Open Comment to EPA
I write on behalf of my organization, the Evangelical Environmental Network (EEN), to express my deep concern over this request for comments itself (Docket ID No. EPA-HQ-OA-2017-0190).
President Trump’s Executive Order 13777, and the Environmental Protection Agency’s (EPA’s) request for comment to fulfill it, displays a profound misunderstanding of both the mission of the EPA and the intended beneficiaries of its policies. You request comments from those you regulate, asking them to tell you about regulations they don’t like, framing the comment process with this leading statement from the Executive Order that its purpose is “to alleviate unnecessary regulatory burdens.” It’s as if someone is pulled over for dangerously weaving through traffic at 80mph in a 55mph zone, and instead of being given a ticket, the speeder is asked, “Tell me all the ways this 55mph speed limit is too hard for you to obey. And here’s a lollipop to make your day sweeter.”
But your mission or calling at the EPA is to defend Americans from a different kind of burden: health burdens from pollution. From your own website:
“The mission of EPA is to protect human health and the environment.
EPA's purpose is to ensure that:
-all Americans are protected from significant risks to human health and the environment where they live, learn and work;
-national efforts to reduce environmental risk are based on the best available scientific information;
-federal laws protecting human health and the environment are enforced fairly and effectively; …”
The Trump Administration’s proposed budget had a 31% cut to EPA’s funding, which would have eliminated vital programs and crippled others. For example, you would have eliminated Energy Star, a voluntary program whose brand adds significant value to consumer products – where’s the regulatory burden in that?
These actions – the proposed budget and this request for comments – provide clear evidence that those the Trump Administration wants to protect are the polluters and not the vulnerable among us who are harmed by such pollution.
Here’s the truth: without the EPA and its sister agencies at the state and local level fulfilling their mission, polluters are free-loaders and moochers, pushing their costs onto others, hiding their costs in the vulnerable bodies of our children, both born and unborn.
EEN is all for using the least amount of government power necessary to get the mission accomplished – but not, obviously, at the expense of the mission itself. In the past we have urged the EPA to provide flexibility to those they regulate, and my organization strives to promote business-friendly policies in general. But we have never asked the EPA to sacrifice its mission and become toothless in its defense of our children’s health. Quite the opposite!
When those hostile to regulations call for cost-benefit analysis, as the President’s Executive Order does, we become quite concerned that the books are about to be cooked, providing an excuse for inaction. In EPA’s case, its mission requires it to defend human health, and no amount of skewed analysis should deter the EPA from fulfilling its mission.
Nevertheless, even cost-benefit analyses of major EPA rules by those critical of regulations in general have shown significant benefits. For example, an analysis in 2003 by the Office of Management and Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA) in the George W. Bush Administration showed that cleaning up our air via the 1990 Clean Air Act led to benefits exceeding costs by 12 times – an investment with an incredible rate of return. Once industry was required to find solutions, they responded with product substitutions, technological innovations, and changed business practices. Production prices dropped as companies learned how to do new practices and procedures better (“learning curves”) and as the products become mass-produced (“economies of scale”).
History shows that once industry has a pollution goal they find ways to exceed it, saving money along the way. We are firm believers in the creative potential of U.S businesses to innovate; even if we set the bar high, they achieve it.
Unfortunately, you not only want to set the bar low, in many cases you seem to want to eliminate the bar entirely. If you succeed our children will suffer – but so will our economic competitiveness. The future belongs to clean tech; pollution is, after all, waste, a sign of inefficiency.
The EPA’s mission is in keeping with Jesus’ call for us to love our neighbors. For the sake of EPA itself, and most importantly our children, both born and unborn, we ask you to suspend this skewed request for comments and simply reaffirm EPA’s mission “to protect human health and the environment.”
The Rev. Mitch Hescox,
Evangelical Environmental Network