Some observers express doubt that the Trump administration can cut the Environmental Protection Agency (EPA) budget by 31 percent and still fund implementation of the newly reformed Toxic Substances Control Act (TSCA), the law that governs the usage of new and existing chemicals found in consumer products from household cleaners to plastic toys. But a recently leaked EPA memo reveals there are plenty of discretionary programs to cut. That would enable the administration to meet statutory requirements for TSCA and other laws while achieving its budget cutting goal.
Drafted by acting EPA Chief Financial Officer David A. Bloom and distributed to other agency officials, the March 21 memo details the administration’s commitment to meeting the EPA’s “core legal requirements” while cutting discretionary programs.
The memo proposes increasing TSCA funding by $14 million, but implementation will likely demand much more. In January, the EPA reported to Congress that it will need $28.4 million in 2018, $38.3 million in 2019, and about $35.8 annually in subsequent years to conduct chemical risk evaluations required under the law.
That may sound daunting, but all of these funds can be found within the largely discretionary programs of the agency’s Office of Research and Development (ORD) budget. ORD is funded as an EPA appropriation line item for “Science and Technology,” which amounted to about $734 million in 2016 and was slated to receive $720 million for 2017, according to the EPA 2017 appropriations report on H.R. 5538, which the House passed last June to fund EPA and other agencies. The Senate did not pass its companion bill, S. 3068, so EPA is funded by the continuing resolution that runs through the end of April.
The EPA could eliminate many—maybe even all—of its science and technology budget items and shift some of those funds to programs designed to implement specific laws, i.e., “core” statutory programs. Even if the administration were to simply cut science and technology programs by 31 percent from the FY2016 level, that would leave more than $507 million to fund TSCA and other programs.
Currently, it’s not particularly clear from the EPA’s budget exactly where all of these science and technology funds go, which is a problem in itself. But it is clear that a good portion is spent to peddle junk science and questionable green advocacy.
As I detailed in a piece for Science 2.0, ORD’s Integrated Risk Information System (IRIS) has long been plagued with problems related to poorly performed chemical risk assessments. Not only are there methodological problems as identified by the National Academy of Sciences (NAS), IRIS assessments lack transparency and tend to be alarmist. Indeed this “research” appears more activist than scientific.
Apparently, Trump’s EPA team agrees, and has indicated that IRIS may be eliminated, which would be a welcome move. IRIS’ budget is included with an appropriations line item of $126 million of spending for “Chemical Safety and Sustainability,” of which IRIS is a part. It’s unclear from the budget how much of those funds go to IRIS, but the EPA memo says that eliminating it will save $5.6 million in “non-pay resources” and cut 104.8 full-time employees. The memo does not specify the fiscal savings related to staff reduction, but it’s likely substantial.
Both House and Senate 2017 appropriations reports directed EPA to devote $1 million of is science and technology appropriations to fund a second National Academy of Sciences’ review of IRIS’s assessment of formaldehyde. NAS sharply criticized IRIS for poor methodology and lack of transparency in its 2011 formaldehyde assessment. According to the 2017 appropriations report, IRIS’ attempts to address problems for the 2011 assessment continue to be deficient. It is not clear whether such funds will be spent under the continuing resolution for 2017, but it certainly would be a waste of money.
The EPA’s continued failure to get this assessment right underscores why the program’s funding should shift into the budget for TSCA implementation. Unlike IRIS, the old TSCA law and the reformed version both require the EPA to employ basic scientific principles, such as applying the “best available science,” transparency, and weight-of-evidence testing. TSCA isn’t perfect, but hopefully it will improve EPA risk assessment.
IRIS is but one of many EPA programs that could be eliminated without sacrificing environmental protection or preventing implementation of environmental laws. Accordingly, TSCA does not provide an excuse to prevent reduction of many of these wasteful and counterproductive EPA programs.
This post was updated on April 26, 2017 to clarify budget data in the original version.