Duplicative regulations would cost taxpayers $474 million

decrease font size  Resize text   increase font size       Printer-friendly version of this article Printer-friendly version of this article

CropLife America (CLA) expressed concern at the findings of a new report that estimates duplicative regulations on crop protection products could cost taxpayers an additional $474 million over the next 10 years, should the existing broken system of endangered species consultations continue for crop protection products.

A new report from Summit Consulting, LLC (Summit) and commissioned by CLA estimates the cost to taxpayers of continuing the duplicative consultation process. Amendments to the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) in 1996 and 2007 established a 15-year cycle of pesticide registration review to ensure that all registered products meet current regulatory requirements; the first cycle must be completed by 2022. All EPA pesticide registration actions are further subject to Section 7 of the Endangered Species Act (ESA), which requires that EPA consult with the Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) if the pesticide use “may affect” endangered species. The Services conduct their own independent risk analysis, despite the fact that EPA already rigorously reviews a product’s potential impacts on the environment in accordance with FIFRA, including possible effects on threatened or endangered species.

The report from Summit documents the review process as currently conducted through the individual agencies. It includes a review of the budgetary capacity of the agencies and a breakdown of estimated costs over time. The report found:

  • Under the current consultation process, where NMFS and FWS conduct their own assessments in addition to EPA, completing the currently scheduled review of 744 pesticide registration dockets by fiscal year 2023 would require an additional taxpayer expense of $474 million above current budgetary levels.
  • Completion of these dockets would require a 13-fold increase in current budget and a 25-fold increase over current staffing levels at NMFS.
  • Completion of these dockets would require a 17-fold increase over current budget and a 71-fold increase over current staffing levels at FWS.

“This new report prepared by Summit confirms that the current regulatory system for review of EPA decisions under FIFRA by FWS and NMFS, under authority of ESA, creates a broken regulatory system for crop protection products, providing no additional benefits to wildlife, farmers or taxpayers,” said Jay Vroom, president and CEO of CLA. “We look forward to working in a collaborative dialogue with EPA, USDA and the Services to find a solution that continues to protect threatened and endangered wildlife, while using government resources more efficiently. It is unrealistic to expect that our government will spend hundreds of millions of dollars more to expand regulatory capacity at FWS and NMFS, only to affect regulatory redundancy.”

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.

Buyers Guide

Doyle Equipment Manufacturing Co.
Doyle Equipment Manufacturing prides themselves as being “The King of the Rotary’s” with their Direct Drive Rotary Blend Systems. With numerous setup possibilities and sizes, ranging from a  more...
A.J. Sackett Sons & Company
Sackett Blend Towers feature the H.I.M, High Intensity Mixer, the next generation of blending and coating technology which supports Precision Fertilizer Blending®. Its unique design allows  more...
R&R Manufacturing Inc.
The R&R Minuteman Blend System is the original proven performer. Fast, precise blending with a compact foot print. Significantly lower horsepower requirement. Low inload height with large  more...
Junge Control Inc.
Junge Control Inc. creates state-of-the-art product blending and measuring solutions that allow you to totally maximize operating efficiency with amazing accuracy and repeatability, superior  more...
Yargus Manufacturing
The flagship blending system for the Layco product line is the fully automated Layco DW System™. The advanced technology of the Layco DW (Declining Weight) system results in a blending  more...
Yargus Manufacturing
The LAYCOTE™ Automated Coating System provides a new level of coating accuracy for a stand-alone coating system or for coating (impregnating) in an automated blending system. The unique  more...
John Deere
The DN345 Drawn Dry Spreader can carry more than 12 tons of fertilizer and 17.5 tons of lime. Designed to operate at field speeds up to 20 MPH with full loads and the G4 spreader uniformly  more...
Force Unlimited
The Pro-Force is a multi-purpose spreader with a wider apron and steeper sides. Our Pro-Force has the most aggressive 30” spinner on the market, and is capable of spreading higher rates of  more...
BBI Spreaders
MagnaSpread 2 & MagnaSpread 3 — With BBI’s patented multi-bin technology, these spreaders operate multiple hoppers guided by independent, variable-rate technology. These models are built on  more...

Comments (0) Leave a comment 

e-Mail (required)


characters left

Tube Series (TS) Conveyors

USC’s Tube Series Conveyors combine the gentleness of the signature Seed Series with the traditional stability of a tube-style conveyor, ... Read More

View all Products in this segment

View All Buyers Guides

Feedback Form
Feedback Form