Letter to EPA re school IPM
Posted: Thu Mar 29, 2012 4:19 pm
Dear School IPM supporters,
Please take a minute to review the letter below, in short the letter urges EPA Administrator Jackson to continue supporting School IPM efforts.
If you would like to be included among the signers, please let Dr. Tom Green (IPM Institute of North America) know immediately, please confirm with your current title, organization and email address. Please email Tom Green at ipmworks@ipminstitute.org.
Many thanks, and my best wishes to everyone, Dawn.
BEGIN LETTER
March 21, 2012
Lisa Jackson
Administrator
US Environmental Protection Agency
Washington DC 20460
Re: Failed Management of US EPA School IPM Initiative
Dear Administrator Jackson:
As members of the four regional school IPM working groups, we know that you consider school environmental health a priority investment to achieve the Agency’s mission. We have been gratified that you value Integrated Pest Management (IPM) as a significant risk reduction strategy – particularly as it relates to risks from chemicals, asthma and equity for underserved school communities.
With your approval, on December 22, 2010, former Assistant Administrator Owens announced an initiative to promote expanded use of School IPM to help meet this priority. This welcome announcement followed a long history of investment by US EPA in pest and pesticide risk reduction in schools. However, at this time we are extremely concerned at the lack of progress since Mr. Owen’s announcement.
Indeed, in our partnership with your Agency there has been unprecedented success reducing the risks (particularly in under represented populations) from pests and pesticides with a voluntary and job-creating program implementing IPM in schools and childcare facilities. Due to our efforts, school districts throughout the nation now understand the difference between IPM and the traditional approach. Selective school districts in approximately 40% of the states actually are implementing IPM – impacting millions of kids. Yet we have a long way to go to replicate these successes efficiently. We estimate that currently only about 5% of school districts nationwide have achieved high-level IPM.
We strongly feel that EPA’s management of the school IPM initiative has not allowed the action needed to create sustainable IPM and take advantage of our extraordinary successes. Specifically, EPA has not released a plan outlining its strategy to implement this initiative. An initial round of grants, first announced by your Office of Pesticide Programs (OPP) on June 3, 2011, has still not made any awards. Recent communications from OPP indicate that no new Requests for Applications for funding will be announced in FY 2012 for school IPM, and that IPM outreach in general will be greatly reduced.
Without your direct assistance we do not believe the change-agent core developed over two decades by the Agency can participate effectively to reach what we know is achievable. More importantly, we are convinced that the potential initiated through your Administration to impact many more millions of children will be lost under current conditions. If we lose momentum now not only will this potential be lost but those who have best shown success will not be able to maintain implementation let alone resume efforts when the funding situation improves. As you know, it is always more cost-effective to implement quality technology transfer programs than it is to rely on permit, compliance monitoring and enforcement to meet program goals.
The September 2007 US EPA Office of Inspector General report on the Strategic Ag Initiative cited the lack of a strategic plan, inconsistent priorities and poor coordination with regions. It appears these shortcomings are just as evident in the implementation of the Agency’s School IPM Initiative. We understand the current budget constraints but feel there is much opportunity for improvement in management, and in more direct involvement by the stakeholder team we have built with the Agency’s help. We do not feel that the expertise represented by this team is being utilized in a true partnership.
Can school IPM still work? Absolutely, but it requires what we have always desired: a commitment through superior leadership, dedicated partnership and demonstrated strategic planning/implementation.
We the undersigned request that EPA:
1. Redirect resources as necessary to make FY 2012 funding opportunities available to the many organizations and professionals currently working towards our goal of full implementation of high-level IPM.
2. Release its strategic plan for the school IPM initiative announced 15 months ago.
3. Immediately make the pending grant awards to the principal investigators who were notified months ago that their proposals were recommended for funding.
We have attached a document which our national working group developed with EPA support last year which documents the strong business case for IPM in schools.
We appreciate your attention to the urgent need to follow through on your agency’s December 2010 commitment to school IPM. We would very much appreciate the opportunity to discuss this situation or any support we might offer at your earliest possible convenience.
Sincerely,
Dawn H. Gouge, Ph.D.
Urban Entomologist, University of Arizona, dhgouge@ag.arizona.edu
Thomas A. Green, Ph.D.
President, IPM Institute of North America Inc., ipmworks@ipminstitute.org
Janet Hurley
Extension Program Specialist, Texas AgriLife Extension Service, jahurley@ag.tamu.edu
Marc L. Lame, Ph.D.
Clinical Professor, Indiana University, School of Public and Environmental Affairs - mlame@indiana.edu
Tim Stock
School IPM Education Specialist, Oregon State University, stockt@science.oregonstate.edu
Bob Stoddard
President, Envirosafe, bob@envirosafeipm.com
cc: Jim Jones, Assistant Administrator, OCSPP
Dawn H. Gouge Ph.D.
Associate Professor and Associate Specialist - Entomologist
University of Arizona - MAC
37860 West Smith-Enke Road,
Maricopa, AZ 85138.
USA
Office (520) 381-2223
Lab 104 phone (520) 381-2222
Fax (520) 568-2556
Cell (602) 418-5202
dhgouge@ag.arizona.edu
Please take a minute to review the letter below, in short the letter urges EPA Administrator Jackson to continue supporting School IPM efforts.
If you would like to be included among the signers, please let Dr. Tom Green (IPM Institute of North America) know immediately, please confirm with your current title, organization and email address. Please email Tom Green at ipmworks@ipminstitute.org.
Many thanks, and my best wishes to everyone, Dawn.
BEGIN LETTER
March 21, 2012
Lisa Jackson
Administrator
US Environmental Protection Agency
Washington DC 20460
Re: Failed Management of US EPA School IPM Initiative
Dear Administrator Jackson:
As members of the four regional school IPM working groups, we know that you consider school environmental health a priority investment to achieve the Agency’s mission. We have been gratified that you value Integrated Pest Management (IPM) as a significant risk reduction strategy – particularly as it relates to risks from chemicals, asthma and equity for underserved school communities.
With your approval, on December 22, 2010, former Assistant Administrator Owens announced an initiative to promote expanded use of School IPM to help meet this priority. This welcome announcement followed a long history of investment by US EPA in pest and pesticide risk reduction in schools. However, at this time we are extremely concerned at the lack of progress since Mr. Owen’s announcement.
Indeed, in our partnership with your Agency there has been unprecedented success reducing the risks (particularly in under represented populations) from pests and pesticides with a voluntary and job-creating program implementing IPM in schools and childcare facilities. Due to our efforts, school districts throughout the nation now understand the difference between IPM and the traditional approach. Selective school districts in approximately 40% of the states actually are implementing IPM – impacting millions of kids. Yet we have a long way to go to replicate these successes efficiently. We estimate that currently only about 5% of school districts nationwide have achieved high-level IPM.
We strongly feel that EPA’s management of the school IPM initiative has not allowed the action needed to create sustainable IPM and take advantage of our extraordinary successes. Specifically, EPA has not released a plan outlining its strategy to implement this initiative. An initial round of grants, first announced by your Office of Pesticide Programs (OPP) on June 3, 2011, has still not made any awards. Recent communications from OPP indicate that no new Requests for Applications for funding will be announced in FY 2012 for school IPM, and that IPM outreach in general will be greatly reduced.
Without your direct assistance we do not believe the change-agent core developed over two decades by the Agency can participate effectively to reach what we know is achievable. More importantly, we are convinced that the potential initiated through your Administration to impact many more millions of children will be lost under current conditions. If we lose momentum now not only will this potential be lost but those who have best shown success will not be able to maintain implementation let alone resume efforts when the funding situation improves. As you know, it is always more cost-effective to implement quality technology transfer programs than it is to rely on permit, compliance monitoring and enforcement to meet program goals.
The September 2007 US EPA Office of Inspector General report on the Strategic Ag Initiative cited the lack of a strategic plan, inconsistent priorities and poor coordination with regions. It appears these shortcomings are just as evident in the implementation of the Agency’s School IPM Initiative. We understand the current budget constraints but feel there is much opportunity for improvement in management, and in more direct involvement by the stakeholder team we have built with the Agency’s help. We do not feel that the expertise represented by this team is being utilized in a true partnership.
Can school IPM still work? Absolutely, but it requires what we have always desired: a commitment through superior leadership, dedicated partnership and demonstrated strategic planning/implementation.
We the undersigned request that EPA:
1. Redirect resources as necessary to make FY 2012 funding opportunities available to the many organizations and professionals currently working towards our goal of full implementation of high-level IPM.
2. Release its strategic plan for the school IPM initiative announced 15 months ago.
3. Immediately make the pending grant awards to the principal investigators who were notified months ago that their proposals were recommended for funding.
We have attached a document which our national working group developed with EPA support last year which documents the strong business case for IPM in schools.
We appreciate your attention to the urgent need to follow through on your agency’s December 2010 commitment to school IPM. We would very much appreciate the opportunity to discuss this situation or any support we might offer at your earliest possible convenience.
Sincerely,
Dawn H. Gouge, Ph.D.
Urban Entomologist, University of Arizona, dhgouge@ag.arizona.edu
Thomas A. Green, Ph.D.
President, IPM Institute of North America Inc., ipmworks@ipminstitute.org
Janet Hurley
Extension Program Specialist, Texas AgriLife Extension Service, jahurley@ag.tamu.edu
Marc L. Lame, Ph.D.
Clinical Professor, Indiana University, School of Public and Environmental Affairs - mlame@indiana.edu
Tim Stock
School IPM Education Specialist, Oregon State University, stockt@science.oregonstate.edu
Bob Stoddard
President, Envirosafe, bob@envirosafeipm.com
cc: Jim Jones, Assistant Administrator, OCSPP
Dawn H. Gouge Ph.D.
Associate Professor and Associate Specialist - Entomologist
University of Arizona - MAC
37860 West Smith-Enke Road,
Maricopa, AZ 85138.
USA
Office (520) 381-2223
Lab 104 phone (520) 381-2222
Fax (520) 568-2556
Cell (602) 418-5202
dhgouge@ag.arizona.edu