UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 WASHINGTON D.C. 20460

OFFICE OF THE ADMINISTRATOR

SCIENCE ADVISORY BOARD

October 22, 2015 

EPA-SAB-16-001

The Honorable Gina McCarthy 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 

Subject: Science Advisory Board (SAB) Consideration of EPA Planned Actions in the Spring 

2015 Unified (Regulatory) Agenda and their Supporting Science 

Dear Administrator McCarthy: 

As part of its statutory duties, the Science Advisory Board (SAB) recently concluded discussions about 

possible review of the science supporting major EPA planned actions associated with the Spring 2015

Unified (Regulatory) Agenda and Regulatory Plan. The EPA Office of Policy provided notice of the 

release of this information on May 22, 2015. The SAB held a public teleconference on September 24, 

2015, to discuss whether to review the science supporting any of the planned regulatory actions in that 

agenda in order to provide advice and comment on the adequacy of the science. 

The SAB focused its attention on the seven major actions identified by the EPA Office of Policy as 

being planned but not yet proposed as of the date the Agenda was published in the Federal Register. At 

the September 24, 2015, public teleconference, the SAB decided that it will not undertake review of the 

science supporting any actions in the Spring 2015 semi-annual regulatory agenda at this time. 

In conducting the review of the planned actions in the Spring 2015 Regulatory Agenda, the Board 

identified two topics — (1) the Integrated Planning Model used to project air emissions from electric 

generating units and (2) the need to transition to greener chemicals, processes and technologies — on 

which it had previously provided recommendations to the agency. While these comments do not 

constitute requests for the further review of the planned action by the SAB, they are presented to 

emphasize opportunities to apply SAB advice and recommendations across the agency’s research and 

program offices.

Integrated Planning Model

The Board notes that several actions on the EPA’s current and previous regulatory agendas (i.e., 

Interstate Transport Rule for the 2008 Ozone NAAQS [2060-AS05] and Greenhouse Gas New Source 

Performance Standard for Electric Generating Units-Emission Guidelines for Existing Sources [2060-

AR33], respectively) rely on the Integrated Planning Model (IPM) for projecting future emissions of 
ozone precursors or greenhouse gases from electric generating units (EGUs). The Board appreciates the 

agency’s response to questions from SAB members regarding the IPM and the agency’s efforts to 

update and improve the IPM as provided on the September 24 public teleconference. The Board agrees 

that incorporating updates and lessons learned are good approaches to update the IPM. Outreach to other 

agencies and forums like the Eastern Regional Technical Advisory Committee and the Energy Modeling 

Forum also should keep the IPM consistent with state-of- the art energy and economic modeling. The 

SAB encourages the agency to continue to engage with stakeholders and to publish the full 

documentation from the IPM to increase its transparency. The SAB recognizes the importance of the 

IPM to project future emissions and provide the scientific and technical support for future actions

relating to emissions of ozone precursors and greenhouse gases and welcomes future briefings on the 

agency’s efforts to increase the transparency and comparability of the IPM to other EGU emission 

projection tools.

Safer and Sustainable Chemicals

The agency developed a great deal of information documenting the science supporting the 

Trichloroethylene (TCE); Rulemaking Under TSCA Section 6(a) and N-Methylpyrrolidone (NMP) and 

Methylene Chloride; Rulemaking Under TSCA Section 6(a). The SAB notes that the publicly available 

information and the agency responses to questions from the SAB Work Group facilitated the Board’s

review of the actions and provides a strong basis for future consideration of actions developed under the 

Toxic Substances Control Act (TSCA) Section 6. Options for alternatives were extensively discussed in 

the information provided by the agency for TCE but not NMP or methylene chloride. The agency noted 

the proposed rules would describe the preferred risk management approach and alternatives explaining 

how the approach achieves adequate protection using the least burdensome requirements, discuss cost 

and benefits of alternative approaches and provide an opportunity for public comment.

The SAB and Board of Scientific Counselors (BOSC) provided advice and recommendations to the 

agency encouraging the transition to safer chemicals and greener processes and technologies. In the 

recent review of the agency’s Strategic Research Action Plans and the six major research program areas

(EPA-SAB-15-004) the SAB and BOSC found that the EPA must be prepared to address questions such 

as: how to design and produce safer chemicals; how chemicals and their byproducts interact in the 

environment; how to promote safer, sustainable use of chemicals throughout their lifecycle as it 

addresses the contribution of chemical exposure to the overall disease burden in humans (including 

susceptible subpopulations) and the environment? The SAB encourages the agency to continue to use 

the results from these research programs and the TSCA evaluations to identify risk management 

alternatives that include safer chemicals and greener processes and technologies.

Information on Planned Actions in the Regulatory Agenda

The agency’s descriptions for the Spring 2015 planned actions continue to improve and generally 

provide more complete information to inform the SAB’s decisions than those provided for past SAB 

reviews of the agency’s regulatory agenda. The explanation of the peer review process provided for the 

Spring 2015 planned actions was complete and helpful to the Board’s review process. The SAB strongly 

recommends that the EPA continue to include specific information on the peer review of the associated 

science and description of the scientific and technological bases for the planned actions in future 

descriptions for SAB consideration.

The SAB appreciates the information provided by the EPA describing the planned actions, associated 

scientific questions, and agency plans for scientific analyses and peer review. The information provided

by the agency and a memorandum documenting the Work Group’s review and fact-finding discussions 

with EPA Staff are available on the SAB website.
On behalf of the SAB, I thank you for the opportunity to support the EPA through consideration of the 

science supporting actions in the agency’s regulatory agenda. 

Sincerely, 

/S/

Dr. Peter S. Thorne, Chair 

Science Advisory Board 

Enclosure 

(1) Roster of SAB Members
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NOTICE

This report has been written as part of the activities of the EPA Science Advisory Board (SAB), a public 

advisory group providing extramural scientific information and advice to the Administrator and other officials 

of the Environmental Protection Agency. The SAB is structured to provide balanced, expert assessment of 

scientific matters related to problems facing the agency. This report has not been reviewed for approval by the 

agency and, hence, the contents of this report do not represent the views and policies of the Environmental 

Protection Agency, nor of other agencies in the Executive Branch of the Federal government, nor does mention 

of trade names of commercial products constitute a recommendation for use. Reports of the SAB are posted on 

the EPA website at http://www.epa.gov/sab.
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U.S. Environmental Protection Agency

Science Advisory Board

BOARD

CHAIR

Dr. Peter S. Thorne, Professor and Head, Department of Occupational & Environmental Health, 

University of Iowa, Iowa City, IA

MEMBERS

Dr. Joseph Arvai, Max McGraw Professor of Sustainable Enterprise, Director, Erb Institute, School of 

Natural Resources & Environment, University of Michigan, Ann Arbor, MI

Dr. Sylvie M. Brouder, Professor and Wickersham Chair of Excellence in Agricultural Research, 

Department of Agronomy, Purdue University, West Lafayette, IN

Dr. Thomas Burbacher, Professor, Department of Environmental and Occupational Health Sciences, 

School of Public Health, University of Washington, Seattle, WA

Dr. Ingrid Burke, Director and Wyoming Excellence Chair, Haub School and Ruckelshaus Institute of 

Environment and Natural Resources, University of Wyoming, Laramie, WY

Dr. George Daston, Victor Mills Society Research Fellow, Global Product Stewardship, The Procter & 

Gamble Company, Mason, OH

Dr. Costel Denson, Managing Member, Costech Technologies, LLC, Hockessin, DE

Dr. Michael Dourson, President, Toxicology Excellence for Risk Assessment, Cincinnati, OH

Dr. Joel Ducoste, Professor, Department of Civil, Construction, and Environmental Engineering, College 

of Engineering, North Carolina State University, Raleigh, NC

Dr. David A. Dzombak, Hamerschlag University Professor and Department Head, Department of Civil 

and Environmental Engineering, College of Engineering, Carnegie Mellon University, Pittsburgh, PA

Dr. Elaine M. Faustman, Professor and Director, Environmental and Occupational Health Sciences, 

University of Washington, Seattle, WA

Dr. R. William Field, Professor, Department of Occupational and Environmental Health, and Department 

of Epidemiology, College of Public Health, University of Iowa, Iowa City, IA

Dr. H. Christopher Frey, Distinguished University Professor, Department of Civil, Construction and 

Environmental Engineering, College of Engineering, North Carolina State University, Raleigh, NC

Also Member: CASAC

Dr. Steven Hamburg, Chief Scientist, Environmental Defense Fund, Boston, MA
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Dr. Cynthia M. Harris, Director and Professor, Institute of Public Health, Florida A&M University, 

Tallahassee, FL

Dr. Robert J. Johnston, Director of the George Perkins Marsh Institute and Professor, Economics, Clark 

University, Worcester, MA

Dr. Kimberly L. Jones, Professor and Chair, Department of Civil and Environmental Engineering, 

Howard University, Washington, DC

Dr. Catherine Karr, Associate Professor - Pediatrics and Environmental and Occupational Health 

Sciences and Director - NW Pediatric Environmental Health Specialty Unit, University of Washington, 

Seattle, WA

Dr. Madhu Khanna, ACES Distinguished Professor in Environmental Economics, Department of 

Agricultural and Consumer Economics, University of Illinois at Urbana-Champaign, Urbana, IL

Dr. Nancy K. Kim, Independent Consultant, Independent Consultant, Albany, NY

Dr. Francine Laden, Mark and Catherine Winkler Associate Professor of Environmental Epidemiology, 

Harvard School of Public Health, and Channing Division of Network Medicine, Brigham and Women's 

Hospital and Harvard Medical School, Boston, MA

Dr. Lois Lehman-McKeeman, Distinguished Research Fellow, Discovery Toxicology, Bristol-Myers 

Squibb, Princeton, NJ

Dr. Cecil Lue-Hing, President, Cecil Lue-Hing & Assoc. Inc., Burr Ridge, IL

Dr. Elizabeth Matsui, Associate Professor, Pediatrics, School of Medicine, Johns Hopkins University, 

Baltimore, MD

Dr. Denise Mauzerall, Professor, Woodrow Wilson School of Public and International Affairs, and 

Department of Civil and Environmental Engineering, Princeton University, Princeton, NJ

Dr. Kristina D. Mena, Associate Professor, Epidemiology, Human Genetics, and Environmental 

Sciences, School of Public Health, University of Texas Health Science Center at Houston, El Paso, TX

Dr. Surabi Menon, Director of Research, ClimateWorks Foundation, San Francisco, CA

Dr. James R. Mihelcic, Professor, Civil and Environmental Engineering, University of South Florida, 

Tampa, FL

Dr. H. Keith Moo-Young, Chancellor, Office of Chancellor, Washington State University, Tri-Cities, 

Richland, WA

Dr. Eileen Murphy, Senior Director Corporate & Foundation Relations, Rutgers University Foundation, 

New Brunswick, NJ
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Dr. James Opaluch, Professor and Chair, Department of Environmental and Natural Resource 

Economics, College of the Environment and Life Sciences, University of Rhode Island, Kingston, RI

Dr. Martin Philbert, Dean and Professor, Environmental Health Sciences, School of Public Health, 

University of Michigan, Ann Arbor, MI

Mr. Richard L. Poirot, Air Quality Planning Chief, Air Quality and Climate Division, Vermont 

Department of Environmental Conservation, Montpelier, VT

Dr. Stephen Polasky, Fesler-Lampert Professor of Ecological/Environmental Economics, Department of 

Applied Economics, University of Minnesota, St. Paul, MN

Dr. David B. Richardson, Associate Professor, Department of Epidemiology, School of Public Health, 

University of North Carolina, Chapel Hill, NC

Dr. Amanda D. Rodewald, Director of Conservation Science, Cornell Lab of Ornithology and Associate 

Professor, Department of Natural Resources, Cornell University, Ithaca, NY

Dr. William Schlesinger, President Emeritus, Cary Institute of Ecosystem Studies, Millbrook, NY

Dr. Gina Solomon, Deputy Secretary for Science and Health, Office of the Secretary, California 

Environmental Protection Agency, Sacramento, CA

Dr. Daniel O. Stram, Professor, Department of Preventive Medicine, Division of Biostatistics, University 

of Southern California, Los Angeles, CA

Dr. Paige Tolbert, Professor and Chair, Department of Environmental Health, Rollins School of Public 

Health, Emory University, Atlanta, GA

Dr. Jeanne VanBriesen, Professor, Department of Civil and Environmental Engineering, Carnegie 

Mellon University, Pittsburgh, PA

Dr. John Vena, Professor and Founding Chair, Department of Public Health Sciences, Medical University 

of South Carolina, Charleston, SC

Dr. Elke Weber, Jerome A. Chazen Professor of International Business, Columbia Business School, New 

York, NY

Dr. Charles Werth, Professor and Bettie Margaret Smith Chair in Environmental Health Engineering, 

Department of Civil, Architectural and Environmental Engineering, Cockrell School of Engineering, 

University of Texas at Austin, Austin, TX

Dr. Peter J. Wilcoxen, Associate Professor, Economics and Public Administration, The Maxwell School, 

Syracuse University, Syracuse, NY

Dr. Dawn J. Wright, Chief Scientist, Environmental Systems Research Institute (Esri), Redlands, CA
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SCIENCE ADVISORY BOARD STAFF

Mr. Thomas Carpenter, Designated Federal Officer, U.S. Environmental Protection Agency, Science 

Advisory Board (1400R), 1200 Pennsylvania Avenue, NW, Washington, DC