🚀 go-pugleaf

Steven J. Milloy (milloy@cais.com) wrote:

:                  SCIENCE-BASED RISK ASSESSMENT:
:                  A PIECE OF THE SUPERFUND PUZZLE
: FOREWORD

: This report is a product of the National Environmental Policy Institute's project on Superfund,

Don't be fooled by the title of the Institute, folk - it's an industry
front.  I normally ignore such groups based on the premise that if
they had anything useful to say, they wouldn't hide behind misleading
names.

Besides, it's too hard to read HONEST statements when the margin is
set to 100 characters, much less a pack of lies.

: More important, however, remedy selection is only a partial solution
: for the flawed Superfund  program. The other overriding issue of who
: pays for cleanup must be addressed.

: Currently, the Superfund law relies on the principle of "Polluter pays"
: as implemented through the draconian and Constitutionally questionable
: application of retroactive, strict, and joint-and-several liability
: of parties associated with sites. Whether or not this principle is "fair,"
: it has not worked in the context of Superfund.

Let's see.  If the polluter doesn't pay, who does?  Let me guess, the
public, right?  Hope you didn't mind my putting your post into
readable form...

"It's not fair for the polluter to pay, so the taxpayer should".

: That being said, all risk assessment techniques are not equal.

And let me guess, we're going to go on to state that those favored
by regulators are bad, while those favored by industry are good, and
then we'll call the result "scientific", right?

: Risk assessment as practiced by regulatory agencies, however, has become
: a stagnant and even regressive process that relies only minimally on
: science.

Ahhh...I could've read the stars for Nancy Reagan.

: 1. In the remedy selection process, policy-based risk assessment should
: be replaced by science-based risk assessment.

Sounds like a high-faultin' goal to me, great!  Let's see what you
REALLY mean though:

: 3. Site cleanups should be prioritized on the basis of current risk and
: future risk as determined by reasonably foreseeable land use.

"Foreseeable land use" is science?

: 4. At this time, ecological risk assessment should be a process based
: in observation and common sense.

Not science?  I could've sworn the prolog to this whole thing was
to take it out of the realm of evil regulators and to base it on
science.  "common sense" is science?  Of course not!  

I know you have a political definition.  Probably similar to the
"common sense" definition of wetlands which excludes damn near
everythiing but oceans, rivers and lakes.

--

- Don Baccus -