Today, seven of Texas' leading air quality advocates wrote the EPA in opposition to the Texas state toxicologist serving on a key federal clean air panel. The group charges Dr. Michael Honeycutt with “an appearance of a loss of impartiality,” disqualifying him from serving on the EPA's Clean Air Science Advisory Committee (CASAC). CASAC plays a powerful role in setting science-based federal policy on air quality. Read the full letter below.  

June 10, 2015

Mr. Aaron Yeow, Designated Federal Officer

Clean Air Science Advisory Committee, EPA Science Advisory Board

Staff Office (1400R)

1200 Pennsylvania Ave. NW

Washington, D.C. 20460

Via email to

Dear Mr. Yeow:

After review of the guidelines and criteria for nomination to the Clean Air Science Advisory Committee (CASAC), the undersigned groups and individuals oppose Michael Honeycutt’s nomination to the committee. Specifically, we believe that Honeycutt’s nomination fails to meet the criteria of “absence of an appearance of a loss of impartiality.” 

Dr. Honeycutt’s record as the Director of the Texas Commission on Environmental Quality’s (TCEQ) toxicology division shows a consistent pattern of ideological behavior, indicative of the appearance of a loss of impartiality. Examples include, but are not limited to:

  • Under Mike Honeycutt’s direction as Director of the Toxicology Division, TCEQ sponsored an ozone workshop in April 2015. Billed as an independent workshop, the conference presented a one-sided perspective of ozone science. The workshop attacked stronger ozone standards currently proposed by EPA and broadly supported by leading scientific organizations. This point was emphasized repeatedly throughout the three-day meeting, giving the false impression that EPA was engaged in unilateral actions to destroy the US economy by overstating the health impacts of ozone. 
  • Honeycutt has made repeated public statements undermining the integrity of the science on ozone as well as other pollutants, including mercury, indicating that his opinion is based on an ideology rather than scientific assessment. 
  • Honeycutt has made repeated public statements undermining the integrity of the science on ozone as well as other pollutants, including mercury, despite consensus from the medical community on the harms of exposure to such pollutants.
  • Honeycutt routinely takes positions demonstrating a lack of understanding of the relationship between causation and association. 

Additionally, it appears that Honeycutt fundamentally misunderstands the process of setting a National Ambient Air Quality Standard, as he has argued that EPA should have considered problems with implementing a new standard when setting one. In fact Honeycutt consistently takes positions favoring industry and a lax regulatory climate over public health protections. This is consistent with the positions taken by others at the Texas Commission on Environmental Quality, which generally prioritizes the economic interest of the state.

Furthermore, Honeycutt has questioned the EPA’s “conscience” in promulgating a new ozone NAAQS and positioned himself as participating in an ideological battle with EPA, claiming that fighting the agency is “the right thing to do.” Honeycutt has:

  • Doubted the link between ozone and asthma.
  • Claimed that “further lowering of the ozone standard will fail to provide any measurable increase in human health protection.” Despite the fact that the CASAC unanimously recommended a revision of the standard to the 60-70 ppb range.
  • Questioned whether a new ozone NAAQS is necessary because “Americans likely spend at least 90 percent of their time indoors.”

While we understand that the CASAC is intended to represent a diversity of perspectives on the committee, including geographic, economic, social, cultural, educational backgrounds, professional affiliations, and other considerations, we feel that Mike Honeycutt’s nomination does not pass the basic criteria for membership and that he cannot be selected as a member of the committee. 

Honeycutt's work at the TCEQ since the late 1990s in downplaying toxic chemical exposures of radionuclides, benzene, heavy metals, and other pollutants have caused serious concerns and distress in impacted communities after participating in meetings with him or reading his reports. Several of these impacted communities are populated by low-income minority residents who were shocked at the toxicological interpretations of Dr. Honeycutt. Frankly, citizens have found that Dr. Honeycutt speaks more like a representative for industrial companies who have a disdain for the public around their plants than a representative of a state environmental agency. Citizens do not feel they can trust Dr. Honeycutt.

Honeycutt questions or accuses the EPA at every turn. For example, he has:

  • Accused the EPA of “overstat[ing] the health risks of lower IQ and heart disease from mercury[.]” 
  • Claimed that the EPA “ignores good science” and promulgates “‘chicken little’ toxicity values for chemicals…[that]…make the public either jaded or unnecessarily scared.”
  • Opposed the promulgation of a new NAAQS for particulate matter and stated that “There is no scientific basis supporting a reduction in the current standard, let alone a two-fold reduction.”
  • Opposed the EPA’s proposed National Emission Standards for Hazardous Air Pollutants (NESHAP) rule for coal and oil-fired electric utility steam generating units (the Utility MACT rule).

For these reasons, Honeycutt does not meet the CASAC membership criteria of “absence of an appearance of a loss of impartiality.” We oppose Honeycutt’s nomination to this Committee.

Thank you for the opportunity to provide comment on this issue. If you wish to discuss this matter further, please contact Adrian Shelley at, 713-528-3779.


Neil Carman, PhD

Clean Air Program Director

Sierra Club Lone Star Chapter


Elena Craft, PhD

Senior Health Scientist 

Environmental Defense Fund


Ilan Levin

Associate Director

Environmental Integrity Project


Luke Metzger


Environment Texas


Jim Schermbeck


Downwinders at Risk

Dallas-Fort Worth


Robin Schneider 

Executive Director 

Texas Campaign for the Environment


Adrian Shelley

Executive Director

Air Alliance Houston