CRE has filed a Data Quality Alert as a precursor to filing a Data Quality Act petition. A Data Quality Alert is a mechanism for informing an agency of the deficiencies in a report which provides a basis for filing a Data Quality petition.
CRE has taken this action in response to the following report issued by EPA:
Environmental Protection Agency, “Benefits of Neonicotinoid Seed Treatments to Soybean Production,” (“Soybean Report”) October 15, 2014.
The aforementioned report indicts the entire FIFRA based regulatory process and if left unchallenged will undermine science based regulation of pesticides.
In particular CRE concludes that:
By not disclosing the data underlying its aggregated results and by using unpublished “proprietary” EPA data of unknown quality and unpublished proprietary federally-sponsored data of unknown quality, EPA has disseminated a study that is biased against American farmers and common sense. The agency does not provide the data and methodology behind its counter-intuitive conclusion that the most sophisticated, data-driven farmers on earth don’t understand their production costs.
See the CRE report SoybeanEconomics.Comments-DQA_Alert