Let’s continue
Chapter 13: the EPA
This chapter appears to be a lot of laws and regulations, and the general theme is “no”
CAA Section 111
If a law is proposed and not finalized within a year, it get’s pulled
Radiation
Assess and update the agency’s radiation standards so that they align with those of other agencies, including the Nuclear Regulatory Commission, Department of Energy, and Department of Transportation, as well as international standards.
Page 427
Do we want to follow international standards, or no?
Personnel, Budget, and Office Restructuring
Require regional air offices to receive approval from OAR before moving forward with enforcement actions in order to ensure that enforcement is meeting the requirements established by regulations and is not going beyond them.
Page 428
Look, we can’t have some areas having better air quality than others.
OFFICE OF WATER (OW)
Its two main statutes include implementing the Clean Water Act (CWA) and Safe Drinking Water Act (SDWA). OW has generated a large number of expansive regulations that infringe on private property rights, most notably with the Waters of the U.S. program.
Page 428
Do you like clean water? Enjoy it while you can. My property rights trump anything you need.
Needed Reforms
The August 6, 2019, “Office of Water Policy for
Draft Documents” memorandum28 should be strictly enforced to ensure transpar- ency as well as good governance by not letting guidance linger in draft form and by also ensuring that guidance documents are clearly just that: guidance. They do not have the effect of law and should not be treated by the office as if they did have any such effect.
Page 428
Basically here they are worried we might make a better world for NO REASON.
Shockingly, the writers do want to spend more money on the Clean Water Act.
OFFICE OF LAND AND EMERGENCY MANAGEMENT (OLEM)
OLEM’s main function is to oversee the execution of cleanups under CERCLA and RCRA; therefore, it is critical that OLEM staff focus on project management more than policy creation
Page 431
They want to hire people with training in project management, not science.
New Policies
Revise groundwater cleanup regulations and policies to reflect the challenges of omnipresent contaminants like PFAS.
Revisit the designation of PFAS chemicals as “hazardous substances” under CERCLA
Page 431
Am I reading this right? They want to allow plastics in everything?
RCRA
To streamline waste management, the following changes are needed in the Office of Resource Conservation and Recovery (ORCR):
Change the electronic manifest (e-manifest) regulations to a 100 percent electronic system and eliminate all paper manifests and manual filing and data input. This system should operate from a range of common handheld devices and could be expanded to accommodate solid waste and materials for reuse and recycling.
Page 432
Weren’t these the same people upset with Elogs for truck drivers?
Personnel
Eliminate or consolidate the regional laboratories and allow OLEM to use EPA, other government, or private labs based on expertise and cost.
Page 432
This whole thing starts with wanting to regionalize everything, now doesn’t want to.
OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION (OCSPP)
OCSPP is constantly pressured to ban the use of certain chemicals, typically based on fear as a result of mischaracterized or incomplete science.
Page 433
Remind me again how these people feel about hormone blockers.
Needed Reforms and New Policy in OPPT (Chemicals)
Ensure that decision-making is risk-based rather than defaulting to precautionary, hazard-based approaches like the Integrated Risk Information System (IRIS).
Page 433
When it comes to chemicals running into my water and land, I’d actually prefer it to be precautionary.
Also, where does Tennessee fall in here with their banning chem trails? Where’s there science and “risk based” analysis?
Needed Reforms and New Policy in OPP (Pesticides)
ESA reform for pesticides is necessary. When approving pesticides, FIFRA allows for cost-benefit balancing, recognizing that pesticides are effective precisely because they harm pests. However, the ESA does not allow for any consideration of the beneficial effects of pesticides. In order to meet ESA obligations, pesticide uses are severely restricted, leaving growers with limited tools for crop protection.
Page 435
Have you considered spraying poison is actually good for things?
With regard to OPP (pesticides), pesticide manufacturers feel that the program is underfunded and would like its budget to be increased so that pesticide actions can be reviewed more quickly. Manufacturers are also willing to pay higher fees to the fee-based portion of the program. However, grower groups have been disappointed by EPA’s actions and have significant concerns about EPA’s ability to conduct science-based risk assessments and take risk management actions that appropriately balance benefits and risks as required by FIFRA. Guardrails and third-party audits should be part of any funding increases through the Pesticide Registration Improvement Act (PRIA) or other mechanisms.
Page 435
Again, these are the people upset about chemtrails, but they want to have fewer safety precautions when it comes to poison on your food.
Suspend and review the activities of EPA advisory bodies, many of which have not been authorized by Congress or lack independence, balance, and geographic and viewpoint diversity.
Page 437
All I see when I read this is “stop funding until we get our people in place”.
The next post should be in for this chapter, but, speaking of pesticides and water, I need to get my garden planted before it gets any later in the year. And, I don’t use any pesticides.
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