Fw: MY DRAFT COMMENT TO epa IN MSWORD

["Ted Rockwell" <tedrock@cpcug.org>]

Here's the last one.

Ted Rockwell

----- Original Message -----
From: Ted Rockwell <tedrock@cpcug.org>
To: clinton bastin <clintonbastin@email.msn.com>; <WKDavis@AOL.com>; Bert
Wolfe <bert.wolfe@gene.ge.com>; Alan Waltar <waltar@trinity.TAMU.edu>; John
Taylor <jjtaylor@epri.com>; Fred Singer <ssinger1@GMU.edu>; Edward Quinn
<equinn@mdmcorp.com>; John Graham <jgraham@rmi.net>; Jim Muckerheide
<muckerheide@mediaone.net>; Stan Hatcher <shatcher@idirect.com>; Chauncey
Starr <cstarr@epri.com>; Jim Toscas <T@nuworld.org>; Chuck Boardman
<charles.boardman@gene.ge.com>; Mel Coops <m.coops@worldnet.att.net>; Carl
Walter <retlaw@worldnet.att.net>; Beth Earl <bethearl@trinity.TAMU.edu>;
Hori-san <mhori@mxb.mesh.ne.jp>; <WBehnkejr@AOL.com>; Andree and Richard
Wilson <wilson@huhepl.harvard.edu>
Sent: Sunday, May 28, 2000 9:02 AM
Subject: Re: MY DRAFT COMMENT TO epa IN MSWORD


> Dick:
>
> You make some good points and you state them clearly.  After you're
> satisfied with the wording (and before the deadline) I hope you'll submit
> them to EPA formally.  You realize, EPA received 600 formal comments on
the
> previous proposed rule, and I doubt if they had much effect.  But they
build
> a case, so that when EPA is taken to court, the record is established.
It's
> worth doing.
>
> Your first point, "addressing the fundamental purpose," is a good one.
You
> don't see that point made very often, and it's fundamental.
>
> Your second point, that EPA should be consistent with NRC or provide a
> detailed and convincing explanation why not, is also good. But I see no
> reason to gratuitously endorse the 25mrem/yr at the fence.  That is
totally
> inconsistent with how we regulate other potential hazards and is not
> reasonably justifiable.
>
> Your point about regulating "what" and not "how" is good and well said.
>
> As you would expect, I object strongly to the idea that we have to
> "sidestep"  the "unknowable issue" of threshold.  LNT advocates used to
say
> they were sorry that some unreasonable policies result from their
> regulations, but all they were doing was to "present the best science."
But
> no one tries any more to justify LNT scientifically.  Instead, we are
urged
> with increasing fervor, not to talk about science, to sidestep it, that
the
> public will not buy it.  But we have good scientific papers by the score,
> that conclude that low-level radiation is not harmful, and can be
> beneficial.  And these papers have a great deal of data to back up their
> conclusions.  It is just not scientific to keep claiming that this
question
> is unknowable, without confronting and refuting this evidence, with great
> specificity.  Generic and philosophical denials simply won't do it.
>
> Meanwhile, EPA has given us an even better target: its proposed rule on
> radioactivity in drinking water.  Some of the relevant documents are
> attached.  This is more general, and much of the same objection applies.
> Also, we have a little more time to reply.  I hope you will give this you
> attention also.  I hope also that other addressees of this msg will also
> comment to EPA and let the rest of us know what you submitted.
>
> Ted Rockwell
>
>
>