Tag Archives: regulation

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.

Sincerely,

Deborah Rudnick, Ph.D.

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