Duplicative regulations would cost taxpayers $474 million
Today’s findings reaffirm the recommendations of the April 2013 report “Assessing Risks to Endangered and Threatened Species from Pesticides” by the National Academy of Sciences (NAS) Committee on Ecological Risk Assessment under FIFRA and ESA. The NAS report found that federal regulatory agencies should use a common approach to evaluate risks. The committee determined that if FWS and NMFS could build on EPA's analysis of whether a pesticide is likely to adversely affect a listed species rather than conduct a completely new analysis, the assessment would likely be more effective. Agreement among the agencies to date has been impeded by a lack of communication and coordination throughout the process. Therefore, the Committee emphasized the need for coordination, which it views as necessary to ensure a complete and representative assessment of risk. Increased coordination would also help ensure that each agency's technical needs are met.
CLA engaged Summit Consulting to produce cost estimates for the operation of the pesticide registration review associated with ESA Section 7 consultations. Founded in 2003, Summit specializes in blending expert academic knowledge in economics and econometric methods with real-world experience in budget cost estimation to design and implement quantitative solutions for federal agencies and private-sector clients. Summit is led by Ph.D. economists and federal budget experts, including a former member of the Office of Management and Budget (OMB) Credit Crew, with significant and direct experience reviewing and approving model methodologies compliant with the Federal Credit Reform Act of 1990 (FCRA). A full copy of the report is available online at http://croplifeamerica.org/ESA-Cost-Analysis.