This week, the U.S. Environmental Protection Agency began sending out test orders under its Endocrine Disruptor Screening Program (EDSP). EPA is asking chemical manufacturers to screen certain chemicals to determine whether they are endocrine disruptors – a term used to categorize any compound capable of causing certain reproductive and developmental abnormalities.

The first round of test orders covers seven pesticide chemicals, the names of which I would surely misspell if I attempted to recite them. You can find the list and more information here. The orders are being sent to all registrants for the pesticides in question. The first round of test orders were sent to 19 different firms, according to EPA’s website.

As expected, the test orders are loaded with references to Other Scientifically Relevant Information (OSRI) – existing studies that could limit or eliminate the need for industry to test their chemicals. Although that term appears in the law authorizing the EDSP, its prominence is a result of pressure from the White House Office of Management and Budget (OMB).

OMB added scads of language to EPA’s initial drafts that appears to encourage industry to submit OSRI. OMB’s edits have caused quite a stir in the public health crowd who say most currently available studies were not conducted with the goal of determining a chemical's effect on the endocrine system and did not study low-dose exposure. Endocrine disruptors are thought to disrupt hormone functions even at very low levels.

At this time, it is difficult to gauge the impact of OMB’s edits: if industry submits existing studies in tandem with fresh data generated through the EPA-developed testing protocols, no big deal; but if industry is able to submit studies in lieu of new testing, EPA may not get the data it needs to make critical decisions that protect the public from harmful substances. That back and forth, which could occur for multiple chemicals, will in part shape the EDSP and determine its effectiveness.

Ultimately, the decision rests with EPA. If the agency doesn’t believe OSRI submitted by industry is sufficient to determine the endocrine disrupting effects of these chemicals, it must push back and demand new data. If industry refuses, EPA has the authority to ban manufacturers from selling certain chemicals until they oblige.

The good news is that EPA appears ready to hold test order recipients to a tight schedule. Recipients have 90 days to tell EPA how they plan to find or generate the data. For those manufacturers submitting OSRI in lieu of new data, EPA writes, “You should be aware that if the Agency determines that the study is not acceptable, the Agency will require you to comply with this Order, normally without an extension of the required due date for submission of the data.” A progress report is due within one year, and the final responses are due within two years.

For more on the program and OMB’s role, see this article from the latest issue of The Watcher: “OMB Role in EPA Chemical Program Questioned.”

Congress yesterday passed a FY 2010 appropriations measure for environmental agencies that exempts factory farms from having to track and report their greenhouse gas emissions. The exemption applies to a rule issued in September by the Environmental Protection Agency (EPA) requiring thousands of large facilities economy-wide to monitor and report their emissions.

The mandatory greenhouse gas (GHG) emissions reporting rule was issued in response to a Congressional demand included in FY 2008's funding bill. By eliminating huge factory farms from the reporting requirement, members of Congress are deliberately blinding themselves to crucial information needed to make policies to combat climate change. The new funding bill prohibits EPA from spending any money to implement the rule if it covers manure management systems, ensuring that for at least another year, Congress and the public will be ignorant of the climate damage caused by these systems. 

The current rule is estimated to cover 107 livestock facilities that use certain manure management systems to handle the tons of animal waste produced by concentrating thousands of animals in feedlots. These manure management systems, which include enormous "lagoons"of liquefied waste, emit roughly 58.7 million tons of carbon dioxide equivalent (CO2e) annually. The manure system operators would only need to monitor methane and nitrous oxide emissions, which are both much more potent global warming gases than CO2, but for comparison's sake, emissions are measured in CO2e. Emissions from these systems have been greatly increasing for years.

Congressional appropriators originally passed the measure calling for the mandatory reporting of GHG to gather information from "all sectors of the economy of the United States."

Iowa Republican Tom Latham inserted the exemption in the House version of the funding bill, and subsequent Republican maneuvers made sure it was in the conference report. According to Latham, "[The reporting rule] doesn't do one thing to improve the standard of living in rural Iowa or any part of this country.  But I will tell you what it does do. It significantly drives up costs for farmers and hardworking American families…"

According to EPA, the GHG registry is "intended to collect accurate and timely emissions data to inform future policy decisions." Apparently Mr. Latham feels he and his colleagues do not need the data, or perhaps are not interested in making informed policy decisions.

As for the costs to "farmers and hardworking Americans," the EPA has provided estimates of the potential economic costs to the 107 livestock facilities likely impacted by the rule. According to the agency, a facility might incur expenses of $857 to $1,812 for labor in the first year and some facilities might see capital costs of up to $961 per year over ten years. So the unluckiest of factory farmers would be hit by up to $2,773 in costs in just the first year.

Keep in mind, we are not talking about the proverbial family farmer grazing a few dozen cows or even a few hundred chickens. The rule impacts the largest of the obscenely large operations. To meet the threshold for having to report its emissions, a facility must have at least 3,200 dairy cows, or at least 29,300 beef cattle. Pigs, the notoriously prolific poop-makers, must number 34,100 before one of the "farms," known as concentrated animal feeding operations (CAFOs), must report its GHG emissions from its manure management systems. As for broiler chickens, EPA is talking about tens of millions of birds.

A hypothetical extreme cost analysis puts the rule in perspective. If the estimated 107 impacted CAFOs must each pay $2,773 in the first year the GHG rule is in effect, and if the costs were passed on to consumers at a dollar-for-dollar rate, and if the only consumers of the farms' products were constituents of Mr. Latham's district (pop. 585,305), the first-year cost per person would be $0.51.

At a time when agricultural interests are pushing hard to cash in on pending climate change legislation through measures that will pay them for farming practices dubiously considered to offset GHG emissions, one would expect farmers to support having their emissions reported. Without the transparency provided by accurate monitoring, the market for GHG emissions offsets from livestock facilities might be less lucrative.

Before any meaningful policies on climate change - such as a cap-and-trade system - can be implemented, we must have thorough data. We must know who is emitting and how much. Other industries that are estimated to emit less global warming gases than CAFOs are also covered by EPA's rule. Hopefully Congress's recent action is not the beginning of the chipping away at an indispensable tool for averting the worst impacts of climate change.

Recent efforts to reform and modernize the voter system have received bipartisan support. The Military and Overseas Voter Empowerment Act, which would allow overseas troops and American citizens to access voter information online, passed Congress last week with bipartisan support from legislators who "decried an antiquated voting system that left as many as one out of four overseas ballots uncounted," according to Roll Call.

In August, the House of Representatives passed a bill that would enable individuals who voted by absentee ballot to track the status of their ballots online. Also, a bill that would expand no-excuse absentee voting has passed in the House Administration Committee.

Another bill currently before Congress would "require all states to offer online voter registration by 2012," according to Roll Call. This would be a major challenge for the vast majority of the country and would require most states to significantly upgrade their procedures. Currently, "only six states offer some form of online voter registration, while half allow voters to verify their registration online. For most states, the voting system is a hodgepodge of snail mail, voter registration drives and polling places," according to Roll Call.

The online voter registration bill would bring the voter registration process in line with the convenience of other aspects of daily living. "Many voters expect to be able to register to vote online as part of their normal routine," Rep. Zoe Lofgren (D-CA), the sponsor of the bill, told Roll Call. "They are used to the convenience of online tools in their daily life and registering to vote should be just as easy and accessible as banking and bill paying," Lofgren said.

Brian Fallon, the Senate Rules and Administration Committee spokesman, told Roll Call that Sen. Charles Schumer (D-N.Y.), chairman of the committee, is "working on a bill to ‘modernize’ the voting system."

Republicans have some concerns about voter fraud, but agree that the system should be modernized.

As a follow up to Craig's earlier post on the AP article/Recovery Act job numbers, the Center on Budget and Policy Priorities just put up a great article on what we will and will not see, data-wise, on Oct. 30, when the rest of the recipient reports are published. The timely report serves as a reminder that the recipient reporting doesn't cover most Recovery Act spending, nor does it reflect many of the jobs "created" by the Act.

Image by Flickr user johnsolid used under a Creative Commons license.