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Informed Discussion of Beekeeping Issues and Bee Biology

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Subject:
From:
James Fischer <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Wed, 16 Sep 2015 08:49:23 -0400
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The statements attributed to an unnamed, but high-level Government person
are not at all credible, as they are breathtakingly dismissive of a very
basic (First Amendment, even!) right:

"...to petition the Government for a redress of grievances..."

If any US government employee wants to call performing their basic duties
under the Constitution a "drain on agency resources", then they have
forgotten who they work for, and should be fired on the spot.  It is
therefore far more likely that these words were not those of a responsible
senior-level government official than anything else.

By definition, money cannot be not "wasted" when policy changes are sought
by citizens, and they merely follow the rules set up by the agency itself.
The plaintiffs went before an administrative law judge, and then appealed
that ruling to the district court, which is not merely their right, but is
the ONLY POSSIBLE MECHANISM by which citizens can hope to change EPA policy
for the better.

I think it is clear that, regardless of where one stands on pesticide
issues, all can agree that the current process is not meeting anyone's
needs.  So change can only be a good thing.

"It's my understanding  that the lawsuits expend large amounts of tax
dollars that could have been used toward assessing chemicals and enhancing
risk assessment tools/methods.  This "expense", from my perspective, is in
large part due to science staff involvement..."

The statement above is strictly true, but highly misleading, as the EPA is
itself a regulatory body, so its actions must involve its "science staff" in
the quasi-litigation of "prosecuting an approval".  The EPA staff does no
significant research of its own - it simply reviews the work of the actual
outside researchers who do the studies.  This "science staff" is always
preparing the same sort of documents, and they are legalistic no matter if
the review is purely internal or external (before an admin law judge or in a
real court).  So if the "science staff" did their work properly, they do it
once, and the same documents are equally useful in all forums, internal and
external.   The science staff does not set policy, and therefore cannot
change or enhance "how risk is assessed", so this aspect of the statement is
very highly misleading.  The way the EPA assesses risk is one of the basic
things that most people would call "broken" about the EPA.

"...directed to feed the coffers of lawyers retained  by various advocacy
groups."

I'm in complete agreement with the above, even if it might not be the actual
words of a "senior official".

Regardless, I was not saying that the EPA that screwed up  - I was pointing
out the errors  of the plaintiffs, which included some beekeepers, remember?


Sheesh, does anyone remember their civics class?  Does anyone actually
believe that we really have an EPA senior employee being so dismissive of
even the successful efforts of beekeepers to force that agency to change how
it does business?   Naw, I'm not buying it.  

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