“Killer Fog”& Bringing Science Back To The EPA — Whether The EPA Wants It Or Not

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Sometime in the 1940s–1950s, a young, passionate socialite activist supplied her alibi to Nero Wolfe: “I dined with the governor to discuss ‘killer fog.'”

Nero Wolfe was educated about everything, and he agreed with her on the automobile pollution she referred to as “killer fog.”

Wolfe inquired, “Are you referring to the London event?”

Archie, his side kick, laughs and explains to Wolfe, “Mrs. Valdon thinks the air has somehow become poisonous, see.”

Without a heartbeat before his response, Wolfe says, “Probably is.”

Mrs. Valdon, earnestly explains, “Archie, it is sulfur dioxide. We are going to poison ourselves to get home from the office 5 minutes sooner.”

The campy mystery flips back to the trail of a murderer for a while. There is another notable sequence in the styled 1940s episode of Nero Wolfe, however. We find Mrs. Valdon addressing a group eager to learn, 1940s styled budding activists, about the inherent horrible health issues of killer fog. Lucy Valdon was right.

News of killer fog is not new news. Electric cars were also possible in the past. There were educated people knocking common sense around in circles early on in the ICE (internal combustion engine) automobile explosion and talking about the downside of “Killer Fog.”

And well before Lucy Valdon in Nero Wolfe was Henry Ford’s wife and her vehicle preference. She was one of the girls that had some sense EVs were better. TIME magazine (h/t GM-Volt forum) notes, “Girls dig electric cars. At least that was the marketing message back in 1915, when petrol-powered autos were beginning to decisively pull away from electric ones.”

CleanTechnica earlier reported that many women of the early 20th century, along with Clara Ford, were leading the way for the coming Lucy Valdons in the 1940s protests about “killer fog.” It’s simply common sense when you think of it. Clara Ford apparently wouldn’t drive the Model T. She stuck to her electric car instead, a 1914 Detroit Electric.

Lucy Valdon was right. What Lucy Valdon called killer fog we are calling exhaust, emissions, air pollution, fine particulate matter.

The benefit of a draconian head of our nation is that many Lucy Valdons are more active in a broader “do it yourself” movement. Private citizens, companies, state and local governments, and others are stepping up to address the environmental and scientific concerns — in effect filling the collapsing structure that activists like Lucy, Lois Gibbs, and many more fought so hard to establish. There is a hole, a bottomless quicksand, created by the Trump administration’s lack of concern for public health and safety. Caring citizens are trying to build solutions.

In the present, modern day, the intelligent fight for clean air continues. On the blog of the Union of Concerned Scientists, Gretchen Goldman, Research Director at the Center for Science and Democracy, sent out a blog post on the same matter:

“For decades—under both Republican and Democratic administrations—the EPA has followed a long-standing science-based process for setting health-based ambient air pollution standards. This process has reliably ensured the nation’s ambient air pollution standards protect public health and welfare. The process has worked remarkably well over the years, even in the face of outside pressures to set weaker standards than the science suggests.

“But the Trump Administration has taken a wrecking ball to this process (Full timeline here).” Here’s that timeline:

• 31 October 2017: Pruitt Memo on Grants and Advisory Committees

Then-EPA Administrator Scott Pruitt issues a memorandum banning scientists with current EPA research grants from serving on science advisory committees, while permitting individuals from regulated industries to continue to serve. The move forced several scientists on EPA’s seven science advisory committees to either step down or give up grants they were awarded in order to continuing serving.

• 12 April 2018: Presidential Memorandum on NAAQS

Presidential Memorandum orders the EPA to make sweeping changes to implementation of the National Ambient Air Quality Standards (NAAQS), including requiring science advisors to consider non-scientific information, restricting the science that can be used in decisionmaking, and shifting responsibility to the states without increasing their resources.

• 9 May 2018: Pruitt Memo on NAAQS Process

Then-EPA Administrator Scott Pruitt follows the president’s memorandum with his own, articulating details of how he will implement the orders at the agency. The Pruitt Memo announces that EPA will follow an expedited timeline for review of the National Ambient Air Quality Standards for particulate matter and ozone, and that the kinds of scientific information EPA can use in its ambient air pollutant standard policy decisions may be restricted.

• 10 October 2018: PM Panel Disbanded

EPA leaders disband the Particulate Matter Review Panel and announce they will not convene an Ozone Review Panel, bodies of independent expertise that have informed air pollution standard reviews for decades. At the same time, EPA leaders replace the members of its Clean Air Scientific Advisory Committee (CASAC) largely from academic institutions with those from state and local regulatory agencies, led by an industry consultant.

• 11 April 2019: CASAC Lacks the Needed Expertise

In an unprecedented move, CASAC sends a letter to EPA Administrator Andrew Wheeler acknowledging that the seven-member group needs additional expertise to adequately advise the agency on the particulate matter ambient air quality standard.

• 5 September 2019: PM Policy Assessment Released

The EPA Draft Policy Assessment for Particulate Matter is released. The document is inclusive of the risk assessment (which has been a separate document in recent history) and considers the agency’s Integrated Science Assessment, which characterizes the state of the science on particulate matter and health and welfare effects.  The Policy Assessment recommends that in order to protect public health with an adequate margin of safety, as the Clean Air Act requires, the primary fine particulate matter standard should stay the same or be tightened.

• 13 September 2019: Consultants Appointed

Rather than appoint a Particulate Matter Review Panel as CASAC and the broader scientific community have asked, EPA leaders appoint a group of consultants to supplement the seven-member CASAC in its review of the particulate matter standards. The consultants will be available for a highly controlled Q&A process, where committee members’ questions must be asked by the committee and answered by the consultants in advance of CASAC’s meeting. Unlike the Particulate Matter Review Panel, the consultants will not be able to engage with the committee or with each other in real time and will not be able to deliberate on topics outside of the narrow questions they are posed.

• 18 September 2019: CASAC Meeting Structure Announced

The CASAC meeting to discuss the Policy Assessment for the Particulate Matter National Ambient Air Quality Standards review is set for October 24 in North Carolina. In an atypical move, the meeting will detach public comments as a separate teleconference two days prior. One challenge with this structure is that public commenters may not have access to the committee members pre-meeting comments and agency briefing material. If all materials are not available by October 22, this would limit the ability of the public to make informed comments to CASAC and the EPA in their discussion of the particulate matter standards.

The administration intends to finish the ambient standard reviews for both particulate matter and ozone by the end of 2020. Stay tuned for new developments as EPA leaders strive to meet this tight timeline.

Ken Kimmell, president of the Union of Concerned Scientists, continues the story:

“A ‘voluntary panel’ comes to the rescue.”

“… This group of scientists, formerly comprised an official ‘pollutant review’ panel set up under the federal Clean Air Act to give expert advice to the EPA on PM 2.5. In October 2018, this panel was disbanded by EPA. Rather than sitting by idly and disempowered, the twenty scientists on this panel decided to meet this week and essentially duplicate what they would have done had they not been disbanded; i.e., review the scientific literature on PM 2.5 exposure and risk, engage in a rigorous debate, and recommend standards that adequately protect public health and welfare.”

Kimmell continues by explaining the legal implications and summarizes, “The panel’s voluntary work here can help with this legal Catch-22. While this panel is no longer an official government advisory group, it is likely that a reviewing court would give its recommendations significant weight. After all, the ‘voluntary panel’ is made up of the same recognized experts from around the country that previously were set to advise the government, and a reviewing court is likely to look skeptically upon EPA if it were to deviate from the panel’s recommendations. Thus, the work of this voluntary panel can provide a check upon EPA and assist in litigation if a weaker standard is challenged in court. …

“This is one blessing of our system of government: when the federal government does not do its job, others, including private citizens, can fill in. While this is not a substitute for a robust federal government committed to science-based policy, we can all be grateful that the scientific enterprise continues, and these twenty scientists deserve our thanks for keeping this important work alive.”

The full stories from the Union Of Concerned Scientists blog can be found here:

• The EPA Cut Science Out of Air Pollution Standard-Setting. We’re Putting It Back.
• Bringing Science Back to the EPA — Whether EPA Wants it or Not.

If we cannot do away with cars, at least we can improve them. The good news is that people are voting with their dollars to get rid of “killer fog.” Well, Clara Ford and Lucy Valdon are smiling if they read these stats.