FW: Comment by 2/16 on EPA PBT Strategy

[Jane Williams <dcap@qnet.com>]

_____________________________________________

NATIONAL WILDLIFE FEDERATION E-MAIL ALERT

Mercury and dioxins are among the most potent poisons on Earth. The 
EPA is proposing a new strategy that retreats from previous 
commitments in the Clean Water Act and other laws to eliminate the 
poisons in our water. Please write to Administrator Browner calling 
for her to strengthen the strategy. 

February 2, 1999

Dear Friend:

Every year over one billion pounds of toxic chemicals are released 
into the environment in the U.S.  The most dangerous chemicals are 
persistent, bioaccumulative, toxic (PBT) chemicals like mercury and 
dioxins. These chemicals can persist for many years or decades, 
building to higher and higher concentrations as they are passed up 
the food chain, where they can poison wildlife, aquatic life, and 
people. 

The threats from these chemicals are very real:

>>Mercury can cause long-term damage to the nervous systems of 
fetuses and young children.   Forty states have issued fish 
consumption advisories due to mercury-contaminated fish.  Mercury 
contamination is deadly to loons -- studies have linked mercury 
poisoning to a massive die-off of approximately 7500 loons in the 
Gulf of Mexico in 1983.  The risks to people also are severe -- 
according to the EPA, up to 166,000 pregnant women are exposed to 
harmful levels of mercury in a given year. 
 
>>Dioxins are extremely potent birth defect-causing chemicals 
produced by incineration of PVC plastics, and in certain 
manufacturing processes.  Research has shown that extremely low 
concentrations -- 60 parts per trillion in tissue -- can kill 50 
percent of young lake trout.

These chemicals are so toxic and persist for so long that simply 
reducing their release into the environment will never be enough. 
The release of these chemicals must be completely eliminated. That 
is why NWF and our allies fought for and won  zero discharge and 
virtual elimination policies adopted by the United States and Canada 
that are designed to eventually eliminate these chemicals from the 
environment.

But now the policies of zero discharge and virtual elimination are 
in danger

The U.S. EPA has published its long-awaited "Multimedia Strategy for 
Persistent, Bioaccumulative, and Toxic (PBT) Pollutants."  The 
strategy takes EPA incrementally in the right direction by focusing 
on all pollutant sources -- air, water, and land; and it is an 
important step in integrating EPA programs that have been fragmented 
and ineffective.  As an effort to implement zero discharge and 
virtual elimination, it is worse than timid; it is actually a 
retreat.  

The EPA strategy abandons the goal of eliminating persistent toxic 
substances in the Great Lakes and other watersheds, and fails to 
propose the most effective policy tools  bans and phase-outs of 
chemicals  needed to achieve that goal. It does so even though the 
EPA is bound by both the Clean Water Act and the Great Lakes Water 
Quality Agreement with Canada to work toward zero discharge and 
virtual elimination goals. 

We need your help

The EPA is accepting public comments on its proposed strategy until 
February 16.  Please write to EPA Administrator Carol Browner before 
Feb. 16 to urge her to develop and implement a strong PBT strategy 
that actually moves us toward these goals. Ask her to amend the 
proposed strategy in these ways:

>>The PBT strategy should include a zero discharge goal that ends 
the release of PBTs.  The current EPA proposal will continue to 
allow significant releases.

>>The PBT strategy should use bans, phase-outs, and sunsetting of 
PBTs. The current EPA proposal relies on the existing permit system 
(which may reduce, but will not eliminate, PBTs).

>>The PBT strategy should require full enforcement and 
implementation of existing programs. The EPA proposal relies on 
inadequate programs and voluntary measures that will not get us 
there.

Please send your letter, with the docket control (identification) 
number of OPPTS-00255 at the top, to (no fax or e-mail option is 
available):

Carol Browner, Administrator
Environmental Protection Agency
401 M St., S.W.
Washington, DC 20460

And, if you have a chance, please send a copy to us at our Great 
Lakes Office:

Andy Buchsbaum, Water Quality Projects Manager
National Wildlife Federation
506 E. Liberty
Ann Arbor, MI 48104
e-mail: buchsbaum@nwf.org

Thank you for your help on this important matter. We must continue 
to fight for clean air, water and soil to protect wildlife, aquatic 
life, and the health of future generations.
                
Sincerely,

Mark Van Putten
President

P.S.  As the number of fish consumption advisories grow and as 
scientists learn that PBT chemicals cause health problems even in 
minute amounts, EPA's Strategy won't eliminate PBT chemicals from 
the environment.  This is unacceptable. Our children deserve better. 
 Please write the EPA to urge the elimination of these toxic 
chemicals.

PLEASE LET NWF KNOW YOU TOOK ACTION BY REPLYING TO THIS EMAIL 
MESSAGE (LEAVE THE SUBJECT LINE INFORMATION INTACT).

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