environmental priorities for the new administrationpubs.awma.org/flip/em-sept-2017/emsept17.pdf ·...

The Magazine for Environmental Managers September 2017

Environmental Prioritiesfor the New AdministrationStakeholder perspectives and recommendations for U.S. policy and regulation

Our Windcube Lidar solutions enable businesses with an interest in air quality management to make intelligent decisions in the face of uncertainty. scanninglidar.com

Photo courtesy of the National Oceanic and Atmospheric Administration.

IPEP Quarterly: Bringing Ethics into Focusby Diana Kobus, IPEP Executive Director

Last Stop: This Month in History (and other fun facts)

Departments

Message from the President: Doing Homeworkby Scott Freeburn

Proposed EPA Air Prioritiesby Keith Baugues, Indiana Department ofEnvironmental Management

A Crisis of Leadership: The UrgentNeed to Restore EPA’s Mission and Valuesby Tomás Carbonell and Peter Zalzal, Environmental Defense Fund

Delivering America’s Energy Futureby Quinlan Shea, Edison Electric Institute

Air Regulation Priorities for the Trump Administrationby Howard Feldman, American Petroleum Institute

Evidence-Based Decision-Making andthe U.S. Environmental ProtectionAgency: Past, Current, and Futureby Jonathan Samet, The Keck School of Medicine of the University of Southern California

Table of Contents

em • The Magazine for Environmental Managers • A&WMA • September 2017

Environmental Priorities for the New Administrationby John Bachmann

For this month’s topic, EM invited contributions from federal agencies, states, industry and environmental groups, and amember of the environmental science community to answer the question: what are your perspectives and recommendationsregarding the most important air- and/or waste management-related priorities for the new U.S. administration. Happily,several stakeholders accepted the challenge, and have provided an interesting set of articles.

Features

Columns

EPA Research Highlights: EPA Releases CMAQ 5.2by Karen StewartThe new release provides access to state-of-the-art tools for understanding air qualityepisodes and management.

PM File: Successful Delivery of a First-Time Serviceby David L. Elam, Jr.Seven steps to developing or adopting newproject services, processes, and procedures.

YP Perspective: Social Media Usage for Environmental Professionalsby Christopher Whitehead Some quick tips,dos, and don’ts for YPs looking to engage insocial media to expand their professionalnetwork.

This Association is at its best when every part is activelypursuing its mission to better educate our members and thepublic regarding environmental issues of interest. Sometimesthe interest is international or at least regional in nature, butmost often it is local. Or perhaps more importantly, often thatwhich one can affect is local. A&WMA has grown as a member-based Association by addressing a myriad of local issues, aswell as common challenges expressed everywhere locally.Our section and chapter organizations have done the bulk ofthis educational work through the years, often as initiators.

The need for this work continues and is the foundation uponwhich local environmental organizations can build. We needto recognize that we either participate in the building, andthereby support our local communities, or someone else will.There are many environmental organizations out there. Sinceeducating the public is our adopted mission, we need to geton with it. Maintaining active local chapters is key to this fundamental role.

The reality is that it takes only a few people to make a chapterfunction well. A small group to look at strategic and local issues and generate topic matter, folks to execute plannedprogramming, and someone to track success and assess andcorrect direction. All to be completed in a socially agreeablecontext. A core of a dozen people, with a plan to spell theweary, will suffice to do this homework. Simple, right?

Considering the simplicity of my outline, one might wonderat the huge disparity in the apparent execution across chapters.Why does it exist? I don’t know. Every chapter has a changingcast and its own environment that sets it priorities and patternof development. That said, my observation is that the chaptersthat always seem to be doing something share the followingcharacteristics:

• A solid core group of willing volunteers;• Some agreed-to structure and expectations for group and

individual performance;• Creativity, but a willingness to repeat what works; and• A commitment to programming of value (right topic and

level of quality) to local members and non-member customers; financial stability; advancing students andyoung professionals; and networking, social engagement,and fun.

In short, sustaining chapters do enough right to cause people(including organizers) to come back again and again.

One way to guarantee continuity is to repeat yourself. A&WMAdoes this all the time with programming that meets a contin-uing need in the form of specialty conferences such as Mod-eling, Visibility, and (with others) MEGA. At the local level,many sections and chapters routinely host sessions wherelocal, regional, and state regulators can meet face-to-face withAssociation members and members of the interested public.Regulatory news gets stale quickly so such meetings are continually viable and can be held fairly frequently and stillbenefit all parties. Some chapters organize similar meetingsaround legislative sessions, where handicapping the environ-mental lawmaking process can attract a diverse audience. If,where you live, there is a tough environmental issue, youprobably support topic-driven programming that is repeated,but not repetitive.

Though I have spoken of meetings, the same logic applies towebinars, which can be executed with less financial risk, sincethe meeting space can be as small as a desktop. I have indicatedbefore that webinars will likely grow as part of A&WMA’s offerings because of the minimal financial risk for the Associ-ation and customers alike. That said, networking, social engagement, and fun are the sinews that bind members together, stabilize chapter membership, and make it easier tomaintain that key core group. Webinars are as good a reasonas any to hold a face-to-face opportunity for your membersand curious non-member attendees.

If there is no one around doing the homework for your chapter,take action! Find a diverse group of folks to revitalize thatcore. It was there at one time or you wouldn’t have a chapter.Homework is due.

So, if the sections and chapters have been at the core of ourlocal work, why all the rest of the Association? I look forwardto that discussion in a future message. em


Message from the President

by Scott A. Freeburn, P.E. » [email protected]

DoingHomework

Environmental Prioritiesfor the New AdministrationStakeholders offer their perspectives and recommendations regarding U.S. environmental policy and regulation.

“Come gather ’round people wherever you roamAnd admit that the waters around you have grown” The Times They Are A Changin’

“Ah but I was so much older then, I’m younger than that now” My Back Pages

—Bob Dylan

Cover Story by John Bachmann




This issue, my last effort as a member of EM’s Editorial Advisory Committee, is a bit different from others I have organized. In previous issues, we have asked the U.S. Envi-ronmental Protection Agency (EPA) to summarize a policy or regulation and then invited stakeholders to give their perspectives and recommendations regarding that policy or regulation. By contrast, for this issue, we pose a muchbroader charge to the invited participants and groups; that is,what are your perspectives and recommendations regardingthe most important air- and/or waste management-relatedpriorities for the new U.S. Administration? We invited contri-butions from EPA, two states, industry, and environmentalgroups, as well as a member of the environmental sciencecommunity. EPA initially agreed to write the lead article, submitting a draft that was accepted for publication, but ultimately withdrew the article a week before the deadline forfinal submission. Happily, other stakeholders accepted thechallenge, and have provided an interesting set of articles.

Given the broad charge, each group prepared their contribu-tions independently of the others. In some cases, the authorsreacted to recent relevant actions and positions taken by theTrump Administration and EPA, while others placed moreemphasis on specific issues, actions, and recommendations of greatest importance to their group. As you will see, mostof the discussion focused on air issues.

With no EPA perspective piece, we can at least point interestedreaders to statements provided by EPA Administrator Scott

Pruitt on his “back to basics” (http://www.epa.gov/home/back-basics-agenda) or “EPA originalism” (http://remagazine.coop/qa-with-scott-pruitt-epa-administrator/) agenda, which, in part,would move more authority over environmental protection to the states. The EPA Administrator has also focused onstreamlining Superfund (http://www.epa.gov/newsreleases/epa-announces-superfund-task-force-recommendations).More specific actions proposed by the Trump Administrationrelating to climate, eliminating regulations, and budget cutshave been widely reported in the press and some are notedin the stakeholder pieces.

Tomás Carbonell and Peter Zalzal of the Environmental Defense Fund (EDF) have a somewhat different take on whata “return to normalcy at EPA” means. They raise concerns regarding rollback of major regulations, disregard for scienceand the law, transparency and access, and reducing EPA’s capacity to carry out its mission through budget and staffcuts. They pay particular attention to the recent actions takento suspend methane and volatile organic emissions standardsfor oil and gas facilities.

Indiana’s Assistant Commissioner for Air, Keith Baugues, proposes that EPA should focus on providing states with thetools and data needed to do their job, outlining the primaryrole states should play in implementing, tracking, and enforcingair programs, and the complementary role of EPA in estab-lishing goals (e.g., the National Ambient Air Quality Standards[NAAQS]) and emissions standards, and in helping with

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technical tools. His position is consistent with the broader recommendations made by the Environmental Council ofStates in their June 2017 paper, “Cooperative Federalism 2.0”(http://www.ecos.org/wp-content/uploads/2017/06/ECOS-Cooperative-Federalism-2.0-June-17-FINAL.pdf). We also invited an article from the California Air Resources Board, but unfortunately, other priorities prevented completion andreview of an article in time for publication in this issue.

Howard Feldman of the American Petroleum Institute (API)believes EPA should adopt a regulatory system that promotesstreamlined permitting and cost-effective regulations, whileprotecting public health and the environment. He has specificrecommendations for reviewing standards for oil and gas,

regional haze, the mercury and air toxics (MATS) rule, andthe ozone, sulfur dioxide, and nitrogen dioxide NAAQS. Notably, Shea calls for EPA to replace and not just repeal theClean Power Plan, and expresses concern about rescindingthe MATS, as electric companies have already fully imple-mented the rule.

In our last article, Professor Jonathan Samet provides an experienced environmental scientist’s opinion on the impor-tance of evidence-based decision-making in environmentalpolicy. He briefly outlines some examples of questions addressed by science and the formal process by which it has been used in establishing air quality standards and otherregulations. He then addresses the increasing rejection of



Dylan was prophetic. The times have changed again for U.S. environmental policy.

renewable fuels, and the ozone NAAQS. More generally, APIsupports the Trump Administration’s plan to review of all EPAregulations, providing a list of 12 criteria for conducting thesereviews, and recommends improving the permitting process,and rebalancing membership of EPA science advisory boards.

The Edison Electric Institute’s (EEI) Quinlan Shea provides abroad look at the state of U.S. power generation and outlinesindustry plans for a “clean and affordable energy future.” Asection on public policy issues addresses industry views onseveral topics: the importance of grid security and promotinginvestments in energy infrastructure, expedited permittingand siting, coal combustion residuals, federal and state green-house gas programs, and several air pollution issues, including

scientific evidence in recent years and the acceleration of thatdismissal and proposed major cuts in climate and other envi-ronmental research by the Trump Administration. He takesspecial note of the unfortunate developments in the dismissalof science in climate policy decisions and has an alternativeperspective on changes to EPA’s science advisory panels. Finally, he summarizes six key recommendations that he andtwo former heads of EPA’s research office offered as guidanceto the Trump Administration. They, as well as the recommen-dations of the other authors, are well worth reading.

Dylan was prophetic. The times have changed again for U.S.environmental policy. The waters around us are definitelygrowing, and it’s getting hotter. I’m going to the beach. em

John Bachmann is principal of Vision Air Consulting, LLC, and until this past June was a long-time member of EM’s Editorial Advisory Committee. Until 2007, Bachmann was associate director for science/policy and new programs for the U.S. EnvironmentalProtection Agency’s air office.

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We are witnessing a U.S. Administration and U.S. Environmental Protection

Agency (EPA) leadership that appear to be at war with the agency itself, and with

the core values that have guided EPA under both Republican and Democratic

administrations. The resulting harm to communities and families across the nation

who depend on clean air and clean water could be deep and irreparable.

A Crisis of LeadershipThe Urgent Need to Restore

EPA’s Mission and Values

Forum invites authors to share their opinions on environmental issues with EM readers. Opinions expressed in Forumare those of the author(s), and do not reflect official A&WMA policy. EM encourages your participation by either responding directly to this Forum or addressing another issue of interest to you. E-mail: [email protected].

by Tomás Carbonell and Peter Zalzal, the Environmental Defense Fund (EDF)

The William Jefferson Clinton Federal Building, which houses EPAheadquarters, is located in the Federal Triangle in Washington, DC.


Forum: A Crisis of Leadership by Tomás Carbonell and Peter Zalzal

For the first time in decades, we are witnessing an administra-tion and EPA leadership that appear to be at war with theagency itself, and with the core values that have guided EPAunder both Republican and Democratic administrations. Theresulting harm to communities and families across the nationwho depend on clean air and clean water could be deep and irreparable.

In this article, we review recent developments that illustratewhy we are so alarmed for EPA as an institution—and why we believe the last few months are a wake-up call for allAmericans to demand that EPA leadership restore the agency’scommitment to the protection of human health and the envi-ronment, through transparent processes guided by scienceand the law. More than any discrete policy intervention, a return to normalcy at EPA must be the agency’s top priority.

Subordinating Human Health and the Environment to Polluter InterestsAlthough Scott Pruitt has only been EPA Administrator for afew months, The New York Times recently identified more than30 health and environmental protections that he has movedto delay or roll back.2 Often, these deregulatory measures havebeen taken after closed meetings with the affected industries,with no or minimal public notice and comment, and with noconsideration given to the impacts these actions will have forhuman health.

One prominent example is a series of actions the Administrator



In ordinary times, a change in administration would be anoccasion to take stock of the most pressing public health andenvironmental threats that face the EPA, and recommend newprotections that build on the work of prior administrations.Unfortunately, these are no ordinary times—and this is no ordinary administration. The first few months of the TrumpAdministration have witnessed an unprecedented assault onbedrock protections for human health and the environment:from attempted delays in the implementation of health-basedstandards for ozone; to suspensions of emissions standardsfor oil and gas facilities and landfills, and safety standards atindustrial facilities; to efforts to roll back the only nationwidelimits on carbon pollution from power plants. In many cases,these actions have been undertaken at the behest of pollutingindustries, without any public comment or any considerationfor public health and safety. What is more, these attacks havetaken place against a backdrop of other actions—from plansfor mass retirements of EPA employees, to efforts to concealthe EPA Administrator’s schedule, to comments by the EPAAdministrator that contradict the agency’s own scientists—thatsubvert the bipartisan tradition of scientific integrity, publictransparency, and rule of law that has always animated theagency’s work.

Given President Trump’s statements on the campaign trailsuggesting he would dismantle EPA,1 these developments arenot surprising, but they are nonetheless shocking. Further,they are qualitatively different from the routine shifts in prioritiesand policy that normally accompany a change in administration.

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action was taken without public comment and without anyassessment of health or environmental impacts, and is beingaccompanied by a proposed rule to extend the stay. On June 28, EPA took final action—which was subsequently with-drawn—to delay the implementation of the 2015 NationalAmbient Air Quality Standards (NAAQS) for ozone, makingthe extraordinary claim that it had insufficient data to makefinal determinations as to which areas are in attainment.7 Andon June 14, EPA issued a two-year delay of critical updates to

has taken to suspend standards for emissions of methane andvolatile organic compounds (VOCs) from new and modifiedoil and gas facilities under Section 111(b) of the U.S. CleanAir Act—actions that already led to an early legal setback forAdministrator Pruitt in the U.S. Court of Appeals for the D.C.Circuit.3 Promulgated in June 2016, these standards requirethat owners and operators of well sites and compressor stationsimplement cost-effective measures, already required in majorenergy-producing states like Colorado and Wyoming, to

accident prevention and chemical safety standards8—the firstsuch updates in over 20 years—despite EPA’s record findingsthat the revisions were necessary to address long-standingdeficiencies in the current program, and would help mitigateor prevent the over 200 chemical safety incidents that occureach year across the nation.9

Disregard for ScienceAdministrator Pruitt has drawn widespread condemnation—and prompted a review by EPA’s Inspector General10—for hisstatements questioning the role that anthropogenic emissionsof carbon dioxide play in causing dangerous climate change.Unfortunately, Administrator Pruitt’s contempt for sciencegoes far beyond his statements to the press. EPA has takenseveral extraordinary and disturbing actions over the last fewmonths that have the effect of withholding important scientificinformation from the public, curbing scientific input on agencydecisions, and undermining the agency’s ability to generateuseful science:

• In April 2017, EPA removed major portions of its websiteproviding scientific information relating to climate change,including resources that had been available for almost twodecades under both Republican and Democratic adminis-trations. One of the pages removed directly contradictedPruitt’s statements on the causes of climate change.

• In May 2017, EPA began dismissing dozens of scientistsfrom the agency’s Board of Scientific Counselors as theycompleted their terms of service, despite a long agency

detect and repair leaks. Even though oil and natural gas facilitiesare the nation’s largest industrial source of methane and contribute to harmful ground-level ozone pollution in manyareas of the country, the Administrator summarily imposed a 90-day stay of these and other requirements two days afterthe June 3, 2017 compliance deadline. This retroactive staywas issued without notice and comment, and was announcedjust weeks after the Administrator met behind closed doorswith the board of directors of the American Petroleum Institute.On June 13, EPA followed this action by issuing two proposedrules that would extend the stay for a total of two years.

Remarkably, the Administrator failed to even assess, muchless give any weight to, the climate and public health impactsof these actions—even though the 90-day stay alone wouldaffect more than 18,000 wells nationwide and cause substan-tial additional methane and VOC emissions at the height of thesummer ozone season.4 The only basis cited by the Adminis-trator for these stays was a desire to reconsider aspects ofthese requirements that he asserted had not been subject tonotice and comment—an assertion that a three-judge panelof the D.C. Circuit concluded was “inaccurate and thus un-reasonable,” requiring that the entire 90-day stay be vacated.5

This incident is part of a far larger pattern. On May 31, EPAissued a similar 90-day stay of stronger emissions standardsfor new and existing municipal solid waste landfills6—standardsthat have not been significantly revised since 1996, and arelong overdue for an update. Like the oil and gas stay, this

The first few months of the Trump

Administration have witnessed

an unprecedented assault on bedrock

protections for human health and

the environment.



practice of renewing those appointments. These dismissalsmean that the 68-member board will only have 11 remaining members as of September 1, crippling theBoard’s ability to conduct business in 2017.

• The Trump Administration’s proposed FY 2018 budget, ifenacted into law, would cut funding for the agency’s Officeof Research and Development by 48 percent, and wouldentirely eliminate climate-related research programs.11 Thecuts to climate programs are so extreme that three Repub-lican former EPA Administrators have called it a “policy ofwillful ignorance…that is destructive of responsible government.”12

• In June 2017, Administrator Pruitt announced at a boardmeeting of a coal industry trade association that EPA waspreparing to convene rival panels of experts to debate thescience of climate change13—a decision that underscoresthe Administrator’s hostility to the established scientific consensus, and appears designed to give climate skepticscredibility that they have not been able to attain throughthe normal peer review process.

Disregard for the LawAdministrator Pruitt has also shown a disregard for our nation’sbipartisan clean air and water laws and settled judicial precedentinterpreting these laws. One pointed example of this trend ishis persistent questioning of EPA’s authority to regulategreenhouse gas emissions under the Clean Air Act, claimingthe agency lacks the tools to address this pressing problemand that Congress has never addressed the issue.14 That viewis flatly inconsistent with multiple decisions of the U.S. SupremeCourt, all of which have affirmed EPA’s authority to addressthis harmful air pollution under the Clean Air Act.15

Administrator Pruitt’s alarming steps to roll back other publichealth and environmental safeguards, some of which are described above, evince an equally disturbing disregard forthe rule of law. The D.C. Circuit’s recent decision vacating theAdministrator’s 90-day suspension of oil and gas protections,for example, found that EPA’s action was unauthorized andmethodically demonstrated that each of the justifications presented for the stay were contradicted by the record.”16

As of this writing, EPA has proposed to extend this unlawfulsuspension for an additional two years,17 without citing anylegal authority to support such an action or providing anybasis beyond an open-ended intention to reconsider the standards.

EPA’s disregard for the law even extends to implementingbadly needed reforms to the Toxic Substances Control Act(TSCA) that were enacted just last year on a broad bipartisanbasis.18 In June 2017, the Administrator signed a final rule

that narrowly interpreted the scope of chemical risk evaluationsin a manner that is contrary to the statutory text, and that departed without notice from the prior administration’s proposed interpretation.

Lack of Transparency and Public InputThe lack of public input on decisions to suspend health protections is emblematic of a broader lack of transparencyAdministrator Pruitt has brought to his role as head of EPA.There is a longstanding tradition—across Republican andDemocratic administrations alike—that EPA operate transpar-ently to enhance public confidence in the agency’s decision-making process. In 1983, EPA Administrator WilliamRuckelshaus authored the “Fishbowl Memo,” which recognizedthe critical importance of public transparency and recommendedthat appointment calendars be publicly available. The memofurther underscores that “EPA will not accord privileged statusto any special interest group, nor will it accept any recom-mendation without careful examination.”19

Administrator Pruitt has largely ignored these conventions,shielding from public view his meetings with outside organi-zations. When those meetings have been disclosed throughFreedom of Information Act requests, they reveal that theAdministrator’s calendar has been “filled” with meetings withofficials from industries that EPA regulates.20

The Administrator has demonstrated a similar lack of trans-parency and openness in his decision-making process. For instance, he withdrew an action designed to gather more information on pollution from the oil and natural gas sectorjust one day after the Attorneys General of Texas, Oklahoma,and other states requested that he do so. When the Adminis-trator transmitted a letter to municipal solid waste industry officials apprising them of his intent to reconsider EPA’s landfillstandards, he only made it available to the public weeks later.

Where the Administrator has sought public input on his decisions, it has been hurried. For instance, the Administratorprovided a brief 30-day comment period in response to Executive Order 13777—directing agencies to broadly reviewexisting regulations that can be repealed, replaced, or modified—that ended on the same day that EPA offices were requiredto submit their regulatory reform recommendations to anagency “task force.”21 Even though the public weighed inoverwhelmingly in support of EPA’s clean air and clean watersafeguards, it is still unclear whether or how this public inputwas ever considered in EPA’s regulatory review.

Undermining Institutional CapacityThe Trump Administration and EPA Administrator Pruitt have



put forward a budget that would cut EPA’s funding by 31percent, eliminate nearly 50 of the agency’s programs, andeliminate 3,200 EPA staff positions. In June, EPA moved tobegin downsizing its workforce by announcing it would buyout 1,200 employees (approximately 8 percent of the agency’sworkforce) over the summer of 2017. If enacted into law, theAdministration’s cuts would severely undermine programs toensure Americans have clean air and water and to promoteclimate protection. Among other things, they would inhibit theagency’s ability to enforce our nation’s health and environ-mental laws and would structurally harm EPA’s ability to performits core functions going forward. As President George W. Bush’sfirst EPA Administrator, Christine Todd Whitman, observed,“the unprecedented budget cuts to the EPA would pose agreat danger to Americans’ lives if enacted.”22

Even if Congress does not ultimately enact budget cuts at thescale the Administration has requested, the proposed budgetis a stark demonstration of the Administration’s intentions to

dismantle EPA—and an alarming sign that vital safeguardsand institutional functions are now at risk.

EPA’s history is one forged from bipartisan congressional action, recognizing the critical importance of protecting publichealth and the environment. EPA has faithfully carried outthese laws across Republican and Democratic administrations,carefully guided by science, the law, and a commitment totransparent and participatory policymaking. This time-testedapproach has secured deep pollution reductions and im-provements in environmental quality, protecting families andcommunities, while the American economy has continued tothrive. Recent developments, however, flout these bipartisanlaws and disregard this longstanding approach. EPA must return to the core values that have faithfully guided theagency over the last several decades to ensure the agencycan effectively address the serious threats to human healthand the environment that we face as a nation going forward. em

References1. See, e.g., The Fox News GOP Debate Transcript, Annotated, The Washington Post (Mar. 3, 2017) (“Department of Environmental Protection. We are going to

get rid of it in almost every form. We’re going to have little tidbits left, but we’re going to take a tremendous amount out.”); available at https://www.washing-tonpost.com/news/the-fix/wp/2016/03/03/the-fox-news-gop-debate-transcript-annotated/?utm_term=.061aded1617e.

2. Davenport, C. Counseled by Industry, Not Staff, EPA Chief Is Off to a Blazing Start, The New York Times (July 1, 2017).3. See, e.g., Clean Air Council et al. v. E. Pruitt, et al., No. 17-1145 (D.C. Cir. July 3, 2017). Note: EDF is part of the NGO coalition that has challenged EPA’s

90-day stay of the methane standards in the U.S. Court of Appeals for the District of Columbia Circuit.4. Emergency Motion for a Stay or, in the Alternative, Summary Vacatur, Declaration of Dr. David R. Lyon, P 9, 22, No. 17-1145 (D.C. Cir. June 5, 2017).5. Clean Air Council v. EPA, supra n. 3.6. Stay of Standards of Performance for Municipal Solid Waste Landfills and Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills,

82 Fed. Reg. 24,878 (May 31, 2017).7. Extension of Deadline for Promulgating Designations for the 2017 Ozone National Ambient Air Quality Standards, 82 Fed. Reg. 29,246 (June 28, 2017).8. EPA, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Further Delay of Effective Date, 82 Fed. Reg.

27,133 (June 14, 2017).9. Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act, 82 Fed. Reg. 4,594, 4,599, 4,683, (Jan. 13, 2017);

Regulatory Impact Analysis, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act, Section 112(r)(7) at 80, 87(Dec. 2016) (indicating that 2,291 reportable safety incidents occurred between 2004 and 2013, including 1,517 that caused measurable harm on- or off-site).

10. Greenwood, M. EPA Watchdog Reviewing Whether Pruitt’s Carbon Remarks Violate Policies, The Hill, Apr. 1, 2017.11. Analysis of Trump Administration Proposals for FY2018 Budget for the Environmental Protection Agency, Environmental Protection Network, 4, 36 (Mar. 22, 2017);

available at http://www.4cleanair.org/sites/default/files/Documents/EPA_Budget_Analysis_EPN_3-22-2017.pdf.12. William D. Ruckelshaus, Lee M. Thomas, and William K. Reilly. Three Republican EPA Administrators: Trump is Putting Us on a Dangerous Path, The Washington

Post, May 26, 2017.13. Plumer, B.; Davenport, C. EPA to Give Dissenters a Voice on Climate, No Matter the Consensus, The New York Times, June 30, 2017.14. See, e.g., Mooney, C.; Dennis, B. On climate change, Scott Pruitt causes an uproar—and contradicts the EPA’s own website, The Wall Street Journal, Feb. 17, 2017

(“Does EPA even possess the tools, under the Clean Air Act, to address [climate change]?”); CNBC, New EPA Head Scott Pruitt: You Can Be Pro-Growth andPro-Environment, Mar. 9, 2017 (“The legislative branch has not addressed this issue [of climate change] at all.”).

15. Massachusetts v. EPA, 549 U.S. 497 (2007); American Electric Power v. Connecticut, 564 U.S. 410 (2011).16. Clean Air Council v. Pruitt, No. 17-1145, 2017 U.S. App. LEXIS 11803, at *17 (D.C. Cir. July 3, 2017) (per curiam).17. 82 Fed. Reg. 27,645.18. Scopes of the Risk Evaluations to be Conducted for the First Ten Chemical Substances under the Toxic Substances Control Act; Notice of Availability, 82 Fed.

Reg. 31,592 (July 7, 2017); available at https://www.gpo.gov/fdsys/pkg/FR-2017-07-07/pdf/2017-14321.pdf. 19. Memorandum from EPA Administrator William D. Ruckelshaus, “Contacts with Persons Outside the Agency,” May 19, 1983.20. Bogardus, K. Meetings with energy chiefs filled Pruitt’s calendar, Greenwire (June 15, 2017).21. Memorandum from E. Scott Pruitt, Executive Order 13777: Enforcing the Regulatory Reform Agenda (Mar. 24, 2017); Evaluation of Existing Regulations,

82 Fed. Reg. 17,793 (Apr. 13, 2017).22. Whitman, C.T. I Ran George W. Bush’s EPA – and Trump’s Cuts to the Agency Would Endanger Lives, The Atlantic, Mar. 31, 2017.

EPA’s mission should be focused on providing states with the tools and data

needed to do their jobs.

Proposed EPAAir Priorities

by Keith Baugues, Assistant Commissioner of the Office of Air Quality, Indiana Department of Environmental Management

Forum: Proposed EPA Air Priorities by Keith Baugues





In this article, I focus on the tasks that the U.S. EnvironmentalProtection Agency (EPA) can carry out to assist states inmeeting their obligations contained in the U.S. Clean Air Act(CAA). I propose that EPA’s mission should be focused onproviding states with the tools and data needed to do theirjobs. In most cases, it is the role of the states to implementnew federal rules, to permit air sources, to monitor the air, to inspect sources, and to carry out enforcement activities.States need timely tools and guidance to carry out these duties. Among these, I would highlight the following 10 tasksgrouped in four general categories:

Establishing National Standards1. Establishing National Ambient Air Quality Standards

(NAAQS)

Ambient Air Monitoring2. Determining what monitoring techniques are

appropriate3. Providing proper oversight of state air monitoring

activities

Tools and Data4. Developing air quality models and appropriate guidance

for their application5. Developing appropriate emission factors6. Overseeing development of national emission inventories7. Conducting technical analyses to establish contributions

and emission reduction budgets for good neighborState Implementation Plans (SIPs)

Emission Standards8. Establishing NAAQS, including New Source Performance

Standards (NSPS) and National Emission Standards forHazardous Air Pollutants (NESHAPs)

9. Setting and enforcing national standards for vehicles10. Setting national standards for non-road engines

Establishing National StandardsStates, except for maybe California and Texas, typically donot have the in-house expertise to establish health-based ambient air quality standards. Even if they did, you mightend up with 50 standards for the same air pollutant. As a result, the public would not be adequately protected and itwould be extremely difficult for facilities to permit from onestate to another.

Ambient Air MonitoringStates do not have the resources to evaluate new monitoringtechniques to determine if they meet needed criteria. Thisfunction needs to be done by a central organization, so that

50 states are not carrying out the same task. A central organ-ization should oversee states’ ambient air monitoring activitiesto ensure that quality assurance is being handled properly,and that sites are being located and maintained properly.Failure to carry out ambient air monitoring properly can result in data for an entire state being invalidated with reper-cussions on neighboring states.

In the long run, it is this air quality data that determine whetheran area does or does not meet the NAAQS. It is imperativethat the correct standards are set, the correct instruments aredeployed and operated appropriately in the field, and samplesare properly handled and analyzed.

Tools and DataStates are dependent on EPA to provide the proper tools anddata, so that they can carry out a number of tasks. First amongthese is the development of air quality models, including airquality dispersion models, photochemical models, and recep-tor models. The development of these models should bedone by a central organization. However, it should have stateinput and involvement, especially in evaluating the model’sperformance. These models are used to evaluate new indus-tries wishing to locate within a state and to establish limits forexisting sources to meet other requirements. The accuracy of such models is extremely important.

Emission estimates from many sources are based on emissionfactors. These factors were developed by EPA by reviewingstack test results from across the nation or by carrying outoriginal testing for selected source categories. This importanttask has been dropped by EPA. Many sources are havingtheir emissions determined based on emission factors thatare 20 to 30 years old. Many technologies have changed during this period and the factors need to be updated.

EPA carries out two national emission inventory efforts everythree years: One is the National Emission Inventory (NEI),which covers criteria pollutants, and the second is the National Air Toxics Assessment (NATA), which looks at airtoxic emissions. These inventories are very important, in thatthey form the basis for national control strategies that rely onair quality modeling results that use emission inventory dataas their input. These emission inventories are always out ofdate by the time they are developed. For example, the 2014NATA inventory will not be ready until spring 2018. EPAneeds to put more resources into more quickly developingcurrent inventories to establish future standards.

EPA is proposing to require many states to establish emissiontargets to lower their impact on ambient air monitors in other



states. In the past, EPA established the emission targets. Theagency now states that it lacks the funds to complete thetasks and expects states to carry the load. This is an unrealisticexpectation, calling for numerous states to coordinate andsubmit one plan. This will result in the expenditure of moreresources (i.e., having many states doing modeling instead ofjust one federal agency.) It is unlikely that a number of stateswill come to agreement on these targets. In some cases, itmay depend on who reduces first, as to the amount that they will need to reduce.

Emission StandardsNew industries need a common set of standards. EPA has established New Source Performance Standards (NSPS) andNational Emission Standards for Hazardous Air Pollutants(NESHAPs), and should continue to do so. EPA has also established emission standards for motor vehicles and fuels,and for non-road engines. The CAA establishes that this isEPA’s role and not the role of states.

Regardless of whether EPA is releasing new rules or standards,states need timely guidance to implement federal rules. TheCAA establishes timeframes to submit SIPs to EPA. However,the states are often put in a position of having to prepare

plans without adequate guidance on what elements will makethe plan approvable. States need and deserve the completetimes granted by the CAA to prepare SIPs that are approvable without revisions.

I have not focused on enforcement as an EPA priority here.Except for national or multi-state cases, the primary authorityfor enforcing standards from the CAA is the responsibility ofthe states. There are exceptions in cases where states do notaccept authority for carrying out selected tasks. If the statesare not doing an adequate job, EPA can remove authorityfrom the state.

It is impossible to address all of the many functions of EPA ina single article. For example, states also need adequate fundingto carry out the many tasks to which they are assigned, aswell as training. While partially the responsibility of EPA, it isalso up to Congress and the White House to determine appropriate funding levels.

In conclusion, I would suggest that there is a role for EPA and the states to work together to continue the process ofimproving the air quality across the nation. em

Consistent with President Trump’s stated objectives of U.S. energy independence

and economic growth, EPA and other federal agencies should advance a

regulatory system that promotes streamlined permitting and cost-effective

regulations, while protecting public health and the environment.

Air Regulation Priorities for the Trump Administration

by Howard J. Feldman, American Petroleum Institute (API)

Forum: Air Regulation Priorities for the Trump Administration by Howard Feldman



The business community, including the oil and natural gasindustry, relies upon a cost-effective regulatory system thatpromotes the certainty and predictability necessary to makethe massive capital investments required to bring energy andother projects to the U.S. economy. Consistent with PresidentTrump’s stated objectives of U.S. energy independence andeconomic growth, the U.S. Environmental Protection Agency(EPA) and other federal agencies should advance a regulatorysystem that promotes streamlined permitting and cost-effectiveregulations, while protecting public health and the environment.In 2011 and 2015, EPA sought to relieve the burdens imposedby its rules and the time has come to review those regulationsand the additional requirements imposed by the Obama

year. On July 21, 2017, EPA proposed for comment the stan-dards for 2018 and the biomass-based diesel volume for2019.7 Unfortunately, there are a number of problems withthe outdated RFS program that EPA should address:

1. EPA should use its waiver authority to reduce the advanced, cellulosic, and total renewable fuel obligationsto ensure the mandate does not exceed the E10 blend wall.

2. In order to maintain a market for ethanol-free gasoline,EPA should not set a RFS mandate that would cause theaverage ethanol content to exceed 9.7 percent of projected

Administration, while promoting public health, safety and theenvironment as industry and citizens support.

Key EPA RegulationsAs described below, EPA should expeditiously review the oil andgas New Source Performance Standards (NSPS),1 RenewableFuels Standards (RFS),2 and ozone National Ambient AirQuality Standards (NAAQS) and their implementation.3

First, regarding the oil and gas final NSPS rule issued last year,4

detailed petitions for administrative reconsideration of the finalrule were filed with then-EPA Administrator McCarthy on August 2, 2016. The previous 2012 standards and innovationare already effectively reducing emissions while productionhas increased significantly. EPA’s April 4, 2017 announcement5

to review the 2016 standards is encouraging, and a full reviewof the rule and the revision of the standards is appropriate.In conjunction, EPA has recently solicited comment on a pro-posed rule staying compliance dates for portions of the NSPSfor two years to provide the EPA sufficient time to propose,take public comment, and issue a final action on specific requirements on which EPA has granted reconsideration of the NSPS.6

Second, under the RFS program, EPA is required to determineand publish annual percentage standards for each compliance

gasoline demand. EPA should use realistic projections ofE0, E15, E85, and cellulosic demand when setting theannual Renewable Volume Obligations.

3. EPA should reject calls to move the RFS Point of Obligation.

4. EPA should work with Congress to reform and ultimatelyend this unworkable program as the program does notreflect current market realities and it creates the potentialfor economic harm.

Third, regarding the ozone NAAQS, the American PetroleumInstitute and other organizations have commented previouslythat the more restrictive ozone standards promulgated byEPA in late 2015 were unnecessary, because ambient ozonelevels were declining and the public health was already pro-tected with an adequate margin of safety. The commentersalso pointed out, as EPA correctly identified, that ozone levelswould keep falling. Unfortunately, EPA’s new standards createtremendous burden on states, risk significant impacts on jobgrowth, and increase the potential number of U.S. countiesthrown out of attainment.

Legal challenges to the 2015 rule have been consolidated,8

and on April 11, 2017, the court agreed to halt the case while



The lack of certainty as to when a permit

will be issued and the arbitrary inclusion of

unanticipated permit requirements create

significant burdens for permittees.



EPA reviews the final rule for possible reconsideration. EPAshould reconsider the 2015 ozone NAAQS based on the issues identified in the comments and court briefs. It is crucialthat the EPA complete this review quickly, as deadlines pertaining to the 2008 and 2015 ozone NAAQS are soon approaching. If EPA decides not to reconsider the 2015ozone NAAQS after its review, the agency should expedi-tiously revoke the 2008 ozone NAAQS as proposed in the2015 ozone Nonattainment Area Classifications and StateImplementation Plan (SIP) Rule in order to avoid the burdensof implementing two ozone NAAQS simultaneously.

Comprehensive Review of EPA RegulationsThe following should be considered in review of all existingand new regulations.

1. The cumulative cost impacts of regulations on individualindustrial sectors.

2. The review should seek and utilize actual compliancecosts from impacted industries to the maximum extentpossible.

3. The benefits clearly attributable to the rule under reviewshould be based on measurable metrics to the maximumextent possible.

4. Benefits should not be double counted (i.e., the samebenefits being attributed to multiple rules).

5. The science supporting a regulation should be reviewedto determine if it is consistent with EPA’s Principles of Scientific Integrity and Policy (2012), with meaningfuldisclosure of potential areas of bias, along with new information available since promulgation.

6. The regulation reporting burdens should confirm theamount, method, and frequency of data collection necessary to meet the objectives of the regulation.

7. General permits should be considered as a cost-effectivepermitting alternative.

8. EPA should evaluate how better to write regulationsmore clearly.

9. EPA should consider incentives for enhancing self-compliance auditing under the EPA Audit Policy and voluntary programs.

10. EPA should consider increasing rule flexibility and supportto allow sources broader use of available improved tech-nologies to monitor, model, and demonstrate compliance.For example, rules dictating precise monitoring, repair,modeling, or compliance measurement methods shouldbe reviewed to eliminate outdated technologies andmethods (i.e., Method 21 for LDAR monitoring).

11. Duplicative and overlapping regulations should be curtailed.

12. Regulations should be examined for any unintended,negative effects on recycling (i.e., regulations that createeconomic barriers to recycling).

Improve the Permitting ProcessThe current federal permitting process presents many challenges for applicants. Significant improvements could beachieved by standardizing permitting processes, improvingcoordination among federal and state agencies (includingdeadlines for permit issuance), and using a dispute resolutionprocess to resolve interagency permitting problems. Further-more, implementation of measures similar to the FAST Act would be beneficial.

Even though responsibility for U.S. Clean Air Act (CAA) permitsis often delegated to the states, tribes, and local air controlagencies, EPA continues to play a role in reviewing andamending the permit programs, as well as weighing in onNonattainment New Source Review (NNSR) and Preventionof Significant Deterioration (PSD) permits in many cases. Evenin cases where a state issues CAA permits under an EPA-approved SIP, there are instances when decisions made bythe permitting authority are re-evaluated and revisited byEPA, duplicating the efforts of the agencies, adding delay and uncertainty for the permittee.

If a project is subject to a National Environmental Policy Act(NEPA) analysis, there will be overlap between the require-ments of the NEPA process and the requirements of certainpermits. For example, a proposed source was issued a PSDand greenhouse gas air permit from a state with an EPA-approved permitting program. The Federal Energy RegulatoryCommission (FERC) has required that the permittee continueanalysis and modeling of the proposed facility air emissionsin combination with mobile air emissions (which can takeseveral months of additional work), but offered no guidanceon how to calculate mobile emissions.

The lack of certainty as to when a permit will be issued andthe arbitrary inclusion of unanticipated permit requirementscreate significant burdens for permittees. Often operatorscannot afford to challenge inclusion of unnecessary or unrea-sonable permit terms because the project has already beendelayed significantly by the agency’s processing time.

Priorities for permit streamlining priorities include standardizedpermitting processes, better coordination among federal andstate agencies, including deadlines for permit issuance, and adispute resolution process to resolve interagency permittingissues. More detailed recommended fixes to CAA NewSource Review (NSR) permits were included in a recent articlepublished in the Environmental Law Reporter.9 Highlights focused on a more realistic approach for air quality modeling;reforms to the offset program; and adoption of a consistenttreatment for pending permit applications.



Additional NSR reform items include:

• Netting should be fixed to allow use of projected actualemissions in lieu of Potential to Emit (PTE), as the rule allows in accordance with the “new level of actual emissions” in 40 CFR 52.21(b)(3)(v).

• Models and procedures should be updated to improveefficiency and to remove the excessive conservativismthat exists in the modeling system.

• Project netting should be allowed not only for existingemission sources, as already allowed in the rule (althoughEPA has written policy memos to the contrary), but forhybrid units as well.

• “Begin actual construction” has, by policy, been extendedto prohibit construction on “any installation necessary toaccommodate the emissions unit”. Sources should beable to conduct early work up until the piece of equipmentis actually emitting.

• Best Available Control Technology (BACT) evaluationsshould be streamlined. BACT is fairly stable and well-known for most industries/sources and evaluations neednot be as onerous as the traditional five-step top-downevaluation that EPA continues to require. BACT for mostsource types is well established and a detailed analysis isnot warranted.

• The Greenhouse Gas Significant Emissions Rate shouldbe re-evaluated and should include a de minimis thresholdabove 75,000 tons per year.

• The 2009 proposal for debottlenecking should be re-evaluated and finalized.

• Streamlining should be achieved through the use ofpermits by rule, where a facility operator can simply notify the permitting agency when all requirements contained in the “rule” are met by the planned construction.

• General permits that apply to a set array of conditionsare useful to commence construction with a notificationof use.

Improve Advisory BoardsEPA’s Science Advisory Board (SAB) was established in 1978

to provide scientific advice to the EPA Administrator. Whilethe participants selected for the chartered SAB and the varioussubcommittees and panels—predominantly from academia—are certainly knowledgeable in their particular fields of study,they are not always well-versed in the industrial, technical, oroperational aspects of the regulations, research, or plansunder review. There are instances where industry has offeredsuperb candidates with the essential extensive practical andcurrent expertise for SAB consideration to provide a properstakeholder input to the advisory panel only to be turned downby the SAB staff due to a perceived “disqualifying financial interest” under the Ethics in Government Act of 1978.

A balanced panel is supported by the Federal Advisory Committee Act (FACA). Section 5(b)(2) of the FACA requires“the membership of the advisory committee to be fairly balanced in terms of the points of view represented and thefunctions to be performed by the advisory committee.” Thecorresponding FACA regulations reiterate this requirement at 41 CFR § 102-3.30(c), and, for discretionary committeesbeing established, renewed, or reestablished, require agenciesto provide a description of their plan to attain fairly balancedmembership during the charter consultation process with theGeneral Services Administration. See, for example, 41 CFR §102-3.60(b)(3).

EPA has acknowledged that there is no automatic exclusionfrom serving on the SAB or its panels merely because anominee may work for industry. The SAB Office should reconsider how it views a balanced panel and be encouragedto fairly evaluate the full suite of candidates interested in servingin this capacity.

ConclusionFederal regulatory policy can either strengthen or weaken theU.S. energy renaissance and the business climate. Regulatoryactions should be rooted in sound contemporary science anddata, with a consideration of the costs and benefits, whileprotecting public health and the environment. The rules citedin this article should be addressed through notice and commentrulemaking and improved as suggested. em

References1. EPA Docket EPA–HQ–OAR–2010–0505.2. EPA Docket EPA–HQ–OAR–2016–0004. 3. EPA Docket EPA–HQ–OAR–2016–0202.4. U.S. Environmental Protection Agency. Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources; Final Rule; Fed Regist.

2016, 81, 35824-35942.5. U.S. Environmental Protection Agency. Review of the 2016 Oil and Gas New Source Performance Standards for New, Reconstructed, and Modified Sources;

Announcement of review; Fed Regist. 2017, 82, 16331-16332.6. U.S. Environmental Protection Agency. Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain

Requirements; Fed Regist. 2017, 82, 27645-27652.7. U.S. Environmental Protection Agency. Renewable Fuel Standard Program: Standards for 2018 and Biomass-Based Diesel Volume for 2019; Fed Regist.

2017, 82, 34206-34245.8. Murray Energy Corp. v. EPA, No. 15-1385 (D.C. Cir.).9. Fraas, A.G.; Graham, J.D.; Holmstead, J. EPA’s New Source Review Program: Time for Reform?; Environmental Law Reporter 2017, 47 (1), 10026-10040.

Also: Resources for the Future, Jan. 09, 2017; http://www.rff.org/research/publications/epa-s-new-source-review-program-time-reform (accessed July 4, 2017).

October 20-22, 2015 • Houston, TX

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The electric power industry is in the midst of a profound transformation, with

major progress in reducing emissions and integrating new technologies.

Delivering America’sEnergy Futureby Quinlan J. Shea, III, Vice President, Environment, Edison Electric Institute (EEI)

Forum: Delivering America’s Energy Future by Quinlan Shea





This year is proving to be a busy one for environmental andenergy policy, with a new Administration and new Congressin Washington, as well as many new governors, legislators,and regulators in the states. President Trump’s stated supportfor modernizing and enhancing our nation’s infrastructure(including the energy grid), enacting comprehensive tax reform, streamlining regulations, and creating jobs to helpunleash our country’s entrepreneurial potential is positive for the electric power industry and for our economy.

The electric power industry is vital to America’s economy, itscommunities, and its people. According to a report by M.J.Bradley & Associates,1 as a whole, the electric power industrycontributes $880 billion to the U.S. GDP and supports morethan 7 million jobs across the United States (see Figure 1).This includes nearly 2.7 million jobs directly provided throughelectric power industry employees, contractors, supply chain,and investments, and an additional 4.4 million induced jobs.2

The electric power industry is undergoing a profound trans-formation driven by many factors, including:

• low natural gas price/decreasing cost of wind and solar;• customer demand for new and clean technologies;• new technologies, including smart meters/smart grid,

electric vehicles, renewables, energy storage, and distributed generation;

• environmental regulations—air, water, waste, natural resources;

• state renewable energy standards and climate policies;• increased diversification of generating resources with major

growth of non-hydro renewables and future growth of distributed generation, energy storage, etc.; and

• financial incentives for renewables.

In just 10 years, the mix of sources used to generate electricityhas changed dramatically and is increasingly clean. Today,one-third of U.S. power generation comes from zero-emissionssources—that is, nuclear energy and renewables, such as hydropower, wind, and solar (Figure 1). Nuclear energy continues to play a dominant role in providing emissions-free electricity, while non-hydroelectric renewables increasedfrom 2.4 percent to 8.4 percent of the generation mix from2006 to 2016.

In 2016, natural gas (34 percent of the generation mix) surpassed coal (30 percent of the generation mix) as themain source of electricity in the United States.3 By comparison,in 2006, natural gas and coal made up 20 percent and 49 percent of the energy mix, respectively.

As a result of these factors, power plant sulfur dioxide and nitrogen oxides emissions were reduced by 91 percent and82 percent, respectively from 1990 to 2016 (see Figure 2).The industry’s carbon dioxide emissions in 2016 were nearly25 percent below 2005 levels (see Figure 3). With low pricesfor natural gas and declining prices for renewable energyand other technologies, the positive progress on air emissionswill continue.

Innovating for a Clean and Affordable Energy FutureThe pace of the electric power industry’s transformation is increasing. As it does, the Edison Electric Institute’s (EEI)member companies are making large investments in advanced technologies to meet customers’ evolving needs.

Industry Capital ExpendituresThe electric power industry is the most capital-intensive industry in America. Electric companies invest more than$100 billion each year to build smarter energy infrastructureand to transition to even cleaner generation sources (Figure 1).This level of investment is more than twice what it was adecade ago.

Generation constitutes more than one-third of our industry’stotal capital expenditures, including considerable investmentsin clean energy resources. Together, the transmission and distribution segments comprise 43 percent of our industry’stotal capital expenditures, driven by efforts to modernize theenergy grid and by the expansion of renewable energy resources.

Renewable Energy and Advanced TechnologiesEEI’s member companies are building a smarter, more dynamic, cleaner, more resilient, and more secure energygrid with a diverse energy mix that is critical to the reliable,affordable electricity customers expect.

On the renewable energy front, electric companies own orcontract for virtually all of the wind energy in the UnitedStates. Based on a March 2017 report from GTM Research,universal (or large-scale) solar projects by electric companiesaccounted for 72 percent of installed capacity in 2016.4

Universal solar is cost-effective. The average cost per watt ofsolar energy from a solar power plant was $1.06 per watt in2016, compared to the average cost of solar energy from private (or rooftop) solar at $2.89 per watt. EEI’s membercompanies are leaders in developing renewable resourcesand integrating them into the energy grid. This trend willcontinue going forward, particularly if inefficiencies in the current permitting and siting processes are addressed.

Figure 1. Smarter energy infrastructure powers America’s economy, homes, and businesses.



!!!!!! Replace me with the correct header information !!!!!!



The continued deployment of digital smart meters—withmore than 70 million installed to date in 55 percent of allU.S. households—is one key building block of a more dy-namic and more secure energy grid (Figure 1). Investmentsthat hasten the integration of other new technologies, such aswind and solar, energy storage, microgrids, and other devicesin our homes and businesses, are another. Together, theseadvanced technologies, and the data they produce, enableenhanced management of an increasingly complex energy grid.

One advanced technology that is rapidly evolving is energystorage, with battery storage being a key driver of today’s energy storage market. Energy storage technology can beused to help provide reliability services for the energy grid, toenhance power quality, provide peak power, and enable theintegration of renewable energy, keeping supply and demandbalanced. The electric power industry uses more than 90percent of all energy storage. Investment in energy storage isgrowing rapidly, with more than 220 megawatts installed in2015 alone, up 243 percent from 2014.

Customer SolutionsA major focus for EEI’s member companies is providing customers the energy solutions and control they want. Thesesolutions include onsite power generation, 100-percent renewable energy options, efficiency, timing and control overpower usage, and improved reliability. Many commercial andindustrial customers continue to request renewable optionsthat meet sustainability goals. Electric companies are providingthese options and are working with state regulators to gainapproval for offering these customer solutions.

New technologies and innovations in the movement towardsmart communities are helping to drive efficiencies, improvesustainability, spur economic development, and enhancequality of life. The growing smart community trend createsnew opportunities for collaboration among electric companies,cities, universities, technology companies, other business part-ners, and citizens. The energy grid is a key platform for smartcommunity innovations, such as smart street lighting andbuildings, distributed energy resources, and new transportationoptions. While each community may have different reasonsfor specific innovations, all smart communities share commonattributes—and they are all powered by smarter energy infrastructure.

As cities and communities seek smart, sustainable mobilitysolutions, electric transportation is a critical component. EEI’smember companies are working closely with their customersto electrify the transportation sector—from electric vehicles tomass transit systems, to seaports and airports. Electric vehiclesales were up 37 percent in 2016 over 2015, a significantnumber made even more remarkable by continued lowgasoline prices.

Automaker announcements point to more long-range batteryelectric vehicles coming to market—refueled by higher-powercharging infrastructure—making the electric power industry’srole in supporting infrastructure even more important. EEI’smember companies are investing $250 million in customerprograms and projects to deploy charging infrastructure andaccelerate electric transportation. In addition, they committed$128 million toward expanding the adoption of plug-in electric

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Figure 2. Power plant emissions of sulfur dioxide and nitrogen oxides have dropped significantly since 1990.



vehicles (PEVs) in their own fleets and successfully increasedthe number of PEVs in their fleets by 18 percent in 2016.

EEI and the Institute for Electric Innovation recently released a report, which projects more than seven million PEVs will beon U.S. roads by 2025.5 According to a study by the ElectricPower Research Institute and the Natural Resources DefenseCouncil,6 the widespread adoption of electric vehicles couldreduce greenhouse gas (GHG) emissions by 550 millionmetric tons annually in 2050, equivalent to removing 100million passenger cars from the road. Since transportationGHG emissions have surpassed those from the electric powerindustry for the first time in nearly 40 years, transportation isan increasing area of focus for state GHG-reduction targets.

Public Policy IssuesEEI and its member companies will continue to seek policiesthat support and maintain a balanced and diverse energymix, including the vital role of 24/7 power (or baseload)sources—such as nuclear energy—in sustaining a diverse, reliable, and resilient energy mix.

EEI will continue to work with President Trump and with keypolicymakers in Congress and in the states on both sides ofthe political aisle to develop an agenda that supports invest-ments in infrastructure, grows the economy, and recognizesthe vital role of the energy grid and the importance of maintaining reliable, affordable, secure, and increasinglyclean energy for all customers.

Protecting the energy grid is the electric power industry’s toppriority, and every day EEI’s member companies are workingto improve grid security, reliability, and resiliency. The industryprotects the energy grid through standards, coordination withgovernment, and incident response exercises. Security strategiesconstantly evolve and are closely coordinated with the federalgovernment through a partnership called the Electricity Sub-sector Coordinating Council (ESCC). By working togetherthrough the ESCC, industry and government greatly enhanceour nation’s ability to defend and protect against cyber andphysical security threats. Government and industry in NorthAmerica have conducted five major coordination exercisessince November 2015. Electric company investments in theenergy grid also have led to streamlined and enhancedstorm response and restoration.

One major opportunity that has emerged is comprehensive taxreform. EEI and our member companies believe that tax reformlegislation must support investments in America’s critical energy infrastructure and keep energy bills as affordable andpredictable as possible for all Americans.

Energy infrastructure is a crucial issue for the nation and theindustry. On the environmental front, there clearly is a lot offocus on the U.S. Environmental Protection Agency (EPA) andland management agencies. EEI is tracking developmentsclosely and remains engaged on a number of environmentalpolicy issues, such as coal combustion residuals, GHGs, andother air regulations.

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Figure 3. U.S. power sector carbon dioxide emissions are declining (2005–2016).Note: The industry’s carbon dioxide emissions were nearly 25 percent below 2005 levels in 2016—the lowest annual level since 1988.

Million Metric Tons Carbon Dioxide



Expedited Permitting and SitingThe Executive Order signed by President Trump in Augustsets a two-year goal for the federal government to completethe permitting process for infrastructure projects and is a positive step forward. The permitting and siting of energy infrastructure on federal lands are subject to a wide array ofland-use authorizations and associated environmental reviewsand, as a result, the average time frame for permitting andsiting an interstate transmission line is approximately 7-10 years.We fully support streamlining and expediting the process forpermitting and siting energy infrastructure, including transmis-sion, natural gas facilities and pipelines, and renewable energyfacilities, to ensure that energy can get where it is needed,when it is needed. We also support hydropower relicensingreform and better electric-natural gas coordination.

Many of the barriers to expedited permitting and siting ofenergy infrastructure are a result of underlying federal statutesthat need to be updated. We look forward to working withCongress and the Trump Administration to modernize federallaws and to streamline their implementation to ensure thatwe are protecting the environment and also are removingunnecessary barriers to the energy production so essential to economic growth and prosperity.

Coal Combustion ResidualsEPA’s 2015 Coal Combustion Residuals (CCR) rule establishedregulations for CCR as a non-hazardous waste under SubtitleD of the Resource Conservation and Recovery Act (RCRA).While the electric power industry supports the regulation ofCCR as non-hazardous waste, the self-implementing natureof the rule would have resulted in significant compliance issuessince affected facilities were required to comply with the newregulations regardless of whether a state adopted the rule. It required neither regulated facilities to obtain permits norstates to adopt and implement the new rule, and it could notbe enforced by EPA. In addition, the rule’s sole enforcementmechanism is through citizen suits brought by a state or acitizen group in federal district court.

The electric power industry achieved a favorable outcome inDecember 2016 with congressional passage of the Water Infrastructure Improvements for the Nation (WIIN) Act. Thelegislation contains an important provision that establishes amechanism for the implementation of the CCR rule throughEPA-approved state CCR permit programs. The electric powerindustry continues to work with EPA to expedite EPA reviewand approval of state CCR permit programs; revise the ruleto include site-specific tailoring of the rule’s requirements andprovide greater regulatory flexibility; and extend compliance

deadlines to provide time for state permit programs and toensure alignment with the now-stayed effluent limitationsguidelines rule of the U.S. Clean Water Act.

Greenhouse GasesOn March 28, President Trump signed the “Promoting Energy Independence and Economic Growth” ExecutiveOrder (EO) that initiated an EPA review of both the final ruleaddressing GHG emissions from existing power plants (theClean Power Plan, or CPP) and the final rule addressing GHGemissions from new, modified, and reconstructed powerplants (the 111(b) rule), including their possible suspension,revision, or rescission. The EO also initiated a court filing bythe U.S. Department of Justice seeking a stay or otherwisefurther delaying the current litigation in the U.S. Court of Appeals for the District of Columbia Circuit while EPA reviews the CPP and 111(b) rules.

With regard to the CPP, it is important to remember that, regardless of the rule’s ultimate fate, electric companies andstates already are transitioning generation assets for the rea-sons discussed above. One key to that transition is allowingelectric companies to use the most cost-effective resourcesthat provide the range of new energy and technology options that customers want.

Since EPA seems likely to repeal the CPP, it is important thatthe agency issue a replacement rule (as opposed to repealingand not replacing the rule, or seeking to overturn the endan-germent finding). A replacement rule consistent with the underlying statute—in which EPA develops guidelines that establish the approach for regulating affected coal- and gas-based units, and states determine both the standards tobe applied to affected units and how compliance is demon-strated—provides the most durable and legally defensible solution to carbon dioxide regulation for the electric powerindustry.

A replacement rule also would: help protect the industryfrom tort and nuisance suits; provide investment certainty forthe current (and future) generation fleet; support state effortsto recognize and value zero-emitting resources, including existing nuclear units; allow states and companies to determinetheir own emissions glide paths for meeting the guidelines,reflecting cost-effective generation options, reliability and customer preferences; and establish precedent on the meaning and use of U.S. Clean Air Act (CAA) Section 111(d)that will inform regulation of carbon dioxide by future Administrations.



Other Clean Air Act IssuesNumerous traditional CAA issues are active before EPA, includ-ing reevaluation of select Obama Administration actions andnew actions required per statute and consent orders.

One topic of concern is regional haze. EPA’s January 10 ruleestablishing requirements for states to implement the hazeprogram’s second planning period, which runs from 2019 to2028, is being challenged, and EPA has received several petitions for reconsideration. While EPA should retain thechanges it made to the deadlines for state plan submissions,many aspects of the rule and associated guidance should bereconsidered, such as overly prescriptive requirements onhow states must craft their plans, as well as front-loaded reductions in the second planning period, notwithstandingthe national goal of gradually eliminating man-made visibilityover the next 50 years. In addition, at the state level, EPAshould reassess recent federal implementation plans (FIPs)and related litigation by working with states to craft approvablestate plans consistent with the statute.

Regarding hazardous air pollutants, in Murray Energy Corpo-ration v. EPA, EPA’s consideration of costs and co-benefits inregulating hazardous air pollutant emissions by electric generators under CAA Section 112(n)(1)(A) is being reviewed.The Trump Administration is evaluating EPA’s stance in thislitigation. Since electric companies already have fully imple-mented the Mercury and Air Toxics Standards (MATS), the

industry is concerned about adverse consequences if the ruleis rescinded. In addition, EPA is required to complete ResidualRisk and Technology Reviews for MATS and combustion turbines by 2020.

National Ambient Air Quality Standards (NAAQS) and inter-state transport are complicated issues for the industry, withmultiple actions underway. Further, EPA is evaluating how itwants to move forward regarding the final 2015 ozoneNAAQS and is under court order to decide whether to update the sulfur dioxide and nitrogen dioxide NAAQS overthe next couple of years. Finally, to implement NAAQS, EPAis in the process of altering its air quality modeling program.For example, EPA has proposed guidance on Significant ImpactLevels (SILs) and Modeled Emission Rates for Precursors(MERPs) that should help some facilities with low emissionrates avoid complicated and costly air quality modeling. However, additional changes may be warranted.

ConclusionThe electric power industry is in the midst of a profoundtransformation, with major progress in reducing emissions andintegrating new technologies. EEI and its member companiesare focused on building smarter energy infrastructure, providing cleaner energy, and creating energy solutions customers want. Together, we are committed to meeting customer’s changing needs and to delivering America’s energy future. em

References1. Michael J. Bradley & Associates, LLC. Powering America, July 2017; available at http://mjbradley.com/ about-us/case-studies/powering-america.2. Note: Induced jobs are spread throughout the economy and include many positions that are the result of paycheck spending by workers and government

spending to support the communities around those workers. (As an example, induced jobs can range from elementary school teachers to medical doctors toreal estate professionals, not to mention the many jobs in the service economy.)

3. U.S. Energy Information Administration. Short-Term Energy Outlook, January 2017; available at https://www.eia.gov/outlooks/steo/.4. GTM Research. U.S. Solar March Insight 2016 Year in Review, March 2017; available at http://www.greentechmedia.com/research.5. Edison Electric Institute and Institute for Electric Innovation. Plug-in Electric Vehicle Sales Forecast Through 2025 and the Charging Infrastructure Required,

June 2017; available at http://www.edisonfoundation.net/iei/publications/Documents/IEI_EEI%20PEV%20Sales%20and%20Infrastructure%20thru%202025_FINAL%20(2).pdf.

6. Electric Power Research Institute and Natural Resources Defense Council. Environmental Assessment of a Full Electric Transportation Portfolio, September 2015;available at https://www.epri.com/#/pages/ product/3002006881/.

Motivated by the actions of the new administration, this commentary addresses

the primacy of scientific evidence in guiding environmental management and the

threat posed to this critical role of research findings.

Evidence-Based Decision-Making andthe U.S. Environmental Protection Agency

Evidence-Based Decision-Making andthe U.S. Environmental Protection Agency

Past, Current, and Futureby Jonathan M. Samet, MD, MS, Department of Preventive Medicine,

The Keck School of Medicine of the University of Southern California

Forum: Evidence-Based Decision-Making and EPA by Jonathan Samet





I write this commentary from the perspective of a physicianand senior environmental health researcher who has activelyparticipated in committees and other activities at the science-policy interface, including committees of the U.S. EnvironmentalProtection Agency (EPA), the U.S. Department of Energy, theWorld Health Organization, and the National Academies ofScience, Engineering, and Medicine. This experience has convinced me that evidence-based decision-making has workedand that effective frameworks are in place for the translationof scientific evidence in regulations and other policy activities.

While some elements of these frameworks have remainedconstant (e.g., hazard identification, characterizing the dose–response relationship, and assessing exposures), advances inscientific methods have been incorporated over time. For example, I recently chaired a highly multidisciplinary committeeof the National Academies of Science, Engineering, andMedicine that was charged with addressing emerging streamsof “omics” (various methodologies used to generate rich datasets on biological indicators, e.g., genomics with reference tothe genome and metabolomics with reference to chemicalspecies in biological tissues) and other data on toxicity andexposure and showing how the new data could be used inaddressing contemporary issues related to risk. The resultingreport, Using 21st Century Science to Improve Risk-RelatedEvaluations,1 reviewed advances in exposure sciences, toxicol-ogy, and epidemiology and then provided examples of howthe 21st century data, coming largely from new “omics” technologies, could be used in real-world scenarios.

For over three decades, I have interacted with EPA as an investigator carrying out research directly relevant to theagency’s mission, and some with EPA support, on: outdoor air pollution (primarily the “criteria pollutants”) and indoor airpollution (nitrogen dioxide, secondhand smoke, and radon).Because of this research, I have served on various commit-tees of the Science Advisory Board and chaired the Clean AirScientific Advisory Committee (CASAC), an experience thatprovided an understanding of how scientific findings need tobe shaped to support EPA’s regulatory approaches. For example,with my colleagues at the Johns Hopkins Bloomberg Schoolof Public Health (Drs. Francesca Dominici and Scott Zeger)we carried out the National Morbidity, Mortality and Air Pollution Study (NMMAPS), which provided a national picture of the risks of particulate matter air pollution.

I chaired the National Research Council’s Committee on Research Priorities for Airborne Particulate Matter (PM),which developed a research agenda that guided EPA and theresearch community generally in addressing the most criticaluncertainties around the PM National Ambient Air QualityStandard (NAAQS). And, as Chair of CASAC, I was involved

in a dialogue with the EPA staff about refining the approachfor NAAQS review in order to assure a transparent review ofall relevant evidence. Similar refinements of the IntegratedRisk Information System (IRIS) Program were initiated withguidance from other National Research Council committeesthat I chaired.

These experiences have offered insights into the critical rolesthat scientists and the evidence that they generate play in advancing environmental management and hence in improv-ing environmental quality. This commentary, motivated bythe actions of the new administration, addresses the primacyof scientific evidence in guiding environmental managementand the threat posed to this critical role of research findings. I first describe some general frameworks that have provedsuccessful for advancing evidence-based actions and thenturn to the threats to this paradigm that began with the risingdisplacement of scientific evidence by belief over the lastdecade and the acceleration and even the dismissal of scientificevidence with the current administration of President Trump.

How Research Guides PolicyResearch on the environment and human health may be directed at several questions:

1. Does an agent cause one or more adverse health effects in people?

2. How does it cause the adverse health effect(s)? 3. What is the distribution of human exposure and what

are the determinants of exposure? 4. How does risk vary with exposure? 5. Is there a range of susceptibility to the exposure and

what determines exposure? 6. What is the impact of the exposure on the health of the

population, and what can be anticipated from variousinterventions?

These questions are embodied in risk assessment, which isoften used as a bridge from scientific research to policy. In the“Red Book” paradigm, referring to the 1983 National ResearchCouncil report that proposed the still-used framework, thereare four elements that are intertwined with these questions:hazard identification, exposure, dose–response, and risk char-acterization. A full evidence-based risk assessment providesan invaluable starting point for environmental management.

One useful and familiar example is the “criteria pollutants”regulated under Sections 108 and 109 of the U.S. Clean Air Act (CAA). “Criteria” refers to scientific evidence, and theCAA requires review of the accumulating evidence on thecriteria pollutants—currently, PM, ozone, nitrogen dioxide,sulfur dioxide, carbon monoxide, and lead—every five years.

As guidance for risk management, the EPA Administrator isrequired to set a standard sufficient “to protect public healthwith an adequate margin of safety”. The need for research tosupport decision-making is evident. EPA needs informationthat will describe whether there is a risk from an agent andhow risk varies with exposure. As evidence on the criteria airpollutants has evolved, adverse effects have been observedat ever lower levels and risk assessment has been used toprovide guidance on the burden of disease that can be avoidedand the residual risk that remains under various scenarios ofair quality management. The current framework is shown inFigure 1, which captures the fundamental role of research as the starting point and the role of scientists in carrying outresearch and in advising the agency through participation indrafting documents and in serving on the CASAC, whichprovides peer review for EPA as it generates and revises the cornerstone documents.

For the criteria and other pollutants, the research is carried outby a broad array of environmental scientists. For air pollution,for example, the relevant disciplines include atmosphericchemistry and meteorology, environmental engineering, exposure sciences, toxicology, and epidemiology. There is arobust research enterprise housed in universities, governmentlaboratories, the private sector, and elsewhere. This enterpriseis sustained by funding that comes primarily from the gov-ernment; it also provides the platform for training the nextgenerations of environmental scientists.

The Trump Administration and Environmental HealthThis commentary is written as the Trump Administration hascompleted its first six months, giving an ample window togain impressions of its intent around environmental protection.As is well known, the news is not good. An Administrator(Scott Pruitt) has been appointed to head the EPA, who has a long record of suing the agency and a clear agenda of reducing EPA’s scope and impact. EPA’s Office of Researchand Development, which drives much research related to theagency’s mission, is at particular risk. Looking beyond EPA,the indications related to the environment are similarlygloomy. Budget cuts are anticipated for agencies that carryout and fund research on climate; even routine monitoringfor data related to the atmosphere is threatened. At the policylevel, the United States, via Presidential Order, has withdrawnfrom the Paris Climate Agreement. The President’s budget,taken symbolically, is very troubling in its proposed cuts toresearch generally; even the National Institutes of Health,which almost never has a proposed budget reduction, is recommended to have a substantial decrease.

Much is at risk with the new administration. Since the passageof groundbreaking and foundational environmental legislation(e.g., the Clean Air Act) almost a half century ago, we havemade great progress as a nation on many indicators of envi-ronmental quality. That legislation was sparked by the terriblypoor condition of the air and water, and the recognition that



Figure 1. U.S. National Ambient Air Quality Standards (NAAQS), 2009.Source: EPA Integrated Review Plan for the Ozone NAAQS, Research Triangle Park, NC, 2011. Figure 1-1.

there was a wide legacy of highly contaminated waste sites,some in cities and residential neighborhoods. The past healthconsequences of environmental pollution were sometimesdramatic, as with the obvious peaks of excess deaths in thepollution episode in Donora, PA, in 1948 and the London(UK) Fog of 1952. In Southern California, smog alerts keptchildren indoors and the pollution regularly obscured themountains and caused respiratory and eye irritation. Suchproblems are increasingly remote and with the steady gainsin environmental quality, some politicians and perhaps someof the public no longer understand why environmental regulation is needed and, for some pollutants, scientific evidence indicates that there are still risks at current levels(e.g., particulate air pollution).

With the current administration, further progress in improvingenvironmental quality is threatened and there is a worrisomepotential for deterioration, even over the four-year span ofthe Trump Administration. At the least, progress in abatingemissions of greenhouse gases will be slowed.

Fortunately, there are checks and balances within the govern-ment. Budget cuts proposed by the President are messagesonly and the Congress, which actually sets the nation’sbudget, is unlikely to agree to all of the proposed cuts to thenation’s support of research. Additionally, the courts are a critical mechanism for assuring that the requirements of environmental laws are met.

What Is at Risk?In a recent commentary in the New England Journal of Medicine,2 co-authored with two former heads of the EPA’sOffice of Research and Development (Drs. Bernard Goldsteinand Tom Burke, serving, respectively under Presidents Reaganand Obama), we explored the potential course of the presentadministration, anticipating much of what has already takenplace. To reiterate, much is at risk: the research enterprise onthe environment and health, both human and ecosystemhealth; the role of science in decision-making; and the use of expert judgment from the scientific community to guidedecision-making. The capacity to respond to inevitable environmental emergencies is also potentially threatened; experience speaks to the inevitability of further disasters, like the Deepwater Horizon oil spill.

Among the most troubling signals is the displacement anddismissal of evidence as the starting point for decision-making.Acknowledging that scientific evidence provides a startingpoint for regulation and environmental management, thereare numerous other considerations that figure in, dependingon the problem, the relevant regulations or other policies, costsand benefits, and technological feasibility. Stakeholder interestsfigure in as well, as may litigation and political considerations;with regard to politics, climate change has become unneces-sarily linked to our two parties: the Democratic Party for givingpriority to addressing the problem and Republican Party forbeing opposed to doing so. Some national leaders, including



In Next Month’s Issue…

Ozone Depleting Substances—New Regulations, New Challenges

The September issue will feature articles on the new U.S. Environmental Protection Agency(EPA) regulations impacting equipment containingozone depleting substances or substitutes. TheEPA regulations were written with the objectiveof reducing emissions of both ozone depletingsubstances and greenhouse gases. The regula-tions are far-reaching and impact not only industrial, commercial, and residential sources,but schools, hospitals, and grocery stores.



President Trump, state that they do not “believe” in climatechange, contrary to abundant evidence and a consensusamong thousands of scientists, as documented repeatedly in the reports of the Intergovernmental Panel on ClimateChange (IPCC). However, beliefs alone are an inadequatebasis for decision-making.

A broad structure of environmental management based onscientific research, guidance from scientific experts, environ-mental monitoring, and informed decision-making is in jeopardy. Bills have been written by the House Science Committee that have the potential to exclude some researchersfrom participating in the EPA Science Advisory Board (i.e., thosefunded by the EPA), and to further discourage participationby requiring a five-year lag between serving on the SAB andreceiving EPA funding. At the same time, participation wouldbe opened to those employed in the industrial sector with in-depth consideration of potential conflict-of-interest. The so-called “HONEST Act” would drastically limit the scientificfoundation for decision-making through its requirement foraccess to research data and other materials at a level that cannot be readily achieved.

What’s Next?In closing our recent commentary in the New England Journalof Medicine,2 Goldstein, Burke, and I offered guidance to theTrump Administration. Quoting directly from the commentary,

• “Evidence-based decision-making on the environmentshould not be abandoned. Reasoned action and

acknowledgment of scientific truth are fundamental todemocracy, public health, and economic growth. Scientificevidence is unchanged when the administrationchanges.

• The Administration needs to continue to engage and

seek advice from the broad community of scientists.

Abraham Lincoln created the National Academy of

Sciences to provide advice to the government,

acknowledging the necessary role of science for our

government.

• Research funding and scientific capacity related to the

environment should be enhanced so as to be able to

grapple with ongoing and emerging problems, and to

reduce the uncertainties as to whether adverse effects

result from environmental challenges.

• Environmental monitoring and surveillance need to be

sustained and at the ready to address the inevitable

emerging problems and disasters, both foreseen and

unforeseen.

• As it is abundantly evident that environmental processes

related to globalization and to the scientifically indis-

putable effects of greenhouse gases will play a growing

role in causing disasters and other challenges to human

health, it would be inappropriate and potentially disastrous

to pause action on mitigation, particularly in concert with

the wider community of nations.

• The Administration should not abandon the majority

and most critical stakeholder, the American people, for

a coterie of special-interest stakeholders.” em

References1. Using the 21st Century Science to Improve Risk-Related Evaluations; National Academies of Sciences Engineering and Medicine, National Academy of

Sciences: Washington, DC, 2017.2. Samet, J.M.; Burke, T.A.; Goldstein, B.D. The Trump Administration and the Environment—Heed the Science; N. Engl. J. Med. 2017, 376 (12), 1182-1188.

EPA Releases CMAQ 5.2Giving states access to state-of-the-art tools for

understanding air quality episodes and management

EPA scientist Hosein Foroutan and his work on CMAQ 5.2 calculations.

EPA Research Highlights


The U.S. Environmental Protection Agency (EPA) has released CMAQ 5.2, the newest version of its CommunityMultiscale Air Quality (CMAQ) Modeling System. CMAQ isa powerful computational tool that simultaneously modelmultiple air pollutants, including ozone, particulate matter,and a variety of air toxics, to help environmental managersdetermine the most effective strategies for improving airquality in their states and communities.

CMAQ 5.2 features numerous updates to modeled meteoro-logical, physical, and chemical processes to better representhow complex mixtures of air pollutants are formed, transported,and eventually removed from the atmosphere. CMAQ is

capable of simulating air quality on geographical scales ranging from local to hemispheric scales, which supports investigation into a broad range of air pollution scenarios.

Key FeaturesNew features include:

• A new windblown dust emission model, increasing the accuracy of windblown dust emission componentsacross regions;

• A new gas-phase photochemistry mechanism, providingusers with more accurate models of chemistry in ruraland remote environments;



• Instrumented diagnostic capabilities, which are additionaltools that calculate and track contributions like sulfateproduction from sources and regions, providing decision-making support for air quality managers; and

• New pathways to organic aerosol, which incorporatesemivolatile partitioning of primary organic aerosol; parameterized formation of secondary organic aerosol(SOA) from intermediate volatility organic vapors; explicit formation of terpene nitrates; and aqueous-phase formation of biogenic SOA from isoprene epoxide processing.

In addition to science updates, the 5.2 release includes manyother improvements like faster model run times, new step-by-step tutorials for getting started with the model, improvederror-checking for common model mistakes, and an updateto the Atmospheric Model Evaluation Tool (AMET) for evaluatingand visualizing model results.

Evolution of the ScienceDevelopments to the CMAQ system are guided by emergingresearch, air attainment goals, and continual evaluation ofmodel results against measurements from surface, aircraft,and remote-sensing platforms.

The updates in CMAQ 5.2 were designed to provide airquality managers with:

• Improved model simulation of contributions from naturalsources, such as wind-blown dust, lightning nitrogen

oxide, biogenic particulate matter precursor species, andstratospheric ozone. By identifying these non-controllableemissions, air quality managers can obtain a more robustexamination of emission strategies from controllablesources;

• Improved representation of primary organic aerosol contribution to ambient particulate matter, enablingmore accurate assessments of fine particulate matter exposure in urban areas; and

• Consistent representation of atmospheric processes fromlocal to hemispheric scales enabling improved examinationof U.S. air quality amidst the changing global atmosphere.

Dr. Dan Costa, EPA National Program Director for Air, Climate,and Energy Research, spoke about the ability to apply CMAQ5.2 to assess the likelihood of localized stratospheric ozone asa contributor to background ozone levels: “Background ozoneremains a conundrum in many state implementation plans toregulate this air pollutant and protect public health. Theseupdates provide new insights into this complex phenomenonand help develop control strategies,” Dr. Costa said.

Users and Case StudiesCMAQ is used by air quality managers, atmospheric researchscientists, environmental and public health professionals, andothers in private, academic, and government organizations.Many use CMAQ to more efficiently implement EPA’s National Ambient Air Quality Standards that protect publichealth from unsafe levels of air pollutants.

2018 Awards: • Frank A. Chambers Excellence in Air Pollution Control Award

• Fellow Grade of Membership

• S. Smith Griswold Outstanding Air Pollution Control O�cial Award

• Charles W. Gruber Association Leadership Award

• Honorary A&WMA Membership

• Richard Beatty Mellon Environmental Stewardship Award

• Outstanding Young Professional Award

• Lyman A. Ripperton Environmental Educator Award

• Richard C. Scherr Award of Industrial Environmental Excellence

• Richard I. Stessel Waste Management Award

Go to www.awma.org/honors for descriptions and criteria.

Dedication definedA&WMA honors outstanding individuals and companies

in the environmental industry. Nominate someone today!



In the United States, the Centers for Disease Control and Prevention uses CMAQ data in community-focused tools that allow the public easy access to county-specific air qualityinformation on ozone and particulate matter. These tools promote awareness for individuals with asthma and otherrespiratory-related ailments by helping them protect theirhealth. Additionally, the National Weather Service appliesCMAQ to produce air quality forecasts twice daily to alertsensitive groups of high pollution days.

ImpactCMAQ has been enabling users to address complex air qualityissues for almost two decades, helping states and communitiessolve challenges with meeting the National Air Quality Stan-dards and determine which emissions control measures areneeded to meet U.S. Clean Air Act requirements. CMAQ isalso used to tackle long-range transport of pollution acrossnations and for predicting air toxics risks. Currently, 27 statesuse CMAQ and it is recognized worldwide as a premiermodeling tool with users in more than 50 countries. With thetransport of air pollutants across continents, this tool is helpingto address worldwide air pollution.

In October 2016, EPA celebrated the 15th anniversary of its partnership with the Community Modeling and AnalysisSystem (CMAS) Center (http://www.cmascenter.org) that hasprovided a variety of services to the user community. CMAS

organizes a high-impact national conference annually, moderates user email exchanges, and provides training forusers of the CMAQ modeling system.

The new source code for CMAQ 5.2 is available through a publically-accessible, version-controlled git repository onGitHub (http://www.github.com/usepa/cmaq), where interestedparties may obtain the open-source software and contributeto enhancements of the model. Resources for new and expe-rienced CMAQ 5.2 users, including scientific documentation,tutorials and test case data, are available on the CMAQ website (https://www.epa.gov/cmaq).

Future EnhancementsThe CMAQ team is continuing work on making the modelingsystem more robust and cost effective for states, air qualitymanagers and public health officials. One way researchersare focusing their efforts is toward using CMAQ to assess theimpact of wildfires on states. Currently, scientists face a complexproblem in characterizing the transport of wildfire smoke. Future CMAQ endeavors include studying the magnitude ofwildfire smoke and how it is distributed vertically in the atmosphere. Visit the Ongoing Research and Developmentpage (http://www.epa.gov/cmaq/ongoing-cmaq-research-and-development) of the CMAQ website to learn aboutmore upcoming developments to the modeling system. em

More Information

Visit the CMAQ website (https://www.epa.gov/cmaq).

For more information on the research discussed in this column, contact Ann Brown, U.S. Environ-mental Protection Agency (EPA), Office of Research and Development, Research Triangle Park,NC; phone: 1-919-541-7818; e-mail: [email protected].

Karen Stewart is a student contractor with the U.S. Environmental Protection Agency’s (EPA) National Exposure Research Laboratoryin Research Triangle Park, NC.

DisclaimerThe views and opinions expressed in this article are those of the author and do not represent the official views of the U.S. Environmental Protection Agency (EPA).

Successful Delivery of a First-Time Service

Or how to do what we have never done before and look like we have done it forever

PM File


As environment, health, and safety (EH&S) project managers, we respond to a number of routine and repeatsupport requests that we are able perform using existingprocesses and procedures. But as regulations evolve andtechnology advances, we have to develop new services,processes, and procedures to satisfy business needs. Thoughwe may be clear that we are performing a service for the firsttime, the service recipient nevertheless expects successful

performance of that service. Accordingly, we need a model for developing or adopting new services and confirming thecompetence of team members who deliver them.

Organizations that conform to ISO 9001 (Quality Manage-ment Systems-Requirements; https://www.iso.org/iso-9001-quality-management.html) or ISO 17025 (General Requirementsfor the Competence of Calibration and Testing Laboratories;

PM File


https://www.iso.org/standard/39883.html) will have definedprocesses that are used to introduce new products, services,or test methods. For example, ISO 9001 requires ensuringpersonnel with product (service) design responsibility are competent to achieve design requirements and are skilled inapplicable tools and techniques. Importantly, the applicable

slides are easily re-sorted as the process is refined. Oncethe process is adequately refined, it is easy to transferthe slide deck contents to a flowchart application.

3. Develop a standard operating procedure (SOP). Oncethe sequence of operations has been flowcharted, it is

Clear, concise, and comprehensible

SOPs have the potential to accelerate

the success of a new service process.

tools and techniques for product or service design must beidentified by the organization.

Similarly, ISO 17025 requires the laboratory to confirm thatit can properly operate standard methods before offering thetest or calibration procedure to customers. In the case of testand calibration methods developed by the laboratory for itsown use, ISO 17025 requires that the introduction of the testor calibration procedures be a planned activity that is assignedto qualified personnel equipped with adequate resources.

Introducing a New ServiceWhile both standards provide flexibility in how organizationscan satisfy these requirements, the below seven steps cansatisfy the ISO requirements and guide any organizationwhen introducing a new service.

1. Define the service. It is important to clearly define thenew service before attempting to design the service delivery process. A clear, crisp definition of the new serviceallows the design team to understand the boundaries ofthe service, identify existing processes or proceduresthat can support the new service, determine organizationneeds (equipment, training, procedures) to provide theservice, and describe what the service delivery processwill accomplish.

2. Flowchart the process. The next step is to conceptualizea sequence of operations for the process and then describethe process with a flowchart. I have found it helpful touse storyboarding techniques (see, for example, “PM File:Storyboarding Builds Persuasive Presentations, (http://pubs.awma.org/flip/EM-Jan-2014/pmfile.pdf)” EM January2014) to outline the process and build a PowerPointpresentation that supports the storyline. The individual

appropriate to supplement the flowchart with a writtenprocedure or instruction that provides details about howthe sequence of operations should be implemented, including any information that should be documentedduring implementation (see, for example, “PM File:Freedom through Conformity: The Value of StandardOperating Procedures, (http://pubs.awma.org/flip/EM-July-2007/pmfile.pdf)” EM July 2007).

4. Test the SOP. Clear, concise, and comprehensible SOPshave the potential to accelerate the success of a newservice process. Accordingly, SOPs must be tested toensure that the instructions can be implemented as described. Effective testing of the SOP should involveboth the SOP author and the anticipated user. The interaction of the author and user during the testingprocess will yield a revised SOP that is clear, concise,comprehensible, and perhaps most importantly, reflects a collaborative development approach.

5. Train staff. Once the revised SOP is developed, the nextstep is training staff who will be required to deliver theservice. As a new process, the training program willlikely include an overview of the service process and itspurpose, the SOP, and a mock service delivery application.The ISO 9001 and 17025 standards provide excellentguidance for training. The flowchart developed in Step 2can be used advantageously in training. In short, the organization should confirm that trained personnel understand the service delivery process and are competent to perform it.

6. Execute the service. Now that the SOP has been validatedand the competence of personnel has been demonstrated,it is time to provide the service. It is particularly important

PM File


that a new service be launched with well-defined projectinstructions (see, for example, “PM File: Simple Commu-nication Tools Drive Project Success, (http://pubs.awma.org/flip/EM-April-2007/pmfile.pdf)” EM April 2007) that address the purpose of the project, team member responsibilities and communication authorities, theschedule, the budget, and required resources.

7. Improve the process. Last, but not least, using the sameconcepts outlined in Step 4, revise the service deliveryprocess and supporting documentation to address anydeficiencies or improvement needs that were identifiedin Step 6.

Ensuring a Successful DeliveryThe business environment for EH&S professionals has alwaysbeen dynamic. But today, the pace of technology change andregulatory uncertainty may be at their highest levels in thehistory of the profession. If we are to remain responsive tothe compliance and commercial needs of our businesses, wemust be prepared to systematically, efficiently, effectively, and quickly develop and deliver new services and associatedprocesses. Although specific requirements will vary with eachservice, incorporating the above seven elements in the designand implantation of a new service will identify and documentdeficiencies prior to roll-out, ensure trained personnel withappropriate procedures and instruction are assigned to the task, and thereby improve the prospects for a successfullaunch. em

David L. Elam, Jr., CIH, CMQ/OE, PMP, is a consultant with TRC. E-mail: [email protected].

Some quick tips, dos, and don’ts for YPs looking to engage in social media and

expand their professional network.

Social Media Usagefor EnvironmentalProfessionals

YP Perspective


In our interconnected age, social media use is a fact of life.Everywhere you look, people have their eyes glued to theirsmartphones, eager to check their social media feeds. Muchof this is likely for personal use, but many people also use social media for business. Two of the most common social

media sites for business are LinkedIn and Twitter. Twitter famously limits users to 140 characters, while LinkedIn capsoff regular posts at 600 characters. If used effectively, thesebrief social media posts can serve as a rapid delivery systemto get content to the eyes of your target audience.

This can be a promising concept for the young professional.You likely have some solid work experience, interesting ideason a certain topic, and are looking for ways to get your voiceheard. Social media is a tool in your toolkit that can help yourcareer progress.

Companies often use marketing campaigns to present them-selves as experts in the field and partners in the community.This can often include posting regulatory alerts, progress reports on impressive projects, employment vacancies, andcompany-related human-interest pieces. Individual users canfollow a similar pattern, posting for a few common reasons,including seeking a job, promoting activity in a related cause,hunting for contacts, individual brand management, and engaging in business development.

I have used social media effectively for a while now, and ithas led to my company getting jobs; but it is only a first stepin the process. No one is going to give you work to bring toyour company through social media. At best, effective socialmedia use can get you a face-to-face meeting or phone call.As your level of interaction with a contact increases, so doyour chances of potentially getting work from that person.

It can be challenging to stand out from the crowd amidseemingly endless competition and untold numbers of memesand political diatribes. Lately, social media has become anoutlet for personal opinions, memes, political arguments, andnon-sequitur posts. While I like a good dog meme as muchas the next guy, I have come to use social media only forbusiness. Over the past year, social media has helped increaseour website views each month. You can have some fun withit, but each post should follow basic criteria and ultimatelysupport whatever overall message that you are trying to establish. In the end, the hope is that the readers will want to hear more of what you have to say.

Getting Noticed: Dos and Don’tsThere are a few simple dos and don’ts that you can follow tohelp build your brand and expand your network.

Do…• Remain professional at all times. If you wouldn’t say it to

your boss, or to a client, do not post it online.• Take a moment to review your post. Make sure that it

includes all of your desired content. Proofread posts. Apost with spelling or syntax errors will look rushed and uninformed.

• Detail any uncommon acronyms. Just because you know

what NIOSH means does not mean that everyone will. (Note:NIOSH stands for the National Institute for OccupationalSafety and Health)

• Find a creative topic or angle that has not received muchattention. If you are the 59th person to just share a storyfrom a popular source, your post will be white-washed.

• If you are trying to gain clients, always find a way to high-light the related services that your company offers. Alwaysend such posts with a direction. “Contact us at______.”

• Build up a history of resourceful posts. If you post a fewmonths on a certain aspect of environmental regulation,eventually readers may come to look at you as an experton that topic.

• Stay on top of regulatory changes and current initiatives.There is a good chance that this will lead to you being thefirst source for readers on that topic.

Don’t…• Post anything about politics. In our current polarized envi-

ronment, such discussions will only lead to division anddistraction from your real goals. Taking a stance against a candidate can alienate “the other side”. Why eliminatepossible business contacts?

• Overstate or exaggerate. If you are trying to present yourself as an expert on a topic, be an expert on that topic. If not, the real experts will be able to sniff out yourinconsistencies.

• Try to “friend” everyone. If you have not worked togetherin the past or hope to in the near future, do not send afriend request. Gaining contacts will only help if you arewilling to follow up with them. Please refrain from late night“friend requests”. It does not look good.

• Plagiarize. If you are posting from another’s work, youmust give them credit. Simple allusions can suffice, but it is always better to over-cite, than under-cite.

• Slam a former employer or client. No good can come of it and such a post will only make you look petty.

• Post a partial services list. This too will likely be white-washed.You have to first get the reader’s interest and then endwith directions for contact.

• If you have even a moment’s pause as to whether or notsomething is safe to post, chances are your instinct is correct.

• Never treat a work account like a personal account. Youare representing a company or organization, and so do soprofessionally. If you list yourself as presently employed bya company, whatever you post may be viewed as comingfrom that company.

• Be too hard on yourself. If you follow these simple guide-lines, you’ll be just fine. em

YP Perspective


Christopher Whitehead, CESM, is with Cemtek Air Permitting and is a member of A&WMA’s Young Professional AdvisoryCouncil (YPAC). E-mail: [email protected].

Bringing Ethicsinto Focus

All Qualified Environmental Professionals (QEPs) and Environmental Professionals In-training (EPIs) must agreeto follow IPEP’s Code of Ethics and participate in continuingeducation in ethics to fulfill ongoing professional developmentrequirements. A number of credentials from other organiza-tions, including the Certified Industrial Hygienist (CIH) credential from the American Board of Industrial Hygiene(ABIH), have similar requirements.

Codifying attitudes and values in a practice area fosters appropriate conduct from practitioners, garners respect forthe profession, and guides processes for evaluating accusationsof unethical behavior in fairness to both sides of an issue or complaint.

The earlier practitioners can be trained to address ethical issues in their careers, the better. This establishes a foundation

of behaviors that is essential for developing ethical profes-sionals. Making the time for role-playing, or other ways of experientially engaging colleagues in preparation of a real-world interaction, can really help a practitioner be preparedwhen an ethical concern comes up on the job or a decisionneeds to be made in the field.

In addition to the minimum requirements of ethics training inthe workplace, making ethics discussions and considerationsa routine part of staff meetings, staff retreats, and planningsessions, helps keep ethical concerns at the forefront of apractitioner’s mind.

Start the discussion in your workplace by reading through IPEP’sCode of Ethics, available online (http://www.ipep.org). em

Accredited by www.cesb.orgwww.ipep.org

IPEP Quarterly by Diana Kobus, IPEP Executive Director


This Month in History (and other fun facts)Did You Know?

Croatian: Rujan

French: Septembre

Italian: Settembre

Polish: Wrzesien

Turkish: Eylül

Sept. 10, 1913: The Lincoln Highway opened as thefirst coast-to-coast paved U.S. highway.

Sept. 1, 1977: The first TRS-80 Model I computerwas sold at Radio Shack.

Sept. 3, 1833: The first issue of The NewYork Sun, New York’s first penny paper, was published.

Sept. 19, 1876: Melville Bissellpatented the first carpet sweeper.

Sept. 2, 1752: Great Britain adapted the Gregorian calendar, making the next day September 14, 1752. There was no September3-13, 1752, in the British Empire, including theAmerican colonies.

This Month in History

More people are born in September than any other month! According to the Georgian calendar, September is the ninth month. But, on the

Roman calendar, it was the seventh month. September has had 29 days, and 31 days; but, since the time of the Emperor

Augustus, it has had only 30 days.

September’s gem is Sapphire, and its flower is Morning Glory.

Last Stop


Sept. 8, 1930: 3M (formerly the Minnesota Mining and Manufacturing Company) began marketing Scotch transparent tape.

Reach decision-making environmental professionals with EM Magazine

Distributed monthly to A&WMA’s general membership,

EM explores a range of issues affecting environmental

managers with timely, provocative articles and regular

columns written by leaders in the field. More than 75%

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represent 45 countries and all 50 states. EM is a key

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Topics covered include regulatory changes; research;

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and more. EM covers a wide range of topics, including air

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climate change, hazardous waste, and remediation.

Ensure that your business receives maximum exposure among environmental professionals worldwide by reserving your space today. Opportunities are available for every budget and frequency package discounts are available.


A&WMA HeadquartersStephanie M. GlyptisExecutive DirectorAir & Waste Management AssociationOne Gateway Center, 3rd Floor420 Fort Duquesne Blvd.Pittsburgh, PA 15222-14351-412-232-3444; 412-232-3450 (fax)[email protected]

AdvertisingJeff [email protected]

EditorialLisa BucherManaging [email protected]

Editorial Advisory CommitteeJohn D. Kinsman, ChairEdison Electric InstituteTerm Ends: 2019

Teresa Raine, Vice ChairERMTerm Ends: 2020

Robert BaslEHS Technology GroupTerm Ends: 2019

Leiran BitonU.S. Environmental Protection AgencyTerm Ends: 2019

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Bryan ComerInternational Council on Clean TransportationTerm Ends: 2020

Prakash Doraiswamy, Ph.D.RTI InternationalTerm Ends: 2020

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EM, a publication of the Air & Waste Management Association, is published monthly with editorial and executive offices at OneGateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA 15222-1435, USA. ©2017 Air & Waste Management Asso-ciation (www.awma.org). All rights reserved. Materials may not be reproduced, redistributed, or translated in any form withoutprior written permission of the Editor. A&WMA assumes no responsibility for statements and opinions advanced by contributorsto this publication. Views expressed in editorials are those of the author and do not necessarily represent an official position ofthe Association. A&WMA does not endorse any company, product, or service appearing in third-party advertising.

EM Magazine (Online) ISSN 2470-4741 » EM Magazine (Print) ISSN 1088-9981

Staff and ContributorsAli FarnoudRamboll EnvironTerm Ends: 2020

Steven P. Frysinger, Ph.D.James Madison UniversityTerm Ends: 2018

Keith GaydoshAffinity ConsultantsTerm Ends: 2018

C. Arthur Gray, IIIAmazon.com Inc.Term Ends: 2019

Jennifer K. KelleyGeneral ElectricTerm Ends: 2020

Mingming LuUniversity of CincinnatiTerm Ends: 2019

David H. Minott, QEP, CCMArc5 Environmental ConsultingTerm Ends: 2020

Brian Noel, P.E.Trinity ConsultantsTerm Ends: 2020

Anthony J. Sadar, CCMAllegheny County Health DepartmentTerm Ends: 2018

Golam SarwarU.S. Environmental Protection AgencyTerm Ends: 2019

Anthony J. Schroeder, CCM, CMTrinity ConsultantsTerm Ends: 2019

Susan S.G. WiermanMid-Atlantic Regional Air Management AssociationTerm Ends: 2018

James J. Winebrake, Ph.D.Rochester Institute of TechnologyTerm Ends: 2018

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