Was The RRP Created for the Right Reasons? - Guest Blog

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Was The RRP Created for the Right Reasons?  

One Person’s Opinion: This is a guest blog submitted by Ray Douglas to express his opinion.  Ray is a remodeling contractor in Brodhead, Wisconsin and has been in business for 34 years. He comments and contributes to RRPedia quite often.  If you would like to express your opinion or offer something of value for RRPedia visitors let me know.

Was RRP Created for the Right Reasons?  

The EPA had good reasons and intentions at first to study the effects and causes of elevated blood lead levels, but the levels of EBLL’s in children ages 6 and under dropped dramatically in years 1997-2007. Data from the CDC documents the drop. 

So common sense and logic would say this problem was correcting itself without this new rule.  So what is the reason for RRP?

The EPA has been working for years on the effects of remodeling and renovation in connection with EBLL’s.  The EPA’s Proposed RRP Rule issued on January 10, 2006 describes how some of their research was conducted.  

In a document dated December 1998 EPA received a study that “was funded and managed by the US Environmental Protection Agency.”   I suspect EPA spent millions if not billions of taxpayer dollars on research, studies, the writing of and implementation of the RRP rule.

But something happened along the way and EBLL’s in children 6 and under dropped dramatically.  So why did EPA go ahead with the RRP?  In my opinion one of two things happened. 

1. EPA didn’t notice EBLL’s were dropping      
2. EPA knew the levels were dropping, but had to justify all the taxpayer money they had already spent. 

The EPA couldn’t go back to congress and tell them most of the money they spent was a waste because the problem was correcting itself.

So what did EPA do?  Create the RRP.  Why?  In my opinion I think it was to justify taxpayer money spent and to create a need for future EPA growth.   A similar situation would be like a department in industry that doesn’t use its entire operating budget in a year.   The next year the budget gets cut (layoffs etc), so the department finds a way to use the money whether it is productive or not, so they don’t have to face a budget cut the following year.

Education and public awareness were keys to EBLL’s dropping, but that may have been problematic for the EPA.  If education and public awareness were enough to reduce the problem then the EPA could potentially lose some of its congressional funding.   But by creating RRP, EPA takes a problem that was solving itself---creates regulations to solve it---then those regulations in themselves become a problem----therefore giving EPA a reason for its own existence and more congressional funding.