CRE filed comments on EPA’s draft Ecological Risk Assessment for atrazine (“ERA”). CRE’s comments included the following conclusion and recommended EPA actions:
There are no field data–no real-world data–supporting the ERA’s modeled effects. EPA should revise its ERA to be consistent with this fact.
If EPA still believes that some change in the current ecological assessment and regulation of atrazine may be necessary, then EPA should first take the following actions:
1) Validate the ERA models in accordance with the principles discussed above;
2) Develop field data supporting any changes proposed by EPA;
3) Have SAPs review EPA’s model validations, field data, and any EPA conclusions based on the models and data;
4) Allow public comment on EPA’s charges to the SAPs; and
5) Inform the SAPs of the data quality, model validation and other requirements that apply to the SAPs’ review, as discussed above.
Click here to read CRE’s entire comments.