stateagspopsletter-967e5ecbdb84bb51.pdf

A letter dated February 28, 2006, from several U.S. state Attorneys General to the House Committee on Energy & Commerce opposing specific provisions of HR 4591. The bill aims to implement the Stockholm Convention on Persistent Organic Pollutants (POPs Treaty), but the signees argue it contains overly broad preemption language and flawed EPA review procedures that would hinder state and federal environmental protections.

• The signees oppose HR 4591 because it contains "unduly broad preemption language" that would restrict the ability of states to regulate toxic chemicals listed under the POPs Treaty, even in cases where the treaty allows for continued use of a substance.
• The letter highlights the risk to existing state regulations, specifically citing brominated flame retardants known as PBDEs, which some states have already banned or are considering banning.
• The signees criticize the bill's proposed EPA review procedures for new POPs, arguing they would duplicate international review processes, delay federal action, and give insufficient weight to the conclusions of the Persistent Organic Pollutant Review Committee.
• The bill is criticized for lacking a required response or deadline for the EPA to act following an international recommendation to list a new POP, as well as lacking an enforcement mechanism to challenge EPA decisions.
• The letter references testimony from Georgetown University Law Professor Lisa Heinzerling, who characterized the bill's cost-benefit balancing approach as being "systematically biased against environmental protection."

APA

Center for International Environmental Law (n.d.). stateagspopsletter-967e5ecbdb84bb51.pdf. https://www.ciel.org/wp-content/uploads/2015/05/StateAGsPOPsLetter.pdf

Chicago

Center for International Environmental Law. stateagspopsletter-967e5ecbdb84bb51.pdf. n.d. https://www.ciel.org/wp-content/uploads/2015/05/StateAGsPOPsLetter.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=stateagspopsletter-967e5ecbdb84bb51.pdf |url=https://www.ciel.org/wp-content/uploads/2015/05/StateAGsPOPsLetter.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallawndstateagspopsletter967e5ecbdb84bb51pdf, author = {{Center for International Environmental Law}}, title = {{stateagspopsletter-967e5ecbdb84bb51.pdf}}, publisher = {Center for International Environmental Law}, url = {https://www.ciel.org/wp-content/uploads/2015/05/StateAGsPOPsLetter.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }