(Beyond Pesticides, July 10, 2017) The state of California has listed glyphosate, the active ingredient in the popular Roundup, as a known carcinogen under its Proposition 65 law. This listing went into effect July 7, 2017. Now, state officials have to develop guidelines for product labels and determine what level of exposure to the pesticide will put people at risk for developing cancer. Some have argued that the state’s proposed levels are not protective enough. Meanwhile, the state continues to face pressure from Monsanto, maker of glyphosate, which continues to challenge the decision to list the chemical as a known cancer-causing agent. California’s decision to list glyphosate as a carcinogen was prompted by the International Agency for Research on Cancer’s (IARC) finding in 2015 that it is a “probable” human carcinogen. This classification was based on sufficient evidence of carcinogenicity in experimental animals. Later that year, California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA) announced that it intended to list glyphosate as a cancer-causing chemical under California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65).  Under California law, Proposition 65 requires that certain substances identified by IARC be listed as known cancer-causing chemicals. Glyphosate’s listing became effective […]

(Beyond Pesticides, July 6, 2017) The Washington State Department of Ecology (Ecology) is evaluating a new permit application for the use of imidacloprid, a toxic neonicotinoid, to combat a growing native population of burrowing shrimp that threatens oyster beds in Willapa Bay and Grays Harbor in Washington state. The application was recently submitted to Ecology by a group of oyster farmers from the Willapa Grays Harbor Oyster Growers Association (WGHOGA), who “propose to use the pesticide to treat tide lands to support their aquaculture practices.” Imidacloprid is known to be toxic to bees and aquatic organisms, raising questions on the impacts of its use on the long-term ecological health of the bays. In April 2015, much to the dismay of activists and concerned local residents, Ecology approved a permit submitted by oyster farmers for the use of imidacloprid to combat burrowing shrimp in these aquatic ecosystems. But with a nationwide public outcry, the permit was withdrawn in May 2015. The recent request that was submitted differs in several ways from this 2015 permit, including: The new permit proposes treating 485 acres in Willapa Bay and 15 acres in Grays Harbor, compared to 2,000 acres combined from both water bodies in the 2015 permit. The oyster farmers […]

(Beyond Pesticides, June 28, 2017) In a move that could portend broader action in the case of environmental crimes, Michigan Attorney General Bill Schuette has filed charges of involuntary manslaughter against five state officials in a death resulting from Flint’s water crisis. While most criminal charges resulting from environmental mishaps and disasters are filed against corporations or their CEOs, one law review article notes, “Prosecutors have become aggressive in seeking out responsible parties. The net of criminal liability is no longer limited to those directly involved in causing the disaster, but may now extend to those involved in the response, as well as officials whose derelictions in office helped create the risk.” In announcing the charges, the Attorney General stated, “All defendants charged with involuntary manslaughter are charged in relation to the death of Robert Skidmore, 85, of Mt. Morris, Michigan. Skidmore died of Legionnaires’ disease after many others had been diagnosed with the illness, yet no public outbreak notice had been issued. The charges allege failure to notify and lack of action to stop the outbreak allowed the disease to continue its spread through Flint’s water system.” Involuntary manslaughter is punishable by up to 15 years in prison, and/or a $7,500 […]

(Beyond Pesticides, June 23, 2017) In a packed hearing room, the Portland, Maine City Council Sustainability and Transportation Committee heard community members testify in support of an ordinance to restrict pesticides on playing fields, parks, and private lawns for nearly three hours on Wednesday night. The hearing focused on a draft pesticide policy that was recently released by the Pesticide and Fertilizer Task Force, set up by Mayor Ethan Strimling. A range of community members testified, including doctors, parents, organic land managers, an organic products retailer, and public health advocates. Beyond Pesticides’ executive director, Jay Feldman, was at the hearing to support the adoption of ordinance language similar to that adopted by neighbor city South Portland in September 2016. In reaction to the Task Force proposal, which advances an undefined integrated pest management (IPM) approach that allows the use of “least toxic” pesticides, Mr. Feldman testified, “An ordinance requires specificity if it is to accomplish the goals that the community embraces –safe playing fields, parks, playgrounds, and a community that does not allow the poisoning of soil, air, and water.” The lack of specificity in the draft contrasts with the South Portland ordinance, which adopts a list of allowed materials and envisions […]

(Beyond Pesticides, June 15, 2017) Communities exposed to frequent aerial spraying for mosquito control experience elevated rates of autism diagnoses, according to new research. The study identifies the frequent use of synthetic pyrethroid insecticides, which are linked to neurocognitive and behavioral impacts, among other health effects. Pediatric researchers at Penn State University and the University of California examined communities in eight zip codes in Onondaga County, New York with frequent aerial spray programs for mosquito control, and contrasted these findings with communities in 16 zip codes that do not employ similar pesticide use programs. According to the study, between 2007 and 2009, the average yearly pesticide burden across the eight aerial exposed zip codes was approximately 11,000 kilograms, compared to approximately 4,000 kilograms of pesticide exposure across the 16 control zip codes. The study finds that the zip codes with frequent aerial pyrethroid exposure are 37% more likely to have higher rates of childhood developmental delays and autism spectrum disorder. The researchers acknowledge that the study establishes a correlational, not a causal, link between pyrethroid exposure and autism/developmental disorders, it adds to a growing body of research demonstrating an exposure-effect relationship between the two. Other studies have similarly linked developmental disorders and autism […]

(Beyond Pesticides, June 14, 2017)  Oak trees in Iowa may be the latest victim of widespread chemical-intensive agriculture, according reports in the Des Moines Register. The newspaper indicates that the Iowa Department of Natural Resources (IDNR) has received roughly one thousand calls this spring from residents concerned about the state of their oak trees. Leaves are ‘tattered’ down to the vein, in an appearance one would first think was related to pest damage, according to the newspaper article. However, foresters with IDNR indicate the cause is likely the use of chloroacetanillide herbicides, which are applied throughout the state and region. Advocates say that this situation contributes to mounting environmental problems associated with chemical-intensive food production that support the need for the adoption of non-toxic weed management strategies. Past research has found associations between the use of chloroacetanillide herbicides, such as acetochlor and metolachlor, and oak leaf tatter syndrome. State officials indicate that the increase in resident complaints is likely related to a colder March, which may have retarded leaf development. By the time leaves began unfurling in early spring, herbicide use was at its height, leading to high ambient concentrations of the chemicals in the atmosphere, according to IDNR officials […]

(Beyond Pesticides, June 12, 2017) Once again, there are reports that soybean and cotton fields are being damaged by off-site drift of the toxic herbicide dicamba. Last summer, farmers in Missouri, Arkansas, and Tennessee reported widespread crop damage from dicamba drift, which led to reduced yields. The U.S. Environmental Protection Agency (EPA) launched a criminal investigation at several Missouri locations into what they said was the illegal spraying of dicamba in October 2016. This year, reports of dicamba drift and damage are already being reported in Arkansas, and 25 formal complaints have already been filed, according to the state Plant Board. In summer 2016, illegal applications of dicamba damaged thousands of acres of soybeans, cotton, ornamental trees and fruits and vegetables. After numerous complaints, EPA launched a criminal investigation into the illegal spraying of dicamba, an investigation that is still ongoing. Many suspect that farmers who planted Roundup Ready 2 Xtend® and XTENDFLEX® Cotton, the new dicamba-tolerant genetically engineered (GE) seeds in the region, when faced with a proliferation of pigweed, illegally sprayed dicamba across their fields leading to drift and off-site crop damage to other farmers. This year, although it is too early to say how many acres have been affected or what specific […]

(Beyond Pesticides, May 25, 2017) Four parks in Maui, Hawaii, have kicked off a year-long pesticide-free pilot program to transition to organic management. A series of training events in the county over the past few weeks focused on soil-based approaches to land management, a more effective solution than solely switching from synthetic to organic pesticides. Last Wednesday, Beyond Pesticides’ executive director, Jay Feldman, and Chip Osborne, president of Osborne Organics, taught training sessions with county Parks and Recreation staff, “discussing lawn care that relies less on outside products and aims to feed the soil, not just the plant.” Beyond Pesticides worked to support the pesticide-free parks movement in Maui by sponsoring these training sessions for Maui County Parks, Department of Transportation, Maui public schools, several local resorts, and golf course management groups. Beyond Pesticides is working with Maui County to provide guidance on transitioning its parks to organic practices. Analysis of soil samples at each site has been conducted, which will provide a baseline to implement cultural changes to improve the biological health of the soil, making it more resistant to weed and insect pressures. The next step includes creation of a report and action plan for each county park by Beyond Pesticides and Osborne […]

(Beyond Pesticides, May 24, 2017) A Hawai’i woman is suing her former employer, DuPont Pioneer, stating that the company retaliated against her for bringing up concerns over pesticide safety. Shanbnell Grilho, who worked for DuPont Pioneer on Oahu’s North Shore, alleges the company required her to apply hazardous herbicides without the proper training or protection, and ultimately fired her after fabricating allegations against her. This lawsuit is the latest claim against multinational pesticide companies operating in Hawai’i, which have been at the center of local and state-level disputes over their use of toxic pesticides where Hawai’i residents live, work, and play. In her complaint, Ms. Grilho indicates that she began working at DuPont Pioneer as a temporary employee, during which time she was awarded a raise and named DuPont Pioneer employee of the month. At the time she did not have to apply pesticides. However soon after her award, she was hired as a full time employee and required to work with Roundup, Liberty, and Honcho herbicides, which contain the active ingredients glyphosate, glufosinate, and glyphosate, respectively.  “DuPont Pioneer required plaintiff to apply herbicides and biocides while wearing a backpack sprayer, driving an ATV while applying herbicides with a backpack […]

(Beyond Pesticides, May 22, 2017) Last week, the Maine Legislature’s Committee on State and Local Government unanimously voted to reject a bill that would have prohibited the right of municipal governments to restrict pesticide use on private property. This victory protects the 27 cities and towns across Maine which are exercising their right to adopt pesticide restrictions that incentivize land management practices supporting healthy environments and allows other communities to follow suit. Opponents of the Governor’s bill successfully argued that its weakening of local control could violate the Maine Constitution. Proponents of the bill included industry trade groups, lawn care companies, and golf courses, who argued that the legislation was necessary to address the growing “patchwork” of local regulations. There is no evidence of this, and on the contrary, there has been a long history of local communities adopting ordinances to respond to matters of public health and welfare. According to the Portland Press Herald, the bill, LD 1505, was a “late introduction on behalf of [Governor] Paul LePage and reportedly mirrored model legislation promoted by the American Legislative Exchange Council, a conservative policy group that works with state lawmakers.” This group and others aim to suppress or preempt local […]

(Beyond Pesticides, May 9, 2017) Last month, San Juan Capistrano (SJC) became the latest community in Orange County, CA to pass an organic landscaping policy for city parks and open spaces. The city’s move follows the passage of an organic land care policy in nearby Irvine, CA last year, and like Irvine, was brought forward by a strong contingent of local advocates, health practitioners, and city officials working together to safeguard public health and the environment. By a vote of 4-0-1, San Juan Capistrano’s City Council put the community on the cutting edge of local changes to pesticide use that are taking place across the country. SJC’s policy is the result of persistent pressure and engagement by community group Non-Toxic San Juan Capistrano with city officials. A change.org petition hosted by the group, which received over 300 signatures, detailed the discussions and responses the group received from local leaders. At the time the City Council took up the issue at a mid-April meeting, Mayor Kerry Ferguson made a strong statement indicating that, “Chemical pesticides and herbicides have been proven to be toxic to children, pets, and the general public.” Mayor Ferguson further said, “While [chemical pesticide] use is somewhat limited […]

(Beyond Pesticides, May 1, 2017) The Florida Keys Mosquito Control District released 20,000 male mosquitoes infected with Wolbachia bacteria near Key West, as a trial strategy to manage mosquitoes that carry Zika and other viruses. The district and others have been exploring new ways to suppress infected Aedes aegypti mosquito populations, which thrive in urban environments and can spread Zika, dengue fever, and chikungunya. It is unclear what impacts, if any, these infected mosquitoes will have on non-target organisms or public health. The trial is the second U.S. test conducted with the naturally occurring Wolbachia bacteria in Aedes aegypti mosquitoes, developed by the Kentucky-based company MosquitoMate. The first test occurred in Clovis, California, last year. In September 2016, the U.S. Environmental Protection Agency (EPA), which registers mosquito control products, approved and expanded an experimental use permit (EUP) for Wolbachia pipientis-infected Aedes aegypti mosquitoes (not to be confused with genetically engineered (GE) mosquitoes).  According to the agency, Wolbachia are naturally occurring bacteria commonly found in most insect species, but not in the Aedes aegypti. This strain of Wolbachia is extracted from Aedes albopictus embryos and microinjected into Aedes aegypti embryos. Male Aedes aegypti mosquitoes are shipped to testing sites where they are released and mate with wild-type Aedes aegypti females that do not carry Wolbachia. After mating, the […]

(Beyond Pesticides, April 27, 2017) Nine organizations filed an Amicus brief this week in support of a 2015 landmark Montgomery County, Maryland ordinance that restricts the use of toxic pesticides on public and private land within its jurisdiction. The law, intended to protect children, pets, wildlife, and the wider environment from the hazards of lawn and landscape pesticide use, is facing a legal challenge filed in November last year by the pesticide industry group Responsible Industry for a Sound Environment (RISE). The plaintiffs, which include local chemical lawn care companies and a few individuals, allege that the local ordinance is preempted by state law, despite the fact that Maryland is one of  seven states  that has not explicitly taken away (or preempted) local authority to restrict pesticides more stringently than the state. The law at issue, 52-14 (the Healthy Lawns Act), which restricts the cosmetic lawn care use of toxic pesticides on public and private land, protects over one million people, the largest number to be covered by any local jurisdiction to date. Passing the Montgomery County Council by a vote of 6-3, the bill allows time for transition, training, and a public education program over several years. In limiting the pesticides […]

(Beyond Pesticides, April 27, 2017) Multinational chemical companies Dow Chemical Company and Shell Chemical Company knowingly sold and marketed fumigants contaminated with a cancer-causing chemical that had a strong propensity to leach into and remain in groundwater, according to a recent report from the Environmental Working Group (EWG) and a lawsuit against the companies. The contaminant of concern, 1,2,3-trichloropropene (TCP), was a manufacturing by-product found in Dow’s Telone and Shell’s D-D fumigant pesticide products with the active ingredient 1,3-Dichloropropene. The products, used to kill soil-dwelling nematodes, are toxic in their own right, but contained TCP in their formulation from the 1940s until the mid-1980s. EWG’s report details widespread contamination of drinking water in California’s agricultural regions, with detections found in 562 wells, and 94 public water systems identifying TCP above legal limits. Thirty-seven additional public water systems serving nearly 4 million U.S. residents throughout the country were also found to contain TCP. The U.S. Environmental Protection Agency has never set maximum contaminant levels for TCP in drinking water, but requires public reporting above the infinitesimally small amount of 30 parts per trillion, roughly six times higher than what the state of California requires. However, even proposed limits of 5 parts per trillion […]

(Beyond Pesticides, April 21, 2017) We are one week away from our 35th National Pesticide Forum, Healthy Hives, Healthy Lives, Healthy Land: Ecological and Organic Strategies for Regeneration! Don’t miss out on an opportunity to listen to and interact with a range of grassroots advocates, scientists, and policy makers. The 35th National Pesticide Forum, held in Minneapolis, Minnesota, at the Humphrey School of Public Affairs, runs from the afternoon of April 28 through the evening of April 29. Registration, which is $45 for the general rate, and $20 for students, includes access to all sessions as well as organic food and beverages. In addition to spending time with scientists and experts on the cutting edge of research, and the opportunity to network, we will serve light hors d’oeuvres and organic beer and wine Friday night, and organic breakfast, lunch, dinner and drinks on Saturday. Walk-in registrations will be welcome, but to ensure that we have enough food and drink, we encourage you to REGISTER TODAY! Learn from Leading Experts: The conference speakers are leading authorities in their fields, which offers participants a unique opportunity to discuss cutting-edge issues focused on protecting human health and the environment. At the Forum, you’ll have […]

(Beyond Pesticides, April 19, 2017) Local activists in Illinois were handed a victory on Monday when a judge granted a temporary restraining order to shut down a construction project due to the presence of the rusty patch bumblebee, a recently listed endangered species. The group Stop Longmeadow, in reference to the Longmeadow Parkway Bridge Corridor project, filed the lawsuit, Case: 1:16-cv-05435, based on the fact that the rusty patch bumblebee has been found in the Brunner Forest Preserve, which borders 5.6 miles of the corridor project. Defendants, including the U.S. Department of Transportation, the U.S. Department of the Interior, and the Forest Preserve District of Kane County, argue that the scheduled construction will not affect bumblebee habitat. The court rejected their position, however, siding in the plaintiffs by finding “the balance of harms weighs in favor of the plaintiffs and against the public’s interest in reduced traffic congestions.” The restraining order was issued by Judge Sharon Coleman in the U.S. District Court for the Northern District of Illinois Eastern Division. Based on the evidence presented by the plaintiff’s motion, Judge Coleman reasoned that “a brief stay to the project is warranted.” She went on to point out that, contrary to […]

(Beyond Pesticides, April 18, 2017) Last week, the Assembly of Anchorage, Alaska voted 10-1 to pass AO2017-59, an ordinance instituting a pesticide-free program on public parks, lands, and properties. The measure codifies and strengthens important protections for public health, particularly children’s health, water quality and the wider environment from the hazards of toxic pesticide use. “Parents, grandparents, aunts, and uncles should not have to worry whether their child will be exposed to a harmful pesticide that could have long-term health consequences when they visit public parks to enjoy the great Alaska outdoors,” stated Pamela Miller, executive director of Alaska Community Action on Toxics (ACAT), which helped galvanize community support for the measure. The new law, introduced by Assembly chair Elvi Gray-Jackson and vice chair Dick Traini, was the product of months of community stakeholder meetings and input. “That’s the way I like to do business in this community,” Ms. Gray-Jackson said to KTUU on the night the bill was passed. “Bring all the stakeholders together and have them work it out so we don’t waste a lot of time at this level.” Like recent policies passed in Washington, D.C., Montgomery County, MD and South Portland, ME, the law establishes a […]

(Beyond Pesticides, April 19, 2017) Local activists in Illinois were handed an exciting victory on Monday when a judge granted a temporary restraining order to shut down a construction project due to the presence of the rusty patch bumblebee, a recently listed endangered species. The group Stop Longmeadow, in reference to the Longmeadow Parkway Bridge Corridor project, filed the lawsuit, Case: 1:16-cv-05435, based on the fact that the rusty patch bumblebee has been found in the Brunner Forest Preserve, which borders 5.6 miles of the corridor project. The defendants, including the U.S. Department of Transportation, the U.S. Department of the Interior, and the Forest Preserve District of Kane County, argue that the scheduled construction will not affect bumblebee habitat. The court rejected their position, however, siding in the plaintiffs by finding “the balance of harms weighs in favor of the plaintiffs and against the public’s interest in reduced traffic congestions.” The restraining order was issued by Judge Sharon Coleman in the U.S. District Court for the Northern District of Illinois Eastern Division. Based on the evidence presented by the plaintiff’s motion, Judge Coleman reasoned that “a brief stay to the project is warranted.” She went on to point out that, […]

(Beyond Pesticides, April 12, 2017) Earlier this week, the Maryland General Assembly took action to protect pollinators found in designated state pollinator habitat by passing SB 386/HB 830, Pollinator Habitat Plans- Plan Contents- Requirements and Prohibition, with bipartisan support. With this bill, the legislature will require pollinator habitat plans developed by any state agency to be as protective of pollinators as the Maryland Department of Agriculture’s managed pollinator protection plan requires. This translates to prohibiting, with some exceptions, the use of neonicotinoid pesticides or neonicotinoid-treated seeds or plants on state land designated as pollinator habitat. The bill’s passage represents the third major legislative victory to protect bees and other pollinators coming out of Maryland in the past year. Last spring, in a historic move, the Maryland legislature voted to become the first state in the nation to ban consumers from using products containing neonicotinoid pesticides, a class of bee-toxic chemicals that has been linked to the startling decline in bees and other pollinators around the world. The Maryland Pollinator Protection Act (Senate Bill 198/House Bill 211), which also received bipartisan support, stipulates that consumers will not be allowed to buy pesticide products containing neonicotinoids starting in 2018. However, the legislation’s reach does not extend […]

(Beyond Pesticides, April 5, 2017) A new study, Occurrence of Neonicotinoid Insecticides in Finished Drinking Water and Fate during Drinking Water Treatment, has detected neonicotinoids, a class of insecticides known for their detrimental effects on bees, in treated drinking water. This marks the first time that these insecticides have been found in water sourced straight from the tap. Federal regulators have not yet addressed safe levels of neonicotinoids in drinking water, so at this point, any detection of these chemicals is cause for concern. The study authors “report for the first time the presence of three neonicotinoids in finished drinking water and demonstrate their general persistence during conventional water treatment.” Drinking water samples “collected along the University of Iowa treatment train” over a seven week period, May through July, 2016 directly after corn and soy planting, find three neonicotinoids, clothianidin, imidacloprid, and thiamethoxam at levels ranging from 0.24 to 57.3 ng/L (nanogams per liter). The University of Iowa tap water is run through a water treatment plant that uses conventional treatment methods.  In contrast, the Iowa City water treatment methods (granular activated carbon filtration) result in substantially lower levels of the neonicotinoids. Additionally, the researchers found that extensive transformation of clothianidin […]

(Beyond Pesticides, March 23, 2017) We’re just over a month away from Beyond Pesticides’ 35th National Pesticide Forum! Join us for Healthy Hives, Healthy Lives, Healthy Land: Ecological and Organic Strategies for Regeneration, at the Humphrey School of Public Affairs, University of Minnesota, in Minneapolis, Minnesota on April 28-29, 2017. Click here to register now! Register Today: Get the Early Bird Discount (available until March 28)! As an Early Bird buyer, you can get a general rate for $40, a student rate for $20, or a business rate for $170. Scholarships are also available. All ticket price rates include organic meals: on Friday, organic beer, wine, and hors d’oeuvre; on Saturday, organic breakfast, lunch, and dinner, plus organic beer and wine at the evening reception. For more details about registration, click here. Forum Overview: The national forum highlights nationally renowned scientists, including professor emeritus of plant pathology at Purdue University, Don Huber, Ph.D., whose agricultural research has focused on the  epidemiology and control of soil borne plant pathogens with emphasis on microbial ecology, cultural and biological controls, and physiology of host-parasite relationships; Vera Krischik, Ph.D., a tenured faculty in the Entomology Department at the University of Minnesota whose lab does research on insect exposure to various insecticides, […]

(Beyond Pesticides, March 21, 2017) Last week, the California Department of Pesticide Regulation (CDPR) released revised rules regarding notification of pesticide applications near schools, weakening standards despite opposition from community and public health groups. The new rules rescind a requirement that schools be granted 48 hours prior notification for a planned application of agricultural pesticides within ¼ mile of a school site. CDPR has re-opened public comments on the new rules, and concerned residents have until April 4 to submit a short statement urging increased protections to the Department at [email protected]. Public health, farmworker, and community groups had urged CDPR to strengthen, not weaken common-sense protections for children’s health. As the rules currently stand, applications of toxic, drift-prone pesticides will only be restricted within ¼ mile of a school site, and only during the hours of 6am to 6pm on weekdays. The original proposal required 48 hour prior notification for other agricultural pesticide applications occurring within ¼ mile of school sites during these times. However, CDPR’s revised rules now only require 48 hour notification if the pesticides applied are not on a list provided to school officials at the beginning of the year. Applicators will still be required to submit annual reports […]

(Beyond Pesticides, March 14, 2017)  The U.S. Environmental Protection Agency (EPA) is opening an investigation into whether the Hawaii Department of Agriculture (HDOA) and the state Agribusiness Development Corporation (ADC) are discriminating against Native Hawaiians in their administration of the state’s pesticide program. The investigation comes after a number of local community groups, represented by the nonprofit environmental law organization Earthjustice, filed a complaint in September 2016 asking EPA to take action against systemic abuses of Native Hawaiian peoples. Local efforts to protect pesticide-exposed communities have been repeatedly stymied by giant pesticide corporations operating on the island, which filed lawsuits that ultimately struck down local laws. EPA’s investigation will focus on the state’s activity on the islands of Kauai and Moloka’i. “The External Civil Rights Compliance Office will investigate whether in administering the pesticides program and the leasing and licensing of the state land program the HDOA and/or ADC discriminated on the basis of race and/or national origin against farm workers and residents of West Kauai and Molokai, in violation of Title VI of the Civil Rights Act, and EPA’s implementing regulation,” wrote Lilian Dorka, director of EPA’s External Civil Rights Compliance Office(ERCO), in a letter to Earthjustice. Under Title […]