March 30, 2001
The Honorable Christine Todd Whitman
Administrator
Environmental Protection Agency
Ariel Rios Federal Building
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20004
Dear Administrator Whitman:
The National Association of State Departments of Agriculture (NASDA), representing the commissioners, secretaries, and directors of agriculture in the fifty states and four territories, requests that the Environmental Protection Agency (EPA) publish for public notice and comment the modified Consent Decree in Natural Resources Defense Council (NRDC) v. Whitman.
We believe the new activities and regulatory duties required under the modified Consent Decree should be subject to public comment and review before the Court decides whether or not to adopt it. The modified Consent Decree prescribes a set of binding obligations on EPA that must be undertaken according to specific deadlines. These directives could have a profound impact on tolerance reassessments under the Food Quality Protection Act (FQPA) and pesticide registrations under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and directly affect the agricultural community.
NASDA fully supports the goals and intent of FQPA to maintain a safe and wholesome food supply. We encourage the smooth implementation of FQPA through the use of sound science, consultation with stakeholders, and transparency by government agencies, and our members have actively participated on the Committee to Advise on Reassessment and Transition (CARAT) and the Tolerance Reassessment Advisory Committee (TRAC). We believe that providing all stakeholders with the opportunity to comment on the Consent Decree will help establish a more open and predictable process for EPA decision-making, while maintaining the rigorous health and safety standards of FQPA.
Sincerely,
<signed>
Leon Graves
President, NASDA
Commissioner, Vermont Department of Agriculture
Tommy Irvin
Chairman, Pesticide Regulation Committee
Commissioner, Georgia Department of Agriculture