Friday, March 16, 2018

NPMA: To Win We Must First Define Our Enemies and Our Allies, Part I

Definition leads to clarity.  Clarity leads to understanding.  Understanding leads to good decision making.  Good decision making leads to harmony! 

Rich Kozlovich

Over the last two years our industry has been asked by the National Pest Management Association (NPMA) to go to Congress on Legislative Day and ask our Representatives and Senators to bump up the Environmental Protection Agency’s (EPA) budget by tens of millions of dollars.  I have some questions:
  • Who at NPMA makes such irresponsible decisions?
  • Who initiates such an irresponsible idea?
  • Did anyone vote on this?
  • If so, who were they and what would possibly possess their minds to think this was a “good thing”?
The EPA was born in corruption with President Richard Nixon.  His goal was to ban DDT.  He appointed William Ruckelshaus as the first director, an underground activist who made the decision to ban DDT irrespective of the fact none of his science advisors agreed, nor did Judge Sweeney, the federal magistrate who ruled none of the claims against DDT stood the test of scientific validity.  Ruckelshaus admitted years later his decision was a political decision, not a scientific one. 

As a result, Nixon, Ruckelshaus, Rachel Carson and the EPA are responsible for the blood of up to 100 million innocent victims, who’ve died unnecessarily from malaria, and hundreds of millions who‘ve been unnecessarily sickened every year since.  And that’s only malaria, that doesn’t count all the other insect borne diseases DDT could have prevented.  Because Rachel lied millions died, and the EPA knew it!

Has anything changed at the EPA?  Absolutely not! The radical agenda of EPA’s activists outranks science, economics or the human disasters they’ve created.  EPA was born in corruption and has remained corrupt ever since, with a virtual lava flow of scientific dubious and destructive regulations.  The fact they've done some good things doesn't give them a pass on who and what they really are. 

Then we have what’s called “sue and settle” regulations, which Pruitt has ended.  An illegal conspiracy to force regulations on the nation they don’t have the power or authority to impose.  A corrupt scheme between corrupt EPA officials and green activists via court decisions.   The greenies sue and the EPA either puts up a halfhearted effort to defend against that suit or they settle giving the greenies all they desire with the imprimatur of the federal judiciary. 
I've been told we don't want to do anything that offends EPA because we want them to trust us.  Our real concern should be is whether or not we can trust them.  And history has shown the answer to that concern - from the beginning of EPA until right now this very moment - is we can't, and we need to stop bending over the barrel for them and the chemical companies. 

Can someone explain to me why that isn’t the definition of a criminal conspiracy that could be prosecuted under the Racketeer Influenced and Corrupt Organizations Act, commonly referred to as RICO?

The current Director, Pruitt, has ended that practice, but what about all the damage that’s been done by those who participated in these corrupt actions?  Who will make those who’ve suffered from this illegal conspiracy whole again?  Who has even been fired for this?

But their “conspiracies” are even broader, more mendacious and more insidious.  Tell you what – we’ll come back to that!

They've spent untold millions promoting a pest control system that doesn’t exist.  IPM!  In point of fact there is no such thing as IPM in structural pest control. (Please see The Pillars of IPM.)
In 1996 the Congress in an effort to fix something called the Delaney Clause of the Federal Food, Drug and Cosmetic Act of 1938 passed something called the Food Quality Protection Act (FQPA). The Food Quality Protection Act was supposed to be a pro-pesticide law, but with EPA tinkering it’s became the most anti-pesticide laws passed since Nixon.  We lost carbamates and organophosphates and now we have bed bugs.  For more information on this please go to my article, We Don’t Need No Stinking Badges. As a result, whole categories of safe effective chemistry was lost to the structural pest control industry, and to the general public.
They’ve instituted regulations to impose restrictions on the use of pyrethrins and pyrethroids based on dubious conclusions and industry played into this.   

And I’ll call it for what I absolutely believe what it is – a conspiracy between big corporations and the EPA that screws the structural pest control industry and the public, raising costs and reducing the effectiveness of our treatments. 

And this is the agency we want to have an increased budget?  Really?  Have we lost our minds?

The truth of the matter is this effort to increase the EPA’s budget is in effect blatant Corporatism.  This effort is all about chemical companies desire to get their products registered as quickly as possible, and I don’t fault them for that.  That’s good business.  But why are we being a party to this?   Is this increase in budget good for the pest control industry?

Do we really believe the EPA doesn’t have the money to do one of their core responsibilities? 

Recently it was reported one of the EPA’s core responsibilities is to clean up Super Fund Projects. How’s that been working? 
"With little media attention EPA under Pruitt has stepped up its efforts to clean the nation’s most toxic Superfund sites, putting the properties back into productive use. In 2016, Obama’s EPA remediated and removed only two sites from Superfund’s national priorities list (NPL). By comparison, in Pruitt’s first year, EPA cleaned up and removed seven sites from the NPL. It’s amazing what the agency can do when it focuses its efforts on core functions. "

We now have an EPA administrator who recognizes just how bad the EPA is for this nation, who before he was the administrator, “successfully sued the EPA numerous times, including convincing the courts to place stays on the Waters of the United States (WOTUS) rule and the Clean Power Plan (CPP).”

Here’s an administration that wants to cut a twenty three percent from the EPA budget and eliminate “dozens of programs”.  But now the NPMA wants our industry to go to Congress to plead with them to add tens of millions back to that budget.  Is it possible Pruitt knows better than the NPMA as to what the EPA needs to perform its core functions?

If the EPA is in such dire economic straits, I have a suggestion that can go a very long way in finding those millions the chemical companies think EPA needs.  Eliminate that core responsibility of registering chemistry from the EPA and return that responsibility to the Department of Agriculture.   Then eliminate all…..and I mean all…. The EPA regional offices.  Every state now has an EPA of their own, why does the EPA need regional offices?

But we have to come back to the core question.  Why are we adopting this stance to increase EPA's budget? 

Because that’s what “our allies”, the chemical companies, want us to, and please don't insult my intelligence claiming otherwise.

The chemical companies are at best leaky vessels as allies.  They treat us as allies of convenience, and we need to recognize that and treat them in exactly the same manner.  When it suits our needs, we defend them.  When it doesn’t – we don’t! If those in leadership can’t understand that, or do but don’t have the courage to act accordingly – we need to take a real hard look at that leadership.

I've talked to a number of the members of the Ohio Pest Management Association who will be attending Legislative Day and none of those I talked to will support this scheme.  One told me he will present NPMA's information and then specifically tell his Representative and Senator he absolutely does not support this budget increase for EPA. 
I encourage every member of every state association attending to take that stance. 
Let’s try and get this once and for all – There’s no good government or bad government.  There’s only limited or unlimited government, and EPA is now and always has been out of control.  They need to become far more limited, or better yet - eliminated, which I will address later.    
We have a window of opportunity with the Trump administration to fix many things.  But when that window closes, and it will at some point - it may close forever.   Leadership needs to get that!  It's now a matter of win or go home!
One more point.  I'm an autodidact who's willing to publicly debate anyone involved with our industry who disagrees with me on any of these points or issues, irrespective of their position or education.  I encourage NPMA to set up such a debate.

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