[BCNnet] Unlucky 7

Karolyn Beebe Karolyn Beebe" <keedo@merr.com
Sun, 16 Mar 2003 21:04:14 -0600


> http://www.saveourbirds.org/ >

Clicking 'Send' brought up an error page, so I sent a copy (below) from my mailbox. Clicking each recipient in the site brought these addys: 

opp-docket@epa.gov ; whitman.christine@epa.gov ; fisher.linda@epa.gov ;  johnson.stephen@epa.gov ; sharp.adam@epa.gov ; gale_norton@ios.doi.gov ; clint_riley@fws.gov ; rick_sayers@fws.gov ; laurie.allen@noaa.gov 

Just select, copy & paste them in the To line. They take the letter to: 
EPA Office of Pesticides Public Docket; Christine Whitman, EPA Administrator; Linda Fisher, EPA Deputy Administrator; Stephen L. Johnson, EPA Assistant Administrator OPPTS; Adam Sharp, EPA Associate Assistant Administrator OPPTS; Gale Norton, Dept. Interior Secretary; Clint Riley, Dept. Interior, Special Assistant to the Secretary for Fish and Wildlife; Richard Sayers, FWS; & Laurie Allen, NMFS. 

--- letter from the site ----

This letter is in strong OPPOSITION to the Advance Notice of Proposed Rulemaking on Endangered Species and Pesticide Regulation proposed in the January 24, 2003 Federal Register and referred to as Docket ID# OPP-2003-0010.  This proposal would allow the Environmental Protection Agency (EPA) to grant itself exemption from Section 7 of the Endangered Species Act (ESA).
Under Section 7, the EPA must consult with the U.S. Fish and Wildlife Service or National Marine Fisheries Service (collectively "the services") on pesticide registrations that may adversely affect endangered species. The decision whether or not to consult is currently made by the services. The proposal would instead enable EPA to make that decision. The services' wildlife experts could be excluded from the Section 7 consultation decision altogether if the EPA so chooses.
Over the past ten years, the EPA has ignored repeated demands from service biologists to conduct consultations. Given the agency's record of consistently failing to consult, I am firmly against any proposal that will take decision making out of the hands of the services and into the hands of the EPA. 
Please do not pursue this or any other proposal that will weaken the Endangered Species Act in any way.

Sincerely,




----- Original Message ----- From: Donald R. Dann  To: BCN (E-mail) Sent: Saturday, March 15, 2003 8:12 AM Subject: [BCNnet] Unlucky 7


Dear BCNnet friend:
 
The Bush Administration is engaged in a serious assault on the Endangered Species Act (ESA), and to understand the severity of the problem a little history is necessary.  
 
The current law includes a provision, Section 7, that mandates the Environmental Protection Agency (EPA) to consult with the U. S. Fish and Wildlife Service (F&W) and the National Marine Fisheries Service (NMFS) for the science required for the EPA to decide on various licensing requests.  For example, when a chemical company would submit a request EPA approval for a particular pesticide, EPA is required to consult with F&W or NMFS for their expertise as to the product's potential harm to wildlife populations.  
 
Notwithstanding this provision no such consultation has occurred in the past 10 years.  This has forced environmental groups to resort to litigation and in every case brought, the courts have agreed with the plaintiff and the appropriate consultation has occurred.  Because this has been such a thorn in the side of EPA and industry, a proposed rule has been promulgated to essentially eliminate the Section 7 requirement.  
 
Not only are bird populations seriously threatened by the proposed rule, but if allowed to stand this could be an opening to seriously weaken the entire ESA.  The EPA has extended the public comment period on the proposed rule until March 25th.  Please go to http://www.saveourbirds.org/ and there is a simple form to tell Christy Whitman, the EPA Director to withdraw this rule.
 
Thanks in advance for your help on this.
 
Donald R. Dann
Highland Park/Lake County