My comments just delivered to the EPA Science Advisory Board about their draft review letters concerning the Trump EPA proposals for rolling back the Obama fuel economy standards, the science transparency rule, the Mercury Air Toxics Standards rule and the Waters of the United States rule (WOTUS).

Good morning. I’m Steve Milloy. I publish JunkScience.com.

I’ve worked on EPA science and risk issues for almost 30 years now — probably on more EPA issues in more EPA programs than any one of you.

The one thing I can tell you about EPA science and risk analysis is that they are awful across every regulatory program.

The Trump administration is trying to fix that. But the SAB seems to just want to get in the way.

As I understand, the drafts before the SAB today have largely been written by career EPA staff.

It’s no wonder they read like the desperate resistance crusade they are.

Please don’t allow yourselves to be bullied, bulldozed and buried in BS.

I’m concerned you’ll take what’s been drafted, rubber-stamp it and help the resistance defeat the change that America voted for in 2016.

None of these issues is very complicated.

On the fuel economy rule, the simple math is that freezing fuel economy standards won’t discernibly change the climate or air quality.

But tighter standards do make cars unnecessarily expensive, which is especially silly amid a glut of oil.

This forces drivers into older, less safe cars.

That is essence of the Trump analysis. It’s not rocket science. It’s common sense. What is the problem?

On the science transparency rule, EPA-funded researchers have hidden data from independent scientist review for 25 years now.

That secret science has cost consumers, taxpayers, and industry over a trillion dollars without providing any health benefits.

I understand why the PM2.5 fraudsters want to keep hiding their fraud. But why would the SAB help them?

On the MATS rule, if you know anything about coal emissions, you know that they are not a significant source of mercury in the environment.

If you know anything about mercury, you know it’s only harmful if you are poisoned with it. But coal stack emissions don’t poison anyone.

There are no subtle effects that have been teased out by magic epidemiology.

And coal emissions have been cut by more than half in the past decade. Why is the SAB wasting its time on this?

On WOTUS, the SAB seems to have bought into the bogus notion that mere detection of various substances in water is some sort of threat to public health and environment.

That flies in the face of the fundamental tenet of toxicology, the dose makes the poison.

Did anyone actually read the studies cited by EPA staff… or you think that mere citation means they are persuasive and determinative.

You should ask EPA staff for some real-world examples –not hypothetical fantasies — of actual harms caused by the water connectivity of concern. Let’s see if there are any.

The bottom line here is that EPA career staff is using the SAB to throw sand in the gears of the Trump administration.

And then their allies in the #FakeNews media are more than happy to take these ridiculous letters and proclaim the Trump EPA is rolling back environment protection without any scientific basis.

But there was never any science in the first place for the over-regulation we’re talking about.

The Trump EPA is trying to stop job-killing overregulation that produces no public health or environmental benefits.

What’s bad for people’s health is putting them out of work or in unsafe cars. Poorer people take worse care of the environment.

I know a lot of you personally. And I know you joined the SAB to do a good job.

But there are a lot of SAB members who are only interested in opposing the Trump administration.

And that is certainly true of EPA career staff who wrote these letters.

I suppose the good news is that Congress was accidentally wise enough to not compel the EPA administrator to accept the SAB’s advice. Administrator Wheeler wouldn’t be the first to ignore the SAB.

But in this case, that would be a shame you bring upon yourselves.

Thank you.