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Chris Frey


Q&A: This air pollution expert advised EPA for a decade. Now, he’s a leading critic

This week, a key science advisory panel to the U.S. Environmental Protection Agency (EPA) will meet to review recent research on a particularly dangerous form of air pollution: tiny soot particles, which have been shown to damage lung and heart function and contribute to premature death.

Such meetings, designed to help EPA meet a mandate to review air pollution regulations every 5 years and revise them if necessary, typically attract little notice. But the 12–13 December meeting of EPA’s Clean Air Science Advisory Committee (CASAC) in Washington, D.C., has drawn unusual attention—and sparked a surge of criticism. In large part, that’s because President Donald Trump’s administration has dramatically remade the committee’s membership, appointing all seven of its members. It has also dismantled a 26-member Particulate Matter Advisory Panel that traditionally was tasked with advising CASAC on soot pollution. (That move was criticized yesterday by two of the current CASAC members.)

The administration says the changes, which are just one part of a larger (and also controversial) effort to remake EPA’s science advice process, are aimed at streamlining and accelerating CASAC’s work. But critics say they are mostly designed to reduce the voice of independent experts in agency decisions and to ease the administration’s efforts to weaken existing air pollution standards or block the imposition of tighter limits. EPA’s standards for particulate matter have been a particular flashpoint. Although the nearly 2000-page science summary that CASAC will be reviewing suggests current U.S. standards are too lax, many industry groups and conservative lawmakers fiercely opposing any tightening of the standards, arguing they would be too costly, even as other nations move to crack down on soot.

One scientist who has emerged as an especially vocal critic of the changes to EPA’s science review process is air pollution specialist Chris Frey of North Carolina State University in Raleigh. He served as CASAC’s chair from 2012 to 2015, and also served on the recently disbanded particulate review panel. Between 2007 and 2018, Frey led or served on CASAC panels that reviewed the state of the science on ozone, sulfur dioxides, nitrogen oxides, lead, and carbon monoxide.

Over the past several months, Frey has been widely quoted in articles examining the Trump administration’s air pollution policies. He has also written analyses and helped organize several lengthy letters from former members of EPA advisory panels commenting on CASAC issues. Yesterday, for example, Frey and 14 other members of the now disbanded particulate review panel sent the CASAC a 134-page comment on its upcoming review of soot science.

It includes some scathing criticism. EPA’s changes “are collectively harmful to the quality, credibility, and integrity of the scientific review process,” they write. And, “The current 7-member CASAC does not have the depth or breadth of expertise needed for the particulate matter review, nor could any group of this size cover the needed scientific disciplines.” Panel members are no longer chosen for their “scientific expertise first and foremost,” they write.

ScienceInsider recently spoke with Frey about his experience and concerns regarding CASAC, the origins of his advocacy, and advice for early-career scientists. The interview has been edited for clarity and brevity.

Q: What is CASAC?

A: Section 109 of the [federal] Clean Air Act [CAA] says that the [EPA] administrator will “appoint an independent scientific review committee composed of seven members including at least one member of the National Academy of Sciences, one physician, and one person representing state air pollution control agencies.” Whether to retain or revise or set new standards has been the main focus of what people think of as CASAC’s role.

CASAC is also asked to advise the [EPA] administrator whether there are areas of uncertainty that might be priorities for new science for a new review cycle … [and to] advise the administrator on the so-called adverse effects of implementation of the standard. That’s been controversial because it’s very clear that EPA may not consider cost or technical feasibility when setting standards. That is [described in] a Supreme Court decision written by the late Justice Antonin Scalia. His interpretation was crystal clear that, under the CAA, Congress intended for EPA to set the standard based on health effects and that cost was not an allowable consideration.

A challenge of asking CASAC to get into the effects of implementing a standard is that those [involve] issues of costs and technical feasibility. Historically, CASAC has not provided that kind of advice—in large part because EPA hasn’t asked for it. However, some observers note that the CAA says that CASAC “shall” provide that advice, implying that it’s mandatory. I think that’s a legal debate. The reality is that since EPA hasn’t asked for that advice, it hasn’t developed assessment documents that would provide a scientific basis for providing that advice.

Q: You have been critical of the Trump administration’s appointments to CASAC. Why?

A: The words I keep coming back to are that the CAA requires a thorough review based on the latest scientific knowledge, and further requires EPA to appoint an independent scientific review committee. All of that language confirms to me that the scientific review committee needs to be comprised of scientists who know the latest scientific knowledge.

I mention that because former EPA Administrator Scott Pruitt wrote a [2017] memo that changed the membership criteria for appointments to EPA federal advisory committees generally, including CASAC. Pruitt stated that key membership criteria of all EPA advisory committees is that they should be based on geographic diversity and should include members from state, local, and tribal agencies, with no distinction regarding science committees.

Those are not inherently bad things in themselves, but they are not consistent with finding the best scientific experts. For a science committee, it is not really necessary to have geographic diversity or more than the minimally required representation. It doesn’t make CASAC four times better to have four representatives from a state agency instead of one.

The concern I have is that, as a group, this is not the right composition to have for CASAC. Many of the [current members] are not on the cutting edge of the latest research. Some of them, it’s been a while since they’ve done things related to air. There is, kind of shockingly, no epidemiologist on CASAC. That’s a central scientific discipline in the review of most of these air quality standards, including ozone and particulate matter.

It’s a very curious combination. It just doesn’t have enough horsepower do to what it needs to do.

Q: What is the remedy?

A: My colleagues and I have strongly called for rescinding [the changes instituted] by former administrator Pruitt. Part of our argument is that imposing those criteria on CASAC is inconsistent with its mandate under the CAA and inconsistent with 4 decades of practice. They were created with the flick of a pen and could be rescinded with a flick of a pen, too.

Q: How did you come by your bent for advocacy?

A: I grew up in Manhattan [in New York City]. As a child, I remember large flakes of soot would come from the sky, almost an inch in width or length. I never liked those. I wrote an essay when I was 9, “Air pollution is bad for people and animals too.” Maybe that was my first advocacy piece.

I’ve always been interested in the public significance of science. I did a Ph.D. in engineering and public policy that gave me some quantitative tools that helped bridge the gap between science and policy. I had some opportunities early in my career to get involved in science advising which is something I tremendously enjoy.

Policy questions are coming at us faster than science can provide answers. For policymakers, that means there’s often uncertainty. Something like an air quality standard is based on value judgments that don’t uniquely belong to scientists. We may have unique expertise, but we don’t have any unique privilege.

Q: Has your advocacy cost you professionally?

A: I’m a tenured professor, so having an opinion is not one of the reasons I can be fired. Not everyone is in that position. What I’m doing now is advocacy for science, for a process not an issue. I’m not at a point in my career where I’m ready to do issue advocacy. I’m not going to chain myself to a fence because of an issue, unless it’s science advising.

Even if you’re an early career researcher, however, if you have unique knowledge [such as on air or water pollution], there is some responsibility to do something. Even if it means sharing it with someone else, or engaging someone else to take it the next step, or to be engaged yourself.

Advocacy isn’t the first thing to do if one is building their research program. Establish your individual niche as a researcher and scholar. Be mindful that that’s a very special and precious thing. The reputation you build is your most important asset, hard to build but easy to destroy.