EGUARD  J. HAHLEY

                          RENO, NEVADA
                       SEPTEMBER 27, 1984
     Good morning, and thank you for the generous invitation

to share some time with you at your annual meeting here in Reno.

As you may know, I am now serving my second term as Administrator

of EPA.  My decision to return to Washington plainly astonished

many of the Agency's staff.  They had been predicting for months

that the President would never find a new Administrator with the

right qualifications—namely, someone smart enough to do the

job but dumb enough to take it.  Given the controversy that

surrounded EPA at the time, I have to admit that only a fool

or a statesman would have agreed to occupy the office.  And

while a consensus may have grown up in support of the former

interpretation, I myself cling steadfastly to the latter!

     Your theme at this convention is credibility—presumably

yours as newspaper people.  If I may, I'd like to discuss credi-

bility as it pertains to a different party—a national agency

engaged in protecting the environment and public health.  For as

necessary as credibility is to a purveyor of truth through the

press, it is just as essential to an agencv like EPA, which seeks

 to determine how much health  or environmental  protection  the

 public  should buy and at  what  price.   Our  authority  to make and

 enforce our decisions, so necessary  to society,  is not based

 solely  on  congressional mandate;  it  is also  founded  on the

 public's willingness  to continue  to  delegate to  EPA  the power

 to make these delicate choices for them.   That delegation will

 ultimately be withheld if we  are  not  trusted to  exercise  it

 fairly.  In short EPA, to function, must be  credible.

     The environmental challenges America  faces  today are truly

 formidable.   With growing frequency,  new scientific  evidence

 suggests that substances  once  thought safe may cause long-term

 harm in  such  frightening  forms as cancer and birth defects.

 With measurement  instruments of  increasing sophistication we

 are now  able  to detect the most minute concentrations of the

 suspect  chemicals, and we are  discovering  these  substances in

 our environment with  increasing regularity.  The questions for

 EPA are  many:  Are these  chemicals dangerous in  the  concentrations

 in which we are finding them?  How dangerous, to how many people,

 and over what period  of exposure?  And, in light of  other

 risks to which society is  inescapably  exposed, to what extent

 should one particular  threat be isolated and controlled as

opposed  to another?  These questions,  needless to say, call as

much for judgment as  for  science in the search for an answer.

     Among the chemicals that cause the most concern are the

necessary waste products of our industrial society.  As a

regulatory agency, EPA is required to define which chemicals

must be controlled, to stipulate the extent of their control,

and to authorize disposal methods appropriate to each class of

waste.  Beyond this, we must come to grips with the legacy of

decades of neglect in the form of abandoned hazardous waste

dumps that litter our landscape and threaten to contaminate our

ground water.  This means finding and sorting these dumps by the

degree of risk they pose to public health and essential natural

resources.  And it means committing public funds to long-term

engineering projects of a type rarely if ever before attempted.

     Now that is a daunting agenda.  And it requires an inspired,

committed, and energetic group of public servants to address it.

Fortunately EPA is blessed with such a workforce.  Further, I

am convinced by three additional facts that we can do this

job and do it well.  First, EPA has done great deeds before.

The record of the Agency in reversing a national trend toward

more conventional gunk in our air and water is a fine one.  And

while it is fashionable nowadays to think of our early efforts

as aimed at the "easy" part of pollution, a review of my working

papers from 1970 reminds me that in those days conventional

pollution of the Nation's air and water seemed to us then just

as daunting a proposition as the control of toxic pcllutants

does now.

      Second,  we now enjoy the professional partnership  of

 States,  whose environmental programs  have  grown  up  in the  past

 thirteen years.  Today States,  not  EPA,  manage by  far the

 majority of  the day-to-day work that  makes for adequate

 environmental protection.  Add  to these  advantages  the  third

 factor,  an abiding  public consensus that the  cost of environmental

 quality  is an investment  worth  making, and we have  the  conditions

 for  continuing  progress.

      There is,  however, one enormously important factor working

 against  further environmental success.   That  is  the matter of

 credibility.   For EPA  adequately to pursue the public interest,

 we must  regain  the  "benefit of  the  doubt"  that allowed  us  to blend

 facts with judgment  in writing  the  rules that led to cleaner air

 and water.  EPA is made up of people—people  who certainly do not

 claim to know all things;  nor are they entirely  ignorant.  But these

 days EPA's people are  being squeezed  between  two views  of  the role

 of a regulatory agency in securing  safety  frn-n toxic substances.

 One group says  that  EPA must  presume  knowledge where there is only

 a question, and  regulate  possible threats  to  public safety

 -whether  or not  they  are proven  and  even  though we lack  adequate

means to secure  absolute  protection.  The  other  view suggests that,

 lacking  complete knowledge  of the threat and  a proven means of

 protection, EPA  should withold  judgment  and temporize on solutions.

Amid a clamorous din from both  sides, EPA  risks  losing  the

 freedom to examine each matter  in turn and  to make  a dispassionate

 judgment in the  public interest.  Our credibility is threatened.

     At first glance, this seems a puzzling development.

After all, in light of EPA's record of achievement over the

past thirteen years, we should be enjoying more latitude in

making these difficult judgments, not less.  Despite a population

increase of 30 million people and GNP growth of nearly 39 percent

from 1970 through 1981, both carbon monoxide and sulfur dioxide

emissions dropped by more than 20 percent.  In the same period

particulate emissions fell by 53 percent.  Ten years ago, a city

like Portland, Oregon, exceeded the carbon monoxide standard a

hundred days out of the year; currently it's more like two or

three days.  That story has been repeated in countless

metropolitan areas, and that's progress.

     As for the water, we have provided high-level municipal

sewage treatment for over 80 million Americans since 1970.

Toxic discharge controls, either already  in place or now being

written into permits, ultimately will eliminate about 96 percent

of those poisonous substances that were routinely dumped into the

nation's streams until 1972.  Overall, since that time, we have

upgraded water quality in 47,000 miles of our rivers and streams,

promoting a renewal of fish stocks and recreational uses that

has restored national pride in the cleanliness and vitality

of the nation's waterways.  Once symbols  of national neglect,

the Willamette and Trinity Rivers and Lake Erie now pay tribute

to our earlier environmental determination.  An environmental

 disaster  such  as  Cleveland's  Cuyahoga  River  bursting  into  flames,

 which  back  then galvanized  public  sentiment  to  reverse  the

 spread  of environmental  contamination,  is  now unthinkable.

 That too  is  progress.

     Yet the question  remains: why does  it seem that  we are

 doing  better and  enjoying  it  less?  True,  today's environmental

 problems are a bit thornier than yesterday's, the unknowns more

 extensive than before, the  solutions more  complex and expensive;

 but EPA is still  unquestionably the institution best-equipped

 to tackle them.   Why,  then, when people  have successfully

 trusted to our discretion in  the past, would they deny  to EPA

 the exercise of that discretion now?   The  answer, I think,

 lies once again in the issue  of credibility.  These days we

 labor with rather less of it  than  in the past.  Two simple

 factors account for this.  One is a natural development'affecting

 all public institutions  over  time; the other was manufactured

 within our own walls.

     The first reason  is what a mayor might call "The Pothole

 Effect."  A local official knows that  no matter how well-supported

 he might be in the community, sooner or  later each of his

constituents will discover a  pothole outside the door that

city hall  had better fix right away.   For every pothole not

filled  properly and immediately, count one more citizen prepared

to give the mayor a hard time on the bigger issues.  Just so      -•

with EPA.  Given the degree of concern over the deteriorating

quality of the environment in 1970, EPA benefitted from a pro-

digious outpouring of public faith and confidence.  Over the

years we have, by and large, lived up to that confidence; but,

just as certainly, at one point or another we have failed every-

one's expectations at least once.  So over time it is natural

that we be questioned harder, and the numbers of our critics mount.

     The second reason  is based in the public perceptionAthat

politics, not commitment to the Agency's mission, had become

a dominant factor in EPA's decision-making.  I do not wish

to belabor the story of EPA's trials prior to my return; that

has received all the attention it is useful to give, and perhaps

more.  Still, the lessons of that painful period must not be

lost on future Administrators of EPA.

     To me the chief lesson is that even the appearance of

politics playing a role in matters affecting the public health

is fatal to the credibility of an institution like EPA.

Arranging the timing of Federal largesse for political purposes

is an old story in Washington, one that barely rates a line of

type any more.  The closer it gets to election day, the greater

the visibility of long-planned Federal grant awards—complete

with attendant ribbon-cutting by Senators or Members of Congress

 pursuing  re-election.   So long  as  it  is  clear that  it  is  the

 timing  of  the  award  that  is  being  manipulated,  and  not the  need

 for  the grant  on  its merits,  this  practice  has  come to be

 accepted  as  part  of  the game  by members  of  both parties and—

 dare I  say it—the press.

      But  not for  awards affecting  the  public  health.   For instance,

 when it comes  to  cleaning  up  Superfund sites, where public  health

 may  be  at  stake,  the" only  acceptable factors  affecting timing

 can  be  the degree and  immediacy of  the threat,  the  sufficiency of

 funds,  and the availability of  effective  control  techniques.

 I do not  suggest  that  there is  no  room for  a  political person

 in environmental  decisions.   In fact,  politics  plays a crucial

 role.   Each  party has  a broad but  identifiable  philosophy that

 defines its  approach to public  issues.  When  Americans vote,

 they  endorse not  only  a candidate,  but the  principles  that  he

 or she  upholds.   Within the broad  latitude  that each party

 affords its members, public officials  are expected  to  act in

 conformance with  the political  principles held  by their party.

 In this broad, philosophical sense  politics should  properly

 influence  how EPA goes  about its business.  But that is the

extent  of  it.  EPA's business is first and  always protecting

public health and the environment.  It is not,  and  must never

be,  finagling priorities in a quest for votes.

     We cannot change history, and I have acKnowledged that one  -

reason for my return to EPA was to help restore its essential

credibility.  We have been working very hard on that problem.

To put our strategy in its most succinct form, we are following

the advice of Peter Drucker, the noted management "guru":  We are

"doing the right thing" and we are "doing the thing right."

Or as Mark Twain so wryly put it, "Always do right? it will

gratify some and astonish the rest."  That is what we are aiming

for, and I have faith that our sustained record of trying to

do right will eventually bridge our temporary credibility


    I want to touch on some of the work we have done in the

last year and a half.  Let's start with Superfund.  When I arrived

EPA's policy called for the Agency to negotiate settlements with

responsible parties to clean up the most dangerous sites before

applying Superfund money to the task.  No longer.  Now, when

quick clean-up is indicated, we do it with Federal funds and

worry about who will pay for it later.  As of June 30, we had

approved 392 short-term emergency clean-ups to eliminate

immediate threats to public health; 328 of these actions are

already complete.  We have reached settlements for responsible

party reimbursement in 125 cases, worth more than $300 million,

and have $123 million more in reimbursements either under

litigation or pending.  So we are doing the right thing, and I

believe we are doing it right.

      You  may  have  seen  that  EPA  has  removed  only  six  from  the

more  than 500  sites  on  our National  Priority List  or  those

eligible  for  federal funds.   In  some cases,  that  figure  is portrayed

as  an indictment of  EPA's management of  the  program.   Let me

tell  you  what  that figure really means.  While  there  is  no

such  thing as  a "typical" Superfund  site, more  often  than not

a major danger posed by the  slow decay of long-abandoned hazardous

waste  containers is  'that the  site  is located over  an  important

aquifer.  As wastes  leach down through the soil they  eventually

penetrate the  aquifer,  forming a plume of contamination  in the

ground water.  Poisoned ground water can be  catastrophic,

especially if  the  aquifer is  a source of drinking  water  for a

community. Ensuring   that such an  aquifer is maintained  in a

usable condition can take as  long  as  fifty years.  Under those

circumstances, we  undertake  long-term treatment, but  while the

problem remains, we  do  not remove  the site from the National

Priority List.

     So, while it  is  true that only  six sites have been  removed

from the National  Priority List, we  have taken  appropriate

action at hundreds more.  We  refuse  to fudge  the numbers to

give the public a  false sense of security.   We  think  that is

the right thing to do.

     Lead.  We have made tremendous strides over the years in

removing lead from the environment.  In fact,  just in the period

between 1975 and 1982, ambient lead—lead in the air—was reduced

by 64 percent.  In 1982 we tightened the standard, but we

subsequently found that the additional reductions in ambient lead

needed to protect public health were not materializing.  Why not?

Well, about 80 percent of all ambient lead comes from leaded

gasoline.  It turns out that too many people were putting

leaded gasoline where it doesn't belong—in the tanks of vehicles

designed to run on unleaded gasoline.

      Since one strategy was not working, we substituted a better

one.  Recently I announced that the current standard of 1.10 gram

per gallon would be reduced to 0.10 gram per gallon as of

January 1, 1986.  In the next few years, with the advent of improved

substitutes for lead in gasoline formulation, it should be possible

to eliminate lead altogether.  In the meantime, kids who live in

areas with heavy auto emissions will no longer bear the burden

of poor health occasioned by those who have been saving a few

cents per gallon by misfueling their cars.  I think that was the

right thing to do.  I also think that we went about setting

this rule in the right way.  We calculated the total cost to

all refiners by eliminating lead to be substantial, around

$575 million.  But when we calculated the net social benefit we

found that the nation would save around $1.8 billion in reduced

 medical  and  rehabilitation  costs,  vehicle  maintenance,  and  fuel

 inefficiency.   Add  the  benefits  of cleaner air  to  the bargain

 and  we snapped  it up.

      One  last,  brief example:  ethylene dibromide,  known—not too

 popularly—as EDB.  EDB has  been use'd for  years as an effective,

 multi-purpose fumigant  for  both  soil and agricultural commodities.

 Its  use  has  saved growers billions of dollars over more than two

 decades  by preserving food  from  spoilage and  infiltration by

 pests.   New  research, fortified  by advanced methods of  residue

 detection, raised the concern  that long-term exposure to EDB

 in minute concentrations could cause cancer, genetic mutations,

 and  reproductive disorders  in  animals and—by extrapolation—in


     This was a case in which  public concern, fanned by a torrent

 of emotional and only partially  accurate reports,  grew  to a fever

 pitch in  a very short time.  EDB had been  in constant use for

 twenty-five years;  the  dangers ascribed to it are  real,  but long-

 term—problems that might develop  only over long periods of regular

 exposure.  While such risks  should not be  tolerated any longer than

 necessary, there was no reason to  believe  that  taking a few weeks

 for careful consideration of all the options would occasion any

measurable additional risk.  As  it  was, the public atmosphere in

which EPA had to review the  facts  and make a regulatory judgment

was one of broad-scale  fear  and  incipient  panic;   we had to make

 the right judgment, and we had to  make it  fast.

     The decision we did make was to issue an emergency suspension

of EDB in grain fumigation in order to halt any further use.

This was reasonable since there are effective alternatives to

EBD for that use.  We also set a safe tolerance level for

previously treated grain products containing any residue of

EDB.  As to citrus and some tropical fruits, we allowed

limited continued use, and set a residue tolerance level that

would minimize risk to the public.

     With regard to EDB, I believe we did the right thing,

but I am not so sure we did the thing right.  We did do risk/

benefit analysis, and we did involve the public in our pro-

ceedings, sharing with them what we knew, and detailing for

them the factors that went into our decision.  But the EDB case

exemplifies a phenomenon that is unsettling and bound to lead

ultimately to bad public policy.  It is the "Chemical of the

Month" syndrome.  This is the condition in which a potential

public health problem comes to the attention of the press and

is then subjected to such a vortex of sensational reporting

that EPA is forced to take hasty action just to calm public

fears.  Sometimes the danger is real and immediate, but in

other cases, it can be either uncertain or remote.  The action-

forcing event may not be a genuine public health emergency,

but an artificial emergency generated by well-meaning people

convinced that someone is not acting forcefully enough.

      I  don't  have  the  total  answer  to the  "Chemical  of  the

 Month"  syndrome.   But  if  it  is  a  sign that the public is not

 yet  ready  to  fully believe what EPA is telling them, it ought

 to subside  as we work  to  restore  confidence in public

 institutions.   I have  firmly committed EPA to share  with the

 public  what information we have in  making  our decisions.  I

 have  insisted that the public be  involved  by their thoughtful

 comment and participation in the  Agency's  business on their

 behalf.  I have stipulated that EPA's doors be open  to  all

 parties to decisions,  both pro  and  con,  and that you members

 of the  press get accurate, detailed answers to your  questions.

 If, after all, we  make mistakes,  they will be honest mistakes,

 made  in the open for all  to  see.  But if,  as I hope  and expect,

 we continue to do  the  right  thing and do it right, I trust

 that  people will take  note of our record,  and come once again

 to trust us to use  our discretion when  needed to bes.t serve

 the public interest.

      As I said at  the  beginning,  the  environmental challenges we

 face  today are formidable.   We  are  operating in an arena charac-

 terized by great scientific  uncertainty, technical complexity,

 and public controversy.  At  any time  a  firestorm of  concern

might erupt over some new environmental threat that has just

 come  to the fore.   You, as writers  and  editors, are  at  the center

of that conflagration.  You must find sense  in the battle of

quickly hurled charges and countercharges.  You must get on

top of subtle and uncertain scientific findings to simplify

and interpret them for your readers.  You must report, fairly

and objectively, whether and to what extent your readers might

be at risk from the substance in question.  And you must do

all this on deadline.  Yours is a near impossible assignment.

     Facing this challenge you absolutely require a credible

witness to whom you can turn and ask with confidence, "What

can I believe? What is really going on here?"  If we are living

up to our responsibility to serve the public interest, EPA

should serve as that witness.  We may not be the only source,

but we should be a reliable source.  I realize that you may

not yet be prepared to give us that confidence.

     You and I, the press and EPA, have a symbiotic relation-

ship.  You need information from us; we need to communicate

through you.  Even in the best of times this relationship can

grow tense and testy.  As in a good marriage, each of us has

something to contribute to the union, but we can maintain a

healthy relationship only if we continue  to earn each other's

trust.  Some time back EPA appeared, at least, to fail your

trust, and it will take time to re-establish the confidence

you must place in us if we are to get our message clearly

 before  the  public.   But  that  is  a  goal  worth  working  for,

 because  the effectiveness  of  America's  efforts  to grapple with

 the  emerging  problems  of post-industrialization in  a  free

 society  hangs in  the balance.  Without  public trust,  we cannot

 serve successfully  the public  interest.

     So  I urge you  today to watch  us closely.   Evaluate carefully

 what we  say and what we do.   Check  for  yourselves whether we

 are doing the right  thing  and  whether we are  doing  it right.

 I believe that if you  will be  both  skeptical  and fair, EPA

 will once again earn your  confidence.

     We  must  both be realistic.  This will not  be easy for

 either of us.  Under conditions  of  high emotion or  in times when

 political posturing  is an  acceptable tactic,  truth  is normally

 the first casualty.  So I  ask  one more  thing  of you.  While we

 are on probation, I  ask you to examine  with equal care the

 words and actions of those who attach themselves to environmental

 issues,  either for or  against, by an appeal to  public emotion.

     We  are both in  the business of truth.  Ours is to discover

 and respond to it; yours is to verify and report it.  By working

 together in a spirit of mutual trust, we can  both be  true to

our trades.   I think we will get to that point  again  soon.

And when we do, we will both benefit from the one thing without

which neither of us  can effectively operate:  public confidence

 in the  integrity of  our word.