Thomas Luben is an epidemiologist who for nearly 20 years worked for the scientific arm of the Environmental Protection Agency — the Office of Research and Development — in North Carolina’s Research Triangle Park. His work focused on what are known as the “criteria pollutants,” which are regulated, under the Clean Air Act, by the National Ambient Air Quality Standards, often shortened to NAAQS (pronounced “nacks”).
At the start of the second Trump administration, life for most scientists at ORD changed dramatically: Many research projects were terminated, and rumors began to circulate that the whole division was being eliminated. (Since then, ORD has, in fact, been dismantled.) Last June, Luben, along with more than 150 other EPA staff members, signed a letter objecting to the way the agency was being run. For putting his name on the letter, Luben was fired in the fall. He now works at the University of Michigan’s School of Public Health.
Luben spoke to e360 contributor Elizabeth Kolbert about what it was like to work at the EPA under Trump 2.0, about the implications for the public of getting rid of ORD, and about the future of science at the agency. “I think that it will take a lot longer to rebuild than to break down,” Luben said. “And I also think that attracting, hiring, and retaining great scientists to the EPA or any federal agency after this administration is going to be incredibly difficult.”
Thomas Luben. Courtesy of Thomas Luben
Elizabeth Kolbert: You spent most of your career at the EPA’s Office of Research and Development. Can you tell me what you worked on?
Thomas Luben: During [my] first 13 years at EPA, my main duties were working on the integrated science assessments [ISA], and as time allowed, I could do some research on the side. In 2020, I moved over to do research full-time.
Kolbert: And you were looking at the six criteria pollutants named in the Clean Air Act?
Luben: So the way the Clean Air Act is set up, they identified these standards back in the 1970s, and every five years we’re supposed to review what they call the criteria pollutants to see if anything has changed and to provide the scientific basis so the policy office and policymakers can decide if the current standards adequately protect public health or if a revision is required.
There are six [criteria pollutants]: particulate matter [PM], ozone, nitrogen dioxide, sulfur dioxide, carbon monoxide, and then lead. I took leadership roles in PM and then in the most recent ozone ISA that was finished in 2020, I was the lead scientist.
Kolbert: So basically you were looking at health effects, asking whether we need to tighten these standards?
Luben: Yes.
Kolbert: You came to ORD in 2007. Can you talk a little bit about what a change of administration typically brought to ORD?
Luben: A change in the president often will lead to a change in the EPA administrator, and each administrator comes in with their own priorities. All the administrators would identify clean air, water, healthy people as main priorities, but then some would have other pet projects that they wanted to prioritize. We did not see large changes in how regulations were being promulgated, I would say, in most administration changes.
“By the end of January 2025, we were told to pause any projects related to climate change, environmental justice.”
Kolbert: So day one, Trump 2.0 starts, and we get this slew of executive orders. Are people immediately saying, “What’s going on here?”
Luben: Yes, it was immediate. I was scheduled to give a lecture at Duke University, I think it was January 27, and the topic was climate change and environmental justice. I had cleared the slides and the topics previously, but that morning it was all of a sudden, “I don’t think that you can go do this lecture.”
Kolbert: In those early months, what was actually happening at ORD?
Luben: By the end of January, we were told to pause anything related to climate change, environmental justice. Then management within ORD started going through lists of all the projects that the scientists were working on, to decide what could move forward and what couldn’t. It didn’t take very long. It was in March, I believe, when they moved from paused to closed and we were prohibited from doing any more work on them.
Kolbert: And did this affect a lot of your projects?
Luben: I had three funded projects at the time, and two of them were paused and then closed — on climate change and environmental justice. One was looking at extreme temperatures and health effects, and the other was looking at environmental exposures in historically redlined areas.
Traffic in Oakland, California. Cars and trucks are a major source of particulate pollution. Justin Sullivan / Getty Images
Kolbert: And the remaining project?
Luben: That one was looking at the health effects of air pollutants, and it was directly relevant to the NAAQS. We often would conduct sensitivity analyses or stratified analyses to look at differences in the associations between white individuals and non-Hispanic Black individuals. We couldn’t do that anymore.
Kolbert: And this was communicated to you in person?
Luben: They did not want to put a lot of things in writing. The federal leader of the Office of Research and Development would have Zoom meetings or Teams meetings and convey the messages.
Kolbert: And then in March you started hearing rumors that the ORD was going to be eliminated?
Luben: Yes. And then in May they said, “Okay, we are going to open up a bunch of internal positions [in other divisions], and we are encouraging folks from ORD to apply for these positions.” I think it was somewhere between 600 and 700 jobs.
Kolbert: So people applied, and then no one got any of these jobs?
Luben: No. And then that’s when they started offering the “Fork in the Road” or deferred resignation programs.
“The new administrator’s priorities included clean air and water, but also energy dominance and the incorporation of A.I.”
Kolbert: You decided against the Fork in the Road. Was anything actually getting done at this time, or was everyone just so upset and so freaked out?
Luben: It was a mix. I felt that I became super-productive on the one project I was allowed to work on; that was how I distracted myself and how I could feel like I was doing something. [That project] was a paper that was published a few months ago looking at infant mortality and air pollution.
Kolbert: Would you say there was a theme to what was going on at the agency?
Luben: Yes, I think so. When the new administrator [Lee Zeldin] came in, he came in with his priorities, which included clean air and water for all Americans, so he said, but also energy dominance, the return of the automobile industry to greatness, the incorporation of A.I. These are topics or themes that aren’t typically included in priorities at the EPA by the administrator. And so it seems to be that these are not just EPA priorities but administration priorities, and they seem to benefit industry and corporate America.
Kolbert: Let’s talk about the letter — the Declaration of Dissent — that you signed.
Luben: The second half of June was the first time I heard about the letter. It included five specific points where they thought the current administration was not aligned with the mission of the agency. The one that rang truest and clearest to me was the elimination of the Office of Research and Development. For about a week they were tinkering with the language. Once the letter was finalized, I did sign with my name and my office where I worked.
During that last week, one of the things that was added to the letter was that we were doing this in our personal capacity as public citizens, so I felt really good. I had been at EPA for 18 years. We have to take ethics training every year. I felt like I knew what the ethics rules were and that I was within ethical guidelines of the agency and protected under the First Amendment.
EPA Administrator Lee Zeldin testifies before a Senate subcommittee in May. Kevin Dietsch / Getty Images
Kolbert: What happened after the letter’s publication, on June 30?
Luben: For the first few days, nothing. And then on July 3, I received a letter saying that I was being placed on administrative leave for two weeks.
Then almost two weeks went by, and we got another email saying that we were put on leave for another two weeks. And then they sent us a Google form that had about seven questions. “Were you at home or at work when you signed the letter? Were you on government equipment or your personal device when you signed the letter?”
I answered the questions and sent it back in, and then at the end of August I got a letter. When I opened [it] and saw a notice of proposed removal, I was pretty floored. The vast majority [of the signatories] got a two-week suspension, and then this small handful of us got a notice of proposed removal.
Kolbert: Did you have a chance to respond to that notice?
Luben: I submitted a written rebuttal, and then I orally responded saying that I had never received anything other than a superior performance rating — this punishment didn’t seem to fit the crime. I also highlighted the fact that I often spoke on behalf of the agency.
I was invited to national and international conferences and meetings to speak. I had published 80 papers while I was at EPA. And they responded that [my firing] was for those reasons — speaking on behalf of the agency internationally — that they could no longer trust that I was scientifically objective and unbiased.
“If we start going backwards on air quality and other regulations, I really worry how the health effects will escalate.”
Kolbert: Now you and five others have filed a case before the U.S. Merit Systems Protection Board [MPSB], claiming the firings violated your First Amendment rights.
Luben: Yes. The MPSB was supposed to respond by June 5. I have not heard from my attorney if they completed that or not.
Kolbert: How did people at the agency feel as they watched the dismantling of ORD?
Luben: It’s heartbreaking. It was not uncommon to hear about or see people in tears.
Kolbert: Why should your average American be concerned that ORD has been dismantled?
Luben: EPA is unique for a number of different reasons. It’s a regulatory agency, it’s a public health agency, and it’s a scientific agency. And having a separate Office of Research and Development, where the science was housed completely separate from everything else, was really important to maintaining EPA’s ability to do all three of those roles in an unbiased, scientifically robust way.
Kolbert: ORD was designed to be independent of the politics in Washington. Do you feel like in your time there, prior to the recent year, you were really left to go where the science told you to go?
Luben: Yes, absolutely. I felt like I had a lot of scientific leeway. Expert judgment was routinely called upon and respected and expected.
EPA employees protest in Philadelphia against staffing cuts at the agency in March 2025. Matt Rourke / AP Photo
Kolbert: In terms of the NAAQS, what are the public health implications of what is happening now, specifically with the PM2.5 standards, which were set to be tightened this year?
Luben: The NAAQS were never intended to be a zero-risk standard. There’s always going to be some amount of risk, and that’s where the administrator’s judgment comes into play of what degree of risk is allowable or acceptable. So even though we keep lowering the level, we’re going to keep seeing health effects, even at the lowest levels. So we’re doing our best to protect those who are highly exposed and most vulnerable. But if we start going backwards on the NAAQS and other regulations, I really worry about how those will continue to escalate.
Kolbert: What kind of health effects are we talking about?
Luben: The strongest associations, the strongest evidence, are for cardiovascular effects. So PM2.5 gets into the bloodstream through the lungs, and it affects everything from these really subclinical, small things, changes in blood pressure, heart rate variability, up to and including death due to cardiovascular disease.
The rollbacks that are going on at EPA, the deregulatory agenda, is just super scary. EPA now, they’ve decided not to use the benefits associated with reducing air pollution when they’re doing their cost-benefit analyses for different regulations, which is just arbitrary and inconsistent. And I find that really frustrating.
Kolbert: Do you think the EPA can ever return to scientific independence?
Luben: It’s my sincere hope that we can. I’m an optimist by nature, but I think that it will take a lot longer to rebuild than to break down. And I also think that attracting, hiring, and retaining great scientists to EPA or any federal agency after this administration is going to be incredibly difficult.
