CRE Alert on IQA Violations in EPA’s Ecological Risk Assessment for Atrazine
Mr. Vaughn Noga
Chief Information Officer
Environmental Protection Agency
William Jefferson Clinton Federal Building
1200 Pennsylvania Avenue, NW Washington DC 20460
On behalf of the Center for Regulatory Effectiveness (CRE), I am sending you the attached
Information Quality Act (IQA) Alert. The IQA Alert concerns EPA’s preliminary ecological risk
assessment for atrazine (“ERA”).
The attached Alert addresses the ERA’s IQA flaws and omissions, which include violations of OMB’s recent Memorandum Improving Implementation of the Information Quality Act (April 24, 2019). Several of the ERA’s IQA violations also violate the Federal Insecticide Fungicide and Rodenticide Act (“FIFRA”
The comment period on the preliminary atrazine ERA ended October 5, 2016. We have not seen any EPA response to CRE’s comments on the preliminary atrazine ERA or to any other public comments the agency has received. We are concerned that a very flawed and misleading document continues to be publicly disseminated. Consequently we request that EPA respond publicly to CRE’s atrazine IQA Alert before EPA issues a proposed Interim Registration Review Decision or takes any other substantive action in the atrazine registration review.
Respectfully,
Jim Tozzi
Director
Center for Regulatory Effectiveness
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