identifying the interested public

[James J. Goodyear <goodyear.jim@epa.gov>]

	EPA should have people whose full time job is to seek out commenters  other than pesticide registrants or users.  I work in the Office of Pesticide Programs.  I have noticed that pesticide manufacturers and their laboratories are well represented in the lists of stakeholders.  The reason is simple, they have employees or contractors whose job is to keep track of pesticide actions.  Even if EPA didn't notify them, they would find out anyway. 

	A good source of people and organizations is the lists of commenters in past Environmental Impact Statements.   EPA could invite these people and organizations to comment on relevant issues.  During the production of the Reregistration Eligibility Decision for anticoagulant rodenticides, I suggested that EPA use the list of commenters in the EIS for the Animal Damage Control unit of the Department of Agriculture.  I was told that we do not do this, that the RED was well advertised, and anyone who was interested would know about it.  They didn't know about it and comments about the ecological effects were sparse.  EPA should investigate how the writers of EISs obtain the names of commenters.

	EPA should pay people who represent opposing opinions to participate.  Pesticide manufacturers have large budgets to affect EPA's decisions.  Individuals and organizations who oppose the blanket reregistration of pesticides do not have the money to mount a campaign against this practice.  During ECOFRAM procedures pesticide registrants were well represented, but their opponents were not.  I have been told that some were asked, but that they declined because of a lack of time and money.  Pay means expenses and per diem.