Natural Resources Defense Council * Sierra Club * Environmental Defense
International Campaign for Responsible Technology - IHEAL
Friends of the Earth * The Hampshire Research Institute * Environmental Law Institute
U.S. Public Interest Research Group * Working Group on Community Right-to-Know
August 14, 2002
James Connaughton
Chair, Council on Environmental Quality
Executive Office of the President
722 Jackson Place, N.W.
Washington, D.C. 20503
Fax: 456-0753
Dear Mr. Connaughton,
RE: U.S. Participation in UN/ECE Pollutant Release and Transfer Register Protocol Negotiation
We
are writing to ask that the U.S. Government participate as a formal
negotiator in the UN/ECE Pollutant Release and Transfer Register (PRTR)
Protocol Working Group. As you know the Protocol negotiations are due
to conclude this fall. It is critical for the United States to participate
in the September 16-17 meeting with negotiating authority if the United
States is to influence the scope of this first international right-to-know
agreement.
A strong PRTR Protocol will
help the U.S. establish a "level-playing field" for its domestic chemical
producers whose international competitors may not face the same reporting
requirements. In addition, our organizations and millions of members
they represent are concerned about good environmental governance. Over
the last 15 years, the United States has provided leadership by showing
how public access to toxics release information can improve public accountability
and help prevent pollution.
A report to be released at
the World Summit for Sustainable Development by a coalition piloting
access indicators documents the need for a strong PRTR Protocol and
shows that information about industrial facilities is the most difficult
type of environmental data for the public to obtain.
Especially now, on the eve of the World
Summit for Sustainable Development, the PRTR Protocol negotiations provide
the United States with an opportunity to demonstrate its commitment
to right-to-know as an efficient and effective incentive for pollution
prevention and reduction.
U.S. NGOs, represented by the Natural Resources Defense Council and the International Campaign for Responsible Technology - IHEAL, are at the negotiating table. However, without formal U.S. government involvement, it is very likely the other UN/ECE countries will establish a pollutant reporting mechanism that is substantially less effective at reducing pollution and ensuring citizen access to information than the U.S. TRI. Establishment of a separate UN/ECE PRTR system would likely hinder progress on PRTR development in the Americas, as countries preparing national systems would face competing and inconsistent models. With U.S. participation, it is likely that the Protocol will move
towards a compromise between the two systems that improves public accessibility, facilitates comparisons, and helps ensure a consistent standard for industry on both sides of the Atlantic.
Until
now, the United States has been an extremely valuable participant in
the negotiations, hampered only its lack of negotiating authority. We
hope that you will promote U.S. participation as a formal negotiator.
Respectfully,
Susan Casey-Lefkowitz
Natural Resources Defense Council
1200 New York Ave, N.W., Suite 200
Washington, D.C. 20005
Tel: 202- 289-2366
Fax: 202-289-1060
Michael Stanley-Jones
International Campaign for Responsible Technology - IHEAL
Silicon Valley Toxics Coalition
Richard Cellarius
Sierra Club
John M. Balbus, MD, MPH
Environmental Defense
David Waskow
Friends of the Earth
John Chelen
The Hampshire Research Institute
Carl Bruch
Environmental Law Institute
Jeremiah Baumann
U.S. Public Interest Research Group
Paul Orum
Working Group on Community Right-to-Know
CC: Linda Fisher, Deputy Administrator,
U.S. Environmental Protection Agency
Jeffrey Burnam, Deputy Assistant
Secretary for Environment, U.S. Department of State