by thanking the companies leading the way in sustainability through shopping power.

So today take a moment think about where our food is comes from, and the hard work and energy that went into its approaches to feed people and protect our planet.

* EDF takes no money from our corporate partners—we are funded solely through grants, donations and membership. 

Katie Anderson

Delta Dispatches Podcast March 16, 2017

7 years 6 months ago

Thanks for listening to the third episode of Delta Dispatchers with hosts Simone Maloz & Jacques Hebert. On today’s show Rudy Simoneaux and Brad Barth, from CPRA talk about sediment diversions and Rebecca Triche joins Simone to discuss the Louisiana Wildlife Federation and their upcoming event.  Below is a transcript of this week's Delta Dispatches Podcast. Listen to the full recording here or subscribe to our feed in iTunes and Google Play.     Listen to Episode 2 now! Show ...

Read The Full Story

The post Delta Dispatches Podcast March 16, 2017 appeared first on Restore the Mississippi River Delta.

rchauvin

Delta Dispatches Podcast March 16, 2017

7 years 6 months ago

Thanks for listening to the third episode of Delta Dispatchers with hosts Simone Maloz & Jacques Hebert. On today’s show Rudy Simoneaux and Brad Barth, from CPRA talk about sediment diversions and Rebecca Triche joins Simone to discuss the Louisiana Wildlife Federation and their upcoming event.  Below is a transcript of this week's Delta Dispatches Podcast. Listen to the full recording here or subscribe to our feed in iTunes and Google Play.     Listen to Episode 2 now! Show ...

Read The Full Story

The post Delta Dispatches Podcast March 16, 2017 appeared first on Restore the Mississippi River Delta.

rchauvin

Delta Dispatches Podcast March 16, 2017

7 years 6 months ago

Thanks for listening to the third episode of Delta Dispatchers with hosts Simone Maloz & Jacques Hebert. On today’s show Rudy Simoneaux and Brad Barth, from CPRA talk about sediment diversions and Rebecca Triche joins Simone to discuss the Louisiana Wildlife Federation and their upcoming event.  Below is a transcript of this week's Delta Dispatches Podcast. Listen to the full recording here or subscribe to our feed in iTunes and Google Play.     Listen to Episode 2 now! Show ...

Read The Full Story

The post Delta Dispatches Podcast March 16, 2017 appeared first on Restore the Mississippi River Delta.

rchauvin

The President’s EPA Budget Lacks Compassion for Seniors and Kids

7 years 6 months ago

Written by Moms Clean Air Force

This was written by Jeremy Symons. It originally posted on The Hill

When budget chief Mick Mulvaney defended President’s Trump proposal to end Meals on Wheels and other safety net programs as an act of “compassion,” he inadvertently did more to expose the callous attacks on America’s social safety net than he did to hide them. In too many areas, Trump’s budget puts ideology and special interests ahead of protecting the most vulnerable, particularly seniors and children. That is especially true with the radical cuts proposed for the budget of the Environmental Protection Agency (EPA), which would slash enforcement against polluters and make deep cuts in the agency’s work to protect public health.

In 2016, the American Heart Association warned that air pollutants from coal burning and from vehicle exhaust lead to high blood pressure — a major risk factor for heart disease and stroke. They advised that seniors and others with high blood pressure should carefully watch EPA’s air pollution monitoring system and limit their exposure on unhealthy air days.

Those air monitoring systems — and the Clean Air Act standards that are designed to reduce the number of “code red” unhealthy air days — are now under attack by President Trump’s proposed EPA budget cuts. His first year budget calls for a cut of 31 percent to the agency, a step toward the goal he has stated of virtually eliminating the agency altogether, leaving only “little tidbits” in place.

That’s bad news for seniors, children, and others vulnerable to asthma and other health illnesses triggered by air pollution. The EPA has been very successful at reducing pollution levels over the past 45 years, but the job of protecting the air we breathe and the water we drink is far from done. Today, up to 10 million homes still get their drinking water through lead pipes — in Flint, Michigan and across the nation. Half of all Americans live in counties with unhealthy air quality.

The man who will have to advise states and cities on how to manage Trump’s budget to axe to clean air programs is Bill Becker, executive director of the nonpartisan National Association of Clean Air Agencies. Becker told me that state and local officials responsible for clean air are “fearful” that proposed cuts will harm the public health, “particularly the elderly, the infirm, and children.”

According to leaked documents Becker has obtained from within the administration, Trump’s budget includes cuts of as much as 45 percent to grants for state and local agencies that fund the people, programs and monitors designed to clean up the air. The loss of EPA financial support will cut deepest in states such as Michigan, Pennsylvania, North Dakota, and West Virginia.

Weakening the air monitoring system is only one of the likely casualties of the Trump budget, which “takes a sledgehammer to EPA,” according to the Washington Post. The budget eliminates more than 50 programs and slashes enforcement, science, toxic safety, and the cleanup of the Great Lakes and Chesapeake Bay. The EPA’s budget is already 20 percent lower than it was in 2010, so any budget cuts would bite especially deep. The Trump administration is also doubling down on its war on the EPA by pairing budget cuts with a series of executive orders to weaken clean water and clean air safeguards that are already in place.What will taxpayers get for these budget cuts to EPA? The entire EPA budget accounts for only two-tenths of 1 percent of federal spending. The savings from Trump’s budget cut to EPA averages out to 34 cents per week for every taxpayer — money that will be shifted to other Trump priorities and never be seen by taxpayers that Mulvaney is compassionately protecting.

Fortunately, Trump cannot make these deep cuts to the EPA unilaterally. Congress has the power of the purse, and the budget is being criticized by Republicans and Democrats alike. It remains to be seen if the Republican majority in Congress will stand up for seniors and all of us when it takes up the EPA budget. Make no mistake — polluter lobbyists who have long fought to cut the EPA down to size will turn out in force.

But standing in their way are voters who strongly side with protecting EPA. In fact, more than three quarters of Trump voters want to preserve or increase the strength of federal regulations on drinking water and clean air, according to a December 2016 poll by Morning Consult.

Every minute we breathe cleaner air thanks to the laws passed under the environmental stewardship of our parents and grandparents. We are all the beneficiaries of the legacy our parents left to us. It would be a moral failing to abandon those same seniors who now face the same prospect of breathing dirtier air when they are most vulnerable to its direct impacts on blood pressure, respiratory illness, and heart disease.

A child born today faces the possibility that the air they breathe will be dirtier and the water they drink will be less safe because of Trump’s war on the EPA. For our nation’s elderly, they face not only threats to themselves, but the prospect of stripping away the environmental legacy they thought they had secured for their grandchildren. There is nothing compassionate about that.

TELL CONGRESS: PROTECT EPA

Moms Clean Air Force

Trump Moves to Cook the Books, Undercutting Common Sense Climate Protections

7 years 6 months ago

By Susanne Brooks

This blog was co-authored with Martha Roberts

It’s reported that the Trump Administration is poised to continue its barrage of attacks on some of our most vital health and environmental protections, following last week’s assault on broadly supported fuel economy and greenhouse gas safeguards for cars and light trucks. Here’s one attack that they may try to sneak under the radar—a move that would undercut common sense climate protection all across the federal government: directing federal agencies to abandon the use of social cost of carbon estimates in their evaluation of new policy.

The social cost of carbon is a measure of the economic harm from the impacts of climate change. Specifically, it’s the dollar value of the total damages from emitting one ton of carbon dioxide into the atmosphere. Weakening or eliminating the use of the social cost of carbon would result in skewed and biased policy-making that ignores the benefits of crucial safeguards and stacks the deck against actions to protect communities from the mounting costs of climate change.

The devastating impacts of climate change on health and the environment – such as extreme weather events, the spread of disease, sea level rise, and increased food insecurity – can cost American businesses, families, governments and taxpayers hundreds of billions of dollars through rising health care costs, destruction of property, increased food prices, and more. Many of these impacts are already being felt by communities across the country, as the government’s leading scientific agencies have found.

When the federal government develops policy affecting the carbon pollution causing climate change, it is both reasonable and essential that it takes these costs into account. The social cost of carbon is a tool that allows policy-makers to do just that.

Currently, the federal government uses a social cost of carbon estimate—roughly $40 per ton of carbon pollution—that was developed through a transparent and rigorous interagency process, relied on the latest peer-reviewed science and economics available, and allowed for repeated public comment as well as input from the National Academy of Sciences.

But that may not last much longer. As we’ve seen, the Trump Administration is waging war against an array of our most crucial health and environmental protections, ignoring the urgent threat of climate change while prioritizing fossil fuel interests. President Trump’s new Administrator of the Environmental Protection Agency, Scott Pruitt, denies that carbon pollution is a primary contributor to climate change, and built his political career by suing EPA 14 times as Oklahoma Attorney General to block protections from mercury, arsenic and smog pollution, hand in hand with the worst elements of the fossil fuel industry. Meanwhile the Administration is proposing devastating cuts to the budgets for EPA and climate research, and is moving towards revoking the Clean Power Plan, America’s first-ever nationwide limits on carbon pollution from power plants.

All of this points to a clear disregard for basic science, economic principles, and our nation’s clean air laws. Eliminating or weakening the social cost of carbon is another pernicious tactic by the Administration to undermine the development of crucial climate safeguards – by erroneously making it appear as though reducing carbon pollution has little or no benefit to society and the economy. Even the current figure is very likely a conservative lower bound since it does not yet include all of the widely recognized and accepted impacts of climate change.

The details of the upcoming attack are still unclear. It’s possible that the Administration may end use of the uniform social cost of carbon estimate at the federal level—despite its rigorous basis and judicial precedent. Other indications suggest that the Administration may choose to artificially and arbitrarily discount the costs of climate change for the health and economic well-being of our kids, grandkids, and future generations—ignoring the growing consensus among economists that supports valuing these impacts more, as does a recent report from the Council of Economic Advisors. Or the Administration may decide to disregard the fact that our greenhouse gas pollution has harmful impacts outside U.S. borders that can have costly repercussions for Americans.

Throwing out the social cost of carbon may play well with President Trump’s supporters in the fossil fuel industry. But the importance and appropriateness of accounting for these costs is a matter of both economics and law. We also know that nearly two thirds of Americans are concerned about climate change. Undermining limits on pollution—protections that are rooted in rigorous scientific research, reflecting long-standing bipartisan economic principles—will ultimately harm the health and environmental safety of all Americans, including Trump’s supporters.

This post originally appeared on EDF's Market Forces blog.

Susanne Brooks

Trump Moves to Cook the Books, Undercutting Common Sense Climate Protections

7 years 6 months ago

By Susanne Brooks

This blog was co-authored with Martha Roberts

It’s reported that the Trump Administration is poised to continue its barrage of attacks on some of our most vital health and environmental protections, following last week’s assault on broadly supported fuel economy and greenhouse gas safeguards for cars and light trucks. Here’s one attack that they may try to sneak under the radar—a move that would undercut common sense climate protection all across the federal government: directing federal agencies to abandon the use of social cost of carbon estimates in their evaluation of new policy.

The social cost of carbon is a measure of the economic harm from the impacts of climate change. Specifically, it’s the dollar value of the total damages from emitting one ton of carbon dioxide into the atmosphere. Weakening or eliminating the use of the social cost of carbon would result in skewed and biased policy-making that ignores the benefits of crucial safeguards and stacks the deck against actions to protect communities from the mounting costs of climate change.

The devastating impacts of climate change on health and the environment – such as extreme weather events, the spread of disease, sea level rise, and increased food insecurity – can cost American businesses, families, governments and taxpayers hundreds of billions of dollars through rising health care costs, destruction of property, increased food prices, and more. Many of these impacts are already being felt by communities across the country, as the government’s leading scientific agencies have found.

When the federal government develops policy affecting the carbon pollution causing climate change, it is both reasonable and essential that it takes these costs into account. The social cost of carbon is a tool that allows policy-makers to do just that.

Currently, the federal government uses a social cost of carbon estimate—roughly $40 per ton of carbon pollution—that was developed through a transparent and rigorous interagency process, relied on the latest peer-reviewed science and economics available, and allowed for repeated public comment as well as input from the National Academy of Sciences.

But that may not last much longer. As we’ve seen, the Trump Administration is waging war against an array of our most crucial health and environmental protections, ignoring the urgent threat of climate change while prioritizing fossil fuel interests. President Trump’s new Administrator of the Environmental Protection Agency, Scott Pruitt, denies that carbon pollution is a primary contributor to climate change, and built his political career by suing EPA 14 times as Oklahoma Attorney General to block protections from mercury, arsenic and smog pollution, hand in hand with the worst elements of the fossil fuel industry. Meanwhile the Administration is proposing devastating cuts to the budgets for EPA and climate research, and is moving towards revoking the Clean Power Plan, America’s first-ever nationwide limits on carbon pollution from power plants.

All of this points to a clear disregard for basic science, economic principles, and our nation’s clean air laws. Eliminating or weakening the social cost of carbon is another pernicious tactic by the Administration to undermine the development of crucial climate safeguards – by erroneously making it appear as though reducing carbon pollution has little or no benefit to society and the economy. Even the current figure is very likely a conservative lower bound since it does not yet include all of the widely recognized and accepted impacts of climate change.

The details of the upcoming attack are still unclear. It’s possible that the Administration may end use of the uniform social cost of carbon estimate at the federal level—despite its rigorous basis and judicial precedent. Other indications suggest that the Administration may choose to artificially and arbitrarily discount the costs of climate change for the health and economic well-being of our kids, grandkids, and future generations—ignoring the growing consensus among economists that supports valuing these impacts more, as does a recent report from the Council of Economic Advisors. Or the Administration may decide to disregard the fact that our greenhouse gas pollution has harmful impacts outside U.S. borders that can have costly repercussions for Americans.

Throwing out the social cost of carbon may play well with President Trump’s supporters in the fossil fuel industry. But the importance and appropriateness of accounting for these costs is a matter of both economics and law. We also know that nearly two thirds of Americans are concerned about climate change. Undermining limits on pollution—protections that are rooted in rigorous scientific research, reflecting long-standing bipartisan economic principles—will ultimately harm the health and environmental safety of all Americans, including Trump’s supporters.

This post originally appeared on EDF's Market Forces blog.

Susanne Brooks

Sea changes: The ‘interesting times’ facing European fisheries

7 years 6 months ago

By Guest Author

By: Erik Lindebo

Calm seas or stormy waters? Well, we are only three months into 2017 and, for a number of reasons, it's already looking like a tumultuous year – calling to mind the ancient Chinese curse “may you live in interesting times”.

Around the world, we are seeing dramatic political shifts. In Europe, Brexit has sent shockwaves through political establishments and, regardless of the final outcomes, we now face years of political uncertainty, and highly complex and no doubt emotive negotiations. Brokering a deal around fisheries will certainly be no exception, if past is prologue; only time will tell how access to waters, resources and markets will look in a divorce settlement with the EU. These changing times require new, adaptive ways of thinking about fisheries management. 

Chokes and complexity in the CFP

The Common Fisheries Policy (CFP) continues, of course, and we continue moving closer towards the full Landing Obligation coming into force in 2019. With this, pressure on Member States (and their fishermen) is building – with questions on how to tackle the most challenging issue of ‘choke’ species at the forefront of many people’s minds. This step-change policy has already thrown up some concerns over the rigidity of founding measures of the CFP; challenging the way quotas are being allocated in the face of changing fish stock distribution and fishing patterns. In parallel to this 2019 goal, we have the task of achieving Maximum Sustainable Yield (MSY) objectives by 2020. The delays in adopting a North Sea mixed fishery plan and a new technical measures framework will only add further complexity to the European picture.

Climate change: a new frontier for fishery management

At the same time, a warming climate is causing changes to global ocean ecosystems at an unprecedented rate: triggering profound impacts on species distributions, with subsequent shifts in fishing patterns and preferences. Recent collaborative research between the Environmental Defense Fund, University of California Santa Barbara and Oregon State University shows that even though total global production of seafood may not be severely impacted by climate change, shifts in fish stock distribution at a regional level will be significant. Critically, the research findings underline that with effective management most fisheries could yield more fish and more prosperity, even with the challenging backdrop of a changing climate.

In Europe, the effects of climate change on fisheries and marine ecosystems, is something that – like recent political shocks – we are hearing a lot more about. Recent shifts seen in commercially important pelagic species has resulted in conflict around quota allocation between coastal states responsible for management of these stocks. Dubbed ‘the herring and mackerel wars’, regional governance structures such as the Northeast Atlantic Fisheries Commission (NEAFC) were not able to overcome the unilateral decision-making of individual nations, putting into question the strength of these over-arching agreements in the face of intense competition for shifting stocks. When unilateral decisions are taken on quota, this does nothing for fish stocks, nor for the collective livelihoods of fishermen, which depend on collaborative governance of an interconnected ecosystem. With climate change expected to exacerbate future fluctuations in fish stock distributions, such governance challenges can only be expected to intensify. We therefore urgently need to absorb and harness relevant research and consider its application through a regional European lens. Applying sound analytics through a regional focus will aid in our prediction of future shifts in stocks, as well as help map out smart management responses to these challenging and complex issues.

Building a shock-resistant future for fishing

Comprehensive and inclusive discussions on how our ecosystems and fisheries will respond to management decisions in the coming years need to start now. We must find a way to absorb and balance the many systemic ‘shocks’ that fisheries may face in the near and distant future. It is critical that everyone contributes their knowledge to offer the best chance of a successful cooperative outcome. If we don’t get it right, the research points to the possibility that we may see widespread ‘fish wars’, a return to overfished and collapsed fish stocks, decimated marine ecosystems, and perhaps a squandering of a critical food and economic resource. Europe can lead the way, and lead by example: with the best available science and research at hand, and collaboration with all stakeholders, we can begin to explore adaptive options for regional fisheries management and develop meaningful solutions that provide a solid future for European fisheries in an ever-changing environment.

Only by building resilient, adaptable management systems can we secure sustainable, prosperous fisheries and protect the livelihoods that depend on them, both now and well beyond our current ‘interesting times’.

Guest Author

Sea changes: The ‘interesting times’ facing European fisheries

7 years 6 months ago

By: Erik Lindebo Calm seas or stormy waters? Well, we are only three months into 2017 and, for a number of reasons, it’s already looking like a tumultuous year – calling to mind the ancient Chinese curse “may you live in interesting times”. Around the world, we are seeing dramatic political shifts. In Europe, Brexit […]

The post Sea changes: The ‘interesting times’ facing European fisheries appeared first on EDFish.

Guest Author

Sea changes: The ‘interesting times’ facing European fisheries

7 years 6 months ago

By Guest Author

By: Erik Lindebo

Calm seas or stormy waters? Well, we are only three months into 2017 and, for a number of reasons, it's already looking like a tumultuous year – calling to mind the ancient Chinese curse “may you live in interesting times”.

Around the world, we are seeing dramatic political shifts. In Europe, Brexit has sent shockwaves through political establishments and, regardless of the final outcomes, we now face years of political uncertainty, and highly complex and no doubt emotive negotiations. Brokering a deal around fisheries will certainly be no exception, if past is prologue; only time will tell how access to waters, resources and markets will look in a divorce settlement with the EU. These changing times require new, adaptive ways of thinking about fisheries management. 

Chokes and complexity in the CFP

The Common Fisheries Policy (CFP) continues, of course, and we continue moving closer towards the full Landing Obligation coming into force in 2019. With this, pressure on Member States (and their fishermen) is building – with questions on how to tackle the most challenging issue of ‘choke’ species at the forefront of many people’s minds. This step-change policy has already thrown up some concerns over the rigidity of founding measures of the CFP; challenging the way quotas are being allocated in the face of changing fish stock distribution and fishing patterns. In parallel to this 2019 goal, we have the task of achieving Maximum Sustainable Yield (MSY) objectives by 2020. The delays in adopting a North Sea mixed fishery plan and a new technical measures framework will only add further complexity to the European picture.

Climate change: a new frontier for fishery management

At the same time, a warming climate is causing changes to global ocean ecosystems at an unprecedented rate: triggering profound impacts on species distributions, with subsequent shifts in fishing patterns and preferences. Recent collaborative research between the Environmental Defense Fund, University of California Santa Barbara and Oregon State University shows that even though total global production of seafood may not be severely impacted by climate change, shifts in fish stock distribution at a regional level will be significant. Critically, the research findings underline that with effective management most fisheries could yield more fish and more prosperity, even with the challenging backdrop of a changing climate.

In Europe, the effects of climate change on fisheries and marine ecosystems, is something that – like recent political shocks – we are hearing a lot more about. Recent shifts seen in commercially important pelagic species has resulted in conflict around quota allocation between coastal states responsible for management of these stocks. Dubbed ‘the herring and mackerel wars’, regional governance structures such as the Northeast Atlantic Fisheries Commission (NEAFC) were not able to overcome the unilateral decision-making of individual nations, putting into question the strength of these over-arching agreements in the face of intense competition for shifting stocks. When unilateral decisions are taken on quota, this does nothing for fish stocks, nor for the collective livelihoods of fishermen, which depend on collaborative governance of an interconnected ecosystem. With climate change expected to exacerbate future fluctuations in fish stock distributions, such governance challenges can only be expected to intensify. We therefore urgently need to absorb and harness relevant research and consider its application through a regional European lens. Applying sound analytics through a regional focus will aid in our prediction of future shifts in stocks, as well as help map out smart management responses to these challenging and complex issues.

Building a shock-resistant future for fishing

Comprehensive and inclusive discussions on how our ecosystems and fisheries will respond to management decisions in the coming years need to start now. We must find a way to absorb and balance the many systemic ‘shocks’ that fisheries may face in the near and distant future. It is critical that everyone contributes their knowledge to offer the best chance of a successful cooperative outcome. If we don’t get it right, the research points to the possibility that we may see widespread ‘fish wars’, a return to overfished and collapsed fish stocks, decimated marine ecosystems, and perhaps a squandering of a critical food and economic resource. Europe can lead the way, and lead by example: with the best available science and research at hand, and collaboration with all stakeholders, we can begin to explore adaptive options for regional fisheries management and develop meaningful solutions that provide a solid future for European fisheries in an ever-changing environment.

Only by building resilient, adaptable management systems can we secure sustainable, prosperous fisheries and protect the livelihoods that depend on them, both now and well beyond our current ‘interesting times’.

Guest Author

New film shows that clean water isn’t a guarantee for many in California

7 years 6 months ago

By Ana Lucia Garcia Briones

Farms in Kern County along the California Aqueduct, in southern San Joaquin Valley.

National Geographic’s new film, “Water & Power: A California Heist,” explores the impacts of California’s drought and the San Joaquin Valley’s groundwater crisis, and highlights issues surrounding the state’s water rights and the powerful interests that sometimes control them.

The film, which uses beautiful cinematography and testimonials from lawyers, water managers and residents, offers a stark contrast between those who have continued to profit during California’s drought and those who have struggled to meet even their most basic water needs.

The film places an emphasis on the “Monterey Amendments,” a back-room deal struck in 1994 that included the creation of the Kern Water Bank, and opened the door to the bank’s eventual privatization. At the time, well-endowed businesses with large land holdings were given control of these groundwater reserves, which they used to shore up highly profitable agricultural businesses. Since then, groundwater levels have plummeted and become contaminated, impacting safe drinking water supplies for small communities.

While the film skews some of the relationships between agricultural water use and drinking water supplies, and distorts some important historical details, it does appropriately shine a light on the critical drinking water needs of the vulnerable communities in California’s Central Valley, and illuminates the importance of transparency in water management.

Access inequality

It is an absurd notion that, within an easy afternoon’s drive of the hub of the world’s tech industry and several of the country’s most affluent cities, tens of thousands of our fellow Californian’s don’t have access to clean drinking water.

In small, rural towns residents rely on one or two community wells. As reserves run dry and become contaminated, residents don’t have the resources to drill a new well or connect to state distribution systems.

Meanwhile, wealthy farms and large cities have the technology and capital to pump more groundwater and build new water conveyance infrastructure to meet their water needs.

This is the dynamic portrayed in “Water & Power” and it’s a problem that must be fixed. Luckily California has the resources to make this happen.

Community participation

Water board leaders from 13 communities throughout California's Central Valley attended the Leadership Academy to build engagement capacity and share lessons about small water system management. (Credit: Kike Arnal)

We at Environmental Defense Fund are re-doubling our efforts, working alongside environmental justice and water management leaders to bring real solutions to these vulnerable communities.

Last year, Self-Help EnterprisesRural Community Assistance Corporation (RCAC) and Environmental Defense Fund executed a series of bilingual leadership workshops in small, rural communities throughout the San Joaquin Valley.

Pulling from RCAC’s years of on-the-ground experience, the Leadership Academy aimed to build engagement capacity of rural community leaders and bridge the communications gap with policymakers.

Recommendations

We applaud the tireless efforts of our partners and other organizations like the Community Water Center and Clean Water Action, who have been working for years to address the needs of these vulnerable communities.

Increased attention to water access from influential water interests including the Association of California Water Agencies (ACWA) and the State Water Resources Control Board (SWRCB) is a sign that these efforts are starting to pay off.

We look forward to working with these groups to design solutions that quickly bring clean, safe drinking water to all the people of California.

This is a problem that California has the knowledge and resources to solve. Let’s get to it.

 

This blog post is not a film review and is not an endorsement of the views expressed in “Water & Power: A California Heist”

 

Related:
What it’s going to take to fund California’s water infrastructure >>

Water heroes emerge in California’s Central Valley >>

From Mexico City to San Francisco: A multi-national perspective on water management >>

Ana Lucia Garcia Briones