I want to be careful not to get into a situation of debating the merits of amendments with members of the committee and I want to respect your role in decision-making.
I think the concern that we as officials might have with this amendment is that it's not.... The bill attempts to create a new list of substances of concern. If in addition we retain the concept of virtual elimination and retain a virtual elimination list, then we actually have three lists. The purpose of the virtual elimination list, and why it is distinct from this new list, is not clear and could add confusion to the intended functioning of the act.
It's not a concern about the notion of persistence by accumulation as indicators of risk, nor is it a concern about the need for the statute to signal the need for more stringent action for some substances, but I think we would be concerned about a proliferation of lists.