UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C. 20460

OFFICE OF THE ADMINISTRATOR
SCIENCE ADVISORY BOARD

October 22 , 2015

EPA

- SAB

- 1 6

- 00 1

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 , 201 5 . 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 Fede ral 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 s emi

- annual regulatory agenda at this time.

In conducting the review of the planned actions in the Spring 2015 R egulatory A genda

, 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 agenda s (i.e., Interstate Transport Rule for the 2008 Ozone NAAQS [206 0

- 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 ofozone precursors or greenhouse gases from electric generating units (EGUs)

. The Board appreciates t he 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. O utreach to other agencies and forums like the Eastern Regional Techn ical Advisory Committee and the Energy Modeling

Forum also should keep the IPM con sistent with state

- of

- the art energy and economic modeling. The

SA B 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 comparabi lity 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 t o questions from the SAB Work Group facilitated the Board’s review of the actions and pro vides a strong basis for future consideration of actions developed u nder the

T oxic S ubstances Control Act (TSC A ) Section 6. Options for alternatives were extensively discussed in the information provided by the agency for TCE but not NMP or methylene chlor ide. T he 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 appro aches and provide an opportunity for public comment.

The SAB and Board of Scientific Counselors (B O SC) provided advice and recommendations to the agency encouraging the transition to safe r 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

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- 004) the SAB and B O SC 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 encourage s the agency to continue to use the results from these research programs and the TSCA evaluations to identify risk management

alternatives that include safe r chemicals and greener processes and technologies.

Informa tion 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 p eer r eview process provided for the Spring 2015 planned actions was complete and helpful to the Board’s review process. The SAB strongly

recommend s that the EPA continue to include specific information o n 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 acti ons, 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 Membersi 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 re port 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

.ii 

### 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, Universi ty 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 Occ upational 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 Excel lence 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 , Distinguish ed 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, MAiii 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. Kimbe rly 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 Env ironmental 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

D r. 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, Brigh am 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 Me non , 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, NJiv Dr. James Opaluch , Professor and Chair, Department of Environmental and Natural Resource

Economi cs, 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 Q uality 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 M innesota, 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 a nd 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 Ch air, 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 , Profess or 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 an d 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, Eco nomics and Public Administration, The Maxwell School, Syracuse University, Syracuse, NY

Dr. Dawn J. Wright , Chief Scientist, Environmental Systems Research Institute (Esri), Redlands, CAv SCIENCE ADVISORY BOARD STAFF Mr. Thomas Carpenter , Designated Feder al Officer, U.S. Environmental Protection Agency, Science Advisory Board (1400R), 1200 Pennsylvania Avenue, NW, Washington, DC