Michelle Miller
--------------------------------------------
Dear Wisconsin Friends:
Tomorrow, on the morning of the next TRAC meeting the public interest
group members of the TRAC plan to resign. My letter captures several of
the key problems from our perspective. Decisions like this are always
difficult to make. They come down to whether the process holds any
hope of generating enough benefits to justify the committment of financial
and human resources. At this juncture, for me it does not.
If any of you have any questions are comments, please feel free to call
and talk to me about this decision. Sarah
The Honorable Peter Robertson, Deputy Administrator
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
The Honorable Richard Rominger
Deputy Secretary of Agriculture
14th Street and Independence Avenue NW
Washington, DC 20250
Dear Deputy Administrator Robertson and Deputy Secretary Rominger:
A year ago you asked me to serve as a member of the EPA-USDA
Tolerance Reassessment Advisory Committee (TRAC). In your invitation
you stated that there would be four public meetings and that our term of
service would end in September 1998. You explained the charge given
to the TRAC by Vice President Gore in his April 8 letter was to apply
sound science in decision making, make the regulatory process
transparent, enhance consultations with stakeholders, and provide
strategies for a reasonable transition for agriculture. I participated
actively in the TRAC process. I appreciated having the opportunity to
make two presentations at TRAC meetings on World Wildlife Fund's work
on transition strategies in agriculture. The TRAC process, I believe has
contributed to improvements in stakeholder understanding of the process
and challenges EPA, USDA and the regulated community face in
implementing FQPA.
However, at the end of the fifth TRAC meeting on September 15-16, 1998
I conveyed my opposition to additional TRAC meetings. I was concerned
that limited Agency financial and human resources were being diverted
away from the work needed to meet the August 1999 deadline for
reassessing a third of the food tolerances, with a focus on those food
tolerances that pose the greatest risk. I reiterated my reservations about
additional TRAC meetings in a January 18, 1999 memo co-signed by
several other public interest groups. In this memo I informed you that my
continued participation on the TRAC was contingent upon reasonable
progress in the following two areas (1) the Agency needed to
demonstrate its intention to meet the August 1999 deadline for reviewing
most if not all of the organophosphate tolerances and its resolve to
initiate, where appropriate, regulatory actions to mitigate excessive risks
identified through the FQPA risk assessment process and 2) USDA and
EPA needed to develop and put forth for public comment a credible
transition plan for agriculture.
We are now three scant months away from the August 19899 deadline.
While EPA will succeed in reaching the goal of reassessing a third of the
food tolerances on the books, they have not yet reassessed the
tolerances for the priority pesticides that pose the greatest risk to kids,
farm workers and/or the environment. No decision on that subset of
high-risk pesticides leaves everyone-kids, farmers, farm workers, food
processors, consumers and our precious biodiversity-vulnerable. The
inability of this Administration to make hard choices in the face of
uncertainty does not mean that continued use of these pesticides are
safe, but instead that EPA could not meet its statutory deadlines.
Rapidly evolving scientific knowledge about the potential impacts of toxic
chemicals on humans, wildlife, and ecosystem functions certainly
involves some uncertainties. Sometimes there is complexity in determining
the extent of environmental health problems, and we often are missing
certain types of information. Continued inaction carries with it manifest
risks to children's health, workers, and the environment. EPA cannot
expect to garner consensus in the near term from all stakeholders as to
the harms resulting from reliance on all pesticides. Faced with
uncertainty, EPA must apply the precautionary approach embraced in
FQPA. The agency must decide how to implement the law using
defensible science, and, as charged by the Act and as articulated by
President Clinton, make hard decisions under this law that "puts the
safety of our children first."
Sound science does not mean consensus on the science, transparency
does not require full agreement on decision making, and consultation
does not oblige endless debate. Confusion over these terms has
resulted in the equivalent of a "Melissa virus" in the EPA decision making
process. Leaving the doors open for continual input of data, studies, and
stakeholder opinions on science and policy interpretation has clogged the
decision making network and brought the regulatory process to a near
standstill. No FQPA-driven decisions on the handful of key pesticide
uses that underlie risks to kids, farmers, farm workers, and the
environment is a benefit for only those that are currently profiting from
the status quo.
The lack of regulatory action on high profile risk drivers also exposes
farmers, food processors, and retailers to economic risks from eroding
consumer confidence in the safety of our food system. In the face of
this uncertainty, many processors and retailers have elected to implement
their own, more stringent, standards to protect their markets. Therefore,
the question must be asked, "who benefits from the current regulatory
stand still?" Not kids, not the environment, and not significant portions
of
the food system.
On a personal note, I believe that the FQPA, in tandem with other
environmental laws, offers an historic opportunity for forging linkages
between agricultural and environmental interests which could result in
renewed public investments in identifying and accelerating adoption of
environmentally and economically viable farming systems. Failure to
implement the Act undermines the bold actions taken by many farmers,
food processors, researchers, independent crop consultants, and
agriculture input suppliers to meet the challenge of producing food and
fiber for the world in economically and environmentally sustainable ways.
Weakening the regulatory hammer will make the courageous actions of
the agricultural leaders, like the farmers I work with in Wisconsin, who
are taking risks to get ahead of the regulatory curve seem foolish if the
rewards, at least in the short run, go to farmers who remain intransigent.
Is this the message that EPA and USDA want to perpetuate-those that
fight safer food production systems and a cleaner environment will be
rewarded? None of us can afford to let this be the FQPA take home
message.
As you know, I am especially interested in contributing to the
development of strategies to transition agriculture away from reliance on
high-risk pesticides and toward farming systems that are environmentally
and economically viable. However, I do not believe this can be achieved
through the TRAC. I am therefore, informing you of my decision to resign
from the TRAC effective immediately. If and when EPA and USDA take
the kinds of actions that are needed to mitigate excessive risk and put
forth a credible transition plan, I would be willing to reconsider my
participation.
Sincerely,
Sarah Lynch
Senior Program Officer
Michelle Miller
1233 Jenifer St., #1
Madison, WI 53703
608/255-1503
fax 255-5885
mmmille6@facstaff.wisc.edu
http://www.uwex.edu/ces/susag
http://www.uwex.edu/ces/susconf.
Michelle Miller
Pesticide Use and Risk Reduction Project
Center for Integrated Agricultural Systems
University of Wisconsin - Madison
U.S. Mail: 146 Agriculture Hall 608.262.7135
Campus: 1535 Observatory Drive 608.262.5200
Madison, WI 53706 fax 265.3020
www.wisc.edu/cias/ mmmille6@facstaff.wisc.edu
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