Steve Helber / AP

We got a sneaky look at the Trump transition team's EPA "agency action" plan. It's the guiding (aspirational) document written by Myron Ebell of the Competitive Enterprise Institute.

One of the striking aspects of the document was its language about the agency's use of scientific research and economic analysis to justify its actions. A section titled 'Addendum on the problems with EPA science' leads with this paragraph:

EPA does not use science to guide regulatory policy as much as it uses regulatory policy to steer the science. This is an old problem at EPA. In 1992, a blue-ribbon panel of EPA science advisers that [sic] 'science should not be adjusted to fit policy.' But rather than heed this advice, EPA has greatly increased its science manipulation.

The document goes on to recommend what can be done to "improve the use of science by EPA":

  • EPA should not be funding scientific research
  • If EPA uses scientific data for regulation, that data must be publicly available so independent scientists can review it
  • EPA's science advisory process needs to be overhauled to eliminate conflicts of interest and inherent bias
  • Science standards need to be developed and implemented to ensure that science policy decisions and epidemiological practices are based on sound science

What you should know: A Republican who knows more than most about aspirations colliding with political reality, gives Axios some smart analysis. "It represents a think-tank wish list of possible EOs and budget cuts," he says. He cautioned that this could scare moderate Republicans who want to avoid being tagged as anti-environment.

A tipster gives us three important contextual points regarding the executive orders:

  1. They may be able to implement some of them administratively, but there will be discomfort amongst some Republicans and it will cost the Administration political capital.
  2. It is not a binary process. In other words, they can't just overturn them, it may take some time if they are already in the process of being implemented and opponents will have legal recourse to challenge some of the actions.
  3. There are huge, entrenched bureaucracies at these agencies, and especially at EPA, which is filled with true believers on the environmental movement, climate change, clean water and air. These thousands of people will dig in and make it very difficult for the thin layer of political appointees atop these agencies to move quickly to undo their years of work to put these things in place.

Update: Axios contacted Myron Ebell for comment Sunday night about the action plan, and he didn't dispute the content. After we posted, Ebell said there is a more recent version, with both overlap and differences. He said that because both documents are confidential, he can't say what changed.

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