Dunn/Milloy: Holding the EPA to Account

Texas ER doc John Dunn and JunkScience.com’s Steve Milloy offer some solutions for corralling the outlaw EPA.

Dunn and Milloy write in American Thinker:

What are some solutions to the EPA’s faults and shortcomings?

1. Shrink EPA. Most environmental protection is done at the state-level. Most environmental regulatory work is done by the states. The Federal agency has too much time and money and that results in overreach and aggressive policy making.

2. End inherent conflict of interest. Research and regulation need to be separated into independent agencies. At a minimum, EPA science reviewers should not be grantee researchers or affiliated with grantee institutions.

3.Risk assessment (RA) and cost benefit analysis (CBA). All rules must be subject to the two. RA and CBA should be judicially reviewable. This could be done through a super mandate that modifies review criteria for all agency activities.

4. Judicial review. Aggrieved parties should have easier opportunities to challenge the agency in court. The “arbitrary and capricious” standard in the Administrative Procedures Act needs to be replaced with a standard that allows proper challenges, such as the standard of review for workplace rules administered by the Occupational Safety and Health Administration. This could be done with a “super mandate” that overrides all existing statutory law.

5. Impose stricter scientific standards. Obligate the Agency to research that is subject to objective, non conflicted peer review and appropriate evaluation of data and methods. Require that taxpayer funded research be reviewable for data and methods and that research comply with the scientific standards from authoritative resources such as the Reference Manual on Scientific Evidence, written by truly independent experts to provide federal judges with guidance on what constitutes reliable scientific evidence in federal courts. If the Reference Manual is good enough for courts, it ought to be good enough for the EPA…

2 thoughts on “Dunn/Milloy: Holding the EPA to Account”

  1. Jek, you mirror my thoughts exactly, especially the parts about the UN and Federal lands.
    Well done!

  2. I’d roll-back the clean air standards 20 years, while freezing auto emissions at ’75 levels. Actually, I’d keep the truck diesel regs, as long as they are frozen indefinitely, not increased, beyond the current point. No CAFE standards–those are gone, because Competition should come up with safe, light, cars, NOT CAFE standards. ALL EPA research could NOT be “in house”,–there must be NO CONNECTION with researchers, and ALL research must comply with Reference Manual and be peer-reviewed. Everything the EPA does MUST be open. Actually, we no longer need an EPA, it should be dis-mantled,–its functions given to the States, other agencies. but if the EPA is merely choked-down to a shadow of itself, any findings of a mud-puddle being declared a moving water/wet-lands should lead to the ARREST of the designee under the appropriate federal felony–“Theft by Conversion?”–“Racketeering.”? No CO2 designations as a greenhouse gas. I’d NOT worry about shale gas/methane. No Green “caps(taxes)” can be levied, and NONE will be paid to foreigners for any reason. An entire findings board could be charged, treated under RICO if such applies. I would keep some of the positions open to gain evidence of Non-profit “conspiracy” to deny use/theft of use/racketeering. No partnered/”friendly”-lawsuits. Any Non-profits that communicate with the remnant EPA would HAVE to have 50% Industrial representation or more, on their administrative boards whose meetings would HAVE to be public and open. Green-mailing is black-mail and would NOT be allowed. Mining would be allowed in/next-to National Parks, so resources can’t be “locked-away” from use, although all mining operations would have to maintain the roads feeding their operations. The U.N. would NEVER have ANY jurisdiction in this country, for ANY reason. Seeing as how they consider the EPA, their own attack-dog, NO Bilderberger meetings can be held in this country, even privately, and if held elsewhere, NO stated/un-stated measures can impune, in any way, with the free, functioning of the USA and its Economy. The federal govt. would have to sell most of its land, so those lands sold, can enter into the tax-base, and generate revenue for its upkeep. Some species may be allowed to become extinct, as 95% of those previously extant became extinct before we started worrying about extinction. Non-profits could purchase lands for maintenance of those species that are endangered. Man is THE steward of this world, and is much more important than any animal species. No bureau can import/reintroduce species into the Wild, without such appearing on a ballot, and voted-on by the taxpayers. It makes no sense to reintroduce a species into the Wild, like Wolves, if through reintroduction, some will have to then be killed to suppress sheep/cattle/other domestic losses. Prisoner work-parties would keep fuel-loads picked-up in Forests, so insect infestations can be treated with smoke,or other means, if necessary, to prevent/stop insect predation of the forests.

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