The Bald Eagle:
A Treasure Preserved
J
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EPA: The First Twenty Years
On December 2,1970, EPA
came into existence,
created by an executive
reorganization plan signed by
President Richard Nixon. This
issue of EPA Journal notes the
Agency's 20th birthday with
features reminiscing about the
past, reviewing the present,
and addressing the challenge of
the future.
President George Bush, the
first chief executive personally
to visit EPA, introduces the
issue with an article and a
happy-birthday wish. Next is
an interview with William K.
Reilly, the Agency's sixth
Administrator, exploring his
vision for EPA as it positions
itself for the next decade and
beyond.
Then F. Henry Habicht,
Deputy Administrator, offers
strategies for reaching EPA's
emerging new goals. Next, a
former Agency official and
long-time observer, Alvin L.
Aim, explains the nature of the
Agency as first conceived and
how it actually is today.
A 14-page special section
follows, reporting on the
progress and delineating the
challenges in major aspects of
EPA's mission: protection of
air, water, and land, and
regulation of chemicals. This
section, which also summarizes
the dollar costs and benefits of
EPA programs, is adapted from
two new EPA reports,
Meeting the Environmental
Challenge and The Cost of a
Clean Environment.
Then, in a format borrowed
from Harper's magazine, some
telling facts about EPA and the
environment are presented.
Five articles follow, each
looking at some key aspect of
the modern environmental
situation from a new
perspective—through a new
"looking glass":
• Frederic Krupp, Executive
Director of the Environmental
Defense Fund, finds growing
areas of consensus on the
environmental front.
• U.S. Senator Quentin Burdick
(D-North Dakota), Chairman of
the Environment and Public
Works Committee, explains the
fresh start that is under way
for environmental education.
• Douglas P. Wheeler, Vice
President of World Wildlife
Fund and The Conservation
Foundation, and writer
Douglass Lea describe the
resurgence of interest in
ecology—in respecting nature
for its own sake.
• Howard Gruenspecht, Senior
Staff Economist with the
President's Council of
Economic Advisers, explains an
emerging new relationship
between economic policy and
environmental concerns.
• Erich Bretthauer, the
Agency's Assistant
Administrator for Research and
Development, discusses the
goal of a strong science, out
front, helping establish the
agenda for environmental
protection.
The next segment of this
Journal issue includes several
features in which outside
observers comment. Included
are a forum in which five U.S.
Senators and Congressmen
offer their views on the major
challenge a Cabinet-level EPA
would face; a feature in which
eight environmental journalists
from around the country
comment from their daily
perspective on EPA's relations
with the public; and articles by
three outside leaders, each
answering the question: What
do you expect of EPA? The
writers are Chris Gregoire,
Director of Washington state's
Department of Ecology;
Michael McCloskey, Chairman
of the Sierra Club; and Frank
Popoff, President and Chief
Executive Officer of The Dow
Chemical Company.
Then writer Phyllis Myers
reviews EPA's first 20 years,
based on extensive interviews
with past and present EPA'ers.
And 18 of today's EPA
employees tell staff writer Roy
Popkin what working for the
Agency means to them.
The issue concludes with a
regular feature,
Appointments. D
A leaded gasoline pump, reminder of an era ended by EPA action
on behalf of public health. Twenty years ago, over 200 billion
grams of lead per year were used in U.S. gasoline. Today the
amount is less than one-half billion grams per year. This
picture by Vera A. Ashworth was among the top three winners of the
EPA employee photo contest recently sponsored by the Agency's 20th
Anniversary Office.
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United States
Environmental Protection
Agency
Office of
Communications and
Public Affairs
v>EPA JOURNAL
William K. Reilly, Administrator
Lew Crampton, Associate Admininistrator
for Communication and Public Affairs
John Heritage, Editor
Karen Flagstad, Associate Editor
Ruth Barker, Assistant Editor
Jack Lewis, Assistant Editor
Nancy Starnes, Assistant Editor
Marilyn Rogers, Circulation Manager
Volume 16, Number 5
September/October 1990
20K-9005
EPA is charged by Congress to
protect the nation's land, air, and
water systems. Under a mandate of
national environmental laws, the
agency strives to formulate and
implement actions which lead to a
compatible balance between
human activities and the ability of
natural systems to support and
nurture life.
EPA Journal is published by the
U.S. Environmental Protection
Agency. The Administrator of EPA
has determined that the
publication of this periodical is
necessary in the transaction of the
public business required by law of
this agency. Use of funds for
printing this periodical has been
approved by the Director of the
Office of Management and Budget.
Views expressed by authors do not
necessarily reflect EPA policy. No
permission necessary to reproduce
contents except copyrighted photos
and other materials.
Contributions and inquiries
should be addressed to the Editor,
EPA Journal (A-107), Waterside
Mall, 401 M Street, SW.,
Washington, DC 20460.
A New Era of Environmental
Stewardship
by President George Bush 2
A Vision for EPA's Future:
An Interview with
William K. Reilly 4
Strategies for Meeting Our
Goals
by F. Henry Habicht 8
A Dream that Hasn't Come
True
by Al Aim 12
Progress and Challenges:
Looking at EPA Today 15
Facts to Reflect On
by Ross Ettlin 29
Changing Perspectives:
—WiiyWin on the
Environmental Front
by Frederic Krupp 30
—Starting Fresh with
Environmental Education
by Quentin Burdick 32
—Rediscovering Ecology
by Douglas P. Wheeler
and Douglass Lea 34
—Forging New Links with
Economic Policy
by Howard K. Gruenspecht 36
—Environmental Science:
Helping Shape EPA's Agenda
by Erich W. Bretthauer 39
Reflections on the Role of a
Cabinet-Level EPA 42
The Agency and the Public:
Journalists Comment 46
What Do You Expect of EPA?
-A State Official
by Chris Gregoire 50
—An Environmentalist
by Michael McCloskey 52
—An Industrialist
by Frank Popoff 55
The Road We've Travelled
by Phyllis Myers 57
What Does EPA Mean to You?
Employees Comment
by Roy Popkin 61
Appointments <64
Front Cover: A bald eagle, cherished
American symbol. The species was
rescued from the brink of extinction by
EPA's ban against DDT in 1972. See
article on page 57. Photo by Johnny
Johnson for AllStock, Inc.
Design Credits:
Ron Farrah
James R. Ingram
Robert Flanagan
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A New Era
of Environmental Stewardship
by President George Bush
n New Year's Day 1970, President Nixon
! launched the "Year of the Environment"
by signing into law the National
Environmental Policy Act. This pioneering law
reflected the growing determination of the
American people to protect and preserve our
nation's environment. In the spring and summer
of that year, while Americans observed the first
Earth Day and organized to fight pollution,
government officials set out to fashion a new
Environmental Protection Agency by stitching
together bits and pieces of federal agencies from
all over the government. EPA opened for
business in December, two months after
Congress passed a ground-breaking Clean Air
Act. Ever since, EPA has been at the forefront
of our country's significant environmental
accomplishments.
Now, 20 years later, it's common to hear people
refer to the 1990s as the "Decade of the
Environment." Concern for environmental
protection and stewardship has grown, solidified,
and deepened over the last two decades. It is in
keeping with this continued commitment of the
American people to a clean, healthy environment
that I've made the vigorous enforcement and
strengthening of our nation's environmental laws
one of my Administration's top domestic
priorities. And it is in keeping with this
continued commitment that I have recommended
that EPA be elevated to Cabinet status.
EPA has come a long way and accomplished a
great deal in 20 years. The issues that dominated
the early years of the Agency were fairly obvious
and straightforward: DDT and the bald eagle,
flames on the Cuyahoga River in Ohio, pollution
so thick you could almost touch it in Pittsburgh
and Los Angeles. Today's issues are much more
subtle, more complex, and harder to deal with.
Toxic chemicals show up in food and water, but
often in doses so small only experts can detect
them. Just how dangerous are these "trace"
amounts? No one knows for sure. Yet the health
of the public and the environment must be
protected, and this must be done without
unnecessarily hampering the nation's
economic growth.
So it is clear that EPA has its work cut out for it
in the 1990s. And I am very pleased that under
Bill Reilly's leadership, EPA has been developing
a variety of creative and innovative new
approaches to environmental protection that will
enable us to build on the environmental progress
the nation made in the 1970s and 1980s.
Congress has just passed, for example, my
proposed strengthening of the Clean Air Act.
Our goals are to protect the American people
from urban smog and toxic air pollution and to
protect vulnerable ecosystems from the adverse
effects of acid rain. Many of these clean air
proposals are based on new, market-based
concepts-such as emissions trading in our plan to
curb acid rain—that will substantially reduce the
cost and increase the flexibility of pollution
controls and thus will make a greater amount of
environmental protection possible in the long run.
The Clean Air Act is just the most visible
element of the environmental agenda we've set
out. We have stepped up Superfund
enforcement; expanded our national parks,
forests, and wildlife refuges; funded a much more
aggressive effort to clean up pollution at federal
facilities; agreed to a complete phaseout of CFCs;
and proposed a healthy increase for EPA's
operating budget—the heart and soul of the
Agency.
As we turn to the future, an important thrust
must be pollution prevention. Preventing
pollution is everybody's job, from the biggest
industrial complex to families and individuals.
Environmental programs that focus on the end of
the pipe or the top of the stack, on cleaning up
after the damage is done, are no longer adequate.
We need new policies, technologies, and
EPA JOURNAL
-------
processes that prevent or minimize pollution-that
stop it from being created in the first place.
To do this, everyone must pitch in. Business
leaders, workers, environmental groups,
consumers: Everyone needs to work together as
partners instead of adversaries. Governments at
all levels have a role to play, and at the family
level, we all can learn to shop more carefully, to
waste less, and to recycle more.
Another step every American can take to help
protect the environment is to plant a tree—plant
lots of trees! Our "America the Beautiful"
initiative calls for planting one billion trees a year
for the next 10 to 15 years. Not only will
planting trees help beautify America, it will
improve air and soil quality, provide wildlife
habitat, and aid in shading our homes, offices,
and public buildings.
In 1908, President Theodore Roosevelt called the
nation's governors together to discuss, for the
first time as a group, the conservation and
development—the wise use—of the nation's
threatened natural resources. "One distinguishing
characteristic of really civilized men is foresight,"
President Roosevelt told the governors. "We
should exercise foresight in conserving and
wisely using the property which contains the
assurance of well-being for [us and our]
children."
I find it encouraging that so many people today
are starring to recognize the wisdom of Teddy
Roosevelt's advice, to acknowledge that economic
well-being and environmental prudence go hand
in hand. In a modern industrial society like ours,
we can't have one without the other.
I hope that 20 or 30 years from now, we'll be
able to look back on EPA's 20th birthday and
conclude that it was around 1990 when the
Agency, and the country, began to chart a new
course: when we began to exercise foresight in a
truly meaningful way. The 1990s must be the
decade when we focus our attention on finding
the most cost-effective, most efficient ways to
prevent pollution, to reduce risks to human
health and the environment, and to achieve
environmentally sound, sustainable economic
growth.
It can be a new era of environmental
stewardship, creating a safer, cleaner, more
productive world for ourselves and our children.
I know EPA will be there to help bring us into
that new era, adding another proud chapter to its
already proud history, c
SEPTEMBER OCTOBER 1990
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A Vision for EPA's Future:
An Interview with William K. Reilly
On this occasion of EPA's 20th anniversary,
EPA Journal asked Administrator Reilly for
his assessment of the challenges facing EPA
and about his goals and vision for the
Agency. Tlie questions and Mr. Reilly's
answers follow:
If you had to say what the most
crucial environmental issues facing the
world in the 1990s are, what would they
be?
I think the most serious and
potentially most destructive
environmental problems have to do with
planetary systems and the possibility of
their destabilization. The depletion of
stratospheric ozone is certainly high on
this list.
The loss of forests, particularly in the
tropics—and more broadly, the
degradation of biological systems and
their productivity—is also very important.
Forest losses in the tropics are
proceeding so fast that within the next 10
to 15 years, the number of mature forest
systems will be very significantly
impaired. Some will be virtually gone at
the present rates of loss.
That loss will diminish the species on
the planet very significantly. It will alter
the rainfall and local climate for a
number of developing countries. It may
well exacerbate the climatic problems
throughout the world.
Poverty and the stresses that very poor
people place on the environment are also
critical. In so many large cities, we see
accumulations of toxics in the air, in the
ground water, and in the soils that are
very difficult to address. It takes
resources to improve the environment.
Unless poor countries can generate
wealth and growth, they're unlikely to be
able to devote any resources to the
environment.
Those, I think, are the most significant
problems. In addition, there are places in
Eastern Europe where people are dying
prematurely due to environmental
problems. Rivers in some cases are
almost half chemicals. Pesticide residues
on food are grossly excessive. Vast areas
are contaminated with cadmium and
other heavy metals. Water supplies are
shrinking as river water cannot be
purified for drinking. In many cases, it
cannot even be used to cool machinery.
More fundamentally, the problem in
our own countrv, as well as in manv
countries that are more grossly affected
by environmental contamination, is to
develop systems of economic growth and
activity that ensure sustainability. We
have not yet done that even here.
There are many systems that are
continuing to deteriorate in the United
States. With all of the efforts we've
made in the Chesapeake Bay, we still see
a steady loss and project a continuing
loss of oxygen. Fish still accumulate
toxins in the Great Lakes. On the other
hand, there are fish in the Great Lakes.
That's a great achievement over the past
20 years, but it's an incomplete one.
Our next question focuses on EPA
and EPA's mission. It is sometimes said
that EPA has taken care of the most
obvious environmental problems. Now,
the Agency faces tougher challenges,
needing basic new approaches. Do you
agree?
I think the accomplishments of EPA
over the past 20 years have been
extraordinary. I believe there is no more
significant success story in the realm of
public policy during this period.
Consider all of the other commitments
society made during that time-whether
to eliminate poverty or provide adequate
housing, or to control crime or eliminate
illegal drugs. We have made more
progress on the environment than in all
of those other areas.
Nevertheless, we still have persistent
environmental problems involving soil
run-off containing pesticides and
nutrients from farms and other lands and
cities. We have a continuing air-
pollution problem that leaves half our
population breathing unhealthy air. We
have a rate of wetlands loss that is really
shocking in view of our understanding of
wetland functions and the long-time
commitment on the part of the federal
government and the states to wetlands
protection. There are contaminated wells
from one coast to the other. And this
problem appears to be becoming more
serious.
Many of these problems are the result
of diffuse, difficult-to-control sources of
pollution. They are not obvious or
visible or corrected by simple
enforcement actions against a spewing
smokestack or a recalcitrant industry.
They really involve all of us. And what
they involve most fundamentally, I think,
is a pattern of use of resources and
resulting waste that is out of control. We
waste far more than many other
successful, competitive modern
industrialized countries do. And that
waste is bedeviling us in all media: air,
water, and land.
Addressing problems of this sort is
going to mean a change in attitude, a
somewhat different ethic with respect to
resource use and disposal-and a much
more individual commitment. To attain
that, EPA has to speak to the public with
a clearer voice, and we have to be more
successful at winning their adherence for
changes in behavior.
That's a somewhat different mission
than the Agency began with. But it's
necessary, I think, to address the
remaining problems we have.
EPA JOURNAL
-------
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What is your primary goal for the
Agency as it positions itself to deal with
the kind of problems that you are
talking about—contemporary
environmental problems?
f\ My principal goal is to ensure that
EPA organizes its own agenda and
communicates to the society a message
based on careful science and systematic
assessment of the seriousness of
problems. I want us to pay attention to
the things that matter. I want us to be
clear about the threats to health. I want
us to avoid being transported by popular
enthusiasms, as Senator Moynihan
warned on my first meeting with him,
and to base our work consistently on
good, sound science.
We need the coherence and integrity
that scientific research can provide us.
And we need scientific information to
defend what will often be difficult,
controversial, or expensive decisions. I
look to science and to risk assessment to
help the Agency put together a much
more coherent agenda than has
characterized the past 20 years, given the
accumulation of separate statutes EPA
has received.
I see all of this as a means of reducing
the risk to health and the destruction of
ecology that continue even into the 1990s.
v j You've already touched on the
theme of pollution prevention as a
strategy for the future. Could you talk
a little bit more about that?
f\ EPA has been very effective, I think,
at developing standards and
promulgating regulations and enforcing
the law. We have been less successful at
causing people to ask questions, before
they become polluters, about the
possibilities for avoiding pollution in the
first place.
As we look to the future, especially in
areas where much progress has been
made against a problem, making a
further dent is going to require certain
fundamental changes. For a lot of
people, it's going to mean asking
different kinds of questions. How will a
product be used? How will it be
manufactured? What kinds of
byproducts will be created in its
manufacture? And how will it be
disposed of? Is it possible to create an
alternative product which entails
significantly fewer environmental
problems—a product which can be
recycled, which is biodegradable, which
minimizes or prevents altogether the
resulting assaults on the environment?
That's a subtle problem. People will
not change their habits without
incentives to do so. We're going to have
to become more adept at communicating,
at providing information and education,
and at leading by constant exhortation.
We must also become more expert at
interrelating environmental proposals
with economic incentives and finding
ways to use incentives and taxes of one
sort or another to deter the creation of
products that have a high cost in terms
of environmental impact and funds that
will have to be invested in cleanup later
on.
I think people at EPA have learned
these principles through experience, but
we have not yet fully applied them. The
lesson of pollution prevention is one that
will ultimately make sense both
economically and environmentally, but
it's not widely understood as I speak.
J You have spelled out a pretty
daunting list of problems and strategies.
Yet historically, the Agency's budget
has been relatively level. How are you
going to realize your vision for EPA in
view of that reality?
: :. Well, we have begun to bring the
operating budget up in the last couple of
years. But it is certainly correct that we
do not ourselves have the resources
SEPTEMBER/OCTOBER 1990
-------
sufficient to solve all of the nation's
environmental problems.
We are, however, the cockpit of great
influence on the expenditure of much
larger sums of money. The percentage of
money spent on the environment that
actually goes to EPA is less than 10
percent. That's less than 10 percent of
the funds being expended by the society
generally-by federal, state, and local
governments and by private industry and
individuals.
EPA influences and often determines
the expenditure of the other 90-plus
percent of funds. There is a steeply
rising curve of expenditure on the
environment in this country, and by the
time this issue of EPA Journal comes out,
we will have issued a report entitled The
Cost of a Clean Environment (see writeup
on page 28). As this report shows, the
United States is committing more money,
as a percentage of gross national product,
to environmental protection than many
of our economic competitors.
I think the kinds of tools that we have
and the increasing personnel resources
that we now deploy-almost 2,000 more
than a couple of years ago—give us not
really adequate staff support, but an
encouraging level of support that will
allow us to carry out our mission.
Vx In your testimony at your
confirmation hearing in Congress, you
said enforcement is the key to an
effective EPA. How are we doing in
that respect?
r\ Enforcement is one of those activities
where if you are vigorous and are seen
to be so, you will gain a great leverage, a
great boost in productivity in all of your
programs. It will be less necessary to
police a system that gets the message
that it had better self-police.
I am very pleased with the enforcement
record in my time here. The measures
we have are either record highs or
second-bests ever. We have been
working well with the Justice
Department. Some milestone cases in the
last couple of years have significantly
strengthened our hand for future
enforcement actions.
One example worth citing is the record
number of Superfund settlements
concerning potentially responsible
parties. I think this record suggests that
lawyers are now giving clients a different
kind of advice. The Agency obviously is
serious. It's going to go after potentially
responsible parties. Before that happens,
they would do well to come forward and
acknowledge their responsibilities.
That's the kind of message I hope will
become broadly understood in other
areas as well.
EPA has also begun to use enforcement
in a more creative way. We have entered
into settlements that require pollution-
prevention commitments from companies
that sometimes go quite beyond the
immediate circumstances of enforcement.
That is a less well-understood possibility,
but one that I think Jim Strock (EPA's
Assistant Administrator for Enforcement)
and I very much believe in. It's possible
to break new ground in crafting
settlements with companies that set the
companies on a new course.
CJ EPA has evolved as primarily a
public health agency. Do you favor an
increased emphasis on ecological
concerns?
A I think EPA was conceived as an
organization that would pay significant
attention to ecology, meaning that a high
proportion of its attention and resources
would go to ecological stabilization and
protection. Obviously we have
enormously significant public-health
responsibilities reflected in the statutes
we administer.
I would like to reestablish the priority
that I think belongs to national resources.
Fundamentally, we all depend on sound,
healthy, natural systems. All human
activity—all economic activity—depends
upon them.
One sees from the experience of
Eastern Europe today what happens
when that's forgotten. You cannot
manage a successful economy for very
long if you allow your ground water to
become contaminated, your soils to
accumulate heavy metals, your rivers to
run with chemicals, and so forth. These
affect public health, but they also affect
the lasting capacity of nature to sustain
life in all of its diversity and richness.
Ecology and ecological systems also
function to warn us about the
consequences of the way we're living.
The fact that we see a high accumulation
of toxic substances in fish in many of our
surface waters, and particularly in the
Great Lakes, should make clear to us the
size of the clean-up job still to be done.
The Great Lakes is not a healthy system.
It will ultimately be unsustainable if it
remains so contaminated, and we've got
to clean it up. The loss of basic resources
like wetlands will translate, I think, into
many other consequences that we
probably half understand.
If you look 20 years into the future,
what do you think EPA might be like?
Whaf s the chief difference you'd like to
see? Will environmental quality be
better?
A First of all, I would hope that EPA
would be understood as an agency with
sufficient scientific capacity, consistency,
and integrity that it is not subject to
transitory seizures of public opinion. I
would hope that our mission is broadly
embraced by the society and that we are
seen as having the key role in reconciling
industrial and economic activity with
nature and environmental protection.
Looking outside the Agency, I would
expect the air in our cities to be
significantly cleaner. The promise of the
Clean Air Act is very great. We have
identified the goals and we've settled on
the means that will, in fact, move us
toward that objective. So that's not
merely wishful thinking. Each generation
will have to revisit the clean air issue as
there are more cars and factories and
other sources, but the new emphasis on
clean fuels and economic incentives will
seve us well as future priorities are
decided.
I would hope that we can be equally
successful in other areas of the
environment and public policy and bring
back the Chesapeake Bay and Long
Island Sound, the Great Lakes, and other
great water bodies to a level of health
and productivity that they have not yet
achieved in recent years.
Internationally, I would hope that we
will have found a means to help many of
the most impoverished countries and
areas with the most degraded
environments to stabilize their
environments, protect public health, and
do for their countries what we have done
and are doing for our own. In my
experience, the stature of EPA seems to
rise with distance from Washington, DC.
Our standards, our epidemiological
resources, our information, and our
example are esteemed and emulated the
world over.
To an extraordinary degree, the world
looks to EPA to chart the course of
environmental protection. What we do
here is watched closely and borrowed
almost immediately. That's a high
responsibility and one that, with our
increasing international capacities, I think
we are better equipped to carry. We are
Many of the nation's rivers were
once foamy from detergents.
Widespread state and local action
with EPA assistance has
dramatically reduced this problem.
Less visible problems now remain.
EPA JOURNAL
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going to be saving lives and restoring
ecological systems on a large scale
outside the country as well as in this
nation in the next 20 years. The simple
fact is there's no one else; there's no
other agency capable of playing that role.
I do believe that environmental quality
in our own country will be better,
perhaps significantly so. I'm reasonably
confident that in some of the new pre-
market economies of Eastern Europe and
Southeast Asia, the next two decades will
see better environmental stewardship.
As the Latin American countries begin
to cope with their debt and-thanks to
President Bush's "Enterprise for the
Americas" initiative-to apply some of
that debt to natural resource and
environmental protection, they also
should be able to bring down the
grotesque levels of air pollution affecting
many of their citizens and get a grip on
toxic substances.
Whether they will succeed in managing
their forests is a larger question and a
more daunting problem. The President's
commitment to an agreement on world
forestry reflects our sense of urgency
about that problem that will cause us to
give it a very high priority. But the
reasons for forest losses are so
fundamentally connected to patterns of
land tenure and settlement and poverty
that it's going to take a great deal of
imagination, and a fair amount of money,
to solve the deforestation problem.
On a more positive note, the world
should have ceased production of ozone-
depleting chemicals within the next 20
years, the developing world having fully
phased them out by then. And within
the not-too-distant future thereafter, we
should begin to see a decrease in the
ultraviolet radiation reaching the Earth as
a consequence of ozone depletion.
Ultimately, I think the prospects for
environmental improvement both in the
United States and throughout the world
will depend on public expectations and
demands. Happily, public consciousness
of the environment is higher today than
I've ever seen it. That is true even in the
developing world. It's true in Mexico,
Brazil, and Chile, and it's certainly true
in Eastern and Western Europe, the
United States, Australia, and Canada.
In a fundamental way, public
consciousness is something we have to
rely upon and also inform. The
relationship is reciprocal. EPA informs
public expectations, and public
expectations drive us to do better. More
than anything else, public trust enables
us to lead and to be effective.
J One last question: Here we are at
EPA's 20th anniversary, some 17,000
employees strong. Sometimes
environmentalists say that EPA is not
doing enough, and sometimes industry
says that EPA is doing too much. Do
you have particular closing thoughts on
how we are doing really?
•~% EPA seems always to sit astride the
controversial nexus between concerns
about health and anxieties about costs,
and between science and economics. We
do have our critics, as any agency
operating with such power in areas of
such importance is going to have. There
have always been concerns on the part of
the regulated community that we are
excessively zealous, insensitive to
economics, or sometimes not informed
about science or sufficiently attuned to
risk. There are also concerns among
environmentalists, as you mentioned, that
we are sometimes slow to act in the
absence of a court suit or a statutory
directive.
I think the quality of people here at
EPA is such that we can maintain the
vigor that we have, and certainly with
the support we have from President
Bush, do a far better job of carrying out
our mission.
We can never fully satisfy the various
critics of the Agency, but we can win
their respect. It seems to me that we are
increasingly doing that.
We can also recapture the agenda. One
of the distressing aspects of the past
several years is the loss of our capacity to
shape initiatives and influence the
Congressional agenda: These are things I
believe EPA is qualified to do.
I feel very strongly about winning back
the kind of trust from Congress and the
country that EPA needs to function
effectively. And the best case we can
ever make on this point turns on the
professional skill, training, integrity, and
sheer vigor of our employees. There are
some government agencies where you
walk through the halls and adrenalin just
flows out your shoes onto the floor. EPA
is not one of those agencies: This is still
a young, aggressive, and vigorous
agency.
Overall, EPA people have wonderful
qualities, and I cannot say enough how
proud I am to be leading them at this
time.D
SEPTEMBER/OCTOBER 1990
-------
Strategies for Meeting Our Goals
by F. Henry Habicht
- •; '"Onmental
-....~ioe EPA's
urisdiciioi example: Asa
li-imauve. the Washington,
TotO'iuan area's recently
cit-d subViiay system is
io (he environment than
;;:>ir!,nui.e! traffic.
As EPA celebrates its 20th birthday
this December, those two decades
may seem like a lifetime to EPA
employees who have spent their entire
professional careers here. Yet EPA still is
a very young agency, especially
compared to federal agencies like the
Department of the Treasury, which
measures its lifespan in centuries.
Despite its relative youth, EPA has
accomplished a great deal. From a few
thousand people linked together by a
Presidential Reorganization Plan in 1970,
we have grown to an agency of more
than 17,000 people working at
headquarters, 10 regional offices, and
several laboratories. As our numbers
have grown, so have our responsibilities:
We now implement and enforce a dozen
major environmental laws and nearly 100
additional ones, all enacted since 1970.
Without doubt, in its 20 years of
existence EPA has played a major role in
causing substantial changes in the world
around us. Because of EPA's efforts to
implement national laws, air emissions
from cars, power plants, and large
industrial facilities have been curtailed
sharply; hundreds of primary and
secondary wastewater-treatment facilities
have been constructed; ocean-dumping of
wastes has been virtually eliminated;
land disposal of untreated hazardous
wastes has largely stopped; hundreds of
hazardous waste sites have been
identified and 52 have been cleaned up;
and the production and use of substances
like asbestos, DDT, PCBs, and leaded
gasoline have been banned. In the
aggregate, actions like these have had a
measurable, positive effect on
environmental quality in this country,
and they have set an example for other
countries around the world.
Even-one at EPA should be proud of
the difference the Agency has made over
the last 20 years. Attacking pollution
with mandated, media-specific controls—
(Habicht is Deputy Administrator of EPA.)
IPA photo.
usually at the end of the pipe—has been
EPA's main operating paradigm since
1970, and this approach indeed has
improved the quality of the environment.
Right now, however, EPA is looking
ahead 20 years to ensure that we are
prepared to sustain environmental
quality in the face of rapidly changing
economics, demographics, and
technology. We should not simply
abandon our traditional tools, but in the
future we must look beyond command-
and-control; we must end
compartmentalizarion at EPA, take a
more systematic view of environmental
risks, and develop more targeted
strategies to reduce them.
In short, the Agency and the country
manifestly need a new paradigm, one
that goes beyond the end of the pipe,
beyond any type of control or
remediation technology, beyond EPA
itself. This new paradigm already is
beginning to emerge, and it promises to
have a profound impact on EPA as the
Agency embarks on its third decade.
The Science Advisory Board Report
EPA's Science Advisory Board recently
produced a report that suggests some of
the ways that EPA should evolve in the
years ahead. Although the report was
not written as a part of EPA's birthday
activities, its timing was fortunate. For
after looking at EPA's past approaches to
environmental protection in the context
of existing and emerging risks to human
health, welfare, and the ecology, the SAB
made several findings and recom-
mendations that suggest what EPA could
look like in the decades ahead.
In late September, the SAB presented
EPA Administrator William Reilly with
Reducing Risk: Setting Priorities and
Strategies for Environmental Protection.
That report reviewed EPA's ground-
breaking study, Unfinished Business: A
Comparative Assessment of Environmental
Problems (1987), in light of the latest
scientific information and then
recommended ways for the Agency to
improve its ability to assess, compare,
and reduce environmental risks.
Reducing Risk made 10 specific
recommendations (see box) that can be
summarized in two simple points. First,
EPA must target its environmental
protection efforts much more than it has
in the past, and, second, EPA must
integrate its environmental protection
efforts much more than it has in the past.
I believe that our success at targeting and
integrating our efforts over the next few
years will shape, to a large extent, the
EPA of the 21st century.
Targeting EPA's Efforts
EPA came into existence 20 years ago at
a time when the people of the United
States felt threatened by several serious,
and readily observable, environmental
problems. Air quality in many American
cities was deteriorating, and the
deterioration was all too visible. The
flammability of the Cuyahoga River,
thick urban smog, fish kills in different
stream segments across the country, and
piles of rusting drums of chemicals were
unambiguous signs that industrial
pollution was imposing very high
environmental costs.
In response, Congress passed a series
of specific laws aimed at specific
EPA JOURNAL
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Mikf Brisson photo.
environmental problems. Each of those
laws prescribed clean-up standards,
control technologies, regulatory
deadlines, or some combination of all
three. Each of those laws was intended
to reduce the risk posed by the
environmental problem in question to an
acceptable level.
But the laws were written without
consideration of other laws, or other
problems. No attempt was made to
prioritize actions across the
environmental policy spectrum; because
all environmental problems were
considered equally serious, all
environmental regulations were equally
urgent. Citing this history, the SAB
stated in its report, "at EPA there has
been little correlation between the
relative resources dedicated to different
environmental problems and the relative
risks posed by those problems."
At EPA, environmental professionals
are finding that this traditional approach,
by itself, will not be as successful over
the next 20 years as it has been in the
past. And the Agency is beginning to
put emerging environmental challenges,
and the strategies for attacking them, into
perspective. For example, the number of
environmental problems that EPA is
asked to address continues to proliferate.
Many of those problems-pesticide
residues on food, indoor air pollution,
stratospheric ozone depletion-are far less
visible than the problems of the 1970s,
and their effects are much more difficult
to measure. To make matters worse,
while new problems multiply, none of
the old ones completely go away.
Yet we continue to blast away at all
environmental targets separately, as if
environmental policy were a kind of
"Space Invaders" video game, as
Administrator Reilly noted in his speech
to the National Press Club last
September. In reality, our fiscal
ammunition during any given time
period is limited. Consequently, in the
future we have to do a better job
focusing EPA's activities where they will
do the most good.
In short, we have to target our efforts
on the basis of risk. We have to use the
discretion available to us under present
law to better inform the public about
risks and how those risks interrelate, and
to focus agency resources—to the extent
we can— on problem areas that, in our
best judgment, pose the greatest risks to
human health, welfare, and ecology.
This recommendation by the SAB is
sometimes interpreted to mean that
EPA's different program offices should
compete for funding on the basis of the
risks they would reduce. This kind of
"riskier-than-thou" interpretation
reinforces the artificial walls that have
grown up between EPA's program offices
and belies the more important message.
That is, each program office should
reevaluate its own internal responsibilities
and set priorities on the basis of risk.
Moreover, in the face of a particularly
serious environmental problem—lead, for
example-the Agency's different program
offices must work together to define the
set of cross-program actions, or even
external actions, that would reduce the
most risk.
In other words, targeting risk within
EPA should mean less turf consciousness
and more cross-program and cross-media
cooperation. Such team approaches will
be key to the new paradigm.
The SAB made one other important
"targeting" recommendation: EPA should
better assess and target ecological risks
than it has in the past. In fact, the SAB
recommended that EPA attach as much
importance to reducing ecological risk as
it does to reducing human health risk.
Concern for ecosystems is a central
part of EPA's heritage. By drawing
attention to the links between chemical
use and declining populations of birds,
Rachel Carson's Silent Spring helped
galvanize public support for strong
environmental laws, and for a strong
federal environmental agency, in this
country. Early environmental laws like
the Clean Air Act and the Clean Water
Act included important ecological
components. Yet, for whatever reasons,
ecological concerns have been a
secondary preoccupation at EPA for the
last decade or more.
The links between ecosystem and
human health are many and obvious: the
value of wetlands in filtering pollutants
out of ground-water aquifers; the
potential future medical use of different
plants' genetic material; the human
health effects of heavy metal
accumulation in fish and shellfish. It is
clear that healthy ecosystems provide the
underpinnings for the long-term health of
economies and societies. In addition, as
SEPTEMBER/OCTOBER 1990
-------
the SAB report pointed out, "natural
ecosystems have an intrinsic, moral
value...." Over the next 20 years, EPA
must reestablish ecological protection as
a vitally important part of its mission.
Integrating EPA's Efforts
During EPA's first 10 years of existence,
Congress passed a series of laws
intended to control emissions of
pollutants into the different
environmental media, or—in some cases—
to clean up pollutants already in the
environment. Because EPA was given
the responsibility for implementing those
laws, it is not surprising that they tended
to shape the way the new agency
conducted its business. In particular,
they shaped the Agency's evolving
organizational structure, its emphasis on
command-and-control, end-of-pipe
technologies, and its predominant
concerns about protecting human health.
As the SAB noted in Reducing Risk, that
kind of ad hoc approach tended to
compartmentalize the Agency. Each
program office saw its set of
environmental responsibilities as most
important, its problems as most serious,
its regulations as most urgent. There
were few linkages among the different
program offices, because there were few
linkages among the different
environmental laws. Because problems
in the environment were artificially
separated from each other in the law,
EPA's programs were artificially
separated from each other in
organizational structure. EPA's
multifarious efforts to protect the
environment proceeded on different and
often unconnected tracks.
After 20 years of experience, we know
now that this compartmentalization of
agency activities is inefficient at best, and
counterproductive at worst. Water
quality in the Great Lakes is affected to a
great extent by toxic air pollutants
emitted hundreds, if not thousands, of
miles away, and by pesticides washed off
farms, lawns, and gardens in a huge
watershed. Thus cleaning up the Great
Lakes is not simply the responsibility of
EPA's water-quality experts. It demands
the coordinated, integrated efforts of
several EPA program offices with
complementary responsibilities. In fact, as
our past experience in the Great Lakes
has shown, real long-term progress
demands the integrated efforts of the
federal governments of both the United
States and Canada, several provincial and
state governments, a host of local
governments, and the private sector and
concerned citizens on both sides of the
border.
The value of this kind of broad policy
integration is implicit in several of the
recommendations made by the SAB in
Reducing Risk. For example, the SAB
pointed out that we have a range of tools
at our disposal for reducing
environmental risk. We are not limited
to the federally mandated command-and-
control regulations that have played so
prominent a role in our environmental
protection efforts of the past two
decades.
The private sector can be given
economic incentives to reduce pollutant
emissions in the most cost-effective ways,
as the new clean air legislation shows.
And look at the power of information.
Emissions data supplied to local
communities, like the information
required in the Toxics Release Inventory
data base, can give businesses economic
and public-relations incentives to cut
back on emissions voluntarily. Finding
the right mix of tools, regulatory and
non-regulatory, and applying them in a
coordinated and integrated way is one of
the major challenges facing EPA
employees in the years ahead.
Some of the best tools for reducing
environmental risk may lie outside the
Agency itself. The SAB noted that the
policies implemented by other federal
agencies can have direct-and substantial
—effects on environmental quality.
National agricultural policy, for example,
influences the quality of wetlands and
riparian (related to land on edge of
natural waters) and ground-water
resources. National transportation policy
clearly is one of the factors that affect air
quality in urban areas. Programs
undertaken at the Department of
Housing and Urban Development may
have a far greater potential for reducing
the health risks posed by lead than
anything EPA's program offices could
do.
In such cases, EPA has a responsibility
to work cooperatively with other federal
agencies to ensure that the environmental
ramifications of their evolving policies
are not overlooked. EPA is not the only
agency whose actions affect the
environment. But EPA is the only
agency with an environment-wide
perspective, and it thus has an important
leadership opportunity in helping fashion
federal efforts to reduce environmental
risk. Consequently, as we evaluate all
the tools that can be used to address a
particular problem, we should reach out
to other federal agencies more
confidently than we ever have before.
Because, more than ever before, I think
those other agencies are willing to listen
and to help.
The SAB report made several other
recommendations that pointed out the
value of EPA's integrating its efforts with
people outside the Agency. It
recommended that EPA do much more
to educate the general public and train
the professional workforce in ways that
will help them make choices, and take
actions, to reduce risk. The report
recommended that EPA work more
closely with the private sector to foster
pollution prevention, which the SAB
believes is by far the most promising
approach to reducing environmental risk
over the long term. But, at root, all those
recommendations make the same simple
point: All of us at EPA have to challenge
our traditional, narrowly defined notions
of programmatic responsibilities and,
using all the tools at our disposal, engage
all elements of society in the business of
reducing environmental risk.
The Future Of EPA
Institutions, like people, have a life cycle.
They are born, they grow, they learn
from their experience. As Administrator
Reilly said in his speech to EPA's Senior
Executive Service last September, EPA
has passed through its youth and
adolescence. It now stands on the
threshold of a long and potentially
productive maturity.
Our collective experience here at EPA
has taught us that it is indeed possible
for a society to be technologically
advanced and economically robust while
it takes conscious actions to protect the
quality of the environment. In fact, it is
increasingly clear that these
characteristics go hand in hand. That
fact was not universally accepted two
decades ago.
But our collective experience has also
taught us that there are better ways to
achieve our goals than we once believed.
Over the next two decades we at EPA
need to apply the wisdom of past
experience to the challenges of a new
decade and a new century.
We have already begun doing that.
Indeed, we already have
under way several of the steps
recommended by the SAB. The vision of
a unified EPA team with a shared
mission is taking hold. Our emphasis on
Total Quality Management, the new
strategic planning process, the pollution-
prevention program, clustered rules, and
10
EPA JOURNAL
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cross-media enforcement efforts: All these
demonstrate our commitment to target
and to integrate our efforts much more
effectively.
But we have to do one thing more: We
have to remain receptive to those new
ideas that will spring up from
tomorrow's experiences, ideas that will
make today's wisdom seem old-
fashioned and ineffective. People at EPA
represent a superb cross-section of
expertise, and each one has to find ways
to improve continuously the way we do
business. If we constantly challenge our
own ideas, we will constantly regenerate
our spirit.O
The 10 Recommendations*!*^
1. EPA should target its environmental
protection efforts on the basis of
opportunities for the greatest risk
reduction. Since this country already has
taken the most obvious actions to
address the most obvious environmental
problems, EPA needs to set priorities for
future actions so the Agency takes
advantage of the best opportunities for
reducing the most serious remaining
risks.
2. EPA should attach as much
importance to reducing ecological risk
as it does to reducing human health
risk. Because productive natural
ecosystems are essential to human health
and to sustainable, long-term economic
growth, and because they are intrinsically
valuable in their own right, EPA should
be as concerned about protecting
ecosystems as it is about protecting
human health.
3. EPA should improve the data and
analytical methodologies that support
the assessment, comparison, and
reduction of different environmental
risks. Although setting priorities for
national environmental protection efforts
always will involve subjective judgments
and uncertainty, EPA should work
continually to improve the scientific data
and analytical methodologies that
underpin those judgments and help
reduce their uncertainty.
4. EPA should reflect risk-based
priorities in its strategic planning
SEPTEMBER/OCTOBER 1990
processes. The Agency's long-range
plans should be driven not so much by
past risk-reduction efforts or by existing
programmatic structures, but by ongoing
assessments of remaining environmental
risks, the explicit comparison of those
risks, and the analysis of opportunities
available for reducing risks.
5. EPA should reflect risk-based
priorities in its budget process.
Although EPA's budget priorities are
determined to a large extent by the
different environmental laws that the
Agency implements, it should use
whatever discretion it has to focus
budget resources on those environmental
problems that pose the most serious
risks.
6. EPA—and the nation as a whole-
should make greater use of all the tools
available to reduce risk. Although the
nation has had substantial success in
reducing environmental risks through the
use of government-mandated, end-of-
pipe controls, the extent and complexity
of future risks will necessitate the use of
a much broader array of tools, including
market incentives and information.
7. EPA should emphasize pollution
prevention as the preferred option for
reducing risk. By encouraging actions
that prevent pollution from being
generated in the first place, EPA will
help reduce the costs, intermedia
transfers of pollution, and residual risks
so often associated with end-of-pipe
controls.
8. EPA should increase its efforts to
integrate environmental considerations
into broader aspects of public policy in
as fundamental a manner as are
economic concerns. Other federal
agencies often affect the quality of the
environment-e.g., through the
implementation of tax, energy,
agricultural, and international policy—and
EPA should work to ensure that
environmental considerations are
integrated, where appropriate, into the
policy deliberations of such agencies.
9. EPA should work to improve public
understanding of environmental risks
and train a professional workforce to
help reduce them. The improved
environmental literacy of the general
public, together with an expanded and
better-trained technical workforce, will be
essential to the nation's success at
reducing environmental risks in the future.
10. EPA should develop improved
analytical methods to value natural
resources and to account for long-term
environmental effects in its economic
analyses. Because traditional methods of
economic analysis tend to undervalue
ecological resources and fail to treat
adequately questions of intergenerational
equity, EPA should develop and
implement innovative approaches to
economic analysis that will address these
shortcomings.
*Source: Reducing Risk: Setting Priorities
and Strategies for Environmental Protection
(EPA Science Advisory Board, 1990).
11
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A Dream That Hasn't Come True
by Al Aim
EPA's creation some 20 years ago was
premised on a new vision of
environmental management. As
theorized by the Ash Council, which
recommended creation of the new
agency, pollutants would no longer be
dealt with in media-specific straitjackets.
Rather, an integrated approach to
environmental management would
prevail, reducing pollution in a
comprehensive manner throughout all
media: land, air, and water. Traditional
media-specific organization and
approaches would wither away-an
anachronism of a less sophisticated
understanding of environment and its
holistic nature.
In fact, EPA has never shaken the
media-specific approach to environmental
management. If anything, the media
programs have become even stronger
over the years. No generic legislation or
organizational structure has emerged or
is likely to emerge.
Nevertheless, although the original
vision for EPA was practically flawed,
the Agency has tremendous
opportunities to expand its vision. By
developing intermedia priorities,
integrating environmental concerns into
(Aim, a former Deputy Administrator of
EPA, is now Director and Senior Vice
President of the Science Applications
International Corporation.)
12
other national policies and programs,
developing new environmental
management tools, pursuing pollution
prevention, and expanding the
knowledge of its staff, EPA can make
real strides toward a more integrated
environmental management system.
EPA's creation in 1970 was precipitated
by the confluence of widespread rising
concern over environmental problems
with President Nixon's desire for
fundamental government reorganization.
At that time, the President's Advisory
Council on Executive Reorganization, the
so-called Ash Council, unanimously
recommended creation of an
"Environmental Protection
Administration." That recommendation
edged out the alternative of creating a
much larger Department of Environment
and Natural Resources.
In transmitting Reorganization Plan #3
to create a new Environmental Protection
Agency, President Nixon spelled out
certain environmental principles: "The
environment must be perceived as a
single, interrelated system .... A single
source may pollute the air with smoke
and chemicals, the land with solid
wastes, and a river or lake with chemical
and other wastes .... Similarly, some
pollutants-chemicals, radiation,
pesticides-appear in all media." Nixon
suggested that an effective approach to
pollution control would include
identifying pollutants, tracing them
through the entire ecological chain,
observing and recording changes in form
as they occur, determining the total
exposure of man and his environment,
examining interactions among forms of
pollution, and identifying where in the
ecological chain interdiction would be
most appropriate.
This Presidential message, taken almost
verbatim from the Ash Council report,
suggested a sharp departure from
traditional approaches to pollution
control. Under the Ash Council
approach, EPA would need to amass a
large data base, initiate new
environmental monitoring programs,
develop "end-use" monitoring schemes to
determine exposure, and understand
interactions among pollutants.
Presumably, armed with this data, the
Agency could establish standards for
individual chemicals or constituents to
minimize exposure to humans and
ecosystems.
To implement this integrated approach,
the Ash Council suggested that EPA
should be organized around its major
functions: monitoring, research,
standard-setting, enforcement, and
assistance. Presumably, programs
transferred to the new EPA would be
divided among these functions, losing
their media identity entirely.
Despite the President's endorsement,
the principles developed by the Ash
Council were not carried out in practice.
The first visible manifestation of the gap
between the Ash Council theory and the
EPA JOURNAL
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Cross-media pollution is a problem
in Lake Superior. One study
suggests that atmospheric deposits
a count for 90 percent of PCB
residues in the lake. EPA's original
organization combined air and
water clean-up efforts in a single
program, subsequently, air and
water programs became separate
entities.
An early meeting at which
President Nixon announced the
ionhcoming creation of EPA.
Some people pictured here
subsequently became EPA officials,
Oiigmal plans called for a fully
m.egraled approach to
enviionmenta! management, but
th: j aarly vision proved elusive.
traditional form of pollution-control
management appeared in EPA's original
organization. This initial organization
was a compromise between the
traditional media-specific form of
environmental management and the
recommendations of the Ash Council.
Two functional offices were created: one
for Research and Monitoring and one for
Enforcement and General Counsel. Two
media offices were also created: one for
air and water programs and one for
pesticides, radiation, and solid wastes-
inelegantly named Categorical Programs.
A fifth entity, the Office of Planning and
Management, provided administrative,
budget, and program-analysis functions.
The 10 EPA regional offices were
organized in a similar fashion.
Over the years, the functional
components lost power at the expense of
media programs. Monitoring programs
increasingly became the province of
program offices. In 1981, essential
authority for enforcement was
transferred to the program offices.
Although research was conducted
Agency-wide by the Office of Research
and Development, program office
budgets for technical studies increased
over time. Throughout its history, EPA's
organization gravitated toward the media
programs.
EPA's implementation of
environmental laws also followed
traditional media boundaries. From the
beginning, the air and water programs
followed fundamentally different
strategies, accentuated by the
geographical separateness of the air-
pollution office in Durham, North
Carolina. As new legislation was
Mikl Brisson photo.
enacted, new program offices were
created, namely the Office of Pesticides
and Toxic Substances and the Office of
Solid Waste and Emergency Response.
Each developed its own approach and
culture.
From time to time, more
comprehensive experiments were tried.
During the Costle era, an integrated
permit initiative for air and water
discharges was started, but ultimately
abandoned due to implementation
problems. Experiments in regulating
chemicals or other constituents across
media lines were tried—only to be
jettisoned later. Regions attempted
various initiatives to cope with state and
regional problems on a multi-media
basis, but rigid allocations of
headquarters resources acted as a barrier
to substantial success.
Despite top EPA managers' recognition
that environmental problems are all
interrelated, EPA has continued to
organize and manage its programs along
media lines.
During the early years, the problems of
such a limited focus seemed less
important. But during the 1980s these
limitations became more obvious. For
example, acidified lakes can be
considered a water-pollution problem
caused by air pollution. Initial
monitoring data suggest that atmospheric
deposits can be a significant source of
total loadings of toxics in water bodies.
One study suggests that atmospheric
deposits actually contribute up to 90
percent of PCB inputs to Lake Superior
and up to 78 percent to Lake Huron.
The Philadelphia sewage treatment plant
is a substantial source of air pollution.
Tough land disposal restrictions result in
pollution being transferred from the land
to the air and water.
Hence, the underlying principles laid
out in the Ash Council Report are more
cogent today than when they were
presented 20 years ago.
Considering the clear desirability of
treating environmental problems in a
more integrated fashion, why have we
been so unsuccessful in this approach? Is
the failure related to the stubbornness of
EPA's career staff or the lack of vision of
its leadership? In fact, the reasons are
more fundamental; indeed, the obstacles-
outlined below—are so formidable that, in
my opinion, the original vision was
unattainable.
• EPA's piecemeal legislative mandates
virtually force piecemeal approaches to
environmental problems. EPA's
legislative structure can be likened to an
archeological dig. Each layer of
legislation represents a set of political
and technical judgments that often do not
bear any relationship to other layers. For
example, EPA has a number of mandated
tests for establishing standards under its
several major statutes. Some take only
public health into account; others call for
balancing risks with benefits. An array
SEPTEMBER/OCTOBER 1990
13
-------
of technological standards has been set.
The different laws have different due
dates for compliance. If EPA's laws
really represented an archeological
exploration, one would conclude that
profound changes occurred within the
culture or, perhaps, that more than one
culture existed.
Congress has never seriously
considered enacting, much less attempted
to enact, generic legislation mandating a
more integrated program. The reasons
are numerous. First, as I will discuss
below, the technical and management
challenges are daunting, if not
insuperable. Second, no political
pressure exists to tackle this problem.
Because of the complexity of
environmental issues, specialists in the
Agency, in Congress, and among interest
groups all have a stake in their piece of
the turf. The participants in this three-
way iron triangle have little interest in a
comprehensive approach which would
disrupt their handiwork.
Finally, at least in the House of
Representatives, an integrated statute
would raise serious jurisdictional
issues—enough to scare off committee
leaders and staff. For these reasons,
leadership toward integrating
environmental legislation will not likely
come from Congress.
• The technical and management issues
posed by integrated environmental
management are beyond the capability
of EPA. EPA's ability to identify
contaminants and their toxicity is limited.
Methodological problems with animal
testing, lack of decent exposure data, and
the paucity of good epidemiological and
clinical data restrict the government's
capacity to characterize contaminants
accurately. The sheer volume of
potential contaminants taxes the
government's systems for testing them.
EPA has succeeded in tracing only a
few pollutants through the entire
ecological chain. The entire scientific
community is in its infancy in
determining interactions among forms of
pollution. Knowledge about the current
state of the environment, exposure levels,
and future trends is primitive at best.
The management challenge is equally
formidable. Although most observers
agree that managing along media lines
has its limitations, the alternatives are
infinitely more complex. Regulating
individual chemicals throughout all
media is a herculean task. The sheer
volume of chemicals, coupled with the
need to understand integrated
technologies to cope not only with
individual chemicals, but other
constituents as well, makes this approach
close to impossible. While certain visible
and large-volume constituents, such as
lead and PCBs, are appropriately
regulated in this fashion, regulation of a
large number of constituents is not very
appealing.
Regulating industrial facilities on the
basis of total residuals to air, water, and
land is somewhat more appealing. This
approach could conceivably work,
although the government would need to
understand industrial processes to a
much greater extent than it does at
present. Moreover, not only do different
laws have different compliance dates and
standards, but these periodically change,
making it difficult to keep comprehensive
permits up to date. Comprehensive
regulation of sources would require
substantial rewriting of environmental
law and much more technical
information than currently exists.
Finally, geographical regulation has
great intellectual appeal. States or
subparts of states could develop
comprehensive environmental plans,
targeting resources on the highest
priorities and dealing with intermedia
conflicts. Such geographic approaches
have been demonstrated in some cities,
regions, states, estuarine systems, and the
Great Lakes.
While geographic approaches are
attractive, the data and analytical costs
are high. For example, over $25 million
per year is spent on geographic programs
for the Great Lakes, and $13 million per
year is spent for similar purposes on the
Chesapeake Bay. A substantial amount
of funds has also been devoted to studies
of regional environmental problems in
Philadelphia, Baltimore, Santa Clara,
Kanawha Valley, and Denver, and to
integrated state environmental programs
in five states.
Although important, most of these
initiatives either are not currently playing
much of a role or they deal only with
residual problems, such as nonpoint
sources or contaminated sediments.
They do not drive regulatory schedules
and generally do not drive the level of
compliance required. At most, they are
supplements to the media-driven
programs.
In short, a truly integrated approach to
environmental management appears to
be many decades and billions of dollars
away. There is little real political will to
pursue such an approach. The technical
and management challenges are
overwhelming in the near term, and
there has not been an adequate
commitment of either funds or people to
lay the groundwork for transition toward
such an integrated system.D
s.
1
S
_c
14
EPA JOURNAL
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Progress And Challenges;
Looking At EPA Today
The following section is an account
of where EPA stands 20 years after
the Agency was established and
where it is headed in the protection
of the environment. This account,
excerpted from new reports by the
Agency, describes successes,
acknowledges failures, summarizes
the dollar costs and benefits of its
programs, and lays out new
directions that EPA is charting to
improve the results of its programs
in the future.
Readers seeking more detailed
information may wish to consult
Meeting the Environmental
Challenge: EPA's Review of
Progress and New Directions
in Environmental Protection
and Environmental
Investments: The Cost of a
Clean Environment.
15
-------
AIR
The "Conventional'
Pollutants
Ozone and Carbon Monoxide
ParUculate Matter
During the past two decades,
atmospheric levels of sulfur
dioxide (SOJ, carbon monoxide,
total suspended particulates, and
lead have all been reduced, in
some cases sharply. Between
1970 and 1988, estimated emis-
sions of SO2 dropped 27 percent,
particulate matter emissions
were down 63 percent, and lead
emissions dropped a dramatic 90
percent. Emissions of nitrogen
oxides (NO*) increased slightly
(7 percent) since 1970, but all
areas of the United States except
Los Angeles have met the
nitrogen dioxide air-quality stan-
dard during the past 10 years.
Ozone Air Quality
Average concentration PPM
20
.15
NAAQS
QE
79 80 81 82 83 84 85 86 87
VOC Emissions
30
Millions metric tons/year
20
1C
Transportation
Industrial processes
These successes notwithstanding,
the challenges ahead remain
formidable. The problem of
ground-level ozone, or "smog,"
has proven particularly difficult.
Atmospheric levels of ozone
have gone up 2 percent in the
last 10 years, although this is due
in part to extremely warm
temperatures during the summer
of 1988. Ozone standards are
still not being met in 96 major
urban areas. Carbon-monoxide
standards are also being violated
in 41 metropolitan areas. Even
in rural, hilly regions, emissions
from woodstoves may create
carbon-monoxide problems.
Although controls on cars, gas
stations, and most other sources
have reduced emissions of
carbon monoxide and ozone-
producing chemicals, these
reductions are being offset by
rapid growth in the number of
sources. In particular, the
CO Air Quality
Average concentration PPM
10
-NAAQS-
79 80 81 82 83 84 85
CO Emissions
87 88
Millions metric tons/year
80
SO
Transportation
1 82 83 84 85 86 87 88
increase in cars and in miles
traveled points to worsening
problems unless the nation un-
dertakes additional measures to
prevent them.
Amendments to the Clean Air
Act will strengthen federal and
state ozone/carbon monoxide
programs in the 1990s. EPA
expects to design and implement
these programs in cooperation
with the states. The Agency will
do a better job of collecting and
evaluating data on emissions and
atmospheric concentrations of
these pollutants. It will set
realistic timetables for areas to
attain the standards, spell out the
consequences for failure to attain
them, and impose appropriate
sanctions to bring nonattainment
areas into compliance. EPA will
need to broaden the scope of
ozone and carbon-monoxide
regulation to cover all sources,
including commercial and
consumer products and motor
fuels.
One important feature of the
new program will assist in
bringing clean-burning
alternative fuels and clean-fueled
vehicles into the marketplace,
thereby reconciling the
automobile and the environment
over the long term. The Agency
expects that a majority of
American cities will attain the
national standards by 2000.
Legend
CO = Carbon monoxide
VOC = Volatile Organc Compounds
TSP = Tolal Suspended Particulates
SO, - Sulfur dioxkJe
NO, - Nitrogen dioxkte
PPM = Parts per milton
NAAOS = National Ambient Air Quality Standards
Ugm3 = Micrograms per cubic meter
There has been considerable
progress in reducing emissions
of the larger particles that are
found, for example, in dust,
smoke, and diesel exhaust.
However, smaller particles still
require more rigorous controls.
In July 1987, EPA revised its
standards to monitor only those
particles called "PM-10." These
pose a risk to health because
they are small enough to pene-
trate the most sensitive regions
of the respiratory tract.
Approximately 30 million peo-
ple live in areas where PM-10
levels exceed the standards. In
addition to controlling industrial
sources of these smaller particles,
EPA is focusing on
unconventional sources such as
woodstoves, urban dust, and the
open burning that is performed
for managing forests and for
agricultural purposes.
TSP Air Quality
Average concentration )ig/m3
-NAAQS-
20
79 80 81 82 83 84 85 86 87
TSP Emissions
16
79 80 81 82 83 84 85 86 87 88
EPA JOURNAL
-------
Sulfur Dioxide, Nitrogen Oxides,
and Acid Deposition
The Clean Air Act amendments
require most areas of the country
to attain the PM-10 standards by
1994. EPA intends to raise
public awareness of the problem
and ways to control it, develop
more accurate data on emissions
and atmospheric concentrations,
and oversee the development of
new state plans for meeting the
standards.
Although controls have brought
most areas of the country into
attainment with the health
standards for SO2 and NOX, they
have not been adequate to check
acid deposition, or "acid rain."
Acid deposition is a regional
problem that affects the health of
animals, plants, and people and
also reduces visibility and
corrodes buildings. SO2 and
NO, emissions that do not pose
health or welfare problems near
their sources can nevertheless
travel long distances in the atmo-
sphere and return as acid
deposition. Two-thirds of SO2
emissions in the United States
come from the burning of fossil
fuels by electric power plants;
about 20 percent come from
other industrial sources. The
primary sources of NOX emis-
sions are highway vehicles (31
percent) and electric power
plants (36 percent).
The new Clean Air Act contains
provisions for large reductions in
emissions of SO2 and NOX to
combat acid rain. The national
goal for the year 2000 is to
reduce SO2 emissions nationwide
by 10 million tons below 1980
levels—a 40-percent decrease.
NO, emissions will be reduced
by 2 million tons below levels
that would occur in 2000 without
new controls—approximately a
10-percent decrease from 1980
levels.
The Agency will achieve these
targets by instituting a variety of
reforms aimed at limiting
emissions after 1995, principally
from electric power plants.
Sources will be permitted to
"trade and bank" their allowed
emissions, thereby achieving
regional and national emission
targets in the most cost-effective
way—a market-based approach to
air pollution regulation.
Add Rain
"Acid rain" refers to all acid deposition which
occurs in the form of rain, snow, fog, dust, or gas.
Manmade emissions of SO2 and NO,, are transformed
into acids in the atmosphere, where they may travel
hundreds of miles before falling as acid rain. Acid
rain has been measured with a pH of less than
2.0-more acidic than lemon juice. The political
implications of the problem are important because
the pollutants may originate in one jurisdiction but
affect another.
EPA research has increased scientific understanding
of the effects of acid rain, including the
sterilization of lakes and streams, reproductive
effects on fish and amphibians, possible forest
dieback, and deterioration of manmade structures.
These effects have been most obvious in the eastern
United States and Canada and in western and eastern
Europe. The Clean Air Act of 1970 helped curb the
growth of SO2 and NOX emissions in the United States,
and the 1990 amendments will bring significant
additional reductions.
SO2 Air Quality
Average concentration PPM
030
-NAAQS-
020
.010
NO2 Air Quality
.06
Average concentration PPM
-NAAQS-
02
79 80 81 82 83 84 85 86 87 88
SOx Emissions
79 80 81 82 83 84 85 86 87
NOx Emissions _
Millions metric tons/year
20
SEPTEMBER/OCTOBER 1990
87 88 79 80 81 82 83 84 85 86 87 88
79 80 81 82 83 84
-------
AIR
Air Toxics
Radon
The dramatic drop in
atmospheric lead levels over the
past decade is mainly the result
of EPA-mandated use of
unleaded gasoline, required to
maintain the effectiveness of
catalytic converters, and
reductions in the amount of lead
permitted in leaded gasoline. In
the early 1970s, over 200 billion
grams of lead were used in
gasoline each year; in 1989 less
than one billion grams were
used.
Lead emissions from stationary
sources also have been
substantially reduced with the
implementation of state plans to
attain the particulate-matter and
lead air-quality standards.
Current lead standards are being
attained in all areas except in the
vicinity of a few "point sources."
In the 1990s, EPA's objective will
be to bring these sources—princi-
pally smelters—into attainment
through a combination of
accelerated enforcement,
additional monitoring, and revi-
sions to state plans.
Lead Air Quality
Average concentration (
-NAAQS-
The problem of toxic chemicals
in the air requires more attention
by everyone. "Air toxics" is the
term generally used to describe
cancer-causing chemicals,
radioactive materials, and other
substances not covered by the
National Ambient Air Quality
Standards for conventional
pollutants. Air toxics result from
many activities in modern
society, from driving a car to
burning fossil fuel to producing
and using industrial chemicals or
radioactive materials. They are
one of the highest health-risk
problems with which EPA is
wrestling. Motor vehicles are by
far the largest contributor to
cancer incidence caused by air
toxics in the United States.
The Clean Air Act requires spe-
cial controls for pollutants that
cause serious or irreversible
health effects. These National
Emissions Standards for Haz-
ardous Air Pollutants are called
NESHAPS. To date, EPA has es-
tablished standards for only
seven substances: arsenic,
asbestos, benzene, beryllium,
mercury, vinyl chloride, and
radionuclides. A new approach
in the Clean Air Act
amendments means many more
will be regulated.
Lead Emissions
Thousands metric tons/year
•100
SO
Transportation
79 80 81 82 83 84 85 86 87
Over the past six years, the
Agency has also carried out a
program to help the states
monitor and control high-risk
local "point" sources and address
multi-pollutant and multi-source
urban toxics problems. The
standards set by the Agency for
exhaust and evaporative
emissions continue to reduce air
toxics from motor vehicles.
EPA's Toxics Release Inven-
tory, a listing of annual toxic
chemical releases to the air and
other environmental media from
large manufacturing facilities,
has helped prompt actions by
industries and communities to
address the problem. In 1990,
nine major U.S. companies
reached an agreement with EPA
to voluntarily reduce toxic air
emissions at 40 chemical plants
in 14 states. When fully imple-
mented in 1993, the agreement
will result in overall annual
emissions reductions from these
plants of almost 83 percent, or
9,460,000 pounds.
In the 1990s, EPA will attempt
to reduce by 50 percent the
nationwide emissions of 189
toxic pollutants listed in the pro-
posed Clean Air Act
amendments. The new Act will
remove legal roadblocks that
have hampered efforts in the
past, particularly with respect to
industrial plants. Sources of the
regulated pollutants will be
required to achieve emission
reductions comparable to similar
facilities that have the best
controls. If the control technolo-
gies prove inadequate, EPA will
take further regulatory action.
States will be given more
responsibility to regulate air
toxics, and their capabilities will
be strengthened.
Exposure to indoor radon is one
of the most serious envi-
ronmental health problems
facing the American public--
second only to smoking as a
cause of lung cancer. Radon is a
radioactive, colorless, odorless,
naturally occurring gas that
seeps through the soil and
collects in homes. Radon
problems have been identified in
every state, and millions of
homes throughout the country
have elevated radon levels.
In 1988, EPA and the Surgeon
General recommended that all
Americans, other than those
living above the second floor in
apartment buildings, test their
homes for radon. The testing is
simple and inexpensive; homes
with high radon levels can be
fixed.
EPA has a number of activities
under way in cooperation with
such national organizations as
the American Medical
Association and the American
Lung Association to motivate the
public to reduce radon levels in
their homes and schools. In the
1990s, EPA will continue to
improve the techniques for radon
testing, mitigation, and preven-
tion, with special emphasis on
schools and workplaces. The
Agency will ensure the reliability
of the radon-assistance industry
and will promote the
incorporation of radon preven-
tion in building codes and radon
inspections at the time houses
are financed.
79 80 81 82 83 84 85 86 87 88
EPA JOURNAL
-------
Indoor Air
Global Atmosphere
Growing scientific evidence
indicates that the air within
buildings, even in the largest and
most industrialized cities, can be
more seriously polluted than the
air outdoors. Many indoor air
pollutants are thought to have an
adverse effect on health. These
include radon, asbestos, tobacco
smoke, formaldehyde, pesticides,
perchloroethylene (associated
particularly with dry cleaning),
paradichlorbenzene (mothballs
and air fresheners), and a broad
array of airborne pathogens.
EPA is taking the lead in coor-
dinating activities to reduce
public exposure to indoor air
pollution. The Agency has
prepared information materials
designed to raise public aware-
ness of the problem and the
strategies available to reduce and
prevent it. These include specific
guidance on construction of new
homes and rehabilitation of
existing ones.
EPA will continue to identify
the health risks from exposure to
indoor air pollutants. Further
research is needed on diag-
nosing building-related illnesses
and correcting their causes.
Air pollution in the home
Kerosene Heater Fresh Dry Cleaning
Carpeting
\ *- Foam Padding-"
T-A Tlr"! Disinfectants
mill—11 I Pesticides
Cleaners
Solvents
Aerosols
Glues
Asbestos
Insulation
Carbon Monoxide
In addition to acid rain, two
other international air-pollution
problems rose to prominence in
the 1980s: stratospheric ozone
depletion and global warming
(the so-called "greenhouse ef-
fect"). Since the early 1970s,
scientists have predicted that
emissions of such chemicals as
chlorofluorocarbons (CFCs)
would ultimately deplete the
stratospheric ozone shielding
Earth's inhabitants from the
sun's harmful ultraviolet rays.
Some studies indicate that these
predictions may be coming true.
In 1978 EPA banned the use in
this country of CFCs in non-
essential aerosol propellants. On
signing the Montreal Protocol in
1987, the United States com-
mitted to reducing other uses of
CFCs 20 percent by mid-1994
and 50 percent by mid-1999. In
response to evidence of
accelerated rates of damage to
the ozone layer, the Protocol was
amended in June of this year to
call for a full phaseout of CFCs
and most other ozone-depleting
chemicals by 2000. The Protocol
also suggests a schedule for
phasing out CFC substitutes that
pose a threat, even though to a
lesser degree. A fund has been
established to help developing
countries make the transition
away from ozone-depleting
chemicals.
Scientific complexity and
uncertainty surround the
problem of global warming. As
a result, much of the federal
government's effort is going into
research. In the Fiscal Year 1991
budget, the President proposes
$1.034 billion for the U.S. Global
Change Research Program, a 57-
percent increase over 1990.
Under this program, EPA is
evaluating the sources of
greenhouse gases and is defining
the potential consequences of
climate change on the Earth's
ecosystems. As the President
noted in a 1990 article on climate
change: "One cannot fail to see
that deforestation, ozone
depletion, ocean pollution, and
the threat of global warming
interconnect to challenge our
future."
In conjunction with other
federal agencies, EPA partici-
pates in the Intergovernmental
Panel on Climate Change (IPCC),
an international body organized
in 1988 by the United Nations
Environment Programme and the
World Meteorological
Organization. This year, the
IPCC is preparing assessments of
current scientific understanding
and the environmental and social
impacts of climate change, and
possible policy responses to it.
Negotiations on a climate
convention will be undertaken
on the basis of these assessments.
SEPTEMBER/OCTOBER 1990
19
-------
WATER
Drinking Water
Rivers, Lakes,
and Streams
America's water-quality record is
a mix of remarkable im-
provements and hard-to-fix
problems that all levels of
government are struggling with.
Controls on point sources of
pollution such as wastewater-
treatment and industrial plants
have been quite effective, but
widespread small sources are
mostly unchecked. Toxic
chemicals are a continuing
problem. Pollution-sensitive fish
have returned to some lakes and
rivers, but aquatic habitats are
becoming degraded in many
coastal waters. At the same
time, population pressures are
increasing the sources of
pollution and leading to
increased demand for clean
water.
EPA's program for the 1990s:
maintain and enforce existing
controls, put extra work into
protecting high-value waters that
are threatened, control toxic
pollutants, assist state and local
governments in reducing
pollutants in run-off ("nonpoint
sources"), focus more heavily on
preventing further degradation
as well as restoring currently
polluted waters, and improve the
ways in which the Agency
assesses the quality of the
nation's waters.
More Americans are drinking
safe water than ever before.
Diseases such as cholera and
typhoid that stem from con-
taminated water have been
eliminated in the United States.
But toxic chemicals and micro-
biological contaminants continue
to threaten both surface and
ground-water sources of
drinking water.
In 1974, the Safe Drinking
Water Act (SDWA) authorized
EPA to limit the amounts of
various substances in drinking
water. In 1986, amendments to
the SDWA accelerated EPA's
regulation of toxic contaminants,
banned all future use of lead
pipe and lead solder in public
systems, mandated greater
protection of ground-water
sources, and streamlined
procedures to ensure that public
suppliers comply with the Act.
The SDWA also established
Community water systems are
performing better with more
supervision
provisions to protect ground-
water supplies from under-
ground injection of wastes.
These controls regulate the
permitting, construction,
operation, monitoring, and
closure of injection wells.
EPA is striving to make further
improvements in the nation's
drinking water. Through the
states, it monitors the operation
of all public water systems, and
it continues to evaluate new
treatment technologies. By 1995,
the Agency will set new
standards for 108 contaminants
and will work with the states to
vigorously enforce them. It will
complete initial monitoring and
regulations for lead and for
radionuclides, including radon.
It will work to improve filtration
of microbial contaminants.
These new requirements, while
ensuring good-quality drinking
water, can be tremendously
expensive, particularly for small
communities. To alleviate the
financial burden, EPA is
exploring new and more
affordable technologies and
helping states certify and train
small plant operators. The
Agency also is encouraging
management efficiencies:
Communities can, for example,
reduce monitoring and treatment
costs through aggressive
wellhead-protection programs
that prevent contamination.
EPA estimates that the costs for
making the necessary
improvements to public water
systems will be $1 to $2 billion
per year. States will need an
additional $200 million in one-
time expenditures to develop
and install new programs; they
will need $131 million annually
to enforce the new regulations.
For the past 20 years, EPA has
been working with all levels of
government, with industry, and
with environmentally committed
citizens to make America's
waters fishable and swimmable.
Most water-pollution controls in
the 1970s were aimed at limiting
discharges of the most common
pollutants from industries and
sewage-treatment plants. These
efforts brought impressive
results. For example, in 1972, 36
percent of the rivers assessed by
the states supported beneficial
uses such as fishing and swim-
ming; by 1988, that figure had
increased to 70 percent. Between
1977 and 1988, the number of
people served by adequate
sewage-treatment plants
("secondary" treatment or better)
increased 84 percent—from 75
million to 138 million.
However, many cities and
towns still have not achieved
secondary treatment of sewage,
defined as 85-percent removal of
such conventional pollutants as
Sewage treatment has improved..
1970 1974 1980 1990
Population in millions served bv
secondary waste water
treatment or better
| SI
I!!
50
1972
1984
1988
20
EPA JOURNAL
-------
Ground Water
Most rivers and lakes assessed by the states
support fishing and swimming
River miles Lake acres
Not supporting 53.449 Not supporting 1,591,391
Partially supporting 104,632 | Partially.supporting 2,70^577
oxygen-demanding materials and
suspended solids. And "new"
pollutants, in the form of minute
amounts of toxic chemicals, are
showing up that are much
harder to identify and control.
Since public sewage systems
were not designed to handle
chemical wastes from industries,
Congress amended the Clean
Water Act in 1987 to require
certain industries to pretreat
their wastes before discharging
them. These pretreatment
but agriculture and other nonpoint
sources need more attention
% impaired stream miles
affected by each pollution source
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requirements have been the
subject of concentrated EPA
enforcement activity in recent
years.
Funding for wastewater-
treatment facilities has already
begun to shift to the states. In
1988, EPA estimated that an
additional $88 billion was
needed for these facilities. Since
federal funding at that level was
not realistic, Congress authorized
seed money for states to
establish revolving loan
programs intended to replace
federally financed construction
grants. Nearly all states have
now established these new
funding programs, and EPA is
helping them find other
mechanisms, such as fees-for-
service, to pay for expansion of
state and local programs.
Nonpoint-source pollution,
which appears to be responsible
for most of the remaining
damage to rivers, streams, and
lakes, also needs much more
attention. Toxics and other
pollutants often come from many
small, widely dispersed sources
that are very difficult to regulate.
Urban run-off and drainage of
pesticides, fertilizers, and animal
wastes from farmland are typical
of the problem. EPA recently
awarded $40 million in grants to
states to help them bring
nonpoint sources under control.
EPA is relying even more
strongly on state and local
governments to achieve the goals
set for surface-water quality.
The Agency will focus on
eliminating risks from point
sources of highly toxic pollut-
ants; reducing risks from other
toxic pollutants; controlling
stormwater discharges, including
combined sewer overflows; and
providing leadership and
assistance to states in controlling
nonpoint sources—particularly
agricultural. Further, EPA is
seeking solutions to other high-
priority concerns related
especially to the nation's lakes,
including eutrophication
(excessive plant growth),
contaminated sediments,
shoreline modifications, and
pollution reaching lakes from the
air and from ground water.
Pollution prevention is a new
focus for all water programs—the
elimination of pollutants at their
sources so as to avoid the more
costly treatment of pollution
after it has occurred.
By 1988, normal agricultural usage
of pesticides had contaminated
ground water in most states
Ground-water protection is an
exceptionally complex issue,
cutting across economic sectors,
all levels of government, and
most environmental statutes.
Ground water is the source of
drinking water for over half the
population; it also supports
ecosystems and serves as a water
supply for industry and
agriculture. Once contaminated,
it can be difficult and
expensive to clean up.
In addition to the special
measures taken with sources
used for drinking, EPA protects
ground water by implementing
pollution-prevention efforts;
controlling the use of pesticides;
controlling hazardous-waste
facilities, municipal landfills,
surface impoundments, and
underground storage tanks; and
cleaning up releases of
hazardous substances.
Since 1985, EPA has provided
over $40 million to help the
states develop their own ground-
water protection strategies and
wellhead protection programs.
By mid-1990, the Agency had
approved six state wellhead-
protection programs and was
working with 24 others on theirs
n
Number of pesticides detected
] No data l -7 ^8-20
21 +
SEPTEMBER/OCTOBER 1990
21
-------
WATER"
Wetlands distribution nationwide
Oceans, Coastal Waters, and
Wetlands
Oceans, near-coastal waters,
estuaries, and wetlands have
been underprotected in the past.
Their deterioration was
highlighted in the summers of
1988 and 1989 when swimmers
fled beaches littered with medi-
cal waste and contaminated with
fecal bacteria. One-third of the
nation's shellfish beds are closed
primarily because of pollution,
resulting in millions of dollars in
lost revenues. Twenty-five
percent of estuarine waters that
have been tested have elevated
levels of toxic substances, and
eutrophication is increasing the
number of "dead zones" where
fish cannot survive. Coastal
fisheries and wildlife and
waterfowl populations have
declined, while population and
industrial growth along the
coasts have increased
dramatically—more than 120
million Americans now live
within 50 miles of the shore.
EPA has continued the
restoration program for the Great
Lakes and has launched
programs in the Chesapeake Bay
and 17 estuaries that the Agency
has designated as part of a
National Estuary Program.
Further, EPA is working toward
a ban on dumping sewage
sludge and industrial waste in
the oceans.
In 1989, EPA set a goal of "no
net loss" of wetlands in the short
term, aiming for a gain in the
quantity and quality of wetlands
in the long term. Wetlands
include coastal marshes, inland
swamps, marshes, tundra, and
bogs. They provide habitat for a
wide variety of wildlife and
serve vital flood and erosion-
control functions. More than
half of the wetlands originally in
the contiguous United States
have been lost since the time of
European settlement. In the two
decades between 1955 and 1975,
over 11 million acres were lost;
others have been degraded by
pollution and hydrological
changes so that they no longer
perform many of their natural
functions.
Currently, EPA and the Army
Corps of Engineers are working
to improve a jointly administered
program that regulates the
physical modification of
wetlands and other waters. EPA
also is providing guidance and
support to state and local
governments on wetlands
protection and is working with
other federal agencies whose
activities affect wetlands.
To achieve no net loss of
wetlands, the Agency is stepping
up enforcement against activities
that degrade them. EPA is
becoming a center of wetlands
expertise, providing more
research, training, and
communication on wetlands
management. The Agency is
helping states build compre-
hensive programs, including
setting water-quality standards
for wetlands and preparing
conservation plans which
incorporate both regulatory and
non-regulatory approaches. EPA
and other federal agencies are
developing better ways to
monitor the health of wetlands.
In the 1990s, EPA intends to
work with state and local
governments to substantially
increase the acres of shellfish
beds open to harvest, reduce
fishery bans and advisories due
to contamination, decrease beach
closures, and eliminate dumping
of sewage sludge and industrial
wastes in the oceans.
The Agency wants to encourage
state and local governments in
managing coastal development in
an environmentally sound
manner. Further, the Agency
will strengthen nonpoint source-
programs in all coastal counties
and tighten controls on point-
source discharges of toxics,
nutrients, and other pollutants to
restore coastal water quality.
Raw-sewage flows from com-
bined sanitary-storm sewers—a
problem especially severe in
Top 10 pollutants in estuaries Sources of pollution in estuaries
30
20-
10
% impaired sq. miles affected
by each pollutant
50-1
% impaired sq. miles affected
by each pollution source
40
y s
x <
O C3
.'o-
Q =»
< s i
(-: P ^
ii
(/i 3 Q_ O_
1 • 500.000
500K-1.000.000
1.000K - 5.000.000
ovei 5.000.000
many older seaboard cities-
needs to be curtailed. Storm-
water discharge permits will be
required for large cities in all
coastal counties; smaller
municipalities will also need
help with storm-water problems.
Operators of all types of offshore
activities, such as oil and gas
operations, will be asked to help
protect marine waters and
surrounding ecosystems from
degradation. The federal
government is taking en-
forcement actions to eliminate
any illegal ocean disposal. EPA
is working with other federal
agencies and states to improve
coastal water monitoring and to
increase the number of
estuarine/marine sanctuaries,
protected refuges, reserves, and
parks.
To help monitor and control
sources of marine debris, the
Agency is supporting citizen
beach patrols. It is working in
partnership with states and
municipalities to implement
plans for protecting estuaries and
other coastal waters around the
country, and EPA is promoting
grass-roots/governmental alli-
ances to improve public
education about coastal
problems.
The Agency is helping develop
the knowledge, technology, and
controls to protect coastal waters
from pollutants transported
through the air. EPA and other
federal agencies are working
with the international
community to assess the health
of the oceans and develop an
integrated approach to
preventing further ocean
degradation.
22
EPA JOURNAL
-------
LAND
Waste Disposal
Air and water pollution are
easier for most people to
conceptualize than land pollu-
tion. Yet, some U.S. lands are
also threatened by toxic,
radioactive, and other hazardous
substances. Pollutants on the
surface of the land or in the soil
frequently migrate to
surrounding air and water,
particularly ground water.
Sometimes this contamination
results from direct applications
of chemicals, as with pesticides;
it can also occur as a result of
improper storage or disposal of
toxic wastes and other
substances.
EPA and the states have
undertaken a sweeping program
to revolutionize waste
management in this country—
especially hazardous wastes.
Before 1980, there was virtually
no regulation of hazardous waste
by the federal government and
little by the states. People in the
hazardous-waste management
business often disposed of waste
in municipal landfills and un-
lined lagoons or simply dumped
it on the ground.
Better understanding of the
environmental impact of such
practices led to the enactment of
the Resource Conservation and
Recovery Act (RCRA) in 1976
and an increasingly complex,
comprehensive regulatory pro-
gram during the 1980s. This
"cradle to grave" program
regulates hazardous wastes from
over 200,000 generators through
transportation, storage, and
treatment to final disposal.
Improperly managed hazard-
ous and municipal waste may
contaminate drinking water
supplies, release toxic vapors
into the air, or cause explosions.
To ensure that hazardous wastes
being generated today do not
become expensive and complex
clean-up problems in the future,
EPA enforces the land disposal
restrictions program. Many
wastes that have not been treated
to specified standards are now
banned from land disposal, and
many more will be banned over
the next several years. The treat-
ment standards are designed to
reduce the toxicity of the waste
and stabilize it before it is
disposed of on land.
EPA has also developed other
environmentally protective
requirements for land-disposal
facilities, such as double liners to
prevent contaminants from leak-
ing into ground water, leachate-
detection and collection systems,
and ground-water monitoring.
Facilities are regulated
throughout their operating life
and 30 years after they are
closed.
Hazardous waste handlers
must now clean up contamina-
tion resulting from past waste
management practices as well as
from current activities. Over the
next decade, EPA will evaluate
which facilities need cleanup and
make sure that the worst sites
"Cradle to Grave": The Hazardous Waste Manifest Trail
Storage Facility\mm
UNIFORM
HAZARDOUS WASTE
MANIFEST
Disposal Facility
Paper and yard wastes
are more than half of our trash
Generator
EPA or State Agency
A one-page manifest must accompany every waste shipment. The
resulting paper trail documents the wastes progress through
treatment, storage and disposal. A missing form alerts the generator
to investigate, which may mean calling in the state agency or EPA.
Note: a manifest is unnecessary for waste treated and disposed of at the point
of generation.
SEPTEMBER/OCTOBER 1990
23
-------
LAND
Cleaning Up Abandoned
Hazardous Waste Sites
get cleaned up first. The Agency
will also explore ways to create
economic incentives that
encourage ingenuity in practicing
waste minimization and
recycling.
Municipal solid waste is
another growing national
problem. Americans produce
more than 180 million tons of
trash each year. EPA has set a
1992 goal for reducing by 25
percent the amount of municipal
solid waste, through source
reduction and recycling.
Pollution prevention is increas-
ingly seen as the centerpiece of a
progressive national waste-
management strategy. EPA will
encourage industry, the general
public, and all levels of govern-
ment to reduce both the quantity
and the toxicity of waste that
they generate.
One of EPA's most important
responsibilities is managing
cleanup of the worst of the
abandoned hazardous waste sites
in the United States. The
Superfund program was founded
under the authority of the
Comprehensive Environmental
Response, Compensation, and
Liability Act of 1980 (CERCLA)
and amended in 1986 by the
Superfund Amendments and Re-
authorization Act (SARA). These
laws authorize EPA to respond
to hazardous spills and clean up
abandoned sites by either filing
suit against the responsible
parties, issuing these parties an
order, or using the trust fund
known as Superfund. If EPA
must conduct the cleanup
because the responsible parties
will not do it voluntarily, the
government can take court action
to recover the costs.
To date, 32,506 potentially haz-
ardous waste sites have been
identified across the nation.
Over 90 percent have been
reviewed. More than 17,800 sites
have been determined to require
no further federal action;
however, the states will have to
clean up many of these. The
number of sites listed or
proposed for listing on the
National Priorities List (NPL),
which identifies the nation's
most hazardous waste sites,
comes to 1,207.
Cleanup, now completed at 52
NPL sites, has begun at 500 more
sites. Short-term emergency
actions were taken at 400
NPL sites to remove or control
immediate threats to human
health and the environment
Work has begun
at most priority sites
Clean-up work completed 52
Cleanup underway
251
mmediate
threat evaluated.
ion not begun 203
Remedy
selected or unde
design 201
Detailed studies of contamination
and remedies underway 539
while long-term cleanups got
under way. Emergency actions
also have been taken at another
1,300 sites not serious enough to
be on the NPL but posing threats
that needed to be addressed
quickly.
As part of SARA, Congress di-
rected EPA to focus on perma-
nent remedies for Superfund
sites rather than simply
containing untreated wastes on
site. Treatment of wastes is now
a major component of the reme-
dies selected for many sites.
Tremendous efforts are un-
derway to develop the
EPA is involving more responsible
parties in clean-up actions
technologies for permanent
clean-up remedies. Under the
Superfund Innovative Technol-
ogy Evaluation Program, EPA is
evaluating new technologies to
destroy, immobilize, or reduce
the volume of hazardous waste.
EPA also is committed to
increasing innovative
technologies to apply to con-
taminated soils and ground
water.
The number of abandoned haz-
ardous waste sites has turned
out to be much larger than was
predicted when Superfund was
created. Furthermore, cleanup
has turned out to be complex,
taking more time and resources
than expected to complete the
job.
After a recent review of the
Superfund program, EPA is
implementing a strategy for
better managing cleanups in the
1990s. The strategy calls first for
eliminating acute health threats.
This has been accomplished at all
current NPL sites. Long-term,
more permanent cleanups then
are conducted on a priority
basis—the worst problems at the
worst sites first. EPA is also
accelerating the clean-up process
and expanding the development
and use of new technologies at
sites. So that more cleanups can
be conducted, EPA is placing
greater emphasis on cleanup by
those responsible for the waste.
Finally, EPA is expanding the
role of communities near the
sites in clean-up decisions.
24
EPA JOURNAL
-------
Underground Storage Tanks
Over two million underground
tanks across the country store
petroleum and other chemicals
beneath gas stations and other
operations. Chemicals escaping
from these tanks can contaminate
drinking-water supplies; fumes
can cause health and safety
hazards. EPA is working with
the states to develop programs
for cleaning up contamination
from leaking tanks and pre-
venting future leaks.
Regulations developed by EPA
since 1984 now call for tank
registration, leak detection, and
leak prevention. Owners and
operators must meet a range of
requirements for the design,
construction, and installation of
their systems, including repair or
closure of systems that do not
meet the requirements.
EPA estimates that 20 percent
of the regulated tanks are leaking
or have the potential to leak. As
of 1990, 63,000 releases had
been confirmed, with one-third
of these releases brought under
control. If a leak occurs,
regulations require that it be
Radioactive Waste
cleaned up appropriately. In
addition, owners and operators
must demonstrate their
capability to pay for clean-up
costs or for damages resulting
from leaks. A $500-million
Leaking Underground Storage
Tank Trust Fund, established by
Congress in 1986, can also be
used by states for clean-up
actions under certain circum-
stances.
State and local governments
are in the best position to
regulate underground storage
tanks because of the high
variability of soil and ground
water in which the tanks are
buried and because there are so
many tank owners and
operators—750,000 nationwide.
In the future, states will become
completely responsible for
operating this program, although
EPA will still identify and
promote the most effective and
least costly clean-up tech-
nologies. EPA will also continue
to help states create innovative
funding mechanisms to pay for
cleanups.
Radioactive waste, generated by
both the commercial sector and
the U.S. federal government, is
usually classified as follows:
low-level waste from activities
such as research, diagnostic
and therapy medicine
manufacturing, electric power
generation, and defense
programs; spent fuel and high-
level radioactive waste from
nuclear reactors; transuranic
waste (man-made radioactive
atoms that are heavier than
uranium) from defense pro-
grams; and waste from mining
and milling of uranium and
thorium ores.
In 1985 EPA issued standards
for the management and
disposal of spent nuclear fuel,
and high-level and transuranic
wastes. However, litigation
forced the Agency to reconsid-
er the standards that applied to
release limits for permanent
disposal systems for these
wastes. EPA plans to re-
propose the standards in 1991
and promulgate them by 1992.
EPA also expects to promul-
gate standards in 1991 for
management and land disposal
of low-level radioactive waste.
The standards for commercial
sites will be implemented and
enforced by the Nuclear
Regulatory Commission. The
U.S. Department of Energy will
implement EPA standards for
federal government facilities.
In the 1990s, EPA will
support regulatory efforts by
providing better public infor-
mation and education to help
develop a balanced perception
of the risks associated with
radioactive wastes. By empha-
sizing technology transfer, the
Agency will also make avail-
able EPA expertise in risk
assessment and other skills
needed by states and the
private sector. EPA will
promote pollution prevention
by focusing on industrial
processes and waste-segrega-
tion efforts that could signif-
icantly reduce the volume of
contaminated waste.
Bioremediation: The Alaskan Oil Spill
In March 1989, the Exxon Valdez
ran aground on Bligh Reef in
Prince William Sound, flooding
one of the nation's most
pristine and sensitive
environments with approxi-
mately 11 million gallons of
crude oil. The spill, the largest
in U.S. history, spread over 700
to 800 miles of shoreline,
damaging the area's diverse
wildlife and directly affecting
the lives of many Alaskans.
A massive cleanup using
conventional techniques such
as booms, high- and low-pres-
sure spraying, skimmers, and
manual scrubbers was orga-
nized to remove oil from the
surface of rocks and beaches.
These techniques, however,
removed only a fraction of the
oilon beaches, under rocks, or
in beach sediments.
For years, EPA had been
studying the use of microor-
ganisms such as bacteria to
enhance the degradation of oil
and other chemicals. Until the
Exxon Valdez accident, howev-
er, no microbial processes had
been developed for removing
crude oil from contaminated
beaches.
In June 1989, EPA entered
into an agreement with Exxon
to test bioremediation for
treating beaches in Prince
William Sound. Nutrient-rich
fertilizers were applied to
selected test beaches, allowing
microorganisms to use the oil
as food and thus degrade it.
Initial findings from field and
laboratory tests during the
summer of 1989 indicated that
using nutrients to enhance
biodegradation is effective and
environmentally safe. All the
treated areas appeared steadily
cleaner through the end of the
summer season, and no ad-
verse ecological effects from
the nutrient application were
detected. EPA along with
Exxon, the Alaskan Department
of Environmental Conservation,
the Coast Guard, and the
National Oceanic and Atmo-
spheric Administration under-
took further studies in the
summer of 1990.
To date, the results are very
encouraging. Tests have
shown no toxicity associated
with fertilizer application. A
single application of fertilizer has
been shown to increase the rate of
oil biodegradation by two to three
times over the rate of an untreated
shoreline. This accelerated rate
is sustained for several weeks,
even after nutrient
concentrations return to
background levels.
SEPTEMBER/OCTOBER 1990
25
-------
CHEMICALS
Emergency Planning and
Community Rlght-to-Know
Toxic Chemicals
The Emergency Planning and
Community Right-to-Know Act
of 1986, commonly known as
Title III (of SARA), provides
communities with unprecedented
access to information about toxic
chemicals in their communities
and creates mechanisms for
minimizing the threats posed by
these chemicals. The law calls
for extensive data collection and
for the creation of State
Emergency Response
Commissions to guide state-by-
state planning for chemical
emergencies. The Commissions,
in turn, have created Local
Emergency Planning Committees
to ensure community partici-
pation and planning. This has
resulted in enormous public
pressure on industries to reduce
toxic releases and fostered better
planning to prevent and respond
to chemical emergencies.
One of the most visible features
of Title III has been the Toxics
Release Inventory (TRI), an
annual inventory of toxic releases
and transfers from over 20,000
manufacturing facilities
nationwide. The TRI contains
extensive data on more than 300
toxic chemicals, waste-
management practices, and
quantities of releases to the air,
water, and land. TRI is based on
the premise that the public has a
right to know about toxics that
may affect health or the
environment. TRI data are
available in many forms,
including printed reports and
computer access, at libraries or
through EPA's TRI reporting
center. A TRI National Report
summarizes the data annually
and provides detailed analyses of
the types of releases and their
sources. The information is a
lever for action, as citizens exact
pledges from local
manufacturing facilities to reduce
toxic discharges.
EPA expects the Toxics Release
Inventory to be an important
national tool for promoting
pollution prevention and for
documenting the success of
pollution-prevention efforts in
the 1990s. TRI continues to
evolve: Chemicals of little or no
toxic concern are removed from
the list, while others are added.
EPA is exploring improvements:
collecting information on "peak
releases" of toxics, expanding the
types of industries required to
report, and collecting data on
pollution prevention at the
reporting facilities.
The Toxic Substances Control
Act (TSCA) and the Federal
Insecticide, Fungicide, and
Rodenticide Act (FIFRA) have a
unique place in environmental
legislation. Most environmental
laws regulate wastes, emissions,
contaminants, or by-products,
but TSCA and FIFRA can
regulate how commercial
chemicals are used. EPA has
three main goals in dealing with
commercial chemicals: preventing
chemicals which pose an
unacceptable risk from entering
the market in the first place;
managing the use of chemicals
that are inherently risky, so
that society can continue to
reap their benefits; and remov-
ing chemicals from the market
when the Agency determines
that they pose an unacceptable
risk.
While nearly everyone has
"trace" levels of PCB's . . .
100%
95
90
-85
•7.5
5.0
,2.5
72
"Trace" PCB levels
. the percentage of
population with "high"
levels has gone down.
"High" PCB levels
JS
One of the main ways EPA
controls toxic chemical risks is by
preventing dangerous chemicals
from being used at all. Since
TSCA was enacted in 1976, EPA
has reviewed more than 15,300
new chemicals proposed for
commercial use. Most were
determined to pose no
unacceptable risk. How-
ever, several hundred were
targeted for regulatory action,
and hundreds more were with-
drawn by their manufacturers in
the face of anticipated action.
In 1984, EPA determined that
TSCA authority could be
extended to the oversight of
products developed through
biotechnology. EPA is now
preparing regulations to
implement the review of
genetically modified micro-
organisms.
TSCA also authorizes the
Agency to regulate chemicals
already in use that have proved
to pose an unacceptable risk to
human health or the
environment. EPA created one
of the first comprehensive
inventories of existing chemicals
in the world. To aid in the huge
task of assessing the 68,000
chemicals in the inventory, EPA
can require manufacturers or
processors to test chemicals if the
Agency determines they may
pose unacceptable risks and
available data are insufficient to
assess them.
Congress and EPA have deter-
mined that several chemicals
pose an unacceptable risk, and
the Agency has regulated them
under TSCA. In 1978, EPA
instituted regulatory controls
over the manufacture, use, and
disposal of polychlorinated
biphenyls (PCBs) and banned
aerosol uses of chloro-
fluorocarbons (CFCs). In 1989,
the Agency banned the man-
ufacture of most asbestos
products; EPA has provided
considerable grants and guidance
26
EPA JOURNAL
-------
U.S. Pesticide Usage
to protect children from exposure
to asbestos previously installed
in schools.
Under TSCA, EPA has
gathered information on
potential exposures, as well as
health and environmental data,
that many EPA programs and
other federal agencies have used
to better assess and reduce
chemical risks.
EPA has undertaken a special
effort to revitalize its review of
the safety of existing chemicals
in the 1990s. The strategy
includes linking chemical
screening more directly to risk
management. The Agency will
screen clusters, or like groups, of
chemicals together. Screening
activities will build on growing
international efforts in which
EPA is already a key player. To
maximize productivity, rules for
testing will be developed for
groups of chemicals wherever
possible.
The EPA pesticide program is
the only one that licenses the v
of chemicals, many of which ai
potentially hazardous to peopl
or the environment. Unlike mo
commercial chemicals, most
pesticides are designed to kill o
otherwise control specific
organisms. In doing so, they
offer a wide variety of
agricultural and other benefits
for society.
Before a new pesticide may be
marketed or used in the United
States, it must be "registered" by
EPA. In registering a new
pesticide, the Agency is
responsible for ensuring that the
chemical, when used according
to label instructions, will not
present unreasonable risks to
human health or the
environment. The nation's
pesticide law (FIFRA) requires
EPA to take into account
economic, social, and
environmental costs and benefits
in making registration decisions.
If data indicate that a pesticide's
risks may outweigh its benefits,
EPA can simply refuse to register
the product, or, it can lessen the
Levels of persistent pesticides have declined in fish and wildlife
Rsh
1 0 Total DDT parts per million
.8
:•
Mallards by flyway
Total DDT parts per million
84
* 65 66 67 68 69 70 71
H Total US CD Agricultural
73 7d 75 76
S3 84 95 86
risks by limiting the amount of
pesticide applied and/or limiting
frequency or location of
application; EPA can also restrict
the use of the pesticide to only
specially trained, certified
applicators.
Before a pesticide is registered
for use on a food or feed crop, a
"tolerance" or residue limit must
be set by EPA. Both domestically
produced and imported foods
are monitored to be sure that
they comply with the tolerances.
In addition to registering new
pesticides, EPA also is
undertaking the monumental
task of re-evaluating the safety of
older pesticides already on the
market.
EPA's pesticide program has a
noteworthy record of accom-
plishments. Over the past 20
years, the Agency banned DDT
(resulting in the dramatic return
of the bald eagle), canceled the
registrations of 34 other
potentially hazardous pesticides,
and eliminated the use of 60
toxic inert ingredients in
pesticide products. EPA disposed
of all stocks of the banned
pesticide EDB and is currently
disposing of dinoseb, banned in
1986.
The Agency trained and
certified 250,000 commercial
pesticide applicators and over
one million farmers. It estab-
lished the National Pesticide
Telecommunications Network,
providing a toll-free number for
obtaining information on the use
and disposal of pesticides, and
how to recognize and manage
pesticide poisonings (1-800-858-
PEST). In 1990, EPA completed a
nationwide survey of the extent
of pesticide contamination of
ground water and developed a
strategy to protect drinking-
water sources from becoming
contaminated. The Agency is
also implementing a program to
protect endangered species from
pesticides.
Although EPA is promoting the
use of fewer and safer pesticides,
the Agency is bound to discover
additional pesticides that pose
undue risks and require
regulatory control. The Agency
learned from its experience with
the EDB and Alar situations
during the 1980s that it needs to
act more quickly when new data
on old pesticides show evidence
of unreasonable risks. The pesti-
cide industry has become more
responsive when serious
questions arise about the safety
of existing pesticides.
In the cases of the EBDC
fungicides, aldicarb, and mercury
in paint, manufacturers took
voluntary action to halt problem
uses of these pesticides while
EPA's risk/benefit assessments
continued. Under the President's
leadership, EPA worked with
other federal agencies to propose
sweeping new food safety and
pesticide regulation reforms. The
proposed legislation includes
SEPTEMBER/OCTOBER 1990
27
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Facts to Reflect On"
by Ross Ettlin
EPA workforce in 1970: 5,500
EPA workforce in 1990: 17,170
EPA budget in Fiscal Year (FY) 1971: $1,289,000,000
EPA budget in FY 1990: $5,145,000,000
Percent of EPA's budget allocated to regional offices in 1981: 15
Percent allocated to regional offices in 1991: 43
Increase in the U.S. population from 1970 to 1990: 48 million
Present ratio of increase in cars to the increase in U.S. population: 2:1
Estimated percent increase in ambient carbon monoxide by
1990 if 1970 emissions controls had remained unchanged: 140
Number of ozone molecules one chlorine atom can destroy: 10,000
Global carbon-dioxide concentrations in 1970 (parts per million): 320
Global carbon-dioxide concentrations in 1986 (in ppm): 346
Lung cancer deaths each year EPA estimates are due to radon: 5,000-20,000
Major federal environmental statutes EPA administers: 11
Pages of EPA statutes (1989): 670
Total number of EPA regulations in 1989: 9,000
Money awarded EPA in civil and criminal penalties in 1989: $45,300,000
Times EPA officials testified before Congressional oversight committees in 1989: 168
Letters to EPA's Administrator and Deputy Administrator in 1989: 49,052
Freedom of Information requests submitted to EPA in 1989: 35,205
Number of times the Superdome in New Orleans could be filled
with the hazardous waste produced annually in the United States: 1,500
Superfund sites placed on the National Priorities List (NPL) by end of 1982: 418
Sites on the NPL by end of 1990:1,207
Superfund sites with clean-up work completed to date: 52
Emergency hazardous waste removals under the Superfund program: 1,700
Acres of wetlands lost annually in the United States: 350,000-500,000
Percentage of U.S. municipal landfills expected to reach capacity in 15 years: 70
Percentage of Americans who rely on ground water as drinking water: 50
Approved local pre-treatment drinking water programs as of 1983: 65
Approved pre-treatment drinking water programs as of 1990: 1,442
Estimated number of underground storage tanks leaking or potentially leaking
and contributing to ground-water contamination: 400,000
Average level of DDT found in humans in 1970 (in parts per million): 8.0
Average level of DDT found in humans in 1983 (in ppm): 2.0
*With all due appreciation for the example of "Harper's Index"
(Ettlin is an editorial assistant with EPA Journal.)
SEPTEMBER/OCTOBER 1990 29
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Win/Win on the
Environmental Front
by Frederic Krupp
Twenty years ago, power plants sent
acrid smoke into our skies. Pesticides
poisoned people, water, and wildlife.
Forests were felled without a fleeting
thought about the future. And through it
all, most politicians and the public slept
soundly in the soft comfort of the status
quo.
Fortunately, since 1970, more and more
people are waking up to the increasingly
persistent signals of an environmental
alarm clock trying to warn us that if we
do not get up soon, it will be too late.
And although there are politicians and
corporate leaders that continue to hit the
environmental snooze button, the
growing consensus on the need for
sweeping environmental action will soon
rouse them from their slumber.
There can be no doubt that there is a
growing consensus among the public that
the environment must be considered in
every decision. A recent Media
General-Associated Press survey found
that four out of five Americans believe
pollution threatens the quality of their
lives, that 75 percent believe current
anti-pollution laws are too weak, and
that Americans favor the prohibition of
excessive product packaging.
Every indicator suggests Americans
care about the environment, are
beginning to take personal steps to
protect it, and are starting to change their
behavior and purchasing habits to ensure
that we have a cleaner world. These new
attitudes represent a dramatic change
from the early 1970s.
In the two decades since the original
Earth Day and the founding of EPA, the
environmental movement's goals have
permeated the American psyche, worked
their way into the nation's laws, politics,
and economic system. While we haven't
made nearly enough progress, the
progress we have achieved can teach us
how to make more.
What approach is most powerful? The
answer can be found in one word:
(Krupp is Executive Director of the
Environmental Defense Fund.)
30
solutions. As it has grown, the
environmental movement has
increasingly recognized that behind the
dams and power plants that threaten
major environmental harm, there are
often legitimate needs-and that
long-term solutions lie in finding
alternative ways to meet those
underlying needs.
To see how the consensus on
environmental protection has been
promoted through the power of
solutions, we need only look at perhaps
the most poignant example of our
environmental ills, one that rears its head
no matter where we turn—waste.
Until recently, environmental
protection was based largely on dealing
with pollution and waste after it had
been produced. From sulfur dioxide to
toxic residues to municipal refuse, the
issue was not how much was produced,
but where to put it. Today, from the
highly touted programs initiated by
corporate giants like PG&E and 3M to
the increasingly powerful "green
consumer" movement, the consensus
among all parties has clearly shifted from
disposal and treatment of emissions and
waste to the preferred approach of waste
reduction.
Waste output and economic growth
have tended to increase at corresponding
rates. We must decouple the two if we
are to protect our environment. Many
companies have already found that by
taking environmental protection into
account at the very earliest stages of their
planning, they can reduce the amount of
pollution they produce while increasing
profits.
Take for example, the case of
California's Pacific Gas and Electric
Company, the nation's largest
investor-owned utility. In the late 1970s,
the company was planning to spend
nearly $20 billion during a 10-year period
on new coal and nuclear power plants.
The company, and many utility
regulators, said the plants were
indispensable to California's economic
health; others thought they would be an
unbearable imposition on the state's
environment.
An Environmental Defense Fund (EDF)
team—a lawyer, an economist, and a
computer analyst—developed a package
of non-polluting alternative energy
EPA JOURNAL
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sources and conservation investments,
including cogeneration (use of waste
industrial heat to generate electricity),
voltage controls, and utility-financed
insulation and efficiency improvements,
that not only met the same electrical
needs, but also meant lower prices for
consumers and higher returns to PG&E's
stockholders. The company ultimately
adopted EDF's plan, and today it even
pays to lease the computer model EDF
used to develop the plan.
The alternatives not only made every
one of the proposed large power plants
(and the pollution they would produce)
unnecessary, but it also helped the state
avoid the financial disasters of half-built
plants that plagued the Washington
Public Power Supply System (WPPSS).
Overly ambitious construction plans
developed by WPPSS ultimately caused
the multi-utility-owned operation to
default on billions of dollars in
construction bonds in the early eighties.
Costly litigation on the default continues
to this day, nearly a decade after the
construction projects were halted.
In the decade since EDF unveiled its
alternative plan, California utilities have
not had to break ground for even a
single large power plant. PG&E says 8
percent of its power now comes from
cogeneration and about 2 percent from
hydroelectric, solar, wind, and other
renewable and non-polluting energy
sources. These alternative supplies have
left the state with spare capacity for at
least the next eight years. And PG&E
has invested more than $1 billion in
conservation. Clearly, the company's
investment in preventing pollution has
paid off.
Other companies, most notably 3M,
have achieved similar success by keeping
Outfalls are still with us, but discharges are
cleaner than they once were. One of EPA's
first priorities was to reduce pollution coming
from specific, identifiable sites called "point
sources." The emphasis is now shifting
toward control of diffuse, "nonpoinl" source- -
3M photo.
the environment in mind when
considering their corporate bottom line.
The Minnesota-based company's much
publicized "Pollution Prevention Pays"
program is reported to have saved more
than $1 billion since its inception.
But the consensus on waste reduction
and pollution prevention does not stop at
the factory or power-plant gates, it has
even been adopted by individual
consumers. From West Germany's "Blue
Angel" label, introduced in 1977, to
America's more recent "Green Seal"
program, the so-called "green consumer"
movement is on the rise.
A July 1989 survey found that 77
percent of Americans say a company's
environmental reputation affects what
they buy. Based on these consumer
demands for greener products, Proctor &
Gamble last year introduced a detergent
in a reusable container. Wal-Mart has
asked its suppliers to provide more
recycled and recyclable products;
hundreds of them are now on the
shelves. K-Mart and at least a dozen
grocery chains have announced similar
programs, all based on consumers'
demands for products made from
recycled materials or for products that
produce less waste. What steps the
Federal Trade Commission may take to
regulate environmental claims will be
important in determining whether
consumers are offered genuine
"Earth-friendly" alternatives or, through
false marketing hypes, are misdirected in
ineffective or even counterproductive
ways.
The growing trend toward recycling
around the country also reflects the
logical and powerful appeal of the
"waste-avoidance" solution. Though not
as preferred as true waste reduction,
recycling is the best way to handle many
materials. It avoids pollution, saves
energy, and conserves natural resources.
As landfill costs have soared and
incinerators have proved hard to site and
operate, many cities and towns have
turned to recycling to shrink their
growing waste disposal problems.
For example: 82 percent of the
households in Olympia, Washington,
have signed up to receive special
recycling containers, and more than 92
percent of the people living in
Barrington, Illinois, participate in the
city's voluntary curbside recycling
program.
According to a recent issue of BioCycle
magazine, the number of curbside
recycling programs nationwide increased
from 1,042 in 1988 to 1,518 in 1989-an
increase of 46 percent in one year.
Current estimates suggest the new
popular programs are being introduced
at an accelerating rate.
The approach of tackling
environmental problems through the
advocacy of constructive solutions has
had a great deal of success in the last 20
years. But that does not mean that the
environment does not face continued
challenges. The news that humankind
has punched a hole in the ozone layer
and threatens to warm the entire globe
indicates that tinkering is not
enough—we need fundamental changes.
Mere opposition is seldom enough to win
those changes. The true successes of the
last 20 years demonstrate the power of
proposing solutions.
The environmental movement must
move forward with consumers and
industry, showing people not only what
not to do, but also what can be done to
ensure safe, sustainable growth. The
American public does not want to be
faced with a continuing draconian choice
between improving our economic
well-being or preserving our health and
natural resources. With the increasingly
popular problem-solving approach to
environmental protection, we can have
both, a
SEPTEMBER/OCTOBER 1990
31
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Changing Perspeci. •,••.-.-
Starting Fresh with
Environmental Education
by Senator Quentin Burdick
America's young people aren't
waiting to express their concerns
about the environment. Pictured is
three-year-old Collette Taylor,
among the demonstrators at a
Rocky Flats protest held at the
Colorado capitol last year.
As any parent knows, it is more
effective to teach an infant not to
throw food than to clean the kitchen
floor after each meal. Likewise, it is
easier to increase environmental
awareness than it is continually to clean
up waste, pollution, and other damage to
the environment.
EPA has grown significantly in the last
20 years as it has faced increasingly
complex and interrelated environmental
problems. So far, the emphasis of EPA's
expanded mission and programs has
been largely on cleaning up long-
standing, obvious pollution. But for cost-
effective environmental protection, both
EPA and Congress need to focus on
education and pollution prevention.
The advantages of preventing pollution
before it occurs are increasingly apparent.
The Superfund program, for example,
demonstrates how complicated and
expensive it can be to restore land that
has been polluted by hazardous
chemicals. The Exxon Valdez oil spill in
a formerly pristine area spurred Congress
finally to adopt comprehensive
legislation both to strengthen response to
oil spills and to prevent future accidents.
The nation faces an enormous
challenge in terms of preventing
pollution, global warming, and ozone
depletion and promoting resource
conservation, recycling, and waste
reduction. Government and concerned
citizens can do much to curtail pollution
from specific sources. Each individual
who adopts better habits at home and at
work helps reduce waste and conserve
resources.
We must encourage Americans,
especially young people, to do their part
to protect the environment. Investing in
environmental education may be the best
way the government can build a
foundation to address effectively a
multitude of pressing national and global
environmental problems.
The obvious place to start educating
the public about the environment is the
classroom. Children are curious about
the natural environment and can adapt to
(Burdick (D-North Dakota) chairs the Senate
Environmental and Public Works
Committee.)
an environmentally conscious lifestyle
more easily than adults. And today's
young people will need the planet's
dwindling, precious resources in the next
century.
Just as we require courses in math,
science, English, and history, we should
include environmental education in every
student's education. Teachers,
counselors, and even lunchroom
personnel should be alert to
opportunities to teach young people
about reducing waste, recycling,
conserving resources, and other ways to
help preserve the environment and
natural resources. Encouraging these
activities is what environmental
education is all about.
Environmental education is not a new
idea; in fact, the need for federal support
on this front was recognized in the late
1960s. The first Earth Day, in April 1970,
sparked new interest in national and
international efforts to preserve the
planet. Just before EPA's creation that
year, Congress passed the National
Environmental Education Act, sponsored
by Senator Gaylord Nelson. The
program was based at the Department of
Education and had great potential to
bring environmental issues into the
classroom.
Yet while EPA grew into a vital
regulatory force, the environmental
education program never took off. The
program died after just 10 years because
of underfunding and lack of aggressive
implementation by the Department of
Education. The Act was repealed in 1981
as part of the Omnibus Budget
Reconciliation Act.
I believe it's time to reestablish our
nation's commitment to environmental
education. Last year, looking toward the
20th anniversary of Earth Day, I
introduced the National Environmental
Education Act; Representative George
Miller (D-Califomia) introduced
companion legislation in the House. The
goal of this legislation is to renew the
federal role in environmental education.
Twenty years ago, the Department of
Education was the best agency to
coordinate environmental education.
Today, EPA is best equipped to
implement a strong environmental
education program. EPA knows first-
hand the many problems facing our
environment—oil spills, global warming,
ground-water contamination, hazardous
waste disposal, radon gas, and others.
The National Environmental Education
Act therefore proposes to give EPA the
primary role in environmental education.
Mike Keefe. Reprinted by permission.
32
EPA JOURNAL
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Recognizing budget constraints, I do
not propose an elaborate program. The
bill authorizes $15 million per year to:
• Establish an Office of Environmental
Education at EPA
• Expand curriculum development and
teacher training
• Provide small grants to local school
systems and colleges
• Support college-level environmental
interns in federal agencies
• Provide national and regional awards
to recognize excellence in environmental
education.
An EPA Office of Environmental
Education could work with the
Department of Education to provide
environmental-education training for
classroom teachers and develop model
curriculum. Each classroom teacher who
becomes more aware of environmental
issues and integrates environmental
concerns into his or her curriculum could
reach dozens of schoolchildren each year.
Also, the new office would administer
a grant program to support innovative
environmental-education programs and
projects. Grants would be capped at
$100,000, and 25 percent would be for
$5,000 or less. The possibility of even
limited federal funding could be a major
incentive for a school to produce creative
environmental-education ideas and
projects.
Internships established in federal
environmental and natural resource
agencies would allow college students to
see the rewards of environmental work.
I often hear complaints about the
shortage of scientists and other
professionals trained in environmental
areas who are willing to work in
government. Part of the long-term
solution is to attract more young people
to pursue environmental careers.
Our society recognizes excellence in
many areas, ranging from athletic ability
to entertainment to financial success. But
we do little to recognize exceptional
commitment to the environment. I
propose establishing several awards for
environmental educators, including
awards in honor of Henry David
Thoreau, Theodore Roosevelt, and Rachel
Carson. These environmental heroes are
perfect examples of what individuals can
do to protect our natural resources.
The new office could encourage other
environmental education efforts as well.
Across the nation, nonprofit
organizations, local and state educational
agencies, and other federal agencies (e.g.,
the Fish and Wildlife Service and the
National Forest Service) are
implementing a wide range of
environmental education programs. This
legislation is designed to complement,
not supplant, those efforts.
The 20th Anniversary of Earth Day
renewed both Congressional and public
interest in protecting the planet.
Establishing an Office of Environmental
Education and fully implementing these
programs would be a major step forward
for environment protection. As indicated
in testimony before my committee, EPA
is ready and willing to accept this
challenge.
Over the long run, we will need
widespread public understanding of
complex environmental problems to
protect our air, our water, and the world
around us. A small investment in
environmental education could make a
big difference in our planet's future.a
Editor's note: In its closing days, the 101st
Congress passed environmental education
legislation similar to that described in this
article.
SEPTEMBER/OCTOBER 1990
33
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Changing Perspectives
Rediscovering Ecology
by Douglas P. Wheeler
and Douglass Lea
Complex problems, like cleaning up
the Chesapeake Bay, require
complex responses. Around 1975,
ecological thinking began to regain
momentum as people realized that
treating the bay solely as a water-
pollution problem wasn't enough.
Pictured is a skipjack, a traditional
vessel on the bay.
More than two decades have passed
since the U.S. government last
mounted a comprehensive and effective
response to overwhelming evidence of
widespread environmental destruction.
In the tradition of other "wars" on
persistent problems, Congress and the
Nixon Administration identified the key
enemy of the era-the pollution and
waste of important resources-and
mobilized a response that was vigorous,
sweeping, and, apparently, decisive.
New policies were declared; new
agencies, including EPA, were created;
and initiatives were launched against
specific environmental problems,
bringing a vast array of laws with
strange acronyms.
Meanwhile, outside the confines of
government actions, the American public
was engaged in the first stirrings of a
new environmental and conservation
ethos. Earth Day 1970 symbolized the
new ethos, but the changes in public
consciousness were too pervasive and
gradual to be captured by a single event
in the same way that Pearl Harbor, for
example, stands for the advent of World
War n. Grassroots politics began to take
on a green coloration. The major
environmental organizations expanded
rapidly in wealth, power, and numbers.
Millions of individuals changed their
everyday patterns of external behavior to
reflect changes in internal values and
consciousness.
Even basic vocabulary was affected.
Emerging from the closets of arcane
science, the word ecology, for instance,
entered everyday language, becoming, in
fact, a rather common usage. Thus, for
example, a biographer of the late Lewis
Mumford, distinguished authority on
cities and architecture, described
Mumford's mindset as follows:
Above all, Mumford's ideal
cities incorporate "balance" and
(Wheeler is Vice President of World Wildlife
Fund and The Conservation Foundation. Lea
teaches American Government and Politics at
The American University, Washington, DC.)
34
"wholeness"—two attributes that
sum up his approach to life.
He was this century's leading
proponent of" ecological
thinking," a way of seeing life
whole in all its variety and
interconnectedness. Like a
biologist at work in nature, he
ceaselessly searched for
interrelationships, and he
always placed the subject he
was writing about-a book, a
building, or an entire city—
within its larger cultural
context.
To halt the decline of an
ecosystem, it is necessary to
"think like an ecosystem."
Unfortunately, however, the popular
new word and the holistic thinking it
conveys were largely ignored in official
discourse. During the late 1960s and
early 1970s, while the strategies and
organizations for waging war on
environmental enemies were taking
shape, the accompanying debate fell into
traditional ways of thinking about
problems: linear and fragmented, based
on discrete cause-and-effect relationships
and case-by-case distinctions. The most
congenial settings for this kind of
thought are the courtroom, the
classroom, and the laboratory, those very
settings where variables can be
controlled, abstractions applied, and
anomalies rationalized. The real world,
of course, is messy and demands an
epistemology, a system of knowledge, of
its own—one that is something like
ecology.
Ecological thinking had to wait,
however, until the limits of the
traditional approaches became obvious
and burdensome. Ironically, the
founders of the modern conservation
movement, who prepared the ground for
the initiatives of 20 years ago, were
chiefly concerned with the use and abuse
of land and, therefore, were ecologists in
fact, if not yet in name. Listen to the
language of "The Land Ethic," the classic
essay in A Sand County Almanac, written
in 1949 by an environmental founding
father, Aldo Leopold: "A thing is right
when it tends to preserve the integrity,
stability, and beauty of the biotic
community. It is wrong when it tends
otherwise."
The new report from EPA's Science
Advisory Board (SAB), Reducing Risk, is a
strong signal that the time for ecological
thinking finally has arrived. For
example, the report recommends that
EPA, in considering risks, give as much
attention to ecological processes as it
does to human health; it also
recommends that the Agency develop
better methods for estimating the real
value of ecosystems. In a sense, the SAB
report merely ratifies changes already
begun at EPA and, indeed, in the larger
environmental community.
The rediscovery of ecology really began
to gain momentum around 1975, when
interested parties acknowledged that the
growing problems of the Chesapeake
Bay, once the world's most productive
estuary, were possibly intractable.
Certainly they were resistant to
traditional problem-solving techniques.
On the theoretical level, the Chesapeake
dilemma is an expression of W. Ross
Ashby's Law of Requisite Variety.
Basically, Ashby's law says that a system
of strategic control succeeds only to the
extent that the strategic system develops
a complexity equal to that of the system
it seeks to encompass and influence.
Although developed in the context of
cybernetics (the study of automatic
control-and-communication systems),
Ashby's law applies to ecology with
special relevance. By 1975, it was widely
known that the complex causes of
biological decline in the Chesapeake
basin, an incredibly dense ecosystem,
would defeat all attempts to apply
simple solutions, particularly those
relying on command-and-control models.
The complexity of the problems
demanded an equivalent complexity in
terms of response. Hence, the usefulness
EPA JOURNAL
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:-^
of the Law of Requisite Variety-and the
rediscovery of ecological thinking. To
halt the decline of an ecosystem, it is
necessary to "think like an ecosystem."
Over the past 15 years, EPA officials
have gradually learned to think
comprehensively about the Chesapeake's
watershed and to use the Agency's full
arsenal of offices and authorities to
address the various dimensions of the
system's deterioration. Moreover, to
generate the "requisite variety" of
response strategies, a vast array of
auxiliary organizations, jurisdictions, and
disciplines have been brought to bear on
the bay's problems. Now state and local
governments and nonprofit organizations
all play leading roles in the continuing
drama.
Similarly, a focus on the bay as an
ecological system means bringing
together a complex weave of talents and
perspectives. For example, Will Baker,
President of the Chesapeake Bay
Foundation, which has mobilized
grassroots support for the bay, says,
quite pointedly, "What happens on the
land affects the water. We've learned
that you cannot save the bay unless you
save the land."
As the Chesapeake Bay experience has
shown, attacking water pollution alone is
no longer sufficient. Greenways and
setbacks are necessarily part of the
program. Non-point sources of pollution,
buffer zones, organizational conferences,
nutrient levels, and sustainable growth:
All of these things are being considered
in relation to each other.
Thus pesticides are being tested in the
field. Species population levels and
predator-prey ratios are attracting more
interest than the one-dimensional effects
measured on indicator species in
laboratories. Microcosms and ecosystems
hog the spotlight. Overall satisfaction
with the evolution of the Chesapeake Bay
program has led EPA to develop a
National Estuary Program that replicates
the Chesapeake approach in 17 other
estuaries and in the Great Lakes region.
The challenge today is to move the
ecological approach beyond its present
tentative, patched-together status. By
linking together ecology and human
health and calling for a reevaluation of
accounting methods that undervalue
ecological resources, the SAB report
highlights important steps toward
establishing a firmer foundation for
ecological initiatives. Recent diplomatic
conventions designed to decelerate the
destruction of the planet's protective
ozone layer and the buildup of
greenhouse gases provide international
legitimacy to ecology's traditional
concerns about the interrelatedness of
apparently distant and superficially
discrete phenomena.
Taking ecology into the very heart of
our educational system is the last
frontier. It is important, therefore, to
follow the recent opening of EPA's Office
of Environmental Education with a
legislative mandate to spread ecological
awareness to even the youngest and most
unlikely of our citizenry. To cope with
the complexity, turbulence, and
uncertainty of the 21st century, the next
generation will need to be extraordinarily
well prepared in the ecological sciences
and sensibilities. That generation will be
forced to do nothing less than anticipate
the unpredictable, plan for the
unintended, and prepare for the
unexpected.
All knowledge and skill become
problematic under conditions of rapid
change. Thus, education, of necessity,
must become continuing education—an
ongoing series, inspired by constant
feedback and new information, of abrupt
adaptations, subtle refinements, and
quick adjustments. Only a deep
grounding in ecological processes can
equip the next generation to cope with
such discontinuities.°
SEPTEMBER OCTOBER 1990
35
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Oi
hanging Perspectives
Forging New Links
with Economic Policy
by Howard K. Gruenspecht
'-i~: ej ca^ te a mc'e e^oem way to achieve environmental goals than
•ic1 encroaches A 'ladeacie allowances system 13 included in the
-^ rec..ce s'j:tur-ci.oxide emissions irom coai-b'jrning power plants.
In a world where we can't have it all,
economics can play a key role in
illuminating the tradeoffs that inevitably
arise between the pursuit of
environmental objectives and other social
wants and needs, or between the many
environmental concerns that compete for
our attention and resources.
Two decades of experience with federal
environmental statutes has taught us that
significant environmental progress can be
made. Since 1970, when EPA was
established, emissions of particulates,
volatile organics, carbon monoxide, and
lead are down by 25, 29, 38, and 96
percent respectively. At the same time,
we have also learned that lofty-sounding
goals of zero risk or zero pollution have
more inspirational than operational value
and that flexible market incentives often
provide a better way to achieve
environmental goals than command-and-
control approaches. These lessons will be
of critical importance as we seek to
accelerate our rate of economic growth
while maintaining our commitment to
environmental progress in the years
ahead.
Traditionally, economic analysis of
environmental issues begins with the
notion of the "possibilities frontier"- the
set of combinations of goods and services
and environmental quality that can be
attained using the technical knowledge,
labor, capital, and natural resources
available at a given point in time.
Ideally, our decisions move us along this
frontier. For example, a decision to build
wastewater-treatment plants and
automobile-emission controls instead of
new factories and more cars would
represent a sacrifice of ordinary goods
for greater environmental quality.
Economics recognizes that, for a
number of reasons, certain unregulated
private markets may allocate too few
resources to the maintenance of
environmental quality. In considering
how environmental policies can be
applied to offset such failures of the
(Dr. Gruenspecht is Senior Staff Economist
at the President's Council of Economic
Advisors.)
EPA JOURNAL
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private marketplace, economics has two
distinct concerns: cost-effectiveness and
efficiency.
Cost-effectiveness reflects our interest in
remaining on the possibility frontier
rather than inside it. For example, it
makes no sense to give up $5 billion in
goods and services each year to achieve a
10-million ton reduction in sulfur dioxide
emissions if the same reduction could be
achieved for only $4 billion through
adoption of a better regulatory approach.
It is estimated that the tradeable
allowances system proposed by the
President for reducing sulfur-dioxide
(SO^ emissions will result in just such an
annual cost savings compared to the
command-and-control alternative.
We should not, of course, become so
enraptured with the cleverness and
power of flexible, cost-effective,
regulatory schemes that, like the Alec
Guinness character in the movie Bridge
over the River Kwai, we forget to ask
whether the program itself is desirable.
The notion of efficiency reflects our
interest in the selection of environmental
objectives that advance rather than
detract from our total well-being. To
apply the efficiency test in our acid rain
example, we would compare the cost of
the last ton of emissions reduction to the
value of the resulting decrease in adverse
environmental impacts. Because it relies
on explicit dollar valuations of
environmental outcomes and impacts,
efficiency is often a much more
controversial standard than cost-
effectiveness.
The simplicity of the static analysis of
tradeoffs outlined above, a virtue in
many respects, is a vice in others. One
major limitation is a failure to account for
the key role of time itself. For example,
the cost of emissions reduction is often
lower at new plants, where controls can
be "designed in" from the beginning,
than at existing facilities, where controls
must be retrofitted. This observation
underlies the present Clean Air Act
requirement that newly built plants be
much cleaner than existing ones, so that
total emissions fall over the long run as
old plants are replaced.
SEPTEMBER/OCTOBER 1990
Experience has shown, however, that
where standards for new plants raise
construction and operating costs
significantly, they may have the
unintended consequence of extending the
lifetime of old plants, so that anticipated
environmental progress is delayed.
Indeed, the slow replacement rate for
existing coal-fired power plants, a major
source of SO z emissions, led to the
decision to make major new reductions
from old plants rather than ever-tighter
new plant standards the centerpiece of
the Administration's initiative to reduce
emissions that cause acid rain.
As we look forward to the next 20 years
of environmental progress, it is a safe bet
that the time factor will become
increasingly important in many
environmental issues. Some of the major
dynamic interfaces between the economy
and the environment are previewed
below.
The Environment and the Economy:
The Future Versus the Present?
Over time, the analysis of environmental
tradeoffs necessarily involves choices that
affect future possibilities as well as
today's mix of environmental quality and
economic goods and services. In a world
where conflict sells better than almost
anything but sex, tradeoffs between
economic growth and the pursuit of
environmental objectives have sometimes
been characterized as nothing less than a
battle that pits the interests of future
generations in a livable planet against the
rampant materialism and conspicuous
consumption of the present. A lifting of
the rhetorical veil reveals a picture that is
far more complex.
First, the discussion of tradeoffs in the
abstract language of growth rates or
dollar costs of environmental protection
should not obscure the importance of
economic growth to the satisfaction of
basic human needs such as food, shelter,
and health care, both now and in the
future. In many developing countries, a
few tenths of a percentage point change
in the annual rate of economic growth
can mean the difference between real
progress and growing despair. Second, it
is no accident that environmental
movements are strongest in the richest
countries; experience has shown that
environmental awareness rises as
material living standards improve.
Continued economic progress is,
therefore, a prerequisite for winning the
cooperation of developing countries in
addressing global-scale environmental
issues, such as deforestation and ozone-
depletion, that are high on our own
environmental agenda.
Many current environmental concerns,
whether local, national, or global in
scope, involve costs and benefits that are
widely distributed across present and
future generations. How should the
interests of our progeny be reflected in
our present decisions? The notion of
sustainable development expresses the
widely held desire to leave future
generations in the best possible position
to satisfy their wants and needs, both
environmental and otherwise.
Sustainable development recognizes that
the possibilities open to future
generations will be determined by the
environmental, physical, and human-
capital resources that we bequeath to
them. These resources are, in part,
substitutable—many combinations of
knowledge, physical, and environmental
capital are consistent with the same level
of future well-being. Future generations,
by applying the resources we place at
their disposal, will be able to change
their mix—just as we are doing by
tackling some of the environmental
problems left by earlier generations.
How do U.S. bequests to future
generations compare to those of other
industrialized countries? Our spending
on environmental protection (1.8 percent
of national output in 1988) is already
among the highest of all nations, and is
expected to increase by 50 percent
relative to output by the beginning of the
next century. In contrast, our rate of
capital investment (gross investment
outside of housing has fluctuated around
12 percent of output in recent years) is
the lowest of the six major industrialized
countries. In education, our per-pupil
expenditures on primary, secondary, and
higher education are also among the
highest in the industrialized world, but
37
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we rank relatively far down the list in
direct measures of educational
attainment.
The Dynamic Element in Target
Selection
Clearly, not all environmental problems
can share equal priority given limits on
our regulatory resources and our desire
for consumer goods and services.
Exercises like the EPA's 1987 Unfinished
Business report and the just-released
report of the Science Advisory Board,
Reducing Risk: Setting Priorities and
Strategies for Environmental Protection, are
a useful step in ordering our
environmental priorities.
As in our acid rain example, the costs
of emissions abatement generally
decrease as more time is allowed for the
development of new technology and the
natural replacement of existing plants
with new ones. Time is also an
important factor on the impacts side of
the equation. The passage of time allows
for changes in existing practices,
replacement or relocation of capital
assets, and the development of new
practices and technologies, all of which
can significantly ameliorate adverse
impacts. Just as a cost-estimate based on
the immediate replacement of all present
facilities would greatly overstate the true
costs of a phased environmental
program, an impacts estimate calculated
as if environmental changes occurred all
at once is almost certain to overstate
actual adverse effects.
In evaluating response strategies for
issues where time is important, does "a
stitch in time save nine," or is it best to
proceed cautiously? Undoubtedly, the
proper mix between research and action
will differ across issues. Commitments
that allow for the replacement of existing
capital as it wears out are generally less
economically disruptive than those
requiring massive retrofitting. If off-the-
shelf technologies have economic and
environmental drawbacks of their own,
strategies that promote the development
of new and improved technologies can be
an attractive alternative to those that lock
in currently available technologies for an
extended period.
Ultimately, the split between action and
research, or between phased and
immediate action, should reflect the
deepest possible understanding of the
role of time as a determinant of both
impacts and response costs.
The Costs of Environmental Regulation:
Hardware Versus Software
Time is money. There is perhaps no
better illustration of this aphorism than
the case of the U.S. nuclear power
industry, whose economic viability has
been demolished over the past decade by
the large cost overruns resulting from the
steady lengthening of the time to
complete its projects. From another
perspective, delays affecting plant
construction or modifications needed to
bring new products to market can
severely damage the competitiveness of
firms operating in a world market where
minimizing the interval between product
design and product introduction is
increasingly recognized as a key
competitive advantage. While
appropriate regulation can be a
constructive force, regulatory
procrastination, which has contributed
significantly to project delays, engenders
major social costs for which there is little,
if any, offsetting benefit.
In today's competitive world, the
"software" of regulatory programs,
through its effect on time lags and
opportunities for innovation, can prove
to be as significant as the costs of
pollution control "hardware" in
determining the economic effects of
environmental regulation. It is the
software that determines the degree of
flexibility, the procedural complexity, and
the degree to which programs focus on
ends rather than means.
The need for better regulatory software
is particularly acute given the rapid
expansion of the regulatory agenda. For
example, EPA projects that
approximately 54 new final regulations
will be needed to implement the
provisions of the pending Clean Air Act
Amendments in the first two years after
enactment. This is an eight-fold increase
over current air-office efforts. A change
in the method of regulation to
approaches that are less prescriptive and
more flexible is essential if regulators are
to carry out their new mandates without
inducing gridlock. A switch to economic
incentives, by way of example, could
achieve policy objectives without the
need for repeated interventions to pass
judgment on individual technologies.
Conclusion
The traditional "timeless" framework for
the analysis of environmental policy
tradeoffs has yielded many valuable
insights. However, the element of time
itself now looms increasingly large in
many aspects of environmental policy.
Our success in achieving a combination
of environmental quality and economic
growth that will best serve the interests
of future generations will depend on our
ability to adopt prioritization schemes,
regulatory approaches, and evaluations
of impacts and response measures that
explicitly account for the role of time, a
The National Pollutant Discharge Elimination System (NPDES) team in the early 1970s.
They developed and implemented the statutory regulations for EPA to issue 60,000
water-pollution control permits-the largest environmental permitting program ever.
38
EPA JOURNAL
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Changing Perspectives
Environmental Science:
Helping Shape EPA's Agenda
by Erich W. Bretthauer
EPA, working with other federal agencies, is
involved in a long-term program to assess the
health of the nation's ecological resources.
The effort is known as EMAP (the
Environmental Monitoring and Assessment
Program). One facet of the research is the
collection and testing of bottom sediments.
(Bretthauer is EPA's Assistant
Administrator for Research and
Development.)
It is frequently said that
environmental policies and regulatory
decisions must be firmly grounded in
science: In other words, science must
lead policy. Not so commonly
recognized, however, is the degree to
which scientists look to policymakers for
guidance about future research. In
reality, policy decisions and scientific
research are inextricably interrelated and
mutually dependent on each other for
progress. This is apparent in the
evolution of environmental science and
policy over the past 20 years, as even a
cursory overview shows.
Twenty years ago, when EPA was
created, the focus was on reducing or
eliminating, if possible, the obvious
pollutants in the nation's air and water.
Our policy goal was to make the air
breathable for even sensitive members of
the population and to make our surface
waters suitable for fishing and
swimming. To support this goal, EPA's
research concentrated on identifying the
potential adverse effects of a small
number of ubiquitous pollutants in the
air and water and on developing
technologies—such as flue gas
desulfurization or low nitrogen oxide
(NOJ emission-burners—to curb
emissions of these pollutants into the
environment.
Thus, in 1970 EPA's clinical health
research facility in North Carolina was
established to assess the effects of low
levels of pollutants such as sulfur dioxide
(SO^ and ozone on human health. That
early beginning generated a body of
knowledge that has been the basis for
many of our regulations and policy
decisions concerning air pollutants.
During these same years, EPA's Office of
Research and Development (ORD) labs
began research on ways to limit pollutant
emissions from large point sources such
as power plants and industrial facilities.
Over the next decade, this research found
expression in countless regulations and
policies.
During the late 1970s and early 1980s,
while we were achieving measurable
success toward our early goals, attention
shifted to less visible pollutants:
chemicals such as heavy metals and
volatile and non-volatile organic
compounds in the environment and their
effects on human health and on
important species in our ecosystems.
These toxic chemicals were emitted in
much smaller quantities than the so-
called "classical" pollutants such as SO2
and nitrogen oxides (NOJ. As many of
these more ubiquitous chemicals were
brought under control, public concern
shifted toward effects such as cancer and
birth defects suspected to result from
exposures to toxic chemicals.
At this juncture, our policies called for
EPA to identify the relationships
between exposure to toxic chemicals and
adverse health effects—and to reduce or
EPA must be a science agency as
well as a regulatory agency, and
our science and research base
has to be much broader than it
has been in the past.
eliminate the contribution that these toxic
chemicals made to the burden of disease
and death in our society. Also at this
time, our policies began to shift
increasingly toward using risk
assessment as an analytical tool and as
an important part of the decision-making
process. As a result, our research efforts
focused on developing methods for
identifying small amounts of toxic
chemicals in the environment (exposure
is, of course, a significant component of
risk assessment) as well as on methods of
assessing the human health and
environmental risks from chemical
exposures. We also studied the impact
of toxic chemicals on other species and
the ways in which these chemicals move
through the environment and how they
may be transformed in the process.
During these years we accomplished
groundwork research in risk assessment
and risk reduction that resulted in
significant progress on both fronts.
EPA's first risk assessment guidelines
were crafted and published during this
period. The Agency's approach to
external review of our risk assessment
procedures was also established at this
time, involving public comment,
comment by scientists outside of EPA,
review by the EPA Science Advisory
SEPTEMBER/OCTOBER 1990
39
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Board (SAB), and full public discussion
and publication.
During the 1980s, regional and global
environmental issues drew increasing
concern. Foremost among these issues
were tropospheric ozone pollution, acid
deposition across regional and national
boundaries, and the likely depletion of
the stratospheric ozone layer by
chlorofluorocarbons (CFCs). These
concerns triggered long-term research
efforts to model the movement of
pollutants across large geographic
regions and to study the effects of acid
deposition on streams and lakes.
The models and other data that
developed from this research enabled
EPA to understand and evaluate
problems such as acid deposition and to
develop policies that reflected our
scientific understanding. For example,
we were able to analyze the causes of
acidification of lakes and streams in New
England and Florida and to assess the
likelihood that this acidification was due
to acid deposition; in some cases, it was
possible to determine that the
acidification was due to other causes.
At the same time, renewed attention
was focused on the scientific
underpinnings of risk assessment. As a
result, revised, more detailed risk
assessment guidelines were published,
based in large part on risk assessment
publications of the National Academy of
Sciences and the President's Office of
Science and Technology Policy. As
before, intensive public and scientific
review and debate preceded the
publication of these new guidelines.
Similarly, EPA and the Office of
Research and Development became
increasingly concerned about finding
practical solutions to environmental
problems. During this period, a series of
programs was developed in innovative
technologies-in biotechnology, in radon
mitigation and indoor air quality in
homes, and in control of CFCs—that was
to result in specific, cost-effective
solutions to environmental problems in
the middle and late 1980s.
It was this kind of problem-solving
research that led, for example, to the
development of the "suicide gene," a
small piece of DNA inserted into
microorganisms effectively preventing
them from living outside the confines of
a specific laboratory experiment. This
research enabled ORD to mobilize
quickly when the Exxon Valdez spilled a
huge amount of oil in Prince William
Sound in Alaska. The result was an
extremely successful biological method
for cleaning up oil-fouled beaches. This
problem-solving approach also resulted
in a highly successful joint venture with
the private sector: recycling CFCs from
automobile air conditioners when cars
are brought in for service.
Today, our point of view is shifting
again. More than ever before, we are
aware of the global scope of many
environmental problems and the need to
formulate policies to deal with them in
their full complexity. The SAB's recently
published report, Reducing Risk, has
highlighted the need to focus on issues
such as global climate change, loss of
habitat, loss of biodiversity, and
stratospheric ozone depletion and
accordingly to change our approach to
environmental protection and redirect
our research efforts. (See article on page
8.)
The new SAB report has also reinforced
the point that the end-of-the-pipe
solutions that have been at the heart of
our policies in the past are often
economically inefficient and
environmentally inappropriate.
Consequently, we are turning our
attention to ways in which we can
prevent pollutants from being generated
in the first place. Our policy goals are
shifting from reducing emissions to
protecting the Earth's resources through
production patterns and life patterns that
are inherently less stressful to the
environment. At the same time, however,
we continue to tackle the many pressing
issues of the past that have not yet been
satisfactorily resolved, such as attaining
our ground-level ozone standard,
reducing emissions of dioxins from
manufacturing facilities, etc.
More important, we have come to
realize that our vision of the research
necessary to support and sustain
tomorrow's policies for environmental
protection and pollution prevention has
been much too narrow. In short, EPA
must be a science agency as well as a
regulatory agency, and our science and
research base has to be much broader
than it has been in the past. This
conclusion reinforces findings put
forward in an earlier SAB report entitled
One of EPA's long-standing projects is the
President's Environmental Youth Awards.
President Jimmy Carter honored a group of
these young environmentalists.
40
EPA JOURNAL
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Future Risk: Research Strategies for the
1990s, issued in 1988, which stated:
Research is the most
fundamental of the tools that
promote environmental quality.
Without the strong scientific
and technical knowledge that
results from research and
development programs,
standard-setting would not be
possible, control technologies
would not exist, and there
would be nothing to enforce ....
EPA is more than a regulatory
agency. It is a research agency
responsible, along with other
federal agencies ... for defining
the nature of—and possible
solution to-the nation's
environmental problems.
The SAB also recommended that EPA
"plan, implement, and sustain a long-
term research program" and that ORD
"develop basic core research programs."
Over the past two years, ORD has
taken the SAB's charge very seriously.
We have created a special core research
program to generate data and methods
that will be valuable in developing long-
term solutions to environmental
problems. This program has three major
components: ecological risk, human
health risk, and risk reduction. The
ecological risk component of the core
program, in particular, deserves mention
in light of the Agency's heightened
policy concerns about ecological impacts.
(See Administrator Reilly's comments on
this point, page 6.) This component,
called the Environmental Monitoring and
Assessment Program (EMAP), involves
research to better understand the status
of ecosystems in this country and around
the world and to detect and identify
trends, either in exposures or in effects,
that may be occurring over time. In
addition, EMAP entails research to
identify appropriate ecological indicators,
so that at some time in the future we
may be able to extrapolate today's
observations to predict the future health
of important ecosystems.
Working cooperatively with other
federal agencies, including the National
Oceanographic and Atmospheric
Administration and the Forest Service,
EMAP has already started to assess the
health of estuaries on the east coast of
the United States and of some
northeastern forests. When fully
implemented in a few years, this
program will cover all the ecosystems of
the country and will provide a
conceptual framework for other federal
agencies, states, and foreign countries to
use in assessing ecological health.
A major frontier for assessing the risk
that pollution poses to human health is
the question of exposure—how much of
particular pollutants are we exposed to
and how much of that exposure actually
reaches vulnerable organs in our body.
This is currently one area of great
uncertainty. It has been called the
weakest link in the risk assessment
process.
The increasing global complexity
of environmental problems
makes the working partnership
between science ana policy-
making more important than
ever for the coming years.
To address the issue of exposure, ORD
developed a program some years ago to
investigate human exposure to chemicals,
called the Total Exposure Assessment
Method (TEAM). This program followed
people during their daily activities,
measuring exposures through personal
monitors that they wore wherever they
went. In addition, people kept diaries of
their activities during the day and
recorded the foods and medications they
ingested. The results of these studies
clearly demonstrated that many
exposures of concern resulted not from
industrial sources, but from ambient
pollution at home, at work, and during
transportation. As a result, human
exposure research has become a
significant part of our core research
program, too.
As in the past, EPA's approach to risk
assessment is once again being called
into question by both scientists and
policymakers. As a result, we have
established a major research program to
investigate the methods and the
uncertainties that are a part of the risk-
assessment process; the exposure
research discussed above is one such
effort. In addition, working together with
the National Academy of Sciences, we
have established a Committee on Risk
Assessment Methods, which will advise
us of opportunities for improvements in
our current approaches. We have also
begun a joint effort with EPA
policymakers to foster and ensure
consistency in risk assessment
approaches across all of the Agency's
programs.
As a part of ORD's overall core
research effort, we are also developing a
program to support the Agency's new
policy of pollution prevention. This
program is looking at broad sectors of
society to identify changes that
individuals, industries, commercial
establishments, and others can make to
eliminate the production and emission of
pollutants into the environment. This
program is the logical extension of our
past efforts to develop solutions for
environmental problems that are on the
forefront of technology, efficiency, and
effectiveness.
In summary, the research programs and
policies of EPA have gone through
distinct changes over the past 20 years.
They have changed in a mutually
dependent way, with science defining the
limits of policies, and policy directions
defining the needs for research. In some
instances, however, these two efforts
have not been well integrated, so that a
science base was lacking when
policymakers needed to make decisions.
It is important to ensure good two-way
communications between scientists and
policymakers, so that policy decisions are
consistently based on sound science, and
a sound science base is ready when
policymakers need it. The increasing
global complexity of environmental
problems makes the working partnership
between science and policy making more
important than ever for the coming
years, n
SEPTEMBER/OCTOBER 1990
41
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Reflections on the Role
of a Cabinet-Level EPA
Representative
Mike Synar
What would be the role of a
Cabinet-level EPA? What
challenges would such an
organization face? Such questions
have been discussed as legislators
considered whether to give the
Agency Cabinet status, and the
debate will probably continue in
the next Congress. EPA Journal
asked several legislators who have
been involved in the debate for
their views on these questions.
Their comments follow.
If and when EPA is
elevated to Cabinet status,
I believe it will have only one
new challenge: to meet the
high expectations of the public
and Congress. Among other
things, this will mean playing a
more visible and aggressive
role in helping solve the many
international environmental
problems facing us and going
to the Cabinet table as an equal
partner when confronting other
federal departments over their
environmental responsibilities.
Beyond this, an ongoing
challenge facing EPA-today
and as a future Cabinet
department—is helping
Congress and the public better
prioritize our environmental
goals to accommodate limited
available resources. It is both
discouraging and ironic that
our understanding of
environmental problems and
(Synar (D-Oklahoma) is Chairman
of the House Subcommittee on
Environment, Energy, and
Natural Resources.)
our view that they must be
properly addressed have
grown in inverse proportion to
the resources we have available
to spend on them.
Recognizing that our loftiest
goals for environmental
protection cannot be fully
reconciled with the
technological and economical
realities facing us, we must
now set our priorities
accordingly. As a result, EPA
must help recraft the nation's
environmental priorities to
ensure that our increasingly
scarce resources are directed
toward areas presenting the
greatest health and
environmental risk. This will
also entail rethinking our
traditional ways of paying for
regulatory programs and
remediation efforts.
I enthusiastically support Bill
Reilly's repeated statements
that pollution prevention must
be the nation's first
environmental priority. If we
have learned nothing else from
20 years of environmental
regulation, we have learned
that preventing pollution is far
cheaper than cleaning it up.
But EPA must match its words
with meaningful actions
throughout its disciplines. And
it must ensure that these
outreach efforts go beyond the
easy target-big businesses~and
extend to small businesses,
communities and community
groups, schools, volunteer
organizations, and the like.
As part of its longer-term
prevention efforts, I believe
EPA must also work with
Congress and others to find
practical ways of making
voluntary environmental
protection efforts-above and
beyond the precise
requirements of the law-
attractive to businesses. EPA
must focus special attention on
small businesses and small
communities (particularly in
rural areas), which can be
significant contributors to
environmental pollution and
which are especially hard-hit
by compliance costs.
Finally, Congress should
assist EPA in looking for ways
to reduce the amount of scarce
money and valuable manpower
which are currently devoted to
litigation of environmental
rules and regulations. With
greater emphasis on alternative
techniques for resolving
disputes, for instance, we may
be able to devote more of our
limited resources to real
environmental action.
EPA deserves the stature
implicit in Cabinet-level status.
Again, the challenge will be to
put that additional stature to
good use in our international
efforts and in dealing with
other federal agencies, and to
find better and more efficient
ways of addressing our
existing environmental
problems.
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Senator
Steve Symms
Senator
John Glenn
Whether or not EPA is
elevated to a Cabinet-level
department or remains an
independent agency matters
little, except perhaps to assuage
some egos. The major
challenge facing EPA today is
the way it is perceived by the
American people. Is it viewed
as a resource, someplace to
turn for help in solving
environmental problems? Or is
it viewed as an environmental
gestapo, a department of storm
troopers to be avoided at all
costs?
That challenge of becoming a
friendly, useful resource in the
eyes of the public will only be
that much greater if the
Agency is elevated to Cabinet-
level status.
There exists a pervasive
American view on
environmental protection that
is not prudently ignored. A
poll compiled by the
(Symms (R-Idaho), a former fruit
fanner, is on the Senate
Environment and Public Works
Committee.)
Conservation Foundation asked
Americans, to respond to the
question, "Is it possible to have
both high environmental
standards and a growing
productive economy at the
same time?" Seventy-five
percent responded
emphatically, "Yes!"
In 1988, George Bush said "I
am an environmentalist" and
then proceeded to run on one
of the most free-market,
pro-economic liberty platforms
of any President in our time.
In his inaugural address he
declared, "We know what
works; freedom works. We
know how to secure a more
just and prosperous life for
man on Earth: through free
markets ... and the exercise of
free will unhampered by the
state."
That doesn't sound like a
man who favors the big
government solutions and the
heavy regulatory hand of past
environmental crusades. Why
did Americans elect him?
Obviously they believe in a
type of environmentalism that
can coexist with economic
development: one that works
with them, not against them.
They believe in an
environmentalism that is
effective without undermining
the institutions of private
property and free markets that
are sweeping the world and
are rooted in our own
Constitution.
Is it possible to promote
environmental values within a
framework of capitalism and
economic growth? Not only is
it possible, but it is EPA's only
real future. The greatest
challenge to our environment,
the field where the battle will
be won or lost, is in the minds
of men and women. We will
never have a national
environmental police force
large enough to prevent a
person from dumping oil down
a gutter. The unmonitored
release, the unseen spill, the
orphan barrel of hazardous
waste can be prevented only by
influencing the attitudes and
values of individuals.
EPA's role must be to
promote environmental values,
not to hamper them. Does
pitting the environment against
a family's ability to put food
on the table and a roof over
their head accomplish that
goal? When a chemical is
.accidentally spilled, is EPA
seen as the first place to call?
Or dreaded as the last?
In debating EPA's future, the
question must be asked, "When
the nation calls for new
thought and new ideas about
how to protect our
environment without
decimating our industry; when
the American people demand a
clean environment AND
private property and free
markets; when the age of this
new environmentalism
desperately demands new
leadership, will the EPA be
ready to meet the challenge?"
Currently, the public view of
EPA is closer to the gestapo
model than the helpful-agency
model. Regardless of whether
EPA is elevated to Cabinet
status, the task is to reverse the
public image and become a
place where people look for
help.
It is my hope and
expectation that this year,
or in the near future—if the
initiative can finally get past
inter-committee differences in
the Senate-EPA will become a
Cabinet-level department.
The reasons why this should
happen have been discussed
widely in EPA Journal and the
popular press. In addition to
continuing EPA's important
fight against the polluting and
poisoning of the air, the seas,
and our drinking water, a
Department of the
Environment would face the
broader challenges of what we
now recognize as humankind's
assault on the overall ecology
of the Earth.
As we elevate EPA to
department status, a couple of
provisions in the proposed
legislation will, I believe, be of
major importance:
•First, anyone who has dealt
with environmental concerns is
(Glenn (D-Ohio) chairs the Senate
Committee on Governmental
Affairs.)
SEPTEMBER/OCTOBER 1990
43
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aware of the tremendous
number of studies conducted in
the field, quite often with
conflicting approaches,
methodologies, and
conclusions. It hardly stretches
the truth to say that one can
take almost any position on an
environmental matter and find
a study that will back it up.
Therefore, in the bill we
propose, the new department
would include a Bureau of
Environmental Statistics which
would assess environmental
studies and masses of data in
much the same way that the
Bureau of Labor Statistics does
in its field. Anyone who
doubts the need for such
assessments need only look
back at the lengthy debate over
the Clean Air Act on the Senate
floor.
•Second, given the
Governmental Affairs
Committee's responsibilities for
the efficiencies as well as the
organizational aspects of
government, we looked at
existing inter-departmental and
inter-agency overlap with
respect to environmental
regulation. Even a cursory first
look made it apparent that
almost every department and
agency is involved in some
way in administering or
otherwise carrying out
environmental laws, rules, and
regulations, and that many of
these activities overlap.
It also became apparent that a
full analysis of such a huge
and complex problem was
beyond the Committee's
capability: hence the
Presidential Commission on
Improving Environmental
Protection in the legislation we
propose. Its mission: Make
recommendations to the
President and Congress on
ways to improve the
application of environmental
laws, including reductions in
overlapping jurisdictions,
uncertainty, and conflicting
authorities. Of course, any
proposals such a commission
might make would only be
recommendations for further
Congressional consideration.
But perhaps the most
important point is this: Unless
the Earth is infinitely resilient,
then the efforts of this
generation and the next to
preserve it~especially of
organizations such as the
proposed Department of the
Environment—may determine
whether or not our
descendants will long survive.
Make no mistake. There is a
distinct possibility that we, as a
species, are heading rapidly
toward disaster. Because we
are burning fossil fuel in ever
greater amounts, the
concentration of carbon dioxide
in the air is increasing
exponentially. If the
greenhouse model of global
warming is correct, as many
leading scientists believe, then
the planet will experience
massive, global disruptions in
climate, with potentially
catastrophic consequences.
Global climate change is by
no means our only concern.
Every year, people cut down
an area of tropical rain-forest
greater than that of the state of
Ohio. We are transforming
fertile lands into deserts,
allowing our topsoil to erode
away at a phenomenal rate.
And without topsoil, we cannot
grow crops.
Naturalists tell us that we are
causing the extinction of
roughly 100 species of plants
and animals every day—a
statistic that simply boggles the
mind.
The hope for somehow
reversing this depressing
downward spiral rests largely
with those private and
government-sponsored
organizations that have a
global, long-term perspective
and the credibility, influence,
and power to convince the
world's societies to begin
acting in common self-interest.
As one of the most visible and
influential of these, the new
Department of the
Environment must seize the
initiative in making our citizens
aware of the seriousness of the
world's ecological problems. It
must lead us in confronting
and overcoming those
problems.
Senator
William V. Roth
4
In the midst of growing
demands and shrinking
budgets, the new Secretary of
the Environment would be
setting out to improve
America's environment in the
1990s. This task will not be
easy. The visibility and clout
of Cabinet-level status are
needed to bring environmental
problems and solutions to the
forefront of this nation's
agenda.
The list of environmental
threats has grown considerably
in recent years; so has the
number of environmental
statutes intended to protect us
from such threats. On
problems ranging from air
pollution to contamination of
lakes and streams, and disposal
of hazardous wastes, the
workload will be bigger and
oversight responsibilities
broader. To meet these
regulatory responsibilities in a
time of scarce funding will
require a high-powered, high-
(Roth (R-Delaware) is Ranking
Minority Member of the Senate
Governmental Affairs Committee.)
profile Department of the
Environment.
A seat at the Cabinet table
would give the new Secretary
prominence and prestige in the
Administration, in Congress,
and in the international
community. This new stature
would send a clear signal that
the United States is moving
expeditiously to address
environmental problems. The
Secretary, much like the
Surgeon General, could use his
or her visibility to educate
Americans and to encourage all
of us to "pitch in." The
environment is one of the few
government-regulated areas
where everyone is affected and
everyone can help. More
difficult, perhaps, will be the
executive tasks of the Secretary:
setting a clear agenda among
competing interests, lending
focus to a very scattered field,
and building a national
consensus among many
conflicting voices.
The Secretary would also
need to play a strong hand at
the international negotiating
table. The rise in common
global problems—climate
change, ozone depletion, acid
rain, ocean pollution-will
require decisive American
leadership to achieve common
solutions. The Secretary, acting
as a peer with foreign
counterparts, would be able to
assert American interests and
initiatives. In this role, he or
she could help bring nations
together-to show, finally, that
our differences are small when
compared with the problems
we must face and solve
together.
44
EPA JOURNAL
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Senator
Frank R. Lautenberg
I see great opportunities for
the Secretary of the
Environment, in concert with
the Secretary of State and other
Cabinet officials, to bring about
new coalitions and new
compacts, among both
developing and industrialized
nations. To note only one
example, the Secretary could
call on the advanced
democracies to help developing
nations take control of their
environmental problems, even
as they labor to improve their
economies and give their
people a better life.
But the Secretary's greatest
challenge will be to work the
will of the people. Time and
again, in poll after poll,
Americans have asked their
government for environmental
protection and stewardship.
They have asked that a clean
environment be given top
billing now, before it is too
late. They have asked for it,
the President has pledged it,
and we must now accomplish
it.
We face no greater challenge
over the next few years
than restoring the integrity of
our environment.
The environment is under
assault. In my home state of
New Jersey alone, 42 million
pounds of toxic chemicals go
into our air each year, 55
million pounds into the water,
and 5 million pounds onto the
land.
In the United States, each of
us produces 1,300 pounds of
garbage a year. That's 1,300
pounds per person of plastic
bottles, newspapers, beer cans,
diapers, waste paper, and
styrofoam, and it's more than
we know what to do with.
As Americans, we contribute
more, per person, to the
depletion of the ozone layer
than any other people on
Earth.
Our climatic system has been
weakened by the cutting down
of forests and by burning fossil
fuels and otherwise releasing
(Lautenberg (D-New Jersey)
serves on the Senate Environment
and Public Works Committee.)
greenhouse gases. The climate
seems to be changing faster
than at any other rime in
human history, and the planet
appears to be getting warmer.
And in other countries
environmental degradation has
reached a crisis point. The
pollution in Bitterfeld, East
Germany, is so severe that its
children fall ill soon after birth,
and its people live five to eight
years less than the average East
German. The burning and
clearing of tropical forests
in Southeast Asia, Africa, and
Brazil are resulting in a loss of
biological diversity. Experts
predict that 15 percent of all
plant species will be eliminated
by the year 2000. And
devastating floods in
Bangladesh have been
exacerbated by deforestation in
the Himalayas.
The planet won't take it
anymore—not without a fight,
not without protest.
This challenge goes right to
the future health of our planet.
It goes to our natural resources,
the building blocks of our
ecology and environment. It
goes to the basic essentials of
nature, which provide our
sustenance. It goes right to our
ability to survive as a modern
society.
Few challenges we face are
more important than the
protection of our environment.
Today, all of us must be
environmentalists. Today, the
government needs to give the
environment the status it
deserves.
Making EPA a Cabinet-level
department is one small step
toward giving environmental
issues this priority. That's why
Senator David Durenberger (R-
Minnesota) and I introduced
legislation on the first day of
the 101st Congress that would
serve two important functions:
First, it would demonstrate a
new commitment to protecting
the environment. It would tell
people in the United States and
other nations that this country
puts a high priority on
preserving the environment
and enhancing the public
health and welfare.
Second, it would help EPA do
its job. It would give EPA
increased clout in:
•Obtaining necessary funding
•Working with other
departments whose actions
affect the environment
• Making national policy
decisions
• Dealing with other nations
who send Cabinet-level
ministers to meetings to
discuss environmental issues.
We can meet the
environmental challenges we
face. But it won't be easy.
Making EPA a Cabinet-level
department is not in itself
enough: We need more
funding, tougher enforcement,
and strong leadership. And
making EPA a Cabinet-level
department is no substitute for
strong environmental policies:
We need new or tougher laws
on air, water, and solid and
hazardous waste.
But as we accelerate our
efforts to meet the
environmental challenges of the
future, I believe that creation of
a Department of Environmental
Protection is one action we
must take to increase our
chances to succeed. _
SEPTEMBER/OCTOBER 1990
45
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The Agency and the Public:
Journalists Comment
Angry citizens at a public meelmy in Casmalia,
California, in 1989. This long-standing dispute
involves a commercial hazardous-waste
landfill.
EPA is frequently on the front
lines in dealing with the public.
Its programs involve a wide range
of controversial issues; its
decisions affect millions of people.
In the day-to-day business of
grappling with environmental
issues, how can EPA communicate
successfully with the public?
More specifically, how can the
Agency effectively inform people of
its mission, build understanding
of its policies and decisions, and
respond to public expressions of
concern ?
For this forum, EPA Journal
asked eight environmental
journalists around the country to
share their thoughts on these
questions. Their responses follow:
© Zachary Singer photo. Greenpeace.
Bill Dawson
A: an EPA public meeting a
few years ago, I witnessed
a clear case of government and
governed talking past one
another.
Plans for cleaning up a
Superfund site were being
aired. EPA officials were
thorough and professional in
explaining how they intended
to deal with the toxic waste. I
don't recall much that
distinguished this Superfund
presentation from others. In
my experience, they have
tended toward the technical
and, perhaps as a consequence,
a bit toward the tedious.
When time came for
questions at this meeting, a
concerned woman from a
nearby neighborhood
addressed EPA officials. She
wanted help in getting her
garbage picked up regularly.
At a meeting about hazardous
waste, household waste was
her top priority.
That exchange, while not
typical, reminded me of
something I try to keep in
mind as a reporter that might
help EPA improve its public
communications: Basically,
remember who you're talking
to.
Environmental issues can
seem distant to people mainly
concerned with maneuvering
through the obstacles of day-to-
day life. And despite the
recent burst of media attention
to the environment, many
people still have only passing
knowledge of the arcane details
inherent in these issues and the
exotic terminology that cloaks
such topics.
Whatever means EPA might
choose to bridge this gap, a
few guidelines can enhance
understanding and interest:
Minimize use of the special
lexicon used by environmental
professionals. Present enough
background information-
including political
controversies, scientific
uncertainties, and experts'
disagreements-to portray
frankly the context for policy
decisions. Finally, note links
between issues to illustrate
their interconnectedness. I
find, for instance, that people
are fascinated to learn that
ozone-depleting CFCs are also
greenhouse gases.
(Dawson is the environmental
writer for the Houston
Chronicle.)
Charles Seabrook
Action speaks louder than
words. If EPA wants to
get a message to the public that
the government is serious
about stopping pollution, EPA
must put its money where its
mouth is. The Agency must
get rougher on polluters.
When EPA causes a recalcitrant
polluter to go to jail or forces a
polluting company to clean up
its environmental problems, the
Agency is sending a message
loud and clear that it is serious
about protecting the
environment. It's amazing
how the word gets around.
The public's perception,
however, is that most polluters
are still getting away with
fouling the environment. In
the 1980s, EPA seemed
46
EPA JOURNAL
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reluctant to carry out its
responsibilities, and the public
got the impression that the
agency was unwilling, even
incapable of preventing
environmental degradation.
Now, as the Agency tries to
rebuild its tarnished image, it
must convince the public that it
means business. Press releases
about what EPA proposes to
do are fine, but they don't
amount to a hill of beans if
EPA doesn't carry out its
promises.
The Agency has proposed
numerous times, for instance,
to take serious action against
cities that perennially violated
federal clean-air standards, but
the action has never come.
Instead, more cities have been
added to the list of violators
than removed from it.
Even when action is taken
against a polluter, one wonders
if the effort was really worth it.
For instance, EPA sends out a
notice that XYZ Company,
which grossed $50 million last
year, was fined $25,000 for
violating a certain
environmental record. For a
company that makes millions
of dollars each year, a $25,000
fine is peanuts.
Perhaps the public would
be better served if EPA
described in detail the bad
things that XYZ company
actually did. When the public
finds out that a company is
polluting a stream in a
community, public pressure
can be much more effective in
making the company mend its
ways than the prospect of
fines. Most companies seem to
fear public opinion and bad
publicity more than fines.
(Seabrook is an environmental
writer with the Atlanta Journal-
Constitution.)
David P. Ropeik
These are times of worry, of
fear. Everywhere the
environment seems under
siege. Global warming, ozone
depletion, rain forest
destruction, smog, acid rain,
ground-water contamination ...
the list of problems is
frighteningly long; the issues
are complex. How the news
media explain these issues to
the public will help decide
whether society moves
constructively toward solutions
or accepts environmental
destruction as inevitable.
I think the news media
irresponsibly foster the
fatalistic view by pounding the
public with negative
environmental news.
Admittedly, the news is pretty
bleak. There isn't much
positive about a Love Canal, a
fetid Boston Harbor, a former
president who ignored the
clear truth about acid rain for
years, or the current lack of
leadership in Washington
which, despite scientific
consensus on global warming,
still refuses to take the
relatively painless actions the
rest of the industrialized world
is now embarrassingly out
front on. The news is often
genuinely pretty damn bleak.
But the media unquestionably
play up the negative, play to
the public's health fears that
stories about environmental
threats implicitly involve.
Does this sell papers, boost
ratings? Sure. A negative
story just seems more dramatic,
more journalistically satisfying,
than a positive one.
EPA can help. Regional
officials should find reporters
they can trust who will handle
stories responsibly and then
keep those reporters well-
informed about everything the
Agency is doing, whether it's
newsworthy or not. EPA
regional administrators should
contact local newspaper editors
and TV news directors to
advocate this kind of coverage,
not just call them when another
dump site has been found or a
polluter fined.
And the news media can do a
better job. More reporters
should be assigned to
environmental "beat" coverage
so they could develop the
background knowledge vital
for understanding and
explaining complex issues.
With environmental stories,
which so often involve issues
of public health, reporters and
editors have to be much more
vigilant than usual against the
temptation to sensationalize. I
don't suggest we ignore "bad"
news, just that we be balanced,
that we take into account the
potential for unduly fueling
public fear that our writing,
reporting, and decisionmaking
can have when dealing with
such volatile issues.
Walter Cronkite used to sign
off his newscasts, "And that's
the way it is." All the public
knows about "the way it is" is
what the news media gives
them. If we give the public
only frightening stories of
environmental health threats,
only news of an environmental
destruction, with no hope of
turning things around, that
hopelessness may invade the
public psyche, and our news
coverage will become a self-
fulfilling prophecy. We can
and must do better.
(Ropeik is environmental reporter
at Boston's WCVB-Channel 5.)
Myron Levin
EPA needs to do a better job
of communicating health
and environmental risks. It's a
difficult challenge because EPA
legal mandates do not cover
some of the most important
hazards, and public education
programs are skewed as a
result.
EPA's outreach to the
public is unavoidably driven
by its regulatory duties.
Citizens tend to assume there
is a perfect fit between the
hazards EPA regulates and the
things that are most harmful to
health and the environment.
This assumption is
understandable but mistaken.
Consider the issue of
Superfund sites, a dominant
subject of environmental news.
Yet many experts believe the
risk of disease and death from
waste dumps is less than from
certain unregulated (and less
publicized) hazards like
second-hand smoke, radon gas,
home and garden chemicals,
and even perfectly legal
industrial air emissions.
People can do more to reduce
their risk of cancer by cleaning
up their diet than by worrying
about a dump site a few miles
away.
Most people don't know
such things. EPA should try to
do a better job of telling them,
without defending or easing up
on toxic polluters.
The public's lack of
perspective on health and
environmental risks is
reinforced by the press, which
is yanked along by the news
hooks that regulation
invariably provides such as
clean-up orders, financial
penalties, consent decrees,
Superfund site lists, and the
like. Unregulated hazards
usually have no news hooks
and, in many cases, barely dent
the news columns. Citizens'
groups rise up to slay the
dragons depicted in the news,
generating more news hooks,
and so on in endless cycle.
There wouldn't be a
problem if the press were more
thoughtful and enterprising.
But even knowledgeable
reporters with independent
sources have trouble breaking
away on the more elusive and
time-consuming stories that put
risks in context.
For EPA, the situation
presents a dilemma and an
opportunity as well. Lacking
enough bodies to do all the
work Congress has assigned,
EPA has little reason to go
looking for additional work.
Still, working harder at risk
communication would not have
to drain the budget. There
would certainly be payoffs. A
more discerning public would
want EPA to have the
manpower and authority to be
a better environmental cop.
And citizens would be better
prepared to protect themselves
from hazards within their
control.
(Levin, an environmental reporter,
works for the Los Angeles
Times.)
(Continued on next page.)
SEPTEMBER/OCTOBER 1990
47
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Jane Kay
EPA has a great name. No
public relations firm could
think of a better one. It's
simple, straightforward, and
Dawson
Seabrook
Ropeik
Levin
Shabecoff
Bishop
euphonious, and it inspires
confidence.
Yet EPA can better live up to
its name as the nation's
guardian of the environment
and health by better conveying
to the public EPA's mission, its
record, its faults, and its
tribulations. From a reporters's
point of view, EPA could
accomplish this by lifting
controls on media queries,
increasing meetings between
reporters and high-level
officials, and giving us a wider
perspective instead of bits and
pieces of information.
Two presidents ago, the EPA
staff was accessible to
reporters. But now the Agency
has a policy that questions
must be funneled through its
Communications and Public
Affairs Office. The rationale is
that this practice makes life
simpler and more consistent.
On the contrary, it delays and
controls; it makes researching
stories time-consuming and
cumbersome.
Other agencies that deal with
sensitive issues—the U.S. Fish
and Wildlife Service and the
National Oceanic and
Atmospheric Administration,
for example—don't discourage
direct contact with their
experts. Their staffs use
judgment and discretion, and if
they can't or don't want to
answer our questions, they
refer us to someone who does.
The EPA policy suggests that
the Agency has something to
hide, and a change would be a
breath of fresh air.
Just as Bill Reilly at times
makes himself available to
reporters to say what's on his
mind and find out what's on
ours, the regional
administrators might do the
same. Twice yearly, reporters
could get an overview and an
update on important issues in
the region. In one region, the
top issues might be air
pollution or ground-water
cleanup. In another region,
ocean dumping might have the
highest priority. Thus, the
press could take a more
profound approach in its
reporting than simply reacting
to crises or announcements.
EPA doesn't need a bigger
work load, but it could help
reporters tame the beast of
information by giving us
overviews of various programs.
For instance, at the end of 1989
the Agency prepared a
valuable report on enforcement
accomplishments. Getting a
big-picture look at Superfund
sites, pesticide controls, and
new policies in handling
biotechnology and lead would
go a long way in combatting
the piece-meal approach that
we now struggle with both in
and outside the Agency.
(Kay is an environmental writer
with the San Francisco
Examiner.)
Janet Day
EPA ... SARA ... HSWA ...
FIFRA ... MCL ... NPL ...
NPDES ... EIS ... VOC ... TCE ...
PCB ... CO ... S02 ... NOX...
parts per million ... parts per
billion ... milligrams per liter ...
rad ... rem ... millirem ...
picocurie ....
Such seemingly simple
acronyms and measurements
become intimidating jargon
when tossed out to the general
public at meetings or in
newspaper stories.
In the two decades since
EPA's inception, the public's
knowledge of environmental
issues has increased, but so
have skepticism and fear as
new laws are created with new
acronyms to understand.
The question of how EPA can
more effectively communicate
with the public implies the
Agency is not doing that part
of its job very well. Such is not
the case in the regional office I
frequently contact, where
project managers and their
staffs are available to the media
rather than routing calls
through the press office.
Public hearings, community
meetings, informal press
briefings, and regularly
published project information
48
EPA JOURNAL
-------
updates help the public
understand the various issues.
But the communication could
be better.
Laws, abbreviations,
measurements, and scientific
conclusions all need to be fully
explained in lay terms.
In many cases, the Agency
needs to explain what studies,
reports, and projects are not, as
well as what they are. When
announcing a clean-up
agreement, settlement, or
study, Agency officials should
fully explain its limits.
People need to know that risk
analyses are not going to
provide a definite link between
a pollution source and
someone's cancer; that dose
reconstructions are only best
guesses of what may have
happened in the past; that diet,
occupation, and heredity have
as much to do with cancer as
does exposure to pollution; or
that the smoke from a fireplace
contains the same suspected
carcinogens as cigarettes.
The public needs to hear that
there are no easy answers and
that nothing occurs quickly. A
process, its shortcomings, and
its expected results need to be
as fully explained as the issue
itself.
In our area, the problems are
many and the solutions
complicated.
Denver is surrounded by
Superfund sites and choking
under some of the dirtiest—
albeit improving—air in the
country. The city is downwind
from a deteriorating nuclear
weapons plant and adjacent to
the Army's most polluted piece
of property.
Colorado and other Western
states are dotted with old
mines oozing toxic metals into
streams. These states have
become targets of crowded
Eastern states looking for
landfill space and incinerators.
The Rocky Mountain West is
struggling to find enough
water to meet its future needs
and to keep that water clean.
Facing all this, residents of
the region have a lot of
questions. They're struggling
to understand concepts such as
acre-feet of water, the 404c veto
process, state implementation
plans, best available control
technology, and the difference
between low-level and
transuranic radioactive waste.
Into the middle of this mess
step EPA and state and local
health officials, each trying to
simplify issues yet accurately
portray situations ranging from
leaking underground storage
tanks to nuclear-waste disposal.
The public and the media as
its interpreter have a lot to
digest.
(Day is an environmental reporter
with the Rocky Mountain News
in Denver.)
Philip Shabecoff
At the outset, let me say that
EPA already does a better
job of communicating with the
public than any of the other
federal agencies I have covered
during my 20 years of
reporting in Washington. This
is largely attributable to the
"fishbowl" policy instituted by
former Administrator William
D. Ruckelshaus in 1983 to
restore the Agency's then-
tarnished credibility. As long
as the leaders and staff of the
Agency continue to be
accessible, open, and honest
with the press and public, its
communications effort cannot
go too far wrong.
There is, of course, room for
improvement. My impression
is that the Agency can do a
better job in dealing with
people at the local level, at
least in some of its regions.
While reporting stories on
waste dumps, or incinerators,
or pesticides, or water-
pollution problems, I have
heard frequent complaints from
angry or frightened citizens
that EPA officials do not seem
interested in their problems
and only listen and become
active when threatened by a
lawsuit or political reprisals.
I understand that regional
offices are often overworked.
But conveying a sense of
understanding, caring, and
responsiveness to those people
who feel immediately
threatened by environmental
pollution is critical to the
success of the Agency. Some
way must be found to improve
community outreach on a
permanent basis.
Most of all, however, the
Agency can improve its
communication with the public
by developing a firmer sense of
its own mission. Although I
have found the career staff of
EPA to be among the most
dedicated public servants in
government, they frequently
receive mixed political signals
from whomever happens to
hold elective power. This
ambiguity inevitably is
communicated to the American
people. Is the Agency on their
side or the side of the
polluters?
There are other federal
agencies for promoting
economic growth and
commerce. EPA was created as
an advocate for and protector
of public health and the
environment. That is the
message it must convey more
clearly.
(Shabecoff is an environmental
reporter for the New York
Times.)
Gordon Bishop
In this "Decade of the
Environment," EPA has a
rare opportunity to reach out
directly and openly to its
grassroots constituents: the
millions of people who
consider themselves
"environmentalists."
From President Bush to the
rank-and-file members of
hundreds of national and local
ecological organizations,
America is ready for a real
"Environmental Revolution"
involving practically every
consumer and producer, each
of whom is ultimately
responsible for the quality of
his or her own life and that of
future generations.
Few governmental agencies
have the high media visibility
of EPA, ranking right up there
with NASA and the Pentagon
in name recognition. The
Agency's mission is clearly
defined and readily identifiable:
environmental protection.
As a journalist covering the
environment regularly since
Earth Day 1970 (but having
written my first pollution
article in March 1960), I have
carefully tracked EPA from its
inception, watching it grow
into what may soon be a full-
fledged Cabinet-level
operation. During these past
20 years, EPA cultivated a
fruitful relationship with the
media and flexed its new-
found might in trying to halt
and reverse some 200 years of
industrial pollution. The
public rallied behind this new
kid on the block—and EPA
responded by cracking down
on the polluters.
In the New York-New
Jersey region which is my
"beat," EPA opened its doors
immediately to public
participation, and a new eco-
consciousness emerged.
By the 1980s, however, EPA
began losing some of its
popular appeal by not being
forceful enough with polluters
and distancing itself from the
hard-core environmental
activists demanding timely
enforcement of anti-pollution
laws. Environmentalists from
coast-to-coast began suing EPA
to do the job it was created to
do: clean up the environment
and prevent further pollution.
EPA was obviously not
communicating effectively with
the public. It was losing its
credibility as America's
environmental leader.
To regain that public trust,
EPA's leadership must go to
the people in their
communities, listen to what
they have to say, and then
represent those people,
honestly caring for their
concerns. This cannot be done
in Washington, DC, or from
EPA's regional offices, but only
in town halls, schools, and civic
centers where residents are
meeting to deal with their
environmental problems.
(Bishop is environment editor and
columnist for the Star-Ledger in
Newark, New Jersey.)
SEPTEMBER/OCTOBER 1990
49
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What Do You Expect of EPA?
\Vhat do you expect of EPA? Tlte Journal
posed this question to three respondents who
have very different perspectives on the
Agency: a state official, an em'ironmentalist,
and an industrialist. Their commentaries
follow:
A State Official
by Chris Gregoire
Washington State Dept. of Emlogy photo.
Part of the Hanford nuclear site ir;
south-central Washington slaie EPA
the Washington State Department o/
Ecology, and the U.S. Department oi
Energy have entered B ni-parry
agreement (or a 30-vear -Jt'c
-------
we drew up an agenda designed to fulfill
the vision.
Environment 2010 has proven a great
success. The state of the environment
report won wide acceptance, with the
public turning out in record numbers at
statewide and local 2010 meetings. The
governor and key legislators endorsed
the agenda, and EPA provided a grant to
help fund the effort. EPA staff helped
state officials develop the initial report,
worked with the public at statewide and
town meetings, and aided in developing
the action agenda. The whole effort was
a fine example of involving the public.
Get the job done. I expect EPA to find
ways to accomplish environmental goals
that will not make them captive to
bureaucratic rules and regulations that
hinder the effort. As my friend Marc
Roberts of Harvard's Kennedy School of
Public Affairs would say: "What is the
question to which this is the answer?"
Will a rule, regulation, or process make
the environment better? I expect the
Department of Ecology to live by that
standard; EPA should as well.
Recognize a state's uniqueness. Fair,
impartial enforcement of national
standards is essential. However, it is
equally important to recognize that every
state has its own unique history,
geography, public perceptions, and
political reality. In pursuing national
goals, EPA should give each state the
latitude it needs to develop its own best
course of action.
A full partnership. We need EPA to ask
our agency the tough questions, listen to
us, and respond to our concerns.
Together, the state and federal
government can make environmental
laws work.
The Hanford nuclear site in south-
central Washington is an outstanding
example in which EPA and Ecology have
cooperated in dealing with a difficult
problem. This U.S. Department of
Energy (DOE) facility has produced
nuclear-weapons materials since the
Manhattan Project days of World War E.
Huge amounts of radioactive and
chemical wastes have been generated as
a byproduct, and much of these wastes
has been stored or disposed of
inadequately. The danger of widespread
contamination has been very real.
Until 1987, DOE officials maintained
that the facility did not have to comply
with state or federal environmental laws.
Ecology and EPA used a combination of
"legal threats and negotiation to develop a
unique three-party agreement to clean up
the site and bring its facilities into
compliance with state and federal
hazardous waste laws.
Demonstrate leadership. EPA should
provide a national vision of
environmental protection and
enhancement. Leadership is more than
just writing new laws and regulations.
We need a program which invites the
states and the public at large to
participate in reaching the vision.
Enforcing environmental laws, even in
an environmentally conscious state like
Washington, isn't easy. We, at the state
level, have great pressures from opposing
forces whenever we develop or
implement a new environmental
standard. We have only limited staff,
resources, and expertise. We need EPA's
help.
As a state agency, we need EPA's
pressure for support in carrying out our
mission. Finding a location, for example,
for a hazardous waste incinerator and
landfill has been very difficult. There is
understandable opposition from
neighbors of candidate sites, who are
worried about health and economic
consequences. Knowing that EPA is
watching to make sure we are following
federal standards correctly helps alleviate
their fears.
Ecology and EPA will have great
opportunities to work together in the
years to come.
We both have a problem with the public
perception of risk from pollution. Many
believe that pollution must be reduced
until there is no public health or
environmental risk. Their view has been
supported over the years as standards for
specific toxic substances have been made
increasingly more stringent. It is my
personal view that this policy will lead
us into a trap where vast amounts of
money are going to have to be spent to
achieve minuscule reductions in risk.
And, although government shouldn't
decide what the public wants, EPA and
the state agencies around this country
should find a way to communicate with
the public not only on risks, but on the
costs of reducing those risks.
On the problem of wastes, the State of
Washington set official goals last year to
reduce the amounts of wastes produced
in the state by 50 percent by 1995. We
lead the nation in solid-waste recycling at
28 percent; however, achieving a
50-percent reduction is a very tall order
indeed.
We now have a handle on the major
waste producers in our state, and they
are required to achieve waste-treatment
goals that are prescribed in permits.
New manufacturing techniques will yield
significant reductions. However, the
major decrease we plan for the 1990s will
have to come from yet another source,
and that is the citizen. We can't write
permits for 4.5 million individuals or
periodically inspect their homes. We can,
however, educate them to recycle their
solid wastes voluntarily, reduce their
dependency on products that result in
hazardous waste, and dispose of the rest
properly.
Frankly, in the case of recycling, our
citizens have been way ahead of
government. Citizens in several cities
forced local officials to start curbside
recycling programs instead of expanding
landfills or building incinerators. They
then signed up for curbside recycling
pickups at their homes. More than 75
percent of Seattle residents, for example,
embraced voluntary recycling almost
immediately.
In conclusion, I'm encouraged by the
direction EPA is taking under Bill Reilly
and Hank Habicht. Further, I have had
consistently good rapport with the
administrators in the Seattle regional
office. Both our agencies are headed into
their third decade. Will the 1990s be the
decade of the environment? Will our
agencies lead the nation into a new
millennium of ecological quality? It's an
intriguing challenge, and an opportunity
for government and our citizens.a
SEPTEMBER/OCTOBER 1990
51
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What Do You Expect of EPA?
An Environmentalist
by Michael McCloskey
In its 20 years of existence, EPA has
accomplished a great deal, and it has
passed through some of its darkest
moments. Nonetheless, it still strikes
many environmental activists as an
agency that has lost its way.
Despite more sympathetic leadership
now than in the recent past, it still has
not overcome its most fundamental
problems. What might those problems
be? They can best be understood by
considering five basic questions:
• Is EPA willing and able
to do its job?
To do the job assigned to it, EPA needs
talented, innovative staff in adequate
numbers. However, the Agency has
suffered from hiring freezes that have left
it far short of the staffing it needs to
handle a workload that has doubled over
two decades.
EPA has also lost any inner-directed
sense of how to pace and present itself as
an agency that intends to fulfill its
mission. It has suffered too much from
rough handling by political appointees,
and a legacy of intimidation hangs over
it.
The net result has been a hemorrhaging
drain of many of its most experienced
and imaginative people. As a
consequence, inexperienced, junior staff
are handling too many taxing
responsibilities. Now the Agency must
rely on its contractors even to design the
questions that EPA, in turn, asks them to
answer. In short, EPA lacks enough
experience and brainpower to be
effective. Its institutional memory is in
the hands of its contractors.
In fact, EPA seems almost the model for
Marver Bernstein's theory of agency
decay. (According to Bernstein's theory,
regulatory bodies typically follow a life
pattern that begins with genuine ardor to
earn' out their legislated mandates but
then proceeds through fairly predictable
stages of disenchantment and decline.)
In its early years, EPA was full of zeal to
achieve its mission. Now after 20 years,
is Chairman of the Sierra Club.)
it is middle-aged and cautiously
balancing its objectives. Some observers
even detect in EPA the early stages of
senility, in which an agency just "goes
through the motions."
Yet one can understand why EPA seems
gun-shy. At the outset, Congress may
not have foreseen how politically charged
EPA's work would become. Every
decision the Agency makes is freighted
with political importance. Instead of just
doing technical work, EPA is caught in
the middle of endless cross fire between
complaining industries and
environmentalists. Too much is at stake
for EPA to be left alone.
When compelled to do the work of
politicians-when it must mediate
disputes over controversial questions—
EPA is forced into work that it is ill-
equipped to do. Lacking hired cadres of
politicians, it suffers a mismatch of
talents. It adapts by trying to stay out of
harm's way; it tries to minimize the
number of times it exposes itself to the
withering fire. It thus leaves the job to a
kind of trial by combat among the other
parties.
• What, then, is EPA's attitude
toward its work?
Environmentalists suspect that EPA sees
itself less and less as an advocate for the
environment and more and more as an
umpire calling "balls and strikes." When
EPA began, environmentalists thought it
would serve as a counterforce to the
Commerce Department, which is an
advocate for business and industry. We
wanted a critical mass of talent to be
recruited for a single purpose:
improving the environment. Once
environmental objectives were
consolidated and given to the new
agency, we thought EPA would avoid
getting caught in the kinds of conflicts
over competing missions that had
EPA JOURNAL
-------
occurred within other federal
departments and agencies. It would be
judged, we thought, by a single measure:
Is it leading the way toward a better
environment?
But is EPA putting forth strong
positions that challenge skeptics in the
Office of Management and Budget and
the Commerce Department? All too
often, EPA puts forth proposals that are
compromised from the start and then
weakened even further in the process of
attrition. The process of compromise
begins too early within EPA.
And is EPA any longer concerned with
getting results? Environmentalists had
hoped that EPA, like the Corps of
Engineers, would have a "can do"
attitude, that it would dauntlessly
persevere to push down pollution levels.
Yet many now sense that EPA sees itself
less as a "mission-oriented" agency and
more as a process-oriented one. EPA
often seems to be concerned with moving
paperwork along as if that were an end
in itself.
Moreover, much of this paperwork is
cast in the context of an ostensible quest
for "good science" to undergird the
Agency's work. EPA may feel it can
escape from political cross fire by
claiming its proposals simply reflect a
pursuit of the implications of scientific
research. Yet, characteristically, much of
EPA's mission involves very different,
value-laden notions-such as margins of
safety, burdens of proof, burdens of risk,
the benefit of the doubt, and acting
ahead of definitive proof of cause and
effect relationships.
The quest for the Holy Grail of "good
science" plays into the hands of the
agents of delay—those in industry who
will always want to put off the day of
reckoning by pointing to shortcomings in
what is definitively proven. The cry of
"good science" originates with industries
seeking exemptions and delays. It is all
too easy for EPA to "study issues to
death" and duck making decisions.
EPA's managers need to realize that the
Agency's mission can be achieved only
by making value judgments and acting in
a timely way-acting in advance of full
scientific understanding. Although lately
(since 1989), EPA seems to have restarted
its engines and begun issuing regulations
once again, the long-term record is one of
growing indifference to its statutory
mandates. For instance, it has done little
to implement the Toxic Substances
Control Act (TSCA), or to regulate toxics
in air pollution, or to require pre-
treatment of wastes by industrial water
polluters.
As a result, in frustration, Congress has
taken away more and more
administrative discretion and made more
and more things mandatory. EPA and
Congress have drifted into an unhealthy
relationship, with neither trusting the
other. An ultimate expression of EPA's
defiance of Congress can be seen in its
own efforts to select priorities for its
work with near indifference to
Congressional direction. It acts as if it
has discretion where it doesn't, as if
Congressional mandates were somehow
not the law.
If EPA is overloaded, unable to do parts
of its work, it should say this plainly to
Congress and ask for guidance.
• How does EPA view the public?
EPA's best chance of gaining the public
support it needs lies in reaching out and
communicating clearly with the public.
Through much of its history, it has failed
to do that.
EPA acts as if it can surmount
difficulties by being invisible and
inscrutable. Like most bureaucracies,
EPA has its own specialized vocabulary
and speaks almost in code regarding its
work. To make its work sound more
scientific, the Agency tends to
overcomplicate its actions. The result is
that it talks only to itself and a small
cadre of specialists who have made it
their business to crack the code.
But the public is seldom able to fathom
what EPA is talking about. And EPA
does not even seem very interested in
talking to the public. Most press
statements are as "gray" and
uninteresting as possible. Only a
halfhearted effort is made to translate
jargon for public consumption.
EPA does get into the press, due to the
importance of its decisions, but its actions
often come across as arbitrary and
inscrutable, partly because no advance
work has been done to give the public a
proper frame of reference. All too often,
some hypertechnical decision suddenly
hits the newspapers, and EPA's friends
haven't even been briefed.
With the exception of a time in the late
1970s, EPA has not seemed interested in
presenting itself in an attractive and
intelligible way to the public. It acts, in
short, as if it doesn't need friends.
EPA could mobilize support by
developing and clearly defining standard
indicators of pollution levels across the
country. There should be indices of the
severity of pollution of different media,
nationally and locally. These should be
communicated through graphic devices,
like thermometers, which are easy to
understand.
But these have never been developed.
EPA has not made it easy to understand
SEPTEMBER/OCTOBER 1990
53
-------
why more regulation is needed. EPA
seems to prefer to operate in a public-
relations vacuum.
• How does EPA relate to the
environmental movement?
Most of EPA's programs have been
shaped by the environmental
movement's efforts to persuade Congress
to tighten the laws relating to the
environment. Some of these laws would
not exist were it not for the movement's
exertions. Moreover, lawsuits filed by
environmental groups have at times been
the principal enforcement mechanism for
environmental laws.
Yet the environmental movement is not
treated as the Agency's core constituency.
Instead it is kept at arm's length, almost
as if contact might contaminate EPA.
Environmentalists are rarely put on
EPA's advisory boards or asked for
opinions on how things should be done.
Environmental lobbyists who know the
legislative history are often ignored.
Part of this reaction may stem from
political fear during times when
environmentalists have been at odds with
sitting administrations. Yet, the basic
indifference persists regardless of
administrations. EPA career people keep
a very low profile regarding first-hand
dealings with people in the
environmental movement. As a
consequence, EPA comes across as
remote and indifferent.
The problem is compounded by the
unevenness of the contest between
environmental and industry lobby
groups. Environmentalists are unable to
assemble a vast team to match industry
in stalking the course of every piece of
rule-making and standard-setting. They
cannot stand toe-to-toe to match industry
on an incredible variety of highly
technical questions. EPA could help
environmentalists be more competitive
by regarding them as a source of
assistance. Instead, EPA treats them as
just another vested interest lobbying for
special advantage.
All of this is made worse as the process
is turned into an endurance contest. Our
ill-equipped and thin forces can rarely
finish these long marches. But not only
do we fall out; so also does the public
interest. Every step in long processes
that go on for years becomes another
potential failure point or ambush point
where industry can prevail and sideline
further regulation. As a result, EPA is
left with no one to rally needed help.
To survive, EPA needs to shorten these
processes, pass through fewer ambush
points, and enlist allies from the
environmental movement to help
defensible proposals advance to see the
light of day.
• Is EPA accountable?
As the years have passed, EPA has not
delivered "fishable and swimmable
water" by 1983, nor much of anything
else by Congressional deadlines. EPA
does not act like it is accountable to
Congress or the public. It acts more like
an assembly of people showing up for
work and collecting pay checks.
EPA does not make it easy for the
public to determine whether it is getting
results. When reports are issued on
trends in air-pollution levels, it is difficult
to see a coherent pattern in the material
presented. Changing standards, shifting
monitoring stations and data sites, and
confusion over technical terms like
"boxplots" and variable use of geometric
and arithmetical means: All these suggest
almost a calculated desire to keep the
reader from understanding what is being
said. The reports on progress made in
cleaning up water pollution are even
worse; for example, the conditions of
different sets of water bodies are
compared each time, making it difficult
to discern any real pattern.
The public is kept at bay, and it is hard
to know whether conditions are getting
better or worse. No good baseline has
been set against which to measure
progress. There are no indices of
composite conditions. International
standards of comparison are seldom
employed. We have no idea how the
United States compares with other
advanced nations—for example, Sweden,
Switzerland, and Japan.
Many in the environmental movement
also fear that the "books were cooked"
during the Reagan years and that figures
now offered to show advances during the
1980s are simply not true. That is why
Congress is being urged to set up a
Bureau of Environmental Statistics which
would be insulated from politics.
EPA may be caught in a sort of "Catch
22" in which it seeks to distance itself
from politics and in doing so becomes
even more suspect of being unresponsive
and unaccountable. Frankly, most of the
environmental movement has no idea
whether EPA is delivering the goods or
is dawdling and hiding.
EPA's failure to be accessible and to
communicate intelligibly has left it
wounded and vulnerable. It is seen
largely through the prisms afforded by
the political appointees placed over it.
Its career cadres need to break out of
their isolation and put the Agency in
touch with those who want it to succeed.
They will be surprised how easy it is to
recruit allies. But those would-be allies
can only be supportive if they are armed
with solid information and treated as
collaborators.
It is time to initiate a new era
for EPA. n
"Does our 'P stand for pollution"or procrastination?" ***** * permissim ofNEA'
54
EPA JOURNAL
-------
What Do You Expect ofEPA?
An Industrialist
by Frank Popoff
If American industry could wave a
magic wand, what kind of EPA
would it create? No doubt this is a
question many of us in the chemical
industry have contemplated during the
past 20 years. After all, with the possible
exception of the Internal Revenue
Service, no federal agency wields more
power over businesses such as ours than
does EPA.
But the answer might surprise some
people. Those who think we would
choose to transform the Agency into a
skeleton of its former self, devoid of
influence and strength, are mistaken. In
fact, just the opposite is true. I believe
industry's best interest lies in an EPA
that is strong and successful, credible and
consistent, with the conviction to base its
decisions on science and technology-not
on political expedience.
It's vitally important for EPA, as
industry's environmental watchdog, to
have some bite behind it. Much of
industry's credibility with the public
hinges on how well people feel EPA is
doing its job. While the prospect of
ineffective regulators may seem
appealing to some in the business
community, the long-term consequences
of such weakness would be devastating.
As history has shown repeatedly, when
the public perceives that industry is
making off with the store while
government looks the other way, the
subsequent backlash is swift and severe.
The result can be arduous, ending up in
unreasonable regulations that cost
taxpayers dearly without achieving
significant benefits.
One way to strengthen EPA is to elevate
the Agency to Cabinet-level status. The
Chemical Manufacturers Association
Tne Cow Chemical Company is involved in several waste-reduction programs,
TiCiuJinq ori~ a! ils Specialty Chemicals Department in Pitlsburg, California,
wi.ere .5 major reduction has been achieved in air-pollutant emissions.
(Popoff is President and Chief Executive
Officer of The Dow Chemical Company.)
SEPTEMBER/OCTOBER 1990
(CMA) is on record as supporting such a
step. The resulting Department of the
Environment would be in a stronger
position to take the lead in forming new
partnerships to break the "environmental
gridlock" which now grips this country.
By environmental gridlock, I mean the
adversarial relationship which too often
exists among government, industry, and
special interest groups. Our increasingly
complex environmental problems seem to
be stuck in a traffic jam, with everyone
honking horns from all sides and
nothing much being accomplished.
Industry is as much to blame for this
situation as anyone else. In the past,
we've been reactive, not proactive, at
times recalcitrant, and not as enlightened
as we should have been with respect to
environmental concerns. In recent years,
we've come a long way in improving our
performance. For example, in 1989
members of the CMA voluntarily
launched a bold initiative called
"Responsible Care." This self-help
program-members helping members-is
designed to promote continuous
improvement in the chemical industry's
environmental, health, and safety
performance.
As an indication of industry's extensive
commitment to this program, CMA
-------
member companies have voted to make
participation in Responsible Care an
obligation of membership in the
association. That obligation includes
pledging to observe a number of guiding
principles and practices, including a
commitment to achieve ongoing
reductions in releases to air, water, and
land. Those who fall short will be
disassociated.
Programs like this are an important
step. Now, we need EPA to be the
catalyst in lowering the level of rhetoric
and getting everyone to the table.
Government has to take the initiative. I
believe EPA Administrator Bill Reilly has
the requisite respect and confidence of
the environmental community, industry,
Congress, and the President to bring all
the parties together.
At the same time, it's important to
remember that industry brings to the
table the technological know-how that
can help lead to meaningful solutions.
The stakes are too high and problems too
urgent for this gridlock to continue.
A stronger EPA would be more likely to
formulate policy based on sound
scientific data instead of political
pressure and public opinion polls. We
commend Mr. Reilly for his efforts to do
just that. Over the years, science seems
to have taken a back seat to politics as a
criterion in setting our national
environmental agenda. EPA needs to be
more successful in getting Congress to
agree to its priorities rather than the
other way around. True, Congressional
oversight is an important part of the
process. But when you consider that
more than 90 committees and
subcommittees now have jurisdiction
over some aspect of EPA, it becomes easy
to see how pressure from Capitol Hill
can stifle the Agency's effectiveness in
setting sound scientific policy.
Along those lines, we believe EPA
should closely examine the way it uses
risk assessment in its decision-making
process. We encourage the increased use
of risk assessment as a tool for
prioritizing what needs to be done. Our
society's resources are limited, so it is
vital these resources are spent in
attacking the problems which most affect
the public.
However, risk assessment should be
used only as a tool in priority setting, not
as the final regulatory criterion. Other
elements need to be factored into the
equation: costs, benefits, alternatives,
and technical feasibility. As a recent
example, we believe EPA effectively took
these criteria into account when it
contributed to the debate surrounding a
new Clean Air Act. But when these
pieces of the puzzle are ignored, the
result can be laws and regulations which
only hurt industry and cost us jobs
without benefiting anyone.
The key to environmental improvement
is to set targets that are cost-effective and
attainable. And once a suitable target is
Our increasingly complex
environmental problems seem to
be stuck in a traffic jam, with
everyone honking horns
from all sides ....
established, industry should be given the
flexibility to decide which technology is
most appropriate to get the job done. In
other words, give us a destination based
on sound data and realistic standards;
then let us figure out the best way to get
there.
Educating the public about
environmental issues—especially
environmental risks-also should be an
important EPA objective. There is so
much information floating around from
so many sources that it's difficult for
anyone to figure out what to believe.
Here, EPA can step in with its scientific
expertise and help put things into
perspective. Such perspective was badly
needed during the recent Alar apple
scare.
We would also like to see EPA use
creative policies and regulatory strategies
to encourage pollution-prevention and
waste-reduction activities, instead of
focusing on end-of-the-pipe treatment.
Most of our regulations today deal with
the management, treatment, and disposal
of waste after it is produced. By taking a
voluntary waste-reduction approach at
Dow, we have been able to eliminate
many wastes before they ever reach the
end of the pipe.
Our company has a program called
WRAP-Waste Reduction Always Pays.
It's an appropriate name because not
only is waste reduction good for the
environment in that it greatly reduces
emissions, it's also good for the bottom
line. For instance, our Louisiana Division
spent more than $12 million on 47 waste-
reduction projects over the past two
years and will be spending another $4
million this year alone. These projects
reduce thousands of pounds per year of
waste and emissions. Beyond that, they
provide hefty dividends in the form of
lower operating costs and higher
productivity by enabling us to improve
product yields and reuse and recycle
waste into valuable products.
The environmental dividends have been
substantial. Thanks in large part to these
waste-reduction efforts, our air emissions
in the United States have dropped by
more than 50 percent since 1984, and we
are committed to another 50 percent
reduction by 1995. Several companies in
our industry have similar success stories.
EPA should take the lead in encouraging
others to hop on the waste-reduction
bandwagon.
Finally, we encourage EPA to seriously
consider the global nature of our
industry when formulating its policies.
This means assessing how regulations
enacted in this country will affect our
ability to compete abroad. We all want a
healthy environment. We also want a
healthy economy with the necessary
resources to address environmental
concerns.
At Dow we believe that in the coming
years environmental issues will have
more bearing on our company's success
than any other factor. I'm proud of our
progress, but at the same time I realize
there's room for continuous
improvement. We can do better, and we
will do better. f-
EPA can help by setting a national
agenda for environmental reform,
playing a leadership role in getting
industry, special-interest groups, and
government to work together on
solutions, and by using science to guide
Agency decisions. Quite simply, if EPA
can succeed, we'll all be winners.- a
56
EPA JOURNAL
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The Road We've Travelled
by Phyllis Myers
The creation of the Environmental
Protection Agency on December 2,
1970, was not a major press event. Only
brief articles inside The Washington Post
and The New York Times mentioned the
new agency and Congress' unanimous
confirmation of William Ruckelshaus as
its first Administrator. To The Wall Street
Journal, the occasion merited seven lines
at the end of its domestic news
summary.
With words still surprisingly fresh,
President Nixon called for the creation of
"a strong, independent agency ... to make
a coordinated attack on the pollutants
which debase the air we breathe, the
water we drink, and the land that grows
our food."
There was little quibbling in Congress
over Nixon's reorganization plan, which
transferred air, solid waste, radiological
monitoring, water hygiene, and pesticide-
tolerance functions from the Department
of Health, Education and Welfare; water
quality and pesticide-label review from
the Department of the Interior; radiation-
protection standards from the Atomic
Energy Commission and the Federal
Radiation Council; and pesticide
registration from the Department of
Agriculture. The transfers included 56
research laboratories located all over the
country. Many of the "charter"
employees at their desks on December
2nd in the new agency remain with EPA
today-about 300 at headquarters, and
1,200 throughout the regions and field
stations.
EPA's authority was strengthened
within weeks by the reauthorization of
the Clean Air Act. The new amendments
called for national standards for ambient
air quality, and state plans describing
how the standards would be attained.
After EPA approval, the plans were to be
enforceable by state and federal law.
Each of the responsibilities transferred
to EPA would receive stronger authority
within the decade; and new programs
(Myers has authored a number of
publications and articles on environmental
issues and is President of State Resource
Strategies. For this article, she interviewed
EPA employees past and present and has
written here a retrospective view of the
Agency based on their comments.)
William D. Ruckelshaus
would be added. Congress addressed
each issue separately, in part because its
own responsibilities for the environment
were fragmented.
The new agency, meanwhile attracted
long-haired, bright, enthusiastic, and
unseasoned workers. "Every young
person worth his salt came here looking
for a job," says Chuck Elkins, now head
of the Toxic Substances Office.
EPA's Early Years
Ruckelshaus and his staff set up
temporary offices at the
old Normandy building, near the White
House. The building, slated for
demolition, was "the pits," recalls Phil
Angell, who was recruited to staff the
new agency's public affairs office. "I
had a little grey office: a grey desk, a
grey chair, a grey manual typewriter, and
a fluorescent fixture. That was it."
Other headquarters personnel were
scattered in separate program offices
around the Washington region. Alan
Eckert, now Associate General Counsel
for Air and Radiation, remembers the
first "all hands" meeting. "We had to
rent a movie theater because there was
no room in our offices large enough."
Ruckelshaus let his staff know early on
that he wanted to "hit the ground
running." Soon after, he announced that
EPA was filing violation notices on three
cities-Atlanta, Cleveland, and
Detroit-for lagging performance in
building wastewater treatment plants.
He followed with action against the Jones
and Laughlin Steel Company and other
industrial giants. ,
His commitment to stronger
enforcement was evident in the number
and quality of attorneys brought on
board. The first two months saw five
times as many enforcement actions as all
the programs united under EPA had
initiated during any similar period. John
Quarles, general counsel and later deputy
administrator, remembers: "We were
caught up in the spirit of the times, the
personality of Ruckelshaus, and the fact
that in a new agency everything was up
for grabs."
DDT was already under a limited ban
when Ruckelshaus took office. The issue
he faced was whether to suspend its use
entirely. Testimony from blue ribbon
scientific panels about its effects on
mammals, manufacturers' arguments that
direct effects on humans had not been
proven, agronomists' warnings about its
importance to the economy, and a law
suit filed by the Environmental Defense
Fund crossed his desk. He made the
long-awaited announcement to phase out
domestic use of the pesticide in June 1972
at the United Nations Conference on the
Human Environment in Stockholm. He
said he was convinced by "evidence in
the record" that the storage of DDT in
human tissue and its persistence in the
food chain posed "a warning to the
prudent" that people "may be exposing
[themselves] to a substance that may
ultimately have serious effects on ...
health."
Reauthorization of the Clean Water Act
in 1972 completely revised the nation's
approach to water pollution. After
contentious debate about "zero
discharge," Congress set an interim goal
of "fishable" and "swimmable" waters to
be attained within a few years. It
mandated national effluent limits for
industrial and municipal discharges and
a permit system based on these
guidelines. The measure was approved
over White House objections to the
"budget-wrecking" $18 billion grants
program to build wastewater treatment
plants.
Confidence that environmental
protection was a finite job soon began to
erode. Dr. Robert Fri, who was
Ruckelshaus' deputy, remembers: "It all
seemed so straightforward at first. But
SEPTEMBER/OCTOBER 1990
57
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even in the two years I was there, one
could easily see how difficult it would
become." The statutes reflected
Congress' conviction that technological
breakthroughs would follow if only
industry were forced to spend enough
money. "At this stage, the Agency was
able to argue that cost was not an issue
.... Pollution was egregious. It would
have been difficult to spend dollars
unwisely." Ruckelshaus refused to grant
extensions requested by automobile
manufacturers to meet hydrocarbon and
carbon-monoxide standards, in effect
forcing adoption of the catalytic
converter.
As Watergate clouds darkened over the
nation's capital in 1973, the White House
asked Ruckelshaus to take over the
troubled FBI. His successor at EPA was
Russell Train. The climate had changed
perceptibly, Train recalls. His
confirmation by Congress took three
months, in contrast to the one day for
Ruckelshaus. A Who's Who description of
Train as a "conservationist" and his
earlier work on a surface mining bill
disquieted some industry critics. "There
was a nice passing of the flame, though,"
says Train. "I was sworn in by Attorney
General Eliot Richardson, with Deputy
Attorney General Ruckelshaus looking
on. They were both soon gone, after
Richardson was fired and Ruckelshaus
resigned."
The DDT decision was put to the test
when a plague of Tussock moths hit the
Northwest forests. The only known
control was DDT. "All the region's
governors, including Tom McCall, a
strong environmentalist, its powerhouse
Senators-Jackson and Magnuson-and
the entire House delegation supported
using DDT," Train recalls. "We were told
that the normal cycle would lead to the
collapse of the Tussock moth at some
point. But when? If it went beyond one
year, the economic impact would be
enormous. I announced my decision to
approve the use of DDT under carefully
controlled conditions in a Seattle press
conference. I remember today
environmentalists sobbing in the room."
Despite his strong conservation
credentials, says Train, "my relations
with environmental groups were about
as hairy as that of most Administrators.
One evening [Supreme Court Justice]
Byron White said to me, 'You're the most
litigious son of a bitch. Your name is on
a thousand lawsuits.'"
Nevertheless, by January 1975, writing
in EPA Journal's inaugural issue, Train
58
Russell E. Train
could point to "real headway .... Our
investments in municipal and industrial
point-source controls are beginning to
pay off in pollution reduction-in lower
counts of bacteria and biodegradable
oxygen demand, and in less phenols. In
air, total suspended particulates and
sulfur-dioxide concentrations have
significantly declined." In 1976, the
Toxic Substances Control Act (TSCA) was
finally passed. The Kepone tragedy at
Hopewell, Virginia, PCB contamination
of the Hudson River, and the accidental
poisoning of cows by PBBs in Michigan,
had kept the toxic issue simmering. Al
Aim and Terry Davies, who had worked
under Train at the Council on
Environmental Quality (CEQ), had
written an influential report on toxic
substances that led to the law. (Davies is
now EPA's Assistant Administrator for
Policy, Planning, and Evaluation.)
"We began to think about ways to deal
with risk," says Aim, who became an
assistant administrator under Train at
EPA. "Train asked me to develop a
policy on cancer. The Carcinogens
Assessment Group was the beginning of
risk assessment machinery. We issued
effluent guidelines and set up the
organization for TSCA. The Safe Water
Drinking Act was passed, and then the
Resource Conservation and Recovery Act
(RCRA). We set up the beginnings of the
Science Advisory Board (SAB). We did a
lot. There weren't so many
encumbrances then."
The Late Seventies
"We didn't realize how complex the job
would be," says Doug Costle, President
Carter's choice for EPA Administrator.
Costle had directed the study that led to
EPA's creation. His appointments
included David Hawkins as assistant
administrator for air, formerly an
attorney for the Natural Resources
Defense Counsel, and Tom Jorling, who
as minority counsel on the environmental
and public works committee had played
a substantial role in crafting EPA's water
and air statutes. Steve Jellinek, formerly
with CEQ, was named to implement
TSCA and the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA),
which was overhauled in 1978.
Costle faced not only a growing backlog
of regulations and lengthening deadlines,
Douglas M. Costle
but also widening recognition of the costs
and time it would take to meet the
ambitious goals mandated by Congress—
if they could be met at all. In the
beginning "most of us thought we
would take care of the big problems in
short order, and then it would be a
matter of maintenance," says Elkins. "We
began to see this wasn't the case in the
late 1970s when we were missing all the
deadlines in the new programs. We
thought then that the deadlines were
tough, but now we see they were
laughable."
The laws were written so that we
would need a policeman at every corner,"
worried Costle. Court suits, filed by
environmentalists on the one side and
industry on the other, became a fact of
Agency life. "The Clean Water Act ...
assumed zero emissions were
achievable," says Costle special assistant
Mary Ann Massey. "The Natural
Resource Defense Council sued, and the
court directed EPA to comply with the
law. 'How can we do it?' we asked. 'You
figure it out/ said the court."
"But," says Massey, "we also began to
think about the bubble policy. This was
EPA JOURNAL
-------
Bill Drayton's idea, putting an imaginary
dome over a region and allowing
industry to trade emissions within the
region, providing they didn't exceed the
limits for the overall bubble." Dray ton,
who directed the Planning and
Management Office, observes: "First,
government writes the rules. Then it
creates the situation where the regulatees
can make a counterproposal and find
cheaper ways of accomplishing the same
things. Innovation in pollution control
technology is unquestionably the most
important need .... If you're stuck with
static technology, then the environment is
in big trouble, since pollution is
increasing."
Meanwhile, Three Mile Island, Valley of
the Drums, and Love Canal catapulted to
headlines and TV screens. Grassroots
heroes and heroines aired fears about
"ticking time bombs." As a result, EPA
was positioned more firmly as a health
protection agency.
Hazardous waste had been addressed
in the Resource Conservation and
Recovery Act (RCRA), the "cradle to
grave" legislation enacted in 1976 to
regulate its generation, storage,
transportation, and disposal. "Congress
thought the job was done when it passed
ambitious laws," observes Sylvia
Lowrance, director of the Solid Waste
Office. "But its laws just set forth broad
requirements. When this office was
established, we didn't know who
managed hazardous waste, where waste
was, and what the problems were."
Today one of EPA's largest programs, the
Office then had 11 people watching over
an inventory of municipal landfills.
The crises also led to the creation of a
ground-water office in 1984. "We had a
lot of Lois Gibbs stuff. People were
excited, rightfully so," says Marian Mlay,
today the Office's director. "Costle asked
us, 'What are we doing about ground
water?' I didn't know what ground
water was. Yet it supplies half of our
drinking water."
"We were always running behind," says
Costle. "Every Christmas in Woodstock,
Vermont, there's a horse parade through
town. Always at the end, there is one
carriage with a man holding a shovel.
When you see him, you know the parade
is over. EPA was like the guy who was
picking up the shovel, going from one
pile to another."
In 1980, in one of his last presidential
acts, Carter signed the Comprehensive
Environmental Response, Compensation
and Liability Act (CERCLA), authorizing
SEPTEMBER/OCTOBER 1990
a "shovels first, lawyers later" approach
whereby EPA would respond
immediately to emergencies caused by
abandoned waste dumps. A five-year,
$1.6 billion trust fund-Superfund—was
established, financed primarily by a tax
on industrial chemicals. The federal
government could sue for recovery of
costs if the liable parties could be found.
Defederalization
In 1981, the Reagan agenda of
defederalization, severe budget
cuts, and regulatory reform swept
through the nation's capital. EPA was
widely seen as a special target. In the
words of Anne Gorsuch, EPA's new
Administrator, "There was no riper
pasture for regulatory reform than EPA."
Gorsuch was, like her predecessors, an
attorney. Otherwise, her credentials
differed substantially. She had gained
visibility as an outspoken conservative in
Colorado's state legislature. "When
Anne Gorsuch
President Reagan asked me to head the
Environmental Protection Agency, I
understood that he wanted me ... to get
out better environmental results with
fewer people and less money ....
Excessive regulations, burdensome
paperwork for industry and government,
federal-state friction, and huge costs at a
time of increasing economic stringency ...
were clear signs that change was needed
in the 1980s.
"One of the things I'm proudest of is
my EPA management system," says
Gorsuch. "I came to the EPA believing
that the budget was the tool of
management, and through it one
controlled policy direction." Personnel
was reduced by 22.6 percent, and the
budget pared from $701 million to $515
million, in constant dollars, excluding
Superfund. The federal share of
construction grants was reduced to 55
percent, and the long-term federal
commitment from $90 billion to $36
billion. Nevertheless, widening public
perception that serious environmental
hazards were being mismanaged or
worse was brought to a head by dioxin
contamination at Times Beach, Missouri,
the firing of Rita Lavelle, who
administered EPA's Superfund and
RCRA programs, and the refusal of
Gorsuch to comply with Congress'
demand that she turn over internal
Agency documents dealing with
Superfund enforcement. She resigned in
March 1983 because, she said, she "had
become an issue in the intense
Congressional controversy about
Administration policies."
Back on Track
President Reagan asked Ruckelshaus to
serve again as Administrator. The
caption on EPA Journal's cover called his
return "the dawn of a new era." When
Ruckelshaus talked to EPA's staff the
first time, "it was like the liberation of
Paris," says Eckert.
Al Aim returned as deputy and Phil
Angell as chief of staff. Lee Thomas,
who had headed the emergency
response team at Times Beach,
became assistant administrator for
the sensitive hazardous waste program.
"The landscape had changed
completely," recalls Angell. "I didn't
recognize the legislation—the Clean Air
Act amendments, and RCRA and
Superfund struggling to come into being.
We faced a new generation of programs:
toxic chemicals, acid rain, orphan dumps,
and transboundary issues. It was
remarkable and reassuring, however, to
find that a number of people I knew
were still there."
"I thought it was important to move
quickly," Aim points out. "We needed to
deliver. It was essential, and surprisingly
difficult, after years of slower pace, to get
the Agency back in a positive mode."
Aim set up 10 task forces to deal with
such issues as ground water, dioxin, acid
rain, and risk assessment. Enforcement
was reinvigorated. Civil penalties
59
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increased in number and size. And "we
brought great new people in."
The role of the Science Advisory Board
was strengthened. "When EPA was
created, we had a large base of
information about air and water built up
over many years," says Erich Bretthauer,
current head of Research and
Development. "In the mid-1980s different
problems surfaced-acid rain, climate
change, sedimentation-that were much
more complex and for which we lacked a
research base."
"Ruckelshaus talked about integrated
legislation to do away with the different
standards in different statutes. The
definitions of benefits and costs, and the
extent to which they can be considered,
for example, are inconsistent," observes
Ed Johnson, who directed the pesticides
program from 1974 to 1984. "Every
Administrator has tried to deal with the
multimedia question. This is evident in
continual reorganization in response to
changing views of the program.
Pesticides, for example, had three major
reorganizations. The emphasis was once
on contamination in water, then in
drinking water, and then [on pesticides]
as a toxic substance."
By 1983, Ruckelshaus reflects, it had
become evident that "environmental laws
tend to be passed in periods of high
emotion," resulting in a hodgepodge of
deadlines and requirements, restrictions
on the Administrator, and insufficient
attention to technological feasibility or
benefits in comparison to costs. "I felt
that rather than argue frontally with
Congress, it was important to gain a
more precise understanding of
comparative risks to public health and
benefits associated with higher and
higher expenditures." This is very
difficult to do, he admits.
Lee Thomas, who was named
Administrator following Ruckelshaus's
resignation at the end of Reagan's first
term, was the first career government
official and first non-lawyer to serve in
the post.
First among his accomplishments,
Thomas unhesitatingly singles out the
1987 Montreal Protocol, an
unprecedented international agreement.
The Agency had banned CFCs, or
chlorofluorocarbons, in aerosol cans in
1978 in response to reports about ozone
depletion. The Protocol froze the level of
CFC consumption and required steady
reductions to achieve 50-percent
Lee M. Thomas
reduction by 1998. "The involvement of
industry in the final agreement was a
model for other environmental actions,"
says Thomas.
Another landmark was the
reauthorization of Superfund in 1986. The
Superfund Amendments and
Reauthorization Act (SARA) was the
culmination of an intense two years of
Congressional debate, and a six-month
process to get it out of an 82-member
conference committee. "Picture this
schizophrenic scenario," says Clem
Rastatter, head of Superfund's program
management office, "We were
anticipating a shutdown. Congress gave
us small amounts of money that we had
to spend fast. There was a hiring freeze.
At the same time we were looking at
Congressional debates that anticipated
raising Superfund from $1.6 billion to
$8.5 billion."
Thomas asked an EPA task force to
compare the Agency's budget priorities
with experts' assessments of risks to
public health, welfare, and natural
systems posed by an array of
environmental hazards. Their report,
Unfinished Business: A Comparative
Assessment of Environmental Problems,
concluded that EPA's priorities appeared
to be more closely aligned with public
opinion, often expressed through
Congressional mandates, than with
estimated risk.
The continuing role of crisis and
emergency response at EPA was amply
demonstrated to William Reilly, who
succeeded Thomas. A career
conservationalist, Reilly had been
President of World Wildlife Fund and
The Conservation Foundation. Soon after
his swearing-in in 1989, a popular TV
program aired charges by the National
Resources Defense Council that the
pesticide Alar was a carcinogen.
Wholesale apple prices dropped 50
percent. And a massive oil spill, the
largest in U.S. history, riveted worldwide
attention on Alaska's Prince William
Sound.
One of Reilh/s first actions was to ask
the Science Advisory Board (SAB) to
review Unfinished Business and to suggest
ways to improve the comparative risk
process. In releasing the Board's report
at the National Press Club this past
September, he said: "We have to find a
better way of setting environmental
priorities .... Risk is a common metric
that lets us distinguish the environmental
heart attacks and broken bones from
indigestion or bruises."
He was not suggesting that
conventional approaches to
environmental problems such as
hazardous waste be abandoned. EPA is
firmly committed to continued,
intensified enforcement of the
environmental laws already on the books.
Yet given growing environmental
problems and growing clean-up costs,
"we do need to think carefully about
where our limited resources can most
effectively be spent," said Reilly.
Based on the SAB's findings about
high-risk problems most threatening to
the future health of people and our
planet, Reilly called for a broad,
integrated review of the nation's
environmental agenda and response
mechanisms. From the review would
emerge a new generation of priorities
and programs to carry the nation into the
21st century. To supplement traditional
command-and-control regulations, the
vision includes research, public education
and information, technical assistance, and
market incentives to prevent as well as
clean up pollution.
Changing the agenda would not be
easy, and it wouldn't happen overnight,
he observed. "The great and dramatic
environmental battles are between 'white
hats' and 'black hats,' and there are still a
good many around. But the significant
new progress we need is with ourselves—
our lifestyles, our energy use, the goods
we buy and use and the waste we
generate." a
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EPA JOURNAL
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What Does EPA Mean to You?
Employees Comment
by Roy Popkin
EPA employees are the people
who must translate EPA
policies and regulations into real-
life, nationwide compliance. They
are a diverse lot. Representing a
wide range of disciplines and
backgrounds, Agency staff include
physical and social scientists,
engineers, managers,
administrators, health care
specialists, communicators,
accountants, contract and grant
specialists, accountants, lawyers,
criminal investigators, data-
handling experts, human resource
specialists, and support staff of all
kinds. They come to EPA from
academia, from business, from
research organizations, and from
other government agencies. Some
come fresh from college or other
training; some are career veterans.
What do EPA employees like
about their jobs? To get an
indication, the Journal asked a
selection of them to comment on
this question. Their responses
follow:
Leo Alderman
Chief, Toxics and Pesticides
Branch
Region 7, Kansas City, Kansas
Leo Alderman, a chemist and
microbiologist by training,
came to EPA in 1975. "When I
got here, the Agency had its
limitations. The pesticide
program was limited in a fairly
narrow sense to the
specifications on pesticide
product labels," he said. "Now
the program encompasses
concerns about ecology, ground
water, wetlands, and health
effects."
For Alderman, the most
satisfying part of his job has
been seeing EPA grow and
being a part of that growth.
He also likes the important role
that EPA's regional offices
play: "Other agencies are
strictly top-down. At EPA, the
action works both ways."
(Popkin is a writer/editor with
EPA's Office of Communications
and Public Affairs.)
Kay Wischkaemper
Geologist
Groundwater Technology Support
Group
Region 4, Atlanta, Georgia
Before joining EPA several
months ago, Kay
Wischkaemper worked as a
geologist for a petroleum
industry and civil engineering
firms. She developed a deep
concern about the pollution of
ground water and ways to
remedy it. "It became obvious
that ground water must be
protected for human health
reasons," she said. She became
a ground-water geologist in
South Carolina, then moved to
EPA.
"Because the Agency has a
high profile, the public watches
what we do. This means that
EPA stresses the importance of
quality work," she said.
Alderman
Wischkaemper
Satterwhite
Mark Satterwhite
Environmental Protection
Specialist
Superfund Program
Region 6, Dallas, Texas
Mark Satterwhite, a 14-year
EPA veteran, finds that his
most satisfying achievement to
date has been negotiating and
implementing a Superfund
agreement with the Navajo
nation that covers everything
from pre-remedial work to
future waste disposal methods.
The lands affected by the
agreement include parts of four
states and three EPA regions.
Another negotiated agreement
with the Cherokee Indians in
Oklahoma will go into effect
soon.
Said Satterwhite: "I consider
myself a bureaucrat who has
become a specialist in finding
ways to cut through
bureaucratic red tape. Like the
people I work with, I enjoy
making something count."
Because programs and
processes developed in the
course of negotiating these
agreements can be used in the
Resource Conservation and
Parrel
Recovery Act (RCRA) and
Leaky Underground Storage
Tank programs, "EPA is getting
a 300-percent return on its
investment in what I'm doing."
David Parrel
Chief, Air and Toxic Operations
Idaho Operations Office
Region 10, Boise, Idaho
"I arrived with idealistic
expectations based on the
environmentalism of the mid-
705, "David Parrel said. An
environmental scientist, Parrel
came to EPA last winter from
other federal agencies and the
Air Force. "I'm now more
realistic and down-to-earth. I
realize many environmental
goals have to be negotiated."
Along with his other duties,
Parrel is working on improving
communications in the state of
Idaho to give EPA a "realistic
appreciation" of Idaho's
concerns. A big plus "for me
and many others is the
inspiration of Administrator
Reilly's ideas and philosophies
.... I like to think of a long-
term commitment to EPA."
SEPTEMBER/OCTOBER 1990
61
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Billy
Settle
Nurse
Collins
Sierszen
Cho
Windham
Garber
Reginald Cheatham
Environmental Engineer
Training and Technical
Assistance Division
RCRA Enforcement
EPA Headquarters
Washington, DC.
Reginald Cheatham, a young
civil engineer, says, "I feel I'm
where I belong." In his slightly
more than a year with EPA, he
has edited the RCRA (Resource
Conservation and Recovery
Act) inspectors' handbook,
helped develop regulations,
participated in on-site
inspections, and, most
importantly from his
viewpoint, trained enforcement
personnel. "I've been interested
in the environment since my
college days," Cheatham says.
"As pollution problems grow,
we're going to need well-
trained, highly professional
'environmental cops.' Training
them is an important part of
what we do."
Tanya Meekins
Press Office Secretary
EPA Headquarters
Tanya Meekins has been with
EPA for six years and is
secretary for the Agency's
headquarters press office. "The
job is great," she says. "It is at
a good pace. It certainly has
its hectic moments, but I enjoy
them." She adds that the
people she works with are very
courteous and thoughtful.
Tanya was raised in the
Washington, DC, area. How
long is she going to stay in this
job? "I'll go as far as I can
here, and then we will see."
Drazan
Barbara Metzger
Director, Environmental Services
Region 2, Edison, New Jersey
"In the beginning, in the early
70s, when I was directly
involved in enforcement,
laboratory supervision, and
quality control, my work was
extremely satisfying," Barbara
Metzger said. When she
became a supervisor, she
missed "not being on the
cutting edge .... It took a while
to change perspective, but I do
find my work as
Environmental Services
Director satisfying. If it
weren't, I wouldn't be here."
Rosalinda Lopez
Accounting Technician
Region 9, San Francisco,
California
Rosalinda Lopez, educated in
the Philippines, came to the
United States 19 years ago.
Her work has always been in
accounting. A newcomer to
EPA, she says, "I'm not a
scientist or an enforcement
person, but I see myself
providing environmental
professionals with support they
need. By doing so, I am being
of service to the nation and
adding to the impact of our
efforts to protect the
environment."
Micheline Ward
Human Resources Development
Officer
Region 10, Seattle, Washington
Micheline Ward understands
what Barbara Metzger
experienced when Metzger left
EPA's front lines, so to speak.
Ward, whose service dates
back to 1973, specializes in
helping new supervisors and
managers make the transition
to leadership roles. "At
non-supervisory levels," she
said, "their jobs seemed more
rewarding in terms of results.
But EPA has grown so much it
needs more supervisors and
managers."
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Marcy Billy
Biologist
Marine and Estuarine Protection,
EPA Headquarters
Washington, DC
After college, biologist Marcy
Billy worked with an
audiovisual firm that produced
an educational film on
wetlands. It piqued her
interest in environmentalism
and led her to join EPA a year
ago. "I wanted to do
something more rewarding
than making TV commercials,"
she said.
She is now involved in
environmental education: "I'm
glad to be part of an Agency
that is moving positively
towards pollution prevention
because I believe preventive,
protective actions are
preferable to crisis reaction."
Mary Settle
Program Analyst
Office of Municipal Pollution
Control
Office of Water,
EPA Headquarters
Mary Settle has found that her
most satisfying assignment, one
now in progress, is the Youth
in Environment initiatives.
These EPA pilot projects train
inner-city youths to work in
the waste-treatment area and to
enter promotion ladder systems
that enable them to work up to
supervisory and managerial
roles. According to Settle, the
projects are now successful in
Atlanta, Washington, DC, and
Lowell, Massachusetts, with
another planned for Kansas
City.
Settle, a former school teacher
who worked with the Federal
Water Pollution Administration
before joining EPA in 1971 (she
left EPA briefly to work for the
Federal Inspector's Office
before returning to the
Agency), said, "I found FWPA
and EPA were looking for staff
with educational backgrounds
to set up training programs to
teach people to operate waste-
treatment plants and systems."
In this work she oversaw
grants to community colleges.
SEPTEMBER/OCTOBER 1990
Leanne Nurse
Superfund Community Relations
Coordinator
Region 3, Philadelphia,
Pennsylvania
Leanne Nurse, who joined EPA
within the past year, has had
experience in broadcasting, the
arts, and policy-related
community organization work.
Her present work at EPA takes
her to Superfund clean-up sites
to inform and reassure people
living near the sites: "My PR
skills are tested to the fullest in
situations the public sees as
local crises."
She finds EPA "an
extraordinarily progressive
element of the federal
government" and likes her job
"more than anything I ever
imagined possible."
Catherine Ann Collins
Environmental Engineer
Air and Toxics Branch
Region 8, Denver, Colorado
"I am looking forward to
working with EPA under the
new Clean Air Act," Catherine
Ann Collins, an environmental
engineer, said. A year with
EPA in her first job since
college, she works on
stationary-source compliance
and National Emissions
Standards for Hazardous Air
Pollutant Standards problems,
especially those in North
Dakota, Wyoming, and Utah.
She believes that
environmentalism is a life's
work and "vastly preferable to
working for someone who is
polluting the environment."
Michael Sierszen
Research Ecologist
Environmental Research
Laboratory
Duluth, Minnesota
As a research ecologist,
Michael Sierszen studies the
affects of toxics in aquatic
systems. With a background in
zoology, oceanography, and
limnology (the study of the
physical, chemical,
meteorological, and historical
aspects of fresh water),
Sierszen finds that his move to
EPA within the past year was a
logical step.
"EPA is a good place for a
scientist to be, especially since
very specific objectives are
being addressed. You can see
the effects of what you do
while doing basic research at
the same time."
Kwong Cho
Chemist
Environmental Compliance
Coordinator
Facilities Management Section
Region 2, Edison, New Jersey
While working for various
contract environmental
laboratories, Kwong Cho
started to wonder why the
tests were made. He studied
the regulations involved and
decided to become a more
direct part of environmental
management by joining EPA.
After joining EPA not long ago,
he finds "what I'm doing now
is far more satisfying." With
approval, he observed that the
Agency has become more
proactive. He also wishes the
public were "more supportive"
and some day would like to
help eradicate the Not-In-My-
Backyard (NIMBY) syndrome.
Sam Windham
Deputy Director, Eastern
Environmental Radiation Facilities
Region 4, Montgomery, Alabama
Sam Windham, a physicist,
came to EPA at its inception
after serving with a
predecessor component of the
Agency in the Public Health
Service. He has worked on
radon surveys in the field and
emergency response activities
that involve nuclear power
plants.
What satisfies him most at
EPA is accomplishing
something in terms of public
health. "By working on clean
air and radon guidelines, we
are extending lives and
improving the quality of those
lives," he said.
Jonathan Garber
Chief, Ecosystems Branch
Environmental Research
Laboratory
Region 1, Narragansett,
Rhode Island
Jonathan Garber, an
oceanographer, said that his
focus is on coastal marine
ecology and how pollution
impacts it. "If the same
opportunity at EPA had been
offered five years ago, I'd
probably not have accepted,
but now environmental action
has a high profile." He hopes
to be in a position to influence
the translation of
environmental research into
environmental protection along
the coasts. Garber's
oceanographic research in
academic settings includes
work with the University of
Maryland's Chesapeake Bay
water-monitoring system.
Daniel Drazan
Attorney
Superfund Program, New York-
Caribbean Areas
Region 2, New York City,
New York
In his first and present position
as a full-fledged attorney,
Daniel Drazan enforces
Superfund laws. In one case,
he noted, he had to work out a
settlement involving 220
principal responsible parties.
"Our job is aggressive
enforcement, to speed the
clean-up process," he said.
"One of the great things
about EPA is that you get a lot
of responsibility up front. You
are expected to take positions
that are best for the
environment." Some day,
Drazan hopes to help write
environmental law. He started
his career as an intern at EPA
and at environmental
consulting firms.
63
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Appointments
Wassersug
Seitz
I
Firestone
Alonzo
Gerald A. Emison is EPA's
Deputy Regional Administrator
for Region 10, which is located
in Seattle, Washington. Since
1984, Emison was the Director
of the Office of Air Quality
Planning and Standards at EPA
Headquarters.
Emison joined the Agency in
1974 as an Environmental
Engineer. He then worked for
the Montgomery County
Council as a Planning Policy
Coordinator and for the Roy F.
Weston Company as a
management consultant.
Emison returned to the Agency
in 1979 as an Environmental
Protection Specialist.
Emison graduated from
Vanderbilt University in 1968
with a degree in Civil
Engineering. In 1981 he
received a Master's degree in
Engineering Management at
Catholic University.
Emison has received two
Silver Medals for Service and
the meritorious SES award in
1988.
Thomas W. Hoya is EPA's
newest Administrative Law
Judge. Hoya worked for the
U.S. Department of Commerce
for 22 years, the last five as an
Administrative Law Judge. He
presided over cases to enforce
U.S. export controls and over
cases to enforce U.S.
regulations protecting marine
life. Previously within the
Department, he served as the
Hearing Commissioner of the
International Trade
Administration, and as the
Chairman of the Operating
Committee of the export
control program.
Hoya, a Phi Beta Kappa
graduate of Harvard, has a J.D.
from Michigan Law School, an
M.B.A. from Northwestern
Graduate School of
Management, and an LL.M.
and a J.S.D. from Columbia
Law School.
His publications include a
book titled East-West Trade
(Oceana, 1984) and many
articles on international trade.
EPA's new Program Manager
for the Regional Environmental
Center for Central and Eastern
Europe in Budapest, Hungary,
is Stephen R. Wassersug.
Wassersug was the Director
of the Hazardous Waste
Management Division for
Region 3 in Philadelphia,
Pennsylvania, since 1985.
Wassersug worked for the
Department of Public Health
and the Public Health Service
from 1964 to 1970 before
joining the Agency. He has
worked in Philadelphia as
Director of the Air and Waste
Management Division, Director
of Enforcement, Director of the
Air and Water Division, and
Regional Air Pollution Control
Director.
Wassersug is currently a
member of the Ground-Water
Steering Committee, the
Department of Justice Civil
Judicial Enforcement
Committee, and the Executive
Resources Board. He is also
the co-chairman of the
Superfund Reauthorization
Committee.
An alumnus of the University
of Massachusetts, Wassersug
graduated with a degree in the
physical sciences. He earned a
Master's degree in Public
Health at George Washington
University in 1969.
John S. Seitz is the new
Director of the Office of Air
Quality Planning and
Standards (OAQPS) in the
office of Air and Radiation.
The OAQPS is located in
Research Triangle Park, North
Carolina. He joined the Agency
in 1971 as a Case Development
Officer after working as a
pesticide inspector in New
York. Seitz joined the OAQPS
as the Director of the
Stationary Source Compliance
Division in 1987. He has also
worked in the Office of
Pesticides and Toxic
Substances and the Office of
Enforcement, and was involved
in the 1976 passage and
implementation of the Resource
Conservation and Recovery
Act.
Seitz is an alumnus of the
University of Delaware. He
has been awarded EPA's Gold
and Silver Medals for
exceptional service.
EPA's new Associate Deputy
Administrator is Nancy B.
Firestone. She was previously
the Special Counsel to the EPA
Deputy Administrator.
Firestone has also served as
Deputy Chief of the
Environmental Enforcement
Section for the Department of
Justice.
Firestone is an alumnus of
Washington University at St.
Louis and the University of
Missouri—Kansas City Law
School. She is also an adjunct
professor at Georgetown
University Law Center, where
she teaches environmental law.
Anne L. Alonzo has been
selected as the first-ever
environmental attache at a U.S.
Embassy. The position is
located in Mexico City. A
career EPA senior attorney,
Alonzo will assist in the
coordination of cross-border
cooperation between businesses
and non-governmental groups
to address environmental
pollution problems and to
further agreements between the
United States and Mexico.
Alonzo worked for the past
six years in the regional
counsel's office of EPA's
Region 5 in Chicago,
specializing in hazardous and
solid waste cases. She was on
special assignment in Mexico
from October 1988 to March
1989, counseling and assisting
the Mexican Secretary of Urban
Development and Ecology
(SEDUE) and the U.S. Embassy
regarding environmental issues
and assisted in the dual
publication by U.S. EPA and
SEDUE of an environmental
compliance handbook for U.S.
and Mexican businesses.
Alonzo is an alumnus of the
University of Illinois and the
Illinois Institute of Technology
-Kent College of Law. She has
received the U.S. Office of Civil
Rights Award of Excellence,
the EPA Regional
Administrator's Award of
Excellence and the U.S. Border
Trade Alliance/Mexican
Maquiladora Association
Special Award. Q
64
EPA JOURNAL
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A clean, healthy environment:
EPA's goal as it prepares for
the future.
Back Cover: Flight in a
coastal marsh. The values
of natural resources such
as wetlands are receiving
a new emphasis at EPA. See
article on page 34.
Photo by Barry Kaplan for
Light Works, Inc.
Mike flnsson photo
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