November 7, 2017

The Honorable Scott Pruitt
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Dear Administrator Pruitt:

I write to express significant concerns with the Environmental Protection Agency's (EPA) October 31, 2017, directive on "Strengthening and Improving Membership on EPA Federal Advisory Committees." It is important that EPA decisions are informed by the best available science and scientific advice. The October 31, 2017, directive does not advance this goal. It will likely have the opposite effect.

EPA's scientific advisory committees should be comprised of recognized scientific experts. To arbitrarily eliminate from service on the panels individuals who have research funding from the EPA does not help to ensure that the agency is receiving the best available advice. Scientists are not interchangeable. One cannot simply assume that because two scientists have training in chemistry they are both competent environmental chemists, for example. Moreover, it is folly to assume that every scientist who has received EPA funding will be biased, but scientists working for commercial interests regulated by the EPA or a state or local government are not biased and therefore more competent to serve. All individuals serving on a panel must be held to a high standard of integrity and expected to comply with appropriate and uniform conflict of interest policies.

Ensuring that scientific advisory committees have appropriate representation of expertise and geographic distribution is important. Per the October 31 directive, however, the EPA has put forth a policy that artificially skews the composition of a panel based on geography with no regard for the expertise required by the committee to fulfill its mission. This action does not promote scientific integrity or competent and well-informed decision-making.

To promote public trust in the EPA and to ensure that the best available science is being used to guide decisions, please rescind and re-evaluate the October 31, 2017 directive.

Sincerely,

Robert Gropp, Ph.D.
Co-Executive Director

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