Re: [CPEO-MEF] Air Force challenges draft TCE assessment

[CPEO Moderator <cpeo@cpeo.org>]

The following was posted by Robert S. Taylor <RST195005@aol.com>
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I have had no involvement with the science surrounding TCE and I have no
special knowledge of either EPA's draft assessment, or of DoD's apparent
concerns with that assessment.  However, your suggestion that DoD should
be prohibited from raising questions or concerns about the validity of a
draft assessment strikes me as quite wrong.  The presumption that the
reason DoD would challenge a draft assessment is "because [it] would
cost the military money" to protect the public health suggests that the
men and women within DoD are reckless and irresponsible, and indifferent
to the protection of the American people (including themselves and their
families).  I know of no such individuals within DoD or within any of
the Services.

According to the excerpt from the Air Force letter you pasted into your
message, EPA's Science Advisory Board has serious concerns about the
draft assessment.  Given DoD's own concerns, and especially given the
Science Advisory Board's concerns, what would you have the Air Force
do?  If the risk suggested in EPA's draft assessment is overstated, then
the millions or more dollars necessary to clean up to more stringent
standards would not be getting the American people any more protection.
As you well know, the money that the American people through the
Congress is willing to provide to DoD to perform environmental clean ups
is not unlimited, and if millions are spent on  actions that do not
meaningfully protect health, then there will be millions less to spend
on actions that would.  I would like to see DoD's environmental budget
increased and increased substantially, but even if that were to occur
right away I would hope that DoD continues to try to spend that money so
as to do the most good.

Money spent on attacking draft assessments does not in itself clean up a
single molecule of pollution, but the small sums DoD spends on such
activities are necessary to  keep the focus on how to achieve the
greatest protection of the public with the resources made available.

The characterization of EPA as some sort of "neutral" entity does not do
the dedicated and committed people of EPA justice.  Those
working on assessment of chemicals are not "neutral" or indifferent;
they are committed to the protection of the public.  Since they are
generally working on one or a few substances at a time, their effort to
accomplish something for the public good tends to get narrowly focussed
on the substance they are working on, and that can lead to such
conservative assumptions, or the piling on of safety factor on top of
safety factor, that the risk relative to other compounds is thrown out
of whack.

Comments from DoD or from industry are not going to move the EPA folks
unless the comments reveal mistakes or unsupported assumptions.  In
other words, the comments are not going to move the EPA folks unless the
comments SHOULD move them.

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