Providing Your Opinions to the EPA

By John D. Musso, CAE, RSBA posted 04-06-2014 10:03

As we have all experienced, sometimes the U.S. federal government tells us to do things, but they don't give us the money to do it. Many times, we aren't given the opportunity to voice our concerns about a pending regulation. But this issue was different.  When the EPA thought about implementing some new regulations around PCBs (polychlorinated biphenyls) that are sometimes found in fluorescent light ballasts produced prior to 1980, they had to seek public comment--because the financial burden of the regulations would exceed the allowable burden under federal law. The official cutoff for not seeking public comment on an unfunded mandate is $25 million nationally.

In the case of the new PCB regulations, ASBO teamed up with AASA (superintendents) and NSBA (school boards) to conduct a survey of members to see how far reaching this issue really is. And talk about an overwhelming response, between the three groups, ASBO International received over 1,200 responses from school business officials across 49 states. 

According to the survey results, PCBs aren't a big problem for your school system, or, you are already taking care of them.  In fact, only 25 total respondents of the 1,200 had ever had a problem with PCBs, and 6 of those 25 had already taken the steps to do a lighting upgrade and remove the remaining PCBs.

So we are urging the EPA to not change the timeline on PCB removal.  I have uploaded the letter we submitted so you can read more of the results of the survey yourself.  But make no mistake, PCBs are dangerous and they need to be removed.  They are potentially harmful, those old fixtures are inefficient, and it's likely that soon you won't be able to find the right kind of bulbs to work in them anyway.

Get more info on PCBs on the EPA website--they are a great resource, but let's show them that this is one issue that we have covered.

My hats off to the school business officials whose overwhelming response to this survey allowed us to issue a strong message indicating Federal intervention in this matter is not necessary, nor is another unfunded mandate.