December 8, 2021
Dear Administrator Regan,
Early last month, ProPublica released a report entitled, "Poison in the Air," that purported to identify "more than a thousand hot spots of cancer-causing air". ProPublica's report included an interactive map that claims to depict the hotspots across the country where "the risk of cancer was above one in 100,000" - a limit that is ten times lower than EPA's acceptable risk limit. In comments published recently following your visit through Louisiana, you said: "We've looked very carefully at your reporting and we're incorporating much of it into our refined and revised system ourselves as well, so that we can begin to address these issues".
The problem with incorporating this reporting into rule making is there are several significant problems with the analysis performed in and findings of the ProPublica report. LCA and its members found serious issues with the following portions of the report:
ProPublica unilaterally chose its own cancer risk factor without citing the criteria that led to that decision.
ProPublica's report relies heavily on data that is nearly a decade old, when more recent, and publicly available data shows drastic emissions reductions from facilities.
ProPublica stated the risk assessment was based on its own software and EPA's RSEI model, despite EPA explicitly saying using RSEI to draw conclusions on such matters is "inappropriate."
ProPublica's location of several facilities on the interactive map is incorrect by several miles in many cases.
While we understand your recent visit through Louisiana, Mississippi and Texas had a full agenda and we were unable to connect with you, the LCA Board of Directors would like to formally request a meeting with you during their upcoming trip to Washington, D.C. The LCA Board, made up of 17 plant managers from facilities across the state, along with the LCIA Board of Directors, will be meeting\,vith the Louisiana Congressional Delegation and other government officials from January 24-28, 2022. If your availability allows it, any time you can allot to this group would be greatly appreciated.
Gregory M. Bowser
President & CEO, Louisiana Chemical Association
CC: Senator Bill Cassidy Senator John Kennedy
Minority Whip Steve Scalise
Representative Troy Carter
Representative Clay Higgins
Representative Mike Johnson
Representative Julia Letlow
Representative Garrett Graves
Governor John Bel Edwards
Secretary Chuck Brown, Louisiana Department of Environmental Quality
Mr. Cedric Richmond, Senior Advisor and Director of the Office of Public Engagement