Last week was a week of horror for anyone paying attention to our federal government. From the president’s weird, stream-of-consciousness press conference in New York to the Senate’s effort to ignore the questionable character of a nominee to the Supreme Court, to EPA’s effort to quietly eliminate its capacity to protect the health of our children (or, in my case, my 14-month old granddaughter). The hits keep coming and whenever you think, well, this must be the lowest the Trump folks can go, they manage to go lower. Last week EPA put Dr. Ruth Etzel, the head of the Office of Children’s Health Protection, on administrative leave. Dr. Etzel is a world renowned expert in children’s health. According to New York Times reporters Coral Davenport and Roni Caryn Rabin:
“Four people within the E.P.A. and a dozen or so who work closely with the agency said that Dr. Etzel’s dismissal was one of several recent developments that have slowed the work of her department, the Office of Children’s Health Protection. Created by President Bill Clinton in 1997, it advises the E.P.A. leadership on the specific health and environmental-protection needs of children, which often leads to tougher or more stringent regulatory standards than those that might be required for adults. That is because children can be more vulnerable than adults to pollutants or chemicals because their bodies are still developing and because they eat, drink and breathe more, relative to their size. In addition, some of their behaviors, such as crawling or putting things in their mouths, potentially expose them to chemicals or other harmful substances.”
While Trump’s first EPA Administrator, Scott Pruitt, specialized in visible, symbolic and ineffectual attacks on environmental regulation, his new guy, acting administrator Andrew Wheeler, seems to be specializing in quiet, sophisticated, and far more effective attacks on EPA’s organizational capacity to develop or enforce environmental rules. The agency’s public relations people insist that the work of this office is being streamlined and reorganized in the name of efficiency. The Times piece cites a variety of other cuts at EPA, including substantial cuts in the enforcement office.
Even before the Trump cuts, EPA had been under budgetary assault for years. The Tea Party-controlled budget process shrunk the EPA under President Obama. In fiscal 2009 EPA had 17,049 staff; by fiscal 2016, the agency dropped to 14,799 people. Today, the number is down to about 14,100. Under Trump, experienced professionals are desperate to escape the agency. As reported by Brady Dennis, Juliet Eilperin and Andrew Ba Tran in the Washington Post:
“During the first 18 months of the Trump administration, records show, nearly 1,600 workers left the EPA, while fewer than 400 were hired. The exodus has shrunk the agency’s workforce by 8 percent, to levels not seen since the Reagan administration. The trend has continued even after a major round of buyouts last year and despite the fact that the EPA’s budget has remained stable. Those who have resigned or retired include some of the agency’s most experienced veterans, as well as young environmental experts who traditionally would have replaced them — stirring fears about brain drain at the EPA.”
While attacks on EPA’s “regulatory over-reach” have been a staple of both Tea Party and Trumpian rhetoric, the fact is that nearly all of EPA’s rules are carefully drafted, driven by consensus, and highly effective. Despite chronic resource shortages, and constant attacks, this dedicated and mission driven agency has had a long and remarkable record of pollution reduction since its creation almost a half century ago. My fear is that a few more years with industry lobbyists in charge could destroy the place. That is President Trump’s objective; he promised to cut EPA dramatically and as he says at his rallies: “promises made, promises kept”. The problem is that these folks seem to want to dump our babies into toxic bathwater.
In states like New York and California, we have strong and sizable environmental and public health agencies, so I worry less about my granddaughter, who is fortunate enough to live in New York City, and more about the children in West Virginia, Michigan, Florida and Mississippi. Many states still rely on federal standards and organizational capacity to protect the health of their children and the quality of their environment. Our businessman president focuses on the costs of environmental regulation, but ignores the benefits. The cuts he is making to EPA and the image of a deregulated environment will embolden some unscrupulous people to ignore environmental rules. This will inevitably expose more children to unsafe conditions.
Environmental rules are far from perfect and they can be improved. But deregulating the environment for the imaginary benefit of promoting a freer free market is like shutting off the traffic lights in midtown Manhattan. Someone is going to get hurt. I understand the appeal of anti-regulatory symbolism to the president’s political base, but they and Trump himself should think through the health implications of increased concentrations of toxic substances in our environment.
Of course, to think through and understand the impact of toxics in the environment, we need the work of high quality, unbiased science. Unfortunately, EPA’s science capacity is also under attack. Just as the Children’s Health Office is being reorganized out of existence, EPA is also about to eliminate its Office of Science Advisor. According to the New York Times’ Coral Davenport:
“After dissolving the office of the scientific adviser, Mr. Wheeler plans to merge the position into an office that reports to the E.P.A.’s Deputy Assistant Administrator for Science, a demotion that would put at least two more managerial layers between the E.P.A.’s chief scientist and its top decision maker.”
In a complex bureaucracy like EPA, organization structure is deeply meaningful and has a direct impact on agency outputs and outcomes. Downgrading these offices deemphasizes the functions they perform. Since a great deal of the information influencing EPA policy under Trump is coming from industry, trade associations, lobbyists, and right wing think tanks, science information free of ideological bias is not as valued as it once was and should be. To conservative ideologues, environmental health science is itself biased; in their view it over-emphasizes risks and under-emphasizes the benefits of new chemicals and technologies. That view has some merit but in this case seems to be built on a substantial misread of scientific processes, debates and peer review. Scientific assessments of risk evolve as new studies are conducted and we achieve greater understanding of the effect of new chemicals and technologies. The conclusions reached by science change as we collect more data and as time allows us to accumulate more experience and we are able to study impacts that take time to develop. We can debate appropriate levels of risk that we are willing to tolerate, but that debate must be based on the best data, analysis and modeling of impacts that we can develop.
By downgrading the role of science in EPA, we elevate the importance of ideology and lobbyists in the regulatory process. Data is data and facts are facts. If people get sick and die from a toxic chemical, the government will have failed in its central, irreducible function of protecting people. Government’s first priority should not be to promote business interests, but to protect the lives and health of its people. Science, properly applied, can generate both the technologies we need to grow the economy and the methods we need to protect us from the negative impacts of those technologies. Over its history EPA has enabled us to improve the environmental quality of our air, land and water while growing our economy. Science and technology has been used to reduce the environmental impact of science and technology. Ideology didn’t invent sewage treatment, catalytic converters, smoke stack scrubbers and countless other clean-up technologies. Science and engineering did. Effective environmental policy requires a deep understanding of science. Downgrading the science function in EPA is dangerous, ideological idiocy. Demoting the doctors working to protect our children from poison is evil.