Henry Miller's essay regarding Environmental Protection Agency (EPA) regulation of plant pesticides and BIO's position ("BIO's 'Cooperation' With Regulators Deals A Blow To Competition," The Scientist, Oct. 2, 1995, page 12) is replete with half-truths and makes a serious allegation that must be answered. Miller speaks of both monolithic regulation by EPA and an industry in lockstep with the regulators. Had he read the EPA proposal and the BIO response, he would have been much better informed.

Contrary to what Miller writes, EPA has not proposed to regulate whole plants, only certain pesticidal substances produced in plants. EPA developed this proposal over a five-year period and sought broad public input at several meetings of its Science Advisory Panel. We can quibble about the definition of what should fall within EPA's scope, but the agency has broad legal regulatory authority under the pesticide statute. BIO filed 19 pages of comment last...

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