The Obama Administration has an opportunity to restore scientific integrity to the process for setting the National Ambient Air Quality Standards (NAAQS).
The NAAQS are at the heart of the nation’s efforts to clean up air pollution. For the most common and widespread air pollutants, the NAAQS define what constitutes air that is healthy to breathe and safe for the environment. The NAAQS set the goals for the states’ pollution control plans and drive much of EPA’s air pollution regulation. Under the Clean Air Act, the NAAQS must protect the public health, including the health of sensitive populations, with an adequate margin of safety.
According to the Clean Air Act, the NAAQS are strictly science-based standards, as affirmed by a unanimous 2002 opinion of the Supreme Court. Yet the Bush Administration has injected politics into the standard-setting process, leaving tens of thousands of Americans at risk of serious health consequences, and eroding public confidence in the health-protectiveness of the standards. Not only has the Bush Administration ignored the advice of its Clean Air Scientific Advisory Committee (CASAC) and the public health community in recent reviews of the standards; it has modified the standard-setting process itself to politicize it and to diminish the role of science.
It is essential that the incoming Obama Administration restore scientific integrity to the standard setting process.
After rejecting the recommendations of EPA staff scientists and the independent Clean Air Scientific Advisory Committee on revisions to the particulate matter standards needed to save tens of thousands of lives each year, the Bush Administration took action to ensure that they would not be publically embarrassed again. The Bush Administration revised the standard-setting process to eliminate the “Staff Paper.” The Staff Paper had provided recommendations of EPA staff scientists on the range and form of the standards, after undergoing public and peer review by CASAC. The “Staff Paper” was replaced by policy recommendations in the form of an Advanced Notice of Proposed Rulemaking (ANPR), developed by political appointees, vetted by an interagency review process, and approved by the White House Office of Management and Budget. This change hamstrung the CASAC and diminished their ability to fulfill their statutory role of advising the EPA Administrator on changes to the standards.
An administrative change to restore the science-based policy recommendations in the Staff Paper can be made immediately.