Tag Archives: environment

Action 156. Tell the administration to stop doing stupid math and start doing good science.

Executive Order 13771 (82 FR 9339, February 3, 2017) on Reducing Regulation and Controlling Regulatory Costs directs all agencies to repeal two existing regulations for each new regulation issued in FY 2017 and thereafter. It further directs agencies that the “total incremental costs of all regulations should be no greater than zero” in FY 2017.

You guys. Did you read that? Seriously, did you read that bad math? Based on WTF law of bad math is the administration devising this Executive Order (EO) to take two steps back for every one step forward? .

This piece of wisdom is part of a trifecta of EOs steeped in bad math and science dubbed “Regulatory Reform” on which the EPA is asking for public comment through May 15.  In addition to random reductions in regulatory ‘rithmetic, the relevant EOs also set up a “Task Force… to evaluate existing regulations and make recommendations to the agency head regarding their repeal, replacement, or modification” and “directs the EPA to review the Clean Power Plan, related rules and the NSPS for Oil and Gas, and all agencies to review existing regulations, orders, guidance documents and policies that potentially burden the development or use of domestically produced energy resources.” It doesn’t take much reading between the lines to see that the point of these orders is to push the EPA backwards on any kinds of regulations that might stand in the way of the dinosaur fossil fuel industry.

The EPA is asking for your feedback, dear reader, and I ask you, please take a few moments to do this; because besides you, me and the folks who are actually protected by the EPA’s regulation to protect our common resources and care to comment, you can guess who else is going to be providing comment: the industries that would love to be regulated a whole lot less.

Here are the comments I submitted to EPA this week:

Dear EPA:

Thank you for the opportunity to comment on the regulatory reforms that are proposed as part of Executive Orders 13771, 13777, and 13783.

As a Ph.D. environmental scientist who has worked for local, state, and federal regulatory agencies as well as in private industry sitting both on the same side of the table with and across the table from EPA and other federal regulatory agencies, I am well informed about the role of the EPA in safeguarding our nation’s air, water and natural resources. In addition, as a parent and an educator, I recognize the importance of these regulations for safeguarding my children and our future generations.

In light of my experience and priorities, I speak to the executive orders and to Director Pruitt’s evaluation of existing regulations with extraordinary concern for the integrity of the mission of this agency, and I have the following comments regarding these proposals:

Executive Order 13771 “directs all agencies to repeal two existing regulations for each new regulation issued in FY 2017 and thereafter. It further directs agencies that the “total incremental costs of all regulations should be no greater than zero” in FY 2017.” I find it fascinating and obscure why the EPA should be directed to play a zero-sum math game with its regulations. Is the administration interested in basic arithmetic, or should they perhaps be more interested in how the agency fulfills its mission? Is there any shred of scientific basis for assigning such arbitrary conditions? I also believe that we the public deserve to understand what is meant by “total incremental costs no greater than zero”. It would seem to me that the total incremental costs of thousands of additional deaths caused by plans to roll back the Clean Power Plan might be greater than zero. Or the loss of natural resources and access rights to public lands caused by re-opening our public holdings to drilling and mining, that might possibly cost We the People a bit more than zero. I do so hope that the administration is intending to consider that these are more-than-incremental costs that most certainly will need zeroing out for consistency with such a policy.

Executive Order 13778 seeks public input on existing regulations. Here is my input on existing regulations: the EPA should be encouraged and supported to continue to regulate the discharge of pollutants into our air, water, and environment to safeguard the health and well-being of the American public. This includes regulation of greenhouse gas emissions, as such emissions are known to contribute to climate change and contributes directly to increased risk to our health, safety and national security through multiple mechanisms including global destabilization, drought, wildfire, hurricanes, sea level rise, oceanic food chain collapse, and multiple other mechanisms which threaten the lives and livelihood of the American people. Attempts by Director Pruitt or this administration to undermine regulation of greenhouse gases and other discharges of pollutants that are done with the sole purpose of short-term economic benefit to specific corporate stakeholders and without regard to the enormous costs to broad segments of the American public and multiple other economic stakeholders including fisheries, tourism, coastal real estate, agriculture and others, is a dereliction of duties with which the EPA is charged.

Executive Order 13783 directs a review of “regulations, orders, guidance documents and policies that potentially burden the development or use of domestically produced energy resources.” This review must consider that the proposed attempt to roll back the Clean Power Plan and associated regulations has significant potential to unduly burden the clean energy industry of the United States, an industry which is promises entirely domestically produced power that is quickly approaching grid parity if not lower costs than fossil fuel sources of energy, and does so with many fewer negative economic and environmental impacts on the American people than does fossil fuel-based energy. In addition, the review should evaluate how fossil fuel industry subsidies lead to an absolutely unfair and inherently anti-capitalist, non-free-market advantage to these dinosaur industries and create a burden on clean energy technologies which have every right to compete on a level playing field with traditional energy sources.

In conclusion, I would like to thank the scientists and staff of the EPA for their incredibly hard work that they do every day to protect our air, land, water and health. I hope and expect our agencies will continue to be able to fulfill their mission in an environment that is fair, open, and supportive of objective, science-based decision making.


Deborah Rudnick, Ph.D.


Action 19. Kiss and hug Senator Bernie Sanders.

Ok fine not really. I only WISH I could kiss and hug Senator Bernie Sanders for his massively important legislation he has just put forward with Senator Boxer to address climate change. What does this proposed legislation do? Well, the most important thing it does is establish a carbon tax (ok, they are calling it a fee, not a tax, probably for good political reasons, but its the same thing as I read it) which would be levied on the manufacturing and production of GHG-emitting forms of energy (in other words, stuff like fossil fuels that emits carbon; and not stuff like solar and wind, which doesn’t). The bill calls for the money collected from this tax to be used for several critical purposes, including:

  • helping communities plan for and adapt to climate change
  • establish a funding mechanism for research into alternative fuel and energy technologies
  • provide a sustained, comprehensive source of funding for federal weatherization programs, which have the potential to significantly reduce energy use and help people lower their energy bills
  • providing a funding mechanism for retraining fossil fuel industry employees to move into clean tech and other sectors.

Another critical aspect of this bill is that it provides a mechanism for refunding We the People for the costs that will quite likely be passed on to us from the fossil fuel industry as a result of this tax by providing a residential rebate using 3/5 of the carbon tax revenue. The regressiveness of the carbon tax- that is, its propensity to unduly hit low-income groups when costs are passed on- has been one of the major arguments against it, so using this approach to offset some of those costs is a very good move.

The Congressional Budget Office estimates this bill could generate $1.2 trillion dollars in revenue over ten years and reduce GHG emissions by 20 percent of 2005 emission values by the year 2025. Is that enough? No, not even close. Several estimates put the needed rate of reduction at 80% or higher by 2050 to avert the most horrendous of climate effects. But is it a major step in the right direction from one of the world’s highest emitters of GHGs? You bet it is. So, while I can’t kiss Bernie, I will send him a HUGE thank you from the bottom of my heart for putting this legislation on the table.

Action 4. Buy a more sustainable toothbrush.

Toothbrushes. Sigh. I wonder if Im the only person crazy enough that the thought of toothbrushes keeps them up at night? Well, it’s that or wondering what will happen next on Downton Abby. Im not sure which is a worse 3am thought pattern.

Anyway, toothbrushes annoy the crap out of me, because they are one of the countless disposable items that just seem like, well, there is no reason they should be filling up our landfills. Seems trivial, right? Well let’s do a simple math exercise and see.

According to this website, about a third of Americans use an electric toothbrush (probably more now since that data is pretty old; more on electrics later), so let’s be conservative and account for more electric users, and maybe discount a few more percents for pre-teeth babies. So, let’s say 50% of our roughly 314 million Americans are using a non-electric brush, and let’s assume they go through 4 of those a year. By my math, 50%*314,000,000*4= 628 million toothbrushes a year. A couple other estimates around the web suggest in the neighborhood of 450 to 500 million. In any case- Holy Hat!! And that’s just in this country alone!

Ok, so the other obvious question is, how do toothbrushes relate to climate change? They relate with respect to a couple different aspects of the toothbrush lifecycle. There’s the fact that most of them are made out of petroleum-based plastics, so we’ve got a product that is part of the fossil-fuel economy, and then we’ve got the issue of landfilling them- a lot of them- on the disposal end, and landfills make a huge contribution to carbon emissions in this country. And that’s when they end up in the appropriate place, instead of all the other places they might end up, like in the stomachs of pelagic seabirds.* Sigh.

I know, toothbrushes are probably a small component of of our total waste stream. But, as I was saying, several hundred million of them a year is nothing to sneeze at.

So what are the alternatives? With the help of my friends at Trash Backwards (I am sure you will be hearing frequently about this wonderful resource in my posts!) and some googling, I found a couple of alternatives. You can buy a Preserve toothbrush, which is both made of recycled plastic and can be recycled (the manufacturer provides a package for you to send it back for recycling). You can also go with a wooden or bamboo toothbrush, which are compostable, if you live in a place that offers such a service (I have no idea if they would break down in your backyard compost, there’s an experiment worth trying!). And there is a brand new biodegradable toothbrush made right here in the USA, the bogobrush, which is pricey at $10 a brush but, I have to say, is a darned pretty toothbrush, and the family making it are also making a commitment to donate a toothbrush to folks who need one for every one that is sold. That’s pretty cool.

ALL that being said, right now these toothbrushes are for my daughter, who does not use an electric toothbrush, and for guests. My husband and I both use electric toothbrushes, and yes, this is another thing that keeps me up at night. I can’t begin to tell you the walls I have run into in trying to figure out how to recycle those things when they die, and of course there is the issue of the head disposal… ugh. And should I even use one, or should I revert to a biodegradable one, trusting that I will use enough good hygienic technique that I don’t need an electric? Oy. That’s just a whole ‘nother subject that maybe I need to save for another Action.

So, perhaps more about toothbrushes than any of us wanted to know. But maybe I can get some more sleep now that Ive thought this through. Or at least focus my obsessions back on Downton Abby.

*If you’ve never visited Chris Jordan’s site, I highly recommend it. He’s an incredible Seattle-based artists that visually documents our consumption patterns in startling and incredible ways. This site would give anybody plenty to think about at 3am!