CPR President Rena Steinzor and Senior Policy Analyst Matthew Shudtz sent a letter to EPA Administrator Lisa Jackson this morning concerning the EPA’s Integrated Risk Information System (IRIS). From the letter:
We are concerned that the recent establishment of the SAB Chemical Assessment Advisory Committee (CAAC) institutionalizes yet another opportunity for potentially regulated parties to disrupt the smooth development of new IRIS profiles. We are writing to encourage you to pay special attention to the nominees’ actual and perceived conflicts of interest as you sign off on the final membership list for the subcommittee. Of the 116 nominees, we count only four individuals who work for environmental NGOs. By contrast, five individuals from the Dow Chemical Company alone have been nominated, as have five other people employed by potentially regulated parties and 21 individuals whose consultancy firms stand to gain or lose significant business depending on the outcome of CAAC deliberations. … Individuals whose employers (or employers’ direct competitors) are potentially regulated parties should not be invited to be committee members.
The letter makes a broader point about the role of further review of IRIS profiles, which undergo at least seven reviews by people or entities outside the IRIS office:
For years, we have argued that the draft toxicological profiles produced by IRIS staff are subject to an excessive number of external reviews. … Given the Federal Advisory Committee Act’s requirements about transparency and public participation, we believe that the CAAC review of draft IRIS profiles should replace the independent expert peer review and be melded with the listening session and public review and comment period.
The letter is here.
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Ben Somberg | June 15, 2012
CPR President Rena Steinzor and Senior Policy Analyst Matthew Shudtz sent a letter to EPA Administrator Lisa Jackson this morning concerning the EPA’s Integrated Risk Information System (IRIS). From the letter: We are concerned that the recent establishment of the SAB Chemical Assessment Advisory Committee (CAAC) institutionalizes yet another opportunity for potentially regulated parties to […]
Lisa Heinzerling | June 14, 2012
Cross-posted from Georgetown Law Faculty Blog. Despite initial signs suggesting a different path, the Obama Administration has promoted the role of cost-benefit analysis in regulatory policy as fiercely as any administration before it. Nothing demonstrates this more clearly, I think, than the Administration’s bizarre and unfortunate decision to apply cost-benefit analysis to measures to limit […]
Alice Kaswan | June 13, 2012
California environmental justice groups filed a complaint last week with the federal Environmental Protection Agency arguing that California’s greenhouse gas (GHG) cap-and-trade program violates Title VI of the federal Civil Rights Act, which prohibits state programs receiving federal funding from causing discriminatory impacts. They allege that the cap-and-trade program will fail to benefit all communities […]
Ben Somberg | June 12, 2012
Rep. Joe Barton, speaking at a hearing last week, stuck it to President Obama’s EPA (at 39:00): In Idaho, just recently, the Obama Administration went against a family called the Sacketts on a wetlands issue. Again, Mr. Chairman, the Congress sets the rules, and the Administration enforces them. This Obama Administration, in the case of […]
Lisa Heinzerling | June 8, 2012
Cross-posted from Georgetown Law Faculty Blog. When an agency defends over three decades of inaction on an important problem by saying that acting would take too long, one hopes a judge reviewing the agency’s inaction will see through the pretense. This is exactly what happened this week, when a federal magistrate judge in New York ruled […]
Martha McCluskey | June 8, 2012
The natural gas industry’s campaign against increased federal oversight of shale gas development has recently produced a spurt of “dirty science” minimizing the environmental risks of hydraulic fracturing, or “fracking.” The University at Buffalo, the branch of the State University of New York where I teach, recently launched its new “Shale Resources and Society Institute” […]
Ben Somberg | June 6, 2012
The House Energy & Commerce Committee’s Subcommittee on Energy and Power holds a hearing today on “EPA Enforcement Priorities and Practices.” CPR Member Scholar Joel Mintz, Professor at Nova Southeastern University Law Center, will be testifying. From his testimony: .. during the eight years of the George W. Bush administration, the civil penalties assessed against […]
Yee Huang | June 5, 2012
Today CPR releases Manure in the Bay: A Report on Industrial Animal Agriculture in Maryland and Pennsylvania. The paper provides a snapshot of the federal Concentrated Animal Feeding Operations (CAFO) permit program under the Clean Water Act (CWA) and how these states are implementing this program. The report provides recommendations for strengthening these programs to […]
Holly Doremus | June 4, 2012
Cross-posted from Legal Planet. The en banc 9th Circuit issued its opinion Friday in Karuk Tribe v. US Forest Service. This opinion brings a welcome reversal of a panel opinion from last April which had ruled in a split decision that the Forest Service did not have to consult with the wildlife agencies before authorizing […]