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NAFTA’s Environmental Watchdog
The Commission for Environmental Cooperation (CEC) is a tri-national organization that serves as NAFTA’s environmental watchdog. Created by the North American Agreement on Environmental Cooperation, a NAFTA side agreement, CEC seeks to "address regional environmental concerns, help prevent potential trade and environmental conflicts, and to promote the effective enforcement of environmental law."
Of particular note, the CEC has established a citizen-initiated process for enforcing environmental regulations. The "Citizen Submissions on Enforcement Matters" mechanism is triggered when a person submits "to CEC a claim alleging...a failure on the part of any of the NAFTA partners" to effectively enforce their environmental laws. "Following a review of the submission, the CEC may investigate the matter and publish a factual record of its findings, subject to approval by the CEC Council."
Recently, a coalition of NGOs including Ecojustice, formerly the Sierra Legal Defense Fund, "allege that the governments are undermining the CEC by obstructing its investigations and severely limiting their scope." An NGO official claimed "increasingly blatant government interference in the operations of this important environmental watchdog."
Free trade is essential to economic and environmental health throughout the Americas. An effectively operating watchdog is an important component of NAFTA and could help promote further increases in free trade. To bolster its own effectiveness and public confidence in the citizen petition process, CEC should adopt Data Quality guidelines, similar to OMB’s, which provide objective, manageable standards for evaluating complaints.
See CEC homepage
See CEC Citizen Submissions on Enforcement Matters Guidelines
See Ecojustice Press Release
See Data Quality Guidelines
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The Union of Concerned Scientists: Unconcerned With Science
The UCS contradicts itself when it comes to supporting scientific integrity by the government. The NGO claims to support sound scientific and economic analysis by the government while simultaneously opposing federal standards requiring quality science.
UCS recently released a report on Concentrated Animal Feeding Operations (CAFOs), which states that CAFOs have "been fostered by misguided public policy. Alternative production methods can be economically efficient...." Logically, the UCS should support the application of rigorous standards by federal agencies in evaluating scientific and economic data when developing CAFO-related regulations. The UCS should also support their own right to seek and obtain correction of data used by agencies which do not meet those standards.
Counter to their own purported objectives, the UCS attacks the scientific standards and administrative correction procedures which could change the basis for what they believe to be incorrect government decisions. UCS released a report, with the absurdly Orewellian subtitle "Securing the Integrity of Science in Policy Making," which opposes the very scientific integrity it claims to support. Specifically, the report falsely states that the Data Quality Act "gives industry groups the ability to challenge any government regulation by filing frivolous DQA challenges to the underlying information."
The DQA gives all persons, including the UCS, the ability to file substantive petitions to seek and obtain warranted corrections of data. The DQA has been successfully used by the notably non-industry Public Employees for Environmental Responsibility. Recently, the DQA was invoked by a trio of Alaskan NGOs.
Various stakeholders have raised serious environmental, economic and ethical concerns about CAFOs. If UCS were genuinely interested in improving public policy, instead of public relations, they would devote their resources to filing non-frivolous DQA challenges to federal use of data not meeting Data Quality standards.
See USC CAFO study
See USC federal science report
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