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Real Environmental Protection: Not a Paper Exercise

February 2012

Citation: ELR 10166

Author: Douglas T. Nelson, Joshua Saltzman, William K. Rawson, Claudia O’Brien, and Bart J. Kempf

In an Article published in the October issue of the Environmental Law Reporter, Elisabeth Holmes and Charles Tebbutt argued that H.R. 872, a bill that would amend FIFRA and the CWA as they pertain to aquatic pesticide applications, should not be enacted. To the contrary, H.R. 872 is a commonsense approach to harmonizing regulatory obligations under FIFRA and the CWA, and it should be enacted promptly. NPDES permits for aquatic pesticide applications are not needed to protect human health and
the environment because EPA already possesses the tools under FIFRA to do the job. Additional CWA permitting requirements are not only unnecessary, overly burdensome, and expensive, they would also place unwarranted strains on governments, the regulated community, and the public in this time of economic uncertainty.

Douglas Nelson and Joshua Saltzman are, respectively, Executive Vice President/General Counsel and Assistant General Counsel of CropLife America, the trade association of the manufacturers, distributors, and formulators of crop protection and crop bioengineered products. William Rawson and Claudia O’Brien are partners, and Bart Kempf is an associate, at the law firm of Latham & Watkins in their Washington, D.C., office.

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