HC79.E5
U6
Regulatory Reform Initiatives Progress Report
October 1979
240R79101
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Reform Closeup
A Tougher Job
Requires
Smarter
Regulation
The Controlled Trading
Complement to
"Command and Control'
Regulation
By William Drayton, Jr.
Assistant Administrator for
Planning and Management
Every year our environmental problems get
worse. Our population continues to grow,
and so does the size of the economy sup-
porting each person. On the other hand, the
quantity of air, water, and land is fixed.
Thus, even before we consider the impact of
our mushrooming chemical and technological
creativity, environmental quality must deteri-
orate if we stand still.
Throughout the 1970s we have been doing
anything but standing still. Birds that have
not been seen for decades have begun to
reappear. Salmon have begun to swim up
the Connecticut River again, and Washing-
ton, D.C. officials are debating whether peo-
ple can safely swim in the Potomac again
next year.
But the 1970s were relatively easy years for
environmental cleanup. We were able to
regain a lot of lost ground because we had
relatively easy targets — a limited number of
sources that could remove a great deal of
pollution for relatively modest per-pound
costs. Moreover, the problem we set out to
address was simpler than the one we now
face. For example, we set out to control a
few gross pollutants such as basic oxygen
demand and particulates, not hundreds of
toxics — let alone the cumulative impact of
various mixes of pollutants.
In order not to lose ground, we will be
steadily pushed to do two increasingly dif-
ficult things: First, we must ask those we
have already regulated to tighten their con-
trols further — forcing them in many cases
up the steep outer extremities of their cost
curves. The incremental pounds of pollution
removed when a company moves from 90 to
97 percent control will almost always cost
very much more than the average cost of the
pounds already being removed. As we push.
further up these cost curves, resistance will
understandably increase.
Second, we must reach out and regulate
ever larger numbers of smaller and smaller
sources. This effort entails much greater ad-
ministrative effort for every pound of pollu-
tion removed because the payoff from each
interaction is small. And it involves an ever
increasing number of voters in what they
commonly perceive as regulatory hassles.
This second path, consequently, also in-
creases public resistance to environmental
legulation.
We are going to have to be innovative to
escape this trap.
First, we must stimulate a sharp increase
in the rate of control technology innovation.
That is the chief, in the long term the only,
way we can protect environmental quality. If
we cannot find a steady and rapid stream of
new ways of controlling more pollution at
lower costs, our society will be forced to
choose between environmental deterioration
and ever rising control costs.
If we allow this to be the choice, everyone
will lose. That is why I believe that finding
new ways of stimulating new control tech-
nologies is essential for the environmental
movement and very important for our
economy.
Second, we should look for other ways of
getting more for less. Whenever we can get
a pound of pollution removed for fifty cents
rather than a dollar (or two pounds removed
instead of one for that dollar), we are mov-
ing in the right direction. Because we have
been operating with relatively crude "com-
mand and control" regulatory tools, enor-
mous opportunities seem available.
In pursuing both these objectives, we must
be rigorously realistic. A good theory is not
enough. We must have practical, implemen-
table programs. Most especially, they must
be as administrable and as enforceable as
what we have now. A "reform" that
becomes a loophole (1) is no help and (2)
will undercut the whole effort to innovate.
Over the last two years EPA has been
developing a closely interrelated set of
reforms that will, I believe, allow us to
escape the trap, to get more for less. These
reforms represent the first realistic comple-
ment, or perhaps alternatives to "command
and control" regulation. They can be
adapted to many non-environmental fields of
regulation as well.
"Command and
Control" Crude
Traditional environmental regulation sets very
specific emissions or discharge limits for
each class of process it regulates. Thus, for
example, we will tell asphalt producers that
they cannot emit more than 5.7 pounds of
paniculate per million cubic feet of air from
their drying process. And then that same
standard applies to their loading and transfer
operations, 5.7 pounds of particulate per
million cubic feet. This sort of regulation
does not leave those it regulates much room
to find more efficient ways, or combinations
of ways, of meeting society's objectives.
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Central commands are likely to be poorly
and belatedly informed; they are certain to
be ignorant of the specifics of each case. A
general standard for drying asphalt products
— or any other process — can never take in-
to account the age, condition, degree of use,
etc. of any particular equipment or process.
Only those who operate the plant have this
information.
Further, those who write central com-
mands can only make relatively crude trade-
offs regarding how much control to ask of
sources of the same pollutant. They com-
monly seek to apply a rough measure of
comparable technological effort, sometimes
reinforced by a local ambient or water quality
modeling effort. Both approaches use eco-
nomics in only the crudest way, if at all.
Such attempts at central planning simply
cannot deal with the enormous variation and
flux of case specifics, let alone the infinite
possible combinations of actions that could
be used to meet any particular environmental
objective.
We can improve the quality and sensitivity
of our central commands — but only within
a very fundamental set of limits. The more
we try to adapt them to real world variations,
the more detailed, cumbersome, and restric-
tive they become. On the other hand, the
more general we make them, the more
wasteful their inattention to specifics
becomes.*
Winning Allies:
The Strategic Alternative
The key to doing a better job — and to
escaping the trap we are now entering — is
to form an alliance. We need those we
regulate to put their case-specific knowledge,
their technical and managerial expertise, and
their energy and imagination to work to solve
the environmental and economic dilemma we
share.
"This paper really only considers the "command"
side of our two-part "command and control"
regulatory system. Once we have adopted sensible
requirements, we must move on to the second
half of the regulator's job: making sure that every-
one does his or her part to comply. This part of
our traditional system has also worked very poorly.
The economic approach to enforcement embodied
in the "Connecticut Enforcement Plan" that I
discuss in my forthcoming Harvard Journal of
Legislation article "Economic Law Enforcement"
is, I believe, how we can best fix this second half
of our dilemma.
If plant engineers felt it were in their and
their firm's interest to find more efficient
ways of abating pollution, we would have
more control technology innovation than we
have ever imagined. (Further, by thus involv-
ing these engineers we would overcome one
of the chief reasons we have such trouble
getting plants that have installed control
equipment to operate and maintain it proper-
ly — the fact that, uniquely, the plant
engineers do not feel that this equipment is
theirs.)
If an engineer finds a way of getting more
particulates out of a plant kiln's emissions at
a low cost, we can let him (or her) increase
his (or her) particulate emissions from
another part of the plant where it costs more
to remove a pound of particulate. Or we can
let the management sell that reduction above
and beyond what is required by law to
another firm in the same area that otherwise
could only meet part of its particulate control
requirements at much higher costs, if at all.
Before either trade could be effected, we
would have to be convinced that we could
administer and enforce the new arrange-
ments easily.
These arrangements, and a host of vari-
ants, give managers and engineers a power-
ful incentive to find more efficient forms of
control and more cost-effective mixes of
control. They create a market in which busi-
ness can make a profit by producing clean
air and water.
As with most other markets, trading must
take place within a set of agreed and policed
rules. I have consequently dubbed the set of
interdependent reforms we are now review-
ing "controlled trading". The following
several sections briefly discuss some of the
specific reforms that EPA plans to develop
together into this overall complement to
traditional "command and control" regula-
tion.
Offsets
Offsets are EPA's first application of the
idea that one source can meet its environ-
mental protection obligations by getting
another source to take additional control ac-
tions. In "non-attainment" areas pollution
from a proposed new source — even one
which controls its emissions to the lowest
level possible — would aggravate existing
violations of ambient air quality health stan-
dards and trigger the statutory prohibition.
Our offset policy lets new sources build
under such circumstances if they
• control emissions to the lowest achievable
level; and
• persuade an existing source(s) to redi
emissions by an amount at least equal t
pollution the new source will add.
The existing source's reduction is sup
posed to offset the impact of the new
source's emissions on air quality. EPA n
approve each proposed offset to ensure
the total amount of pollutants emitted is
tually less than before the offset transac
opportunity. In seeking an existing soun
emissions that could be reduced to offsi
emissions, the owner of the new source
probably look for the most cost-effective
pollution reduction available.
For example, in Oklahoma City, Gener
Motors worked out an offset agreement
local oil companies so that it could build
new auto assembly plant. The oil compa
agreed to install either floating roofs (a v
economical type of control) or vapor
recovery systems on their storage tanks <
GM agreed to use a new painting proces
The expected reduction of hydrocarbon
emissions (a major ingredient in smog) w
enough so that GM could build a $400
million plant that eventualty will employ
several thousand people.
A similar offset transaction made it pos
ble for Volkswagen to open its first U.S.
assembly plant at New Stanton, Pennsyl-
vania. The offset came when the state hi<
way department substituted water-based
hydrocarbon-based asphalt in its road cor
struction program for western Pennsylvan
The offset policy lets a new source mee
ambient health standards by turning to
another source to find needed extra emiss
controls. There is no reason to confine thi
flexible arrangement to new sources in are
violating air quality standards.
The Bubble
The bubble policy explicitly encourages th<
owners of plants facing high marginal cost
of pollution control to meet their emission
reduction requirements by putting extra co
trols on discharge points within the plant
with lower control costs in exchange for e<
ing the pollution control requirements for
discharge points in the plant with high con
trol costs. The bubble policy is so named
because it gives business managers the fle>
ibility to think of reducing total emissions
from an imaginary canopy, or bubble, plac<
over all the emission sources of a plant. If
they find it is cheaper to tighten the contro
of a pollutant at one point and relax contro
at another, they can do so as long as the
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I pollution from the plant does not ex-
J the sum of the current limits on in-
Jual sources of pollution in the plant.
here are some restrictions, of course.
des must be made between discharges of
same pollutant. We would not, for in-
ice, allow a firm to emit more of a car-
agenic pollutant in return for an equal
ume reduction in a more innocuous one.
Mants with several industrial processes and
ny emissions sources are the best can-
ates for "bubbling". Chemical companies,
el mills and petroleum refineries are
ong those now studying ways to imple-
nt the bubble.
Jnion Carbide may realize a savings of
ire than $5 million by using the bubble at a
3St Virginia metal fabricating plant. To
iet current State regulations for particulate
ntrol, the company would have to replace
high-energy scrubber with a new control
vice, called a bag collector. This could
st between $5 and $6 million. Because
jy now have alternative ways of reducing
rticulates within the plant, Union Carbide
proposing to reduce emissions in another
ay. The company would shut down two
rnaces elsewhere in the plant to reduce
irticulates by more than three times the
el achieved by replacing the scrubber.
us, the people of West Virginia and Union
rbide both get cleaner air at lower cost.
The DuPont Corporation tells us that
plying the bubble to one of its largest
nts will allow it to remove 89 percent of
t plant's hydrocarbon emissions for $5
Ilion. Otherwise it estimates that it would
ve to pay $20 million to remove 84 percent
these emissions.
The Offset and Bubble approaches allow
reased pollution to be balanced by com-
nsating decreases of the same pollutant
m other sources. Because business firms
ve considerable freedom to choose the
lluting operation from which to reduce
issions, these approaches can accomplish
llution reduction at the lowest possible
st.
nking and Brokerage
any new firms locating in urban areas will
ed to find offsets. We want to encourage
tablished firms to anticipate the demand
r offsets by controlling emissions more
an the law requires and "banking" the ex-
for later sale to another firm, or for their
m future use. Firms with lower control
sts will be able to sell their offset for less
d are more likely to attract customers.
ich firms will have a considerable incentive
find the most effective, efficient control
stems.
To help this still small-scale market
become more fluid and efficient, we will also
need brokers to arrange trades between new
firms and firms with banked (or bankable)
emissions reductions. We will need such
brokers if we are to get smaller firms, which
generally cannot afford the sort of in-house
axpertise trading that such specialized
markets will require, to participate in any
number.
In the Oklahoma offset case, for example,
it was the Chamber of Commerce, anxious
to attract new jobs for the city, that served
as a middleman. The Chamber sought out oil
companies in the area that were willing to
create the offsets and brought them together
with General Motors and the regulatory
agencies. In some areas state or city govern-
ments are taking on this function, in a few
others private for-profit firms have begun to
function.
To encourage the activities of these brok-
ers, EPA is working to set up information
clearinghouses so that firms seeking offsets
can easily locate firms wanting to sell them.
Part of that assistance includes improved
computer models to assess how sources
contribute to air pollution and to estimate the
effects of new sources of pollution.
Some of the grants EPA has recently
awarded to cities for air quality technical
assistance will be used for developing emis-
sions trading markets in urban areas that
have not attained air clean enough to meet
national standards.
Marketable Rights
Under contract to EPA, the RAND Corpora-
tion is studying the use of marketable per-
mits as a way of first allocating and then let-
ting permit holders transfer to others some
or all of their rights to emit pollution.
RAND's study focuses on permits to emit
fluorocarbons, but the concept clearly has
broader potential application. With modifica-
tions the idea might eventually strengthen
the controlled trading market discussed
above.
Further Steps
Now we need to work hard at implementing
this new framework. We need state and local
agencies and individual companies to work
together and with us to refine this promise
and turn it into the fundamental alternative I
believe it can and should become.
There is a great deal of refining still to do.
We need to find possible loopholes and close
them. We need to see how far we can ex-
tend offset trading geographically and how
big geographically we want to make bubbles
grow. We need to see how far we can go in
linking the several controlled trading pieces
together into one "market". Can we, for ex-
ample, allow trades between bubbles and
offsets? And so on.
This testing will help make clear what
legislative changes may make sense when
our air and water acts next are reviewed by
the Congress — as they are every four to
five years. Already I believe it is clear that we
should press to allow new sources to partici-
pate as fully as old sources in this controlled
trading. (New sources cannot now partici-
pate in most of these activities.)
By giving those we regulate incentives
to propose better ways of getting the job
done, we can avoid leaving society with
the disastrous choice of environmental
deterioration or ever-rising costs. By
releasing and directing their energy and
skills to finding new control technologies
and other ways of getting more done for
less we will accomplish many times
more than we ever could by trying to do
the job better ourselves.
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Reform Update
EPA:
Environmental
Protection
Auditors
EPA's Office of Enforcement is
studying the use of a new
private market system for
monitoring compliance with en-
vironmental laws. It would
operate much the way that
public accountants certify the ac-
curacy of a company's financial
records.
EPA would license indepen-
dent contractors who had the
skills necessary to be environ-
mental auditors. The monitors
would measure a company's in-
dustrial discharges and prepare
reports which the businesses
would forward to EPA. Either
EPA or the state would certify
that an audit was done. EPA
would charge the businesses a
fee for the audit certificates to
cover the cost of the program.
At the present, the govern-
ment does not have enough peo-
ple to inspect all the industrial
sources regulated by EPA
statutes. For example, only 20%
of major water pollution point
sources are inspected annually.
A program of private sector
auditors would help reduce the
monitoring gap without adding
inspectors to EPA's payroll. In
addition, private sector involve-
ment in enforcement activities
might lead to greater productivity
in the monitoring field.
To maintain quality control
and prevent bribery in the audit-
ing program, EPA would estab-
lish standards for auditing firms
and would conduct sample re-
views of their work. In addition,
auditors would not be allowed to
monitor the same facility for two
consecutive years in hopes that
this would reduce the chances of
interpersonal relationships affect-
ing the accuracy of monitoring.
A contractor is studying the
feasibility of setting up the
auditing network for stationary
air pollution sources. The final
report is due by December. The
Enforcement Office is also con-
sidering use of such a system for
the water pollution and toxic
substances programs.
In another effort to improve
enforcement of EPA regulations,
the agency is considering the
possibility of awarding grants to
citizen groups to participate in
various aspects of enforcement
of environmental laws including
monitoring, legal research, and
administrative aspects of the en-
forcement process. Feasibility
studies are currently underway.
Agency contact:
Gerald Bryan
Office of Enforcement
EPA (EN-329)
Washington, D.C. 20460
202-755-2505
Urban
Growth
with Cleaner
Air
EPA is one of four Federal agen-
cies sponsoring a $4 million
demonstration program to help
cities attract new and retain ex-
isting industry while meeting
clean air requirements.
The grants to eight urban
areas will stimulate a number of
innovations in state and local air
pollution policies. These pro-
grams will include:
Boston (Mass.): To create off-
sets for growth by reducing
emissions at city-owned facilities,
and to provide technical assis-
tance to small pollution sources
to make use of economies of
scale (for example, by organizing
dry cleaners to purchase pollu-
tion control equipment together).
Buffalo/Erie County (N.Y.): To
establish an offset information
center to help small and medium-
sized firms facing pollution con-
trol requirements that can im-
pede growth, and to operate an
offset bank.
Philadelphia (Pa.): To identify
target industries to attract to the
city and to propose financing
mechanisms for environmental
control devices and manufactur-
ing processes most appropriate
for these targeted industries, to
investigate emission fees as a
strategy, and to develop new or
modified industrial plant siting
policies.
Chicago (III.): To develop and
maintain an emission offsets
bank, to design strategies for ad
ditional emissions offsets, and to
develop mechanisms for financial
and technical assistance to com-
panies.
Minneapolis/St. Paul (Minn.):
To begin work on establishing
emission limits in the region's
zoning process, to develop pro-
cedures for incorporating air
quality assessments into regional
capital improvement programs,
and to create offset banking and
an air quality ordinance as tools
for long term air quality manage-
ment.
Elizabeth (N.J.), Bridgeport/
Waterbury (Conn.), and Portland
{Ore.) were also selected for
grants from among the 75 appli-
cants. The cities were awarded
up to $500,000 each, based on
the degree of economic or social
distress, the severity of air pollu-
tion problems, and the area's
commitment to economic devel-
opment and attainment of air
quality standards. The sponsor-
ing agencies also considered
how innovative the cities' pro-
posals were, whether the local
programs could be duplicated in
other areas, and the likelihood of
a continuing, self-supported
system after the demonstration
funding is complete.
The sponsoring agencies (the
Departments of Commerce,
Transportation, Housing and Ur-
ban Development, along with
EPA) will hire a consultant to
evaluate the demonstration pro-
gram on a national level. EPA
staff will monitor the programs
and provide assistance.
Agency contacts:
Meri Bond
Office of Transportation and
Land Use Policy
EPA (ANR-445)
Washington, D.C. 20460
202-755-0570;
John S. Hoffman
Policy Planning Division
EPA (PM-221)
Washington, D.C. 20460
202-755-9033
Banking Crec
for Pollution
Reductions
EPA's Emissions Offset PC
allows areas with air quali
worse than national stand;
encourage industrial growl
while still making progress
toward clean air goals. Ne
sources of air pollution cai
locate in these areas if exis
sources reduce their emiss
by more than the emission
added from new pollution
sources. Many states now
adopting an offset approac
way to accommodate new
growth.
Under a recent revision i
offset policy, companies w
reduce their emissions can
"bank" those reductions fc
future use or sale, either in
set transactions or in other
actions such as internal pla
changes under the "bubble
concept. Banking creates a
centive for companies to re
emissions even more than s
regulations require. It creati
pool, or inventory of emissi
reductions which new or e>
panding facilities can draw
Without banking, the onl
to achieve the emission redi
tions necessary to offset eci
nomic expansion in nonatta
ment areas (those where air
pollution exceeds national s
dards) is by imposing stricte
control requirements on mai
sources which have already
stalled air pollution control
equipment. This additional c
trol would force firms to rep
newly-installed equipment, a
unnecessarily increase the cc
of pollution controls. Bankin
opens up less expensive opti
for reducing emissions now,
rather than making firms wai
until there is a pressing need
an offset.
Banking will reduce the un
tainty facing firms now planr
expansions or new plants. If
emissions have been reduced
and banked, there will be opi
tunities to build new facilities
Firms will face fewer delays.
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less uncertainty about the price
and availability of the emission
reductions they may neeJ for ex-
pansion. And if companies can
draw on these banked inven-
tories in the future, they are
more likely to invest more in
pollution control today.
The agency is actively seeking
the participation of states, local
government and businesses, and
will assist groups wanting to
establish banking systems. EPA
will publish more detailed mate-
rials to help state and local
governments develop specific
rules on how and when banked
emissions can be created,
stored, and used.
Agency contact:
John S. Hoffman
Policy Planning Division
EPA (PM-221)
Washington, D.C. 20460
202-755-9033
Final Report on
Resource
Conservation
Incentives
The EPA Administrator chairs a
Cabinet-level, interagency
Resource Conservation Commit-
tee that recently completed a
study of present and proposed
policies affecting resource con-
servation and solid waste man-
agement. The Committee's final
recommendations were pre-
sented to the President and to
Congress in June.
The Committee had mixed
views on the issue receiving the
greatest attention — mandatory
beverage container deposit
legislation. Proponents of this
measure cited expected savings
in materials and energy, as well
as reductions in expenditures for
solid waste management and lit-
ter control. Opponents argued
that such legislation would not
be cost-effective. Still others
favored delaying a decision on
national container deposit legisla-
tion until there is more ex-
perience with container deposits
at the State level. The Commit-
tee also endorsed further study
on extending deposit legislation
to durable and hazardous goods
and rejected a proposal for a na-
tional litter tax.
The Committee recommended
against legislation to adopt a Na-
tional Solid Waste Disposal
Charge (Product Charge). The
Committee did find a theoretical
justification for making a
product's price reflect municipal
solid waste management costs.
Although the data base is uncer-
tain, the Committee found the
net economic benefits and waste
reduction would most likely be
low in practice. On the other
hand, the Committee did favor
local user fees for municipal solid
waste collection and recom-
mended further research on the
subject.
The Committee found that the
present Federal tax structure
reduces the cost of domestic
virgin materials significantly,
leading to overuse of these
resources. Most of the Commit-
tee members recommended con-
sidering elimination or modifica-
tion of these subsidies as part of
the Administration's next tax
reform package. Most of the
members also recommended that
new virgin material extraction
taxes not be considered until ex-
isting tax policies encouraging
use of virgin materials are
eliminated.
The Committee also examined
subsidies for resource recovery
and product regulations as a
resource conservation strategy. It
found that subsidies can be an
effective but potentially expen-
sive tool to stimulate resource
recovery, and did not recom-
mend any new subsidies. Like-
wise, the Committee found that
product design regulations could
be effectively employed as a
resource conservation tool, but
the costs appear to outweigh the
benefits in most cases.
Agency contact:
John Robinson
Associate Assistant
Administrator for Program
Management and Policy
EPA (PM-208)
Washington, D.C. 20460
202-755-0698
Regulators
Working
Together
EPA, the Food and Drug
Administration, the Occupational
Safety and Health Administration
and the Consumer Product Safe-
ty Commission formed the Inter-
agency Regulatory Liaison Group
(IRLG) to coordinate Federal ef-
forts to protect the public from
hazardous substances. The IRLG
introduced reforms at both head-
quarters and the regional levels
to reduce regulatory overlap,
inconsistency, and duplication.
These efforts have led to:
• A report describing how the
four agencies are handling 24
hazardous substances that two
or more of the agencies regulate;
• Feasibility studies of a com-
mon chemical regulations and
guidelines system and a common
chemical testing support system;
• Sharing of laboratory work
and equipment among IRLG field
offices;
• Interagency referrals of inspec-
tion observations and consumer
complaints, as well as sharing
lab analyses, supplying expert
witnesses, and coordinating en-
forcement actions against the
same firm;
• A substantial improvement in
sharing information on emergen-
cy health problems among agen-
cies; and
• A long range preventive health
plan for dealing with problems of
chronic degenerative diseases,
environmental cancer, repro-
ductive toxicity, and other im-
munologic diseases.
In January, the Food Safety
and Quality Service (U.S.
Department of Agriculture)
became the fifth agency to join
the IRLG.
In addition to the reforms
described above, IRLG work dur-
ing the first half of 1979 in-
cludes:
• A report on scientific methods
to identify and evaluate sub-
stances that may pose a risk of
cancer to humans; and
• An FDA-EPA neurotoxicology
research program at EPA labora-
tories in North Carolina.
Agency contact:
Toby Clark
Office of the Administrator
EPA (A-100)
Washington, D.C. 20460
202-755-0453
Screening
Old
Regulations
EPA reviews some of its regula-
tions periodically because of
statutory requirements. For ex-
ample, the Agency reviews the
National Ambient Air Quality
Standards every five years to
take into account new data on
the health effects of air
pollutants.
In addition to these required
revisions, EPA has begun a com-
prehensive review of its other
regulations. The President ini-
tiated this review in his Executive
Order 12044, "Improving Govern-
ment Regulations". The Admin-
istrator responded by committing
the Agency to a two-step pro-
cess.
The first step is to screen each
regulation to decide whether:
• It is acceptable as it is;
• It requires short-term improve-
ment; or
• It should be scheduled for a
long-term evaluation.
For each regulation. Agency
work groups are considering its
costs, benefits, enforceability,
language quality, overlap with
other regulations or programs,
and paperwork requirements.
The Agency expects to complete
this screening process by
November 1979.
The second step is to make
the necessary short-term revi-
sions, and to conduct long-term
evaluations of regulations with
particular problems or especially
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significant effects. The long-term
evaluations will occur over a five-
year period.
EPA's program offices have
reviewed several regulations and
scheduled others for review this
year. These include:
• Office of Pesticide Pro-
grams is screening all of its
regulations.
• Office of Air Quality Plan-
ning and Standards is review-
ing and rewriting its regulations
on State Implementation Plans
and will screen several of the
standards for hazardous air pol-
lutants.
• Office of Mobile Source Air
Pollution Control is reviewing
emission regulations for light and
heavy-duty vehicles, aircraft, and
fuel economy of motor vehicles.
• Office of Radiation Pro-
grams is reviewing rules on the
uranium fuel cycle and on con-
trol of radiation hazards in
uranium mining.
• Office of Noise Abatement
and Control has screened
regulations on interstate rail car-
riers, motor carriers, and medium
and heavy-duty trucks, and will
review rules on portable air com-
pressors.
• Office of Drinking Water
has begun a review of regula-
tions on grants to state drinking
water programs and national in-
terim primary drinking water
regulations.
• Office of Solid Waste has
screened six regulations and
plans to eliminate three regu-
lations and revise two others.
Other program offices will screen
the remaining regulations later in
1979. EPA's regional offices will
also be involved in the screening
process.
Agency contact:
Daniel J. Fiorino
Standards and Regulations
Evaluation Division
EPA (PM-223)
Washington, D.C. 20460
202-755-2265
Consolidating
EPA's
Permits
Administrator Costle's task force
to simplify and consolidate per-
mit programs recommended that
EPA consolidate its permit pro-
gram regulations and policy
guidance; develop a single ap-
plication form; establish a single
organizational unit in EPA
Regional Offices to process and
issue permits; and work with
states and other Federal agencies
on permit consolidation.
Deputy Administrator Blum
approved the report of the task
force on February 5, 1979.
EPA(will soon propose con-
solidated permit program regula-
tions for the hazardous waste
management program under the
Resource Conservation and
Recovery Act, for the under-
ground injection control program
under the Safe Drinking Water
Act, for the National Pollutant
Discharge Elimination System
under the Clean Water Act, and
for Section 404 (Dredge and Fill)
programs under the Clean Water
Act. To the extent feasible,
these consolidated regulations
will define standard permit con-
ditions, grounds for modifica-
tion, and procedures for process-
ing permit applications and for
issuing permits.
Public hearings on the con-
solidated regulations were held
in Dallas, Chicago, Seattle,
Washington, D.C. and Denver in
July and August of 1979.
In a parallel project, an Agen-
cy work group has been develop-
ing a single application form
which can be used for all EPA
permits. Where a single facility
requires multiple EPA permits, it
will soon be able to apply for all
EPA-issued permits on a single
form.
EPA will issue seven citizens
guides on permit consolidation at
the same time the proposed
regulations are published in the
Federal Register. These guides
will describe:
• The Agency's efforts in permit
consolidation;
• The proposed regulations ap^
plication form;
• Permit consolidation from the
state perspective;
• The proposed requirements for
consolidated permit regulations
for the hazardous waste pro-
gram;
• The proposed requirements for
the underground injection con-
trol program;
• The proposed requirements for
the dredge and fill programs;
• The National Pollutant
Discharge Elimination System
(NPDES) under the Clean Water
Act.
Agency contact:
Leonard Miller
Permits Division
Office of Water Enforcement
EPA (EN-336)
Washington, D.C. 20460
202-755-2545
Making English
Our Official
Language
The Agency's recently-formed
plain English team has been
helping all EPA offices write
regulations in clear language
without jargon, archaic legal
phrases, or incorrect grammatical
construction.
Initially, each Assistant Ad-
ministrator chose one regulation
from each program office to be
drafted in plain English.
At various stages of the
regulatory process, the plain
English team evaluated and
edited drafts of nine model
regulations and their preambles.
By February, all of the model
regulations had gone through
the process. In addition to these
model regulations the Plain
English Project prepared a report
on how EPA could continue to
improve its regulation writing.
Agency contact:
Chris Kirtz
Standards and Regulations
Evaluation Division
EPA (PM-223)
Washington, D.C. 20460
202-426-2693
Regulatory
Reform
Conference
EPA will hold a national con-
ference on "Regulatory Refor
of Environmental Protection F
grams" in spring 1980. The
agenda will cover EPA's con-
trolled trading program, the p
project to improve ways of
measuring the benefits of poll
tion control programs, the
economic impact of EPA's prc
grams, the environmental aud
concept and other current issi
in regulatory reform. State am
local pollution control officials,
academic experts, EPA person
from headquarters and the
regions and representatives of
business and environmental
groups will participate in panel
discussions.
Agency contact:
Paul Halpern
Standards and Regulations
Evaluation Division
EPA (PM-223)
Washington, D.C. 20460
202-755-2811
Speeding Up
Construction
Grants
EPA hopes to speed up the
average processing time for run
water and sewer grants and loa
applications by more than a yea
under regulations published
September 27, 1978 in the
Federal Register. The shortened
processing time will come from
reduced reporting requirements
on several types of loan applica-
tions and from consolidating
grants to small municipalities foi
developing project plans and ac-
tual construction.
Agency Contact:
Elaine Stanley
Facility Requirements
Office of Water Program
Operations
EPA (WH-595)
Washington, D.C. 20460
202-426-9404
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Regulatory Reform Calendar
Improving
Benefit
Analysis in
Regulations
In analyzing new regulations,
EPA has found it is considerably
more difficult to measure the
benefits than the cost of its pro-
posals. While we have made
progress in computing the
overall benefits (reduced medical
bills, reduced property damage,
etc.) of pollution control, benefit
estimation techniques are not ad-
vanced enough to analyze the
projected benefits of individual
regulatory proposals.
The Agency plans a pioneer
$1.5 million project to advance
the new science of benefit esti-
mation. Because scientific re-
search is uncertain and expen-
sive, EPA will test the benefits
assessment approach on selected
regulatory proposals.
This effort will draw on other
EPA projects that have built up
benefit estimation methodolo-
gies, including:
• A major study of methods for
Assessing Air Pollution Control
Benefits (the Wyoming study),
released in February 1979,
developed national data about
benefits from air pollution con-
trol. The study concluded that
such benefits may be substantial-
ly greater than previous studies
indicated, because they failed to
include benefits from reduced ill-
ness as well as lower death
rates. The Wyoming project also
studied Los Angeles area air
quality, finding a 30 percent im-
provement would lead to be-
tween $650 million and $950
million in economic benefits per
year.
• Studies by the National Aca-
demy of Sciences (NAS) analyze
the benefits and costs of con-
trolling 12 pollutants. NAS has
completed two of these studies
(for halomethanes and nitrates)
and three more (chlorobenzelate,
odors, and PCB's) will be done
soon.
Agency contact:
Deborah Taylor
Economic Analysis Division
EPA (PM-220)
Washington, D.C. 20460
202-755-0733
Indexing The
Opinions of
EPA's General
Counsel
The Environmental Law Publish-
ing Service of Chatsworth, Cali-
fornia has just published a two-
volume work, "The Opinions of
the General Counsel of EPA". It
contains legal memoranda from
the General and Regional
Counsels in response to com-
monly raised questions about the
meaning of EPA's governing
statutes. The new work includes
the decisions on the National
Pollutant Discharge Elimination
System which are the legal back-
bone of EPA's water permit pro-
gram. These opinions do not
carry the force of law, but
together with court decisions,
will give environmental lawyers
access to the legal documents
affecting their work.
Agency contact:
Bill Pederson
Office of General Counsel
EPA (A-130)
Washington, D.C. 20460
202-426-0508
The calendar on the following pages lists all of EPA's Regulatory
Reform Initiatives and the status of each, as of September 1979. Many
of these initiatives are described in greater detail elsewhere in this
report. Others are explained in the agency's December 1978 progress
report on Regulatory Reform Initiatives.
You may obtain more information about any of these reforms from
the agency contact listed. The Agency's Regulatory Reform Staff will
provide a current inventory of all EPA's regulatory reform initiatives
upon request (See address below).
Name
Address
City ft State
Company or Organization
D
I would like to receive a list of EPA publications on regulatory
reform
I would like more information about EPA's conference on
"Regulatory Reform of Environmental Protection Programs"
(available early next year)
I would like to receive future progress reports on EPA's
Regulatory Reform Initiatives (DO NOT CHECK THIS BOX IF
YOU HAVE ALREADY SENT IN A FORM TO THE REGU-
LATORY REFORM STAFF)
SEND THIS FORM TO:
Daniel Fiorino
Regulatory Reform Staff
(PM-223)
Environmental Protection Agency
Washington, D.C. 20460
-------
Regulatory Reform Calendar
Alternatives and
Supplements to
Regulation
Initiative
1. Marketable Permits
2. Economic Incentives
to Control Air
Pollution
3. Innovative Resource
Conservation and
Solid Waste
Management
Alternatives
EPA, assisted by the Rand Corporation, is studying alterna-
tive ways to control emissions of chlorofluorocarbons
(CFC) from sources other than aerosol sprays, including
the allocation (perhaps by auction) of production or use
permits for environmentally acceptable amounts of CFC.
Under Section 405 of the 1977 Clean Air Act Amendments,
EPA has begun to study economic incentives as alterna-
tives to traditional regulation in controlling air pollution.
The EPA Administrator chairs a Cabinet-level, interagency
Resource Conservation Committee, which has examined
several innovative ways to conserve resources and
manage solid waste, including beverage container deposits,
product charges, and tax incentives for recycling.
Status
Draft final report due
in September
Studies over the next
year will cover
nitrogen oxide and
benzene emissions
Final report approved
in June 1979
Agency Contact*
Jim Hughes
Office of Regulatory Analysis
(TS-794)
755-6660
Willard Smith
Economic Analysis Division
(PM-220)
755-2887
John Robinson
Associate Assistant
Administrator for
Program Management
and Policy
(PM-208)
755-0698
4. Study of Operation
and Maintenance
Strategies
5. Federal
Procurement
Incentives
To ensure proper operation and maintenance of pollution
control equipment the Agency is evaluating a number of
policy alternatives, including two supplements to traditional
regulation: (1) increased use of private sector services to
diagnose problems, correct them, and operate and main-
tain publicly owned treatment works, and (2) economic
penalties on violators of pollution standards equal to what
they save by not properly operating or maintaining the
equipment.
Procurement incentives rely on the Federal Government's
purchases of goods and services from private industry to
encourage the production of environmentally superior
products.
Decisions on the
POTW portion of the
Study are expected in
September 1979
Incentives for noise
reduction have been
applied to trucks, air
compressors and
lawnmowers
Ron Brand
Program Evaluation Division
(PM-221)
755-0350
Stanley B. Durkee
Technology and Federal
Programs Division
(ANR-490)
557-7634
6. Encouragement of
Innovative Technology
7. Nonconformance
Penalties
Several programs under the Clean Air and Clean Water
Acts encourage the development of better control tech-
nologies, by extending compliance deadlines for dischargers
using innovative pollution control systems.
Heavy-duty engine manufacturers which fail to meet an
emissions standard may continue to sell their product if
they pay a nonconformance penalty. The penalty is de-
signed to keep non-complying manufacturers from using
their cost advantage against those who comply.
EPA accepting
applications for
compliance date
extensions; several
grants made to state
and local
governments
Proposed regulation in
Federal Register
Feb. 12, 1979; final
rule expected in
March 1980
Stephen Bugbee
Permits Division
(EN-336)
472-3365 for water program
compliance date extensions;
Joe Easley
Municipal Construction
Division
(WH-547)
426-4445 for grants for in-
novative systems;
Francis J. Biros
Stationary Source
Enforcement Division
(EN-341)
755-2560 for air program
compliance date extensions.
Frank Slaveter
Mobile Source
Enforcement Division
(EN-340)
755-1572
*AII contacts are located in Washington, D.C. (area cods 202)
unless otherwise indicated. The numbers in parentheses are mail
codes for offices at EPA Headquarters, 401 M Street, S.W.,
Washington, D.C. 20460.
8
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Initiative
Status
Agency Contact
8. Plantwide
Emission Reduction
9. Alternative
Strategies for Clean
Air Nonattainment
Areas
10. Banking of
Emissions Reductions
11. Air Quality
Technical Assistance
Grants
12. Economic Incen-
tives for Prevention of
Significant Deteriora-
tion of Air Quality
13. Noise Emission
Labelling
14. Clean Air
Noncompliance
Penalties
EPA would view each plant's emissions as a whole and
give plant managers the flexibility to seek the least costly
ways of limiting their emissions, so long as total pollution
from the plant would not exceed that allowed under cur-
rent standards. EPA refers to this approach as the
"bubble" concept.
EPA is reviewing alternative ways to accommodate growth
and control pollution in areas where pollution is already
worse than national standards. These include non-
traditional means of pollution control such as emission
charges, the emissions offset market, and other economic
approaches.
EPA announced that sources who reduce their emis-
sions under its offset policy can "bank" emission
reductions for future use or sale, either in offset
transactions or in other transactions which EPA and
the states currently allow (such as internal plant ex-
changes under the "bubble" concept). This group will
work with State and local governments to assist in
establishing operating systems.
EPA, along with the Departments of Commerce, Transpor-
tation and Housing and Urban Development, is sponsoring
a $4 million demonstration project to aid cities in achieving
industrial growth while meeting clean air requirements.
Air bubble in
Federal Register;
Jan. 18, 1979;
water bubble pending
Revised work plan
due in September
1979
Guidance to states
on alternative
systems issued by
late fall
Eight urban areas
selected to receive
the grants
EPA is studying the use of economic incentives such as Report due in late
marketable permits and emissions charges in the "preven- 1979
tion of significant deterioration" (PSD) of air currently
cleaner than required by national standards.
Rather than directly regulating noise emitted by consumer Final rules due in
products, EPA is requiring manufacturers to inform con- September 1979
sumers of the noise levels of products.
EPA is required to assess administratively a noncompliance
penalty against polluters who violate Clean Air Act re-
quirements. The amount of the penalty will equal the
money the violator has saved by not installing pollution
control equipment.
Proposed rules
published in Federal
Register March 21,
1979
James Kamihachi
Economic Analysis Division
(PM-220)
755-2677
Alex Christofaro
Policy Planning Division
(PM-221)
755-2733;
Darryl Tyler
Office of Air Quality Plan-
ning and Standards,
Research Triangle Park,
N.C.
(MD-15)
919-541-5425
John Hoffman
Policy Planning Division
(PM-221)
755-0933
Meri Bond
Office of Transportation and
Land Use Policy
(ANR-445)
755-0570;
John Hoffman
Policy Planning Division
(PM-221)
755-0933
Marty Wagner
Policy Planning Division
(PM-221)
755-4803
Tim McBride
Office of Noise Abatement
and Control
(ANR-490)
557-2710
Bob Homiak
Stationary Source
Enforcement Division
(EN-341)
755-2581
15. Environmental
Auditors
16. Citizen Role in
Enforcement Activities
The Office of Enforcement is considering a new monitoring
system of environmental auditors based on the model of
certified public accountants.
The Office of Enforcement has given grants to citizen
groups to participate in environmental enforcement
activities including monitoring and participation in
permit reviews. The Enforcement Office is consider-
ing expanding the program to other activitip-
Final report of con-
tract study due in
December
Feasibility studies
currently underway
Gerald Bryan
Office of Enforcement
(EN-329)
755-2505
Judy Shaffer
Office of Enforcement
(EN-336)
755-0750;
Bob Steinwurtzel
Office of Enforcement
(EN-338)
755-0750
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Regulatory Reform Calendar
Improving the
Quality of
Regulation
Initiative
1. Studies of Cumula-
tive Impacts of
Regulation
2. Screening and
Review of Existing
Regulations
3. Evaluation Plans for
New Regulations
4. Evaluation of
Alternatives
5. Plain English Project
6. Task Force on
Public Participation
7. Water Program
Public Participation
Policy
8. Reimbursement for
Public Participation
EPA is conducting studies on the cumulative effects of the
Agency's air and water regulations on major industries.
EPA has begun to review all of its existing regulations to
decide which can be eliminated, simplified, replaced with
non-regulatory policies, or otherwise improved.
EPA now includes with each new significant regulation a
plan to evaluate it within five years after it is implemented.
The evaluation will assess the regulation's cost, its public
acceptance and extent of compliance.
EPA is studying ways to improve work group's considera-
tion of non-regulatory alternatives.
The Agency recognized the need to write its regulations
more clearly. It has begun a number of projects to ensure
EPA regulations are written in plain English.
In April 1978, the Administrator and Deputy Administrator
created a task force on public participation to survey and
evaluate the Agency's efforts to involve the public.
The Agency has proposed a regulation establishing public
participation requirements for programs under the Safe
Drinking Water Act, the Resource Conservation and
Recovery Act, and the Clean Water Act.
EPA has started a pilot project to pay the expenses of
groups that cannot otherwise afford to participate in
regulatory proceedings.
Status
Six studies already
published; more in
progress
Results will be pub-
lished at end of 1979
Regulation Develop-
ment Manual is being
written
A checklist of
alternatives is now
available
EPA style manual is
drafted
Currently developing
Public Participation
Policy and Pilot Com-
pensation Program
Report in Federal
Register February 16,
1979
One toxics project
has been completed.
Air and water pro-
grams are developing
their own pilot
projects
Agency Contact
Willard Smith
Economic Analysis Division
(PM-220)
755-2887
Daniel Fiorino
Standards and Regulations
Evaluation Division
(PM-223)
755-2265
Daniel Fiorino
Standards and Regulations
Evaluation Division
(PM-223)
755-2265
Daniel Fiorino
Standards and Regulations
Evaluation Division
(PM-223)
755-2265
Chris Kirtz
Standards and Regulations
Evaluation Division
(PM-223)
426-2693
Sharon Francis
Office of the Administrator
(A-100)
755-0425
Lee Daneker
Office of Hazardous
Materials
(WH-556)
755-7638
Bill Pederson
Office of General Counsel
(A-130)
426-0508
10
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Initiative
9. Regulatory Agenda
10. Indexing of the
Opinions of EPA's
General Counsel
11. Interagency
Regulatory Liaison
Group IIRLG)
EPA publishes its Regulatory Agenda in the Federal
Register four times a year. The Agenda provides informa-
tion to assist public participation in EPA's regulatory ac-
tivities. It includes a list of regulations the Agency is
preparing; the status of each regulation; and an Agency
contact for each regulation.
The Environmental Law Publishing Service of Chatsworth,
California has published a two-volume work, "The
Opinions of the General and Regional Counsels of EPA." It
contains legal memoranda in response to commonly raised
questions about the meaning of EPA's governing statutes.
EPA, the Food and Drug Administration, the Occupational
Safety and Health Administration and the Consumer Prod-
uct Safety Commission have formed the Interagency
Regulatory Liaison Group (IRLG) to coordinate Federal ef-
forts to protect the public from hazardous substances.
Status
Agenda published
first week of May
Completed
Cancer identification
document published
February 1979;
USDA's Food Safety
and Quality Service
joined IRLG in
January
Agency Contact
Phil Schwartz
Standards and Regulations
Evaluation Division
(PM-223)
755-2693
Bill Pederson
Office of General Counsel
(A-130)
462-0508
Toby Clark
Office of the Administrator
(A-100)
755-0453
12. Regulatory Reform
Conference
13. Improving Benefit
Analysis in Regula-
tions
EPA will hold a national conference on "Regulatory Spring, 1980
Reform of Environmental Protection Programs." State and
local officials, academic experts, EPA personnel and
representatives of business and environmental groups will
participate.
The agency has initiated a new study to advance the state Two year study
of the art of benefit estimation. The project will draw on a started
previous study of methods for assessing air pollution con-
trol benefits released in February 1979 and a series of Na-
tional Academy of Science studies.
Paul Halpern
Standards and Regulations
Evaluation Division
(PM-223)
755-2811
Deborah Taylor
Economic Analysis Division
(PM-220)
755-0733
1 1
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Regulatory Reform Calendar
Reducing
Regulatory
Burdens
Initiative
1. Improving New
Source Permit
Reviews
2. Consolidating EPA's
Permits
3 Revised Ad-
judicatory Hearing
Procedures
4 Sunset for New
Reporting Re-
quirements
Numerous permits are often required before a company
can begin construction of a new source of pollution. To
reduce delay, complexity, and uncertainty EPA has an-
nounced new rules for handling these permits.
Administrator Costle directed an Agency task force to
work on consolidating all agency permits, using a single
permit application form; common application procedures
and regulations, consistent definitions of key terms, and
consistent reporting periods and due dates.
The Office of General Counsel (OGC) is changing hearing
procedures that should lead to improved, more streamlined
decision-making while preserving parties' rights.
EPA has adopted a sunset policy for reporting or record-
keeping requirements of each new regulation
Status
Rules announced in
Sept. 1978; task force
continuing
Report approved Feb.
5, 1979; regulations
proposed on June 14;
hearings held in July
and August
Hearing procedures
for new pesticide per-
mit consolidation due
in fall 1979
Completed
Agency Contact
Abby Pirnie
Policy Planning Division
(PM-221)
755-2733
Leonard Miller
Permits Division
Office of Water Enforcement
IEN-336)
755-2545
Bill Pederson
Office of General Counsel
(A-130)
426-0508 for water permits;
Dave E. Menotti
Office of General Counsel
(A-132)
755-2680 for pesticide
hearings.
Phil Schwartz
Standards and Regulations
Evaluation Division
(PM-223)
755-2693
5. Internal Report
Reduction Task Force
6. Construction Grant
Application Processing
Two Agency task forces have been working on reducing
reports that EPA requires of its regional offices and State
agencies
Under regulations published in the Federal Register, EPA
hopes to speed up the average processing time for rural
water and sewer grants and loan applications by more than
a year
Completed,
recommendations
implemented
Rules published Sept.
27, 1978; Interagency
Agreement for rural
water and sewer
grants signed
December 1st
Ferial Bishop
Office of Toxic Substances
(TS-794)
755-8963;
Howard Howell
Program Reporting Division
(PM-227)
245-3000
Elaine Stanley
Facility Requirements
(WH-547)
426-9404
12
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Appendix
How EPA
Develops
Regulations
EPA produces regulations in a
five-stage process: (1) starting
work on a regulation, (2) prepar-
ing a development plan, (3) pre-
paring a decision package, (4) in-
ternally reviewing the regulation
and decision package, and (5)
publishing the regulation in the
Federal Register. Each regulation
goes through the last three
stages twice, first as a proposed
regulation and again as a final
regulation.
When the Assistant Administra-
tor for a lead office (the office
responsible for developing the
regulation) determines that a
regulation is required by law or
otherwise decides to start work
on a new regulation, he sends a
notification form to senior
management. This brief standard
form requires no analysis. The
lead office submits this notifica-
tion form as soon as possible,
usually within 45 days of the
time it learns (through passage
of new legislation, a court order,
etc.) that regulation may be
necessary.
Next, the lead office forms a
work group with members from
relevant EPA offices. With the
help of the work group, the lead
office then prepares a plan for
developing the regulation. The
lead office includes in this
development plan, among other
information, an analysis of the
alternatives to regulation, a
public participation plan, a
schedule for developing the
regulation, and a priority
classification of the regulation.
The lead office, with the assis-
tance of the work group, then
prepares a decision package.
This package consists of the
regulation, a preamble stating
the purpose of the regulation, a
statement of the resources re-
quired to implement the regula-
tion, and an analysis of the antici-
pated environmental and eco-
nomic impacts of the regulation.
It also includes such supporting
documents as the reporting im-
pact statements and evaluation
plan.
After the lead office Assistant
Administrator approves the deci-
sion package, he submits it for
prepublication review. This pro-
cess has three parts: Steering
Committee review, Red Border
review, and final review by the
Administrator and Deputy Ad-
ministrator. The details of the in-
ternal review vary depending on
the priority classification
assigned to the regulation. The
Steering Committee is a group
of representatives of the Assis-
tant Administrators and chief
staff offices that generally over-
sees the regulation development
process. The "Red Border"
review is the next stage of inter-
nal review. It derives its name
from the color of the cover sheet
we put on the package which
goes to our senior management.
The regulation then goes to the
Administrator and Deputy Ad-
ministrator. When the Adminis-
trator has signed it, it is pub-
lished in the Federal Register.
The chart, which appears
in EPA's Final Response to the
President's Executive Order on
"Improving Government Regula-
tions," illustrates EPA's regula-
tion development process:
Stages in The
Development of
Significant EPA
Regulations
1. Start work:
Send Notification Form
Invite work group
members
Schedule a
development plan
2. Prepare a
development plan:
Classify regulations as
Major or Routine
Identify purpose,
issues, major
alternatives
Plan external
participation measures
Describe analyses
including Regulatory
Analysis when required
Establish development
and publication
schedules
Notify interested and
affected parties of work
plans
3. Prepare a decision
package:
Involve public,
State/local officials
Analyze effects:
— Environmental
— Economic
-Urban
— Resource
— Paperwork
Write rule, preamble
Recommend action to
Administrator
4. Conduct internal
reviews:
Conduct Steering
Committee review
Conduct "Red Border"
review by senior
management
Conduct final review by
Administrator
5. Publish in Federal
Register:
13
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