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ARCC
Letter to Brooks B. Yeager
February 10, 2000 Brooks B. Yeager
Dear Deputy Assistant Secretary Yeager: On behalf of the Alliance for the Responsible Use of Chlorine Chemistry (ARCC), an alliance of major American unions and companies, we are writing with regard to the Department of State's position in upcoming UNEP negotiations on the by-product Persistent Organic Pollutants (POPs) treaty to be held in Bonn, Germany, in March 2000. For many years, the Department of State has fairly represented the democratic balance of interests of U.S. workers, companies and communities before UNEP. A clear example of sensitivity to national interests has been the Department's historic position on the issue of by-product POPs. The Department (along with the JUSCANZ nations) has maintained that the risks associated with by-product POPs should be strictly controlled by policies designed to continuously reduce human exposure and emissions to the environment -- without imposing dramatic and unnecessary costs on industrialized economies. Historically, our nation's environmental policies in international forums have been developed through an interagency process. Departments and Agencies including Commerce, USTR, EPA and State have collaborated to ensure that U.S. policy reflects the broader range of U.S. interests. The interagency process has yielded the consensus that by-product POPs should be controlled by risk management. At its core, the interagency process is supported by confidence in the American system of regulation and risk management as it has developed in national law and policy. However, we understand that some environmental groups are exerting strong pressure on the Department of State to disregard the risk management consensus, and instead support treaty language calling for the "total elimination" of by-product POPs at Bonn. We believe that this radical changeover would be totally unjustified and against U.S. national interest. The U.S. structure of risk management and regulation is working. It should not be abandoned suddenly in favor of another approach proposed by a minority of activists. There is no environmental, economic or political justification for the Department of State to advocate a position that directly threatens hundreds of thousands of U.S. workers employed in the production of beneficial products. Page 2 Clearly, for the United States, the risk management approach is succeeding. For example, the EPA reports that environmental emissions of by-product dioxins have been slashed by 75 percent since 1985, with the result that human and animal tissue dioxin levels have declined in like manner and are projected to continue falling. This has been accomplished - without major job loss or economic displacement - by the U.S. political and regulatory processes in conjunction with the deployment of improved technologies and cooperation by industry. A similar approach in Europe has yielded comparable results in emission reductions. We believe that this is an ongoing success story that proves that our system is working. One clear example of risk management success is found in the recently issued EPA "Cluster Rule" affecting POPs emissions from pulp and paper plants. By mandating a switch from elemental chlorine to chlorine dioxide, the EPA will virtually eliminate dioxin emissions to below detectable limits, resulting in the lifting of all remaining fish advisories downstream from U.S. pulp and paper plants. This changeover did cause the loss of over 12,000 U.S. pulp and paper jobs due to the closure of some mills, but it has resulted in a major environmental improvement and maintained the U.S. paper industry as a world leader. The alternative to EPA's rule decision, supported by the environmentalists, would have caused the loss of almost 90,000 U.S. jobs and a large number of U.S. mills for no measurable net environmental benefit according to EPA. On behalf of the Alliance, we respectfully ask that the Department of State continue to support the risk management approach to by-product POPs at the Bonn negotiations. We believe that the by-product POPs treaty should bring the rest of the world up to the level of protection achieved by the United States. Sincerely,
CC: Daniel Fantozzi
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