[Featured image, Chester Higgins: East River and Manhattan, 1973]
Dear Mr. Pruitt,
I understand that under Executive Order 13777 your agency is seeking to identify regulations to repeal, replace or modify. I am sure you are hearing plenty from those who would love lift the reins of regulation. I imagine they must now feel like kids in a candy shop – but I’d suggest that they are more like kids in Willy Wonka’s candy factory – a place fraught with danger for the uncontrolled child. Although in this case, we’d all suffer if they are allowed to indulge in their desires.
Sure, there must be regulations in need of updating. Just consider what we’ve learned about the toxicity of increasingly smaller air particles or about the potential for commercial chemicals to cause reproductive and developmental toxicity; or the levels of arsenic that cause cancer. But repeal and replace?
What if EO 13777 had been in place in EPA considered banning DDT in 1972? At that time Monsanto was so worried that they dreamed up a “Desolate Year.” A story about a country without its miracle pesticide, plagued by insects overrun by rats and mice, and bereft of fruits and vegetables. Fortunately EPA went ahead and banned DDT and you and I grew up in times of plenty — without it. And Monsanto seems to have survived as well.
Now there are increasingly innovative options for replacing twentieth century chemical pesticides. Consider the economic benefits and job opportunities that can be realized by developing biologically based pesticides (now a billion dollar industry, with plenty of opportunities for small start-up companies). Even Monsanto is into biologicals (a good thing or not, depending on who you are.)
Imagine if EO 13777 had been in play as the lead industry fought back against lead regulations in gasoline, which at its peak released some 250,000 tons of lead into our air, water, soil and children? The lead industry imposed upon us a toxic chemical that continues to poison children in older homes coated with lead paint. I am sure they had some great economic arguments hoping to sway you towards deregulation. But, we still have cars fueled by gasoline and plenty of house paint.
When EPA first regulated power plants, ordering them to reduce the release of chemicals like SO2 and nitrogen oxides which acidified our rain, or the automobile emissions for carbon monoxide, hydrocarbons and other chemicals, these industries didn’t go out of business — they innovated. Now lakes and forests are recovering.
When you consider axing those so-called “job-killing” or “costly” regulations, please consider the future costs and benefits for human health, environmental health and economic health of this nation. That is your mission, it says so right here. If you are worried about costs that exceed benefits, then consider the past fifty years. While the regulatory process is not perfect, I think few can argue that we are not better off than we were before EPA began regulating the release of toxic chemicals into our food, water and environment.
Submitted for comment, EO 13777. Comment period closes May 15, 2017.