United States
Environmental
Agency
Volume 9
Number 1
July 1983
Dawn of a New Era
.
-------
Charting a
New Course
"You have my total support in
your difficult job of enforcing
and administering our Nation's
environmental protection laws. "
— President Ronald Reagan to
William D. Ruckelshaus at the
nationally-televised swearing-in
ceremony for EPA's new
administrator May 18, 1983.
Along with this assurance of
vigorous support, the President
also assigned EPA's leader the
responsibility "to accomplish our
goal: the protection of the health
and well-being of the American
people."
The President told Ruckelshaus
that "I'm counting on you, in
your daily performance of your
duty, to reaffirm this Administra-
tion's firm commitment to a
sound and safe environment—
and an EPA that is trusted and
respected by all."
Buoyed by this Presidential
backing and a 97-0 confirmation
vote from the United States
Senate, Administrator Ruckels-
haus began his second term at
EPA, the agency he organized in
1970 and led until 1973.
In this issue of EPA Journal,
we take a look at EPA's new
priorities outlined by the
President at the swearing-in
ceremony and in Administrator
Ruckelshaus' public statements
and testimony during confirma-
tion hearings before the Senate
Committee on the Environment
and Public Works.
This issue includes articles on
changes in leadership at the
agency and new policies.
In addition, a photo essay on
wild birds illustrates one of the
results of Ruckelshaus' first term
at EPA. The bald eagle, our
national symbol, and other
creatures today have a better
chance of survival because of
the Administrator's 1972 action
banning most uses of DDT.
In future issues, the Journal
will report on fresh developments
as the Agency sets out on a new
course, with the objective of
helping ensure a safer, cleaner
environment for the American
people and the world.
An ocean beach, part of the environment which mi/lions of people are visiting this summer.
*
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United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington, DC 20460
Volume 9
Number 1
Jury 1983
JOURNAL
William D. Ruckelahaus, Administrator
William J. Ahlfeld, Director, Office of Public Affairs
Charles D. Pierce, Editor
Articles
EPA is charged by Congress with
protecting 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.
The EPA Journal is published
quarterly 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 print-
ing this periodical has been approved
by the Director of the Office of
Management and Budget through
4/1/84. Views expressed by authors
do not necessarily reflect EPA policy.
Contributions and inquiries should be
addressed to the"Editor IA-107).
Waterside Mall, 401 M St., S.W.,
Washington, D.C. 20460. No permis-
sion necessary to reproduce contents
except copyrighted photos and other
materials.
President Reagan Assigns
EPA Four Priority Tasks 2
Science, Risk
and Public Policy 3
Ruckelshaus Outlines
Major Issues 6
New EPA Team Begins
To Take Shape 9
Sunlight Policy Guides
EPA Officials 10
Eagles, Other Birds Thrive
After EPA's 1972 DDT Ban 12
Changes To Speed
Hazardous Waste Program 14
How Many MPG?
Let's Be Realistic 15
The Return of
"An Extraordinary
Public Servant" 16
Front Cover: Sunrise over Washing-
ton as seen from the Lincoln
Memorial with the Washington
Monument and the U.S. Capitol in
the background
Photo Credits: U.S. Fish and Wildlife
Service, Photri, Steve Delaney.
Documerica.
Design Credits: Ftoben Flanagan,
Ron Farrah.
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President Reagan Assigns
EPA Four Priority Tasks
President Reagan has charged EPA to act
promptly in four major areas: controlling acid
rain, expediting Superfund cleanups, clarify-
ing roles of the various levels of government,
and vigorously enforcing environmental laws.
"We must do even more to protect and
cleanse our environment," the President told
Administrator William D. Ruckelshaus at his
swearing-in ceremony May 18. President
Reagan cited four "areas of immediate
concern":
Acid rain: "First, many of us—both here
and in Canada —are concerned about the
harmful effects acid rain may be having on
lakes and forests. I would like you to work
with others in our Administration, with the
Congress, and with State and local officials,
to meet this issue head-on.
"At a time when spending in other areas
must be curtailed, we have already asked for
an increase of 112 percent in research funds
for acid rain. People on both sides of the
border must understand that we are doing
what's right and fair in this area."
Superfund: "Second, accelerate efforts to
put the Superfund to good use, cleaning up
those hazardous dumps that present an
imminent or serious threat to human health.
We've made progress—we must make still
more. Let's pledge that no American will be
held hostage or exposed to danger because
of bureaucratic snafus or legal disputes over
responsibility."
Federal, state, local authorities:
"Third... we need a sorting out process to
determine the areas of authority between
the various levels of government. I've
always thought that protecting the
environment was something in which the
State and local governments could and
should play an important role. When I
was Governor of California I was proud
that our State led the way in many
aspects of this battle, including the laws
concerning air pollution. I hope you can
focus on this and provide us with a
better idea of who is best equipped to
handle specific areas of responsibility."
With William D. Ruckelshaus standing in the background, the President announces that
he is nominating the former EPA Administrator to head EPA again.
Environmental laws: "Fourth, we must
insure that the laws concerning this vital area
continue to be vigorously enforced. We
expect nothing less than full compliance with
the letter and spirit of the law."
The President noted that "13 years ago,
under another Republican administration, the
EPA was formed to preserve and enhance
the quality of America's most precious
assets—our air, land, and water. Its creation
signaled a new awareness of the ecology and
the impact of urbanization and industrializa-
tion on the quality of our lives.
"EPA was fortunate to have, as its first
Administrator, an extraordinary public
servant who gave direction and momentum
to the fledgling environmental agency. His
assignment, not an easy one, was performed
with dedication, integrity and a balanced
understanding of the Nation's needs. He
soon became known—and with good reason
— as 'Mr. Clean.'
" Today, at a time when we are opening a
new chapter in the history of this agency, I
cannot imagine anyone who is more qualified
or better suited to be at the helm once again
than 'Mr. Clean' —Bill Ruckelshaus." The
President said that Ruckelshaus "helped set
this Nation on a course we still follow today
— a course that has brought many tangible
signs of progress. The quality of air in the
United States, especially in our cities, is
better today than it was 13 years ago.
Streams, rivers and lakes all across the
country are becoming cleaner. Regulations
are now in place that come to grips with the
problems of hazardous waste disposal.
Progress is being made in cleaning up the
abandoned chemical dumpsites which mar
the countryside."
With the leadership of Administrator
Ruckelshaus "and the assistance of EPA's
fine career professionals and with a good
working relationship with State and local
environmental agencies," the President said
he was confident the health and well-being
of the American people would be protected.
EPA JOURNAL
-------
Science,
Risk, and
Public Policy
r
(Excerpts from remarks by EPA
Administrator William D. Ruckelshaus to
the National Academy of Sciences, June
22, 1983, in Washington, D. C.)
We are now in a troubled and emotional
period for pollution control; many
communities are gripped by something
approaching panic and the public
"discussion is dominated by personalities
rather than substance. It is not important
to assign blame for this. I appreciate that
people are worried about public health
and about economic survival, and
legitimately so, but we must all reject the
emotionalism that surrounds the current
discourse and rescue ourselves from the
paralysis of honest public policy that it
breeds.
It is no accident that I am raising this
subject here in the house of science. I
believe that part of the solution to our
distress lies with the idea enshrined in
this building, the idea that disciplined
minds can grapple with ignorance, and
sometimes win: the idea of science. We
will not recover our equilibrium without a
concerted effort to more effectively
engage the scientific community.
Somehow our democratic
technological society must resolve the
dissonnance between science and the
creation of public policy. Nowhere is this
more troublesome than in the formal
assessment of risk—the estimation of the
association between the exposure to a
substance and the incidence of some
disease, based on scientific data.
Here is how the problem emerges at
the Environmental Protection Agency.
EPA is an instrument of public policy,
whose mission is to protect the public
health and environment in the manner
laid down by its statutes. That manner is
to set standards and enforce them; and
our enforcement powers are strong and
pervasive. But the standards we set,
whether technology or health-related,
must have a sound scientific base.
Science and the law are thus partners
at EPA, but uneasy partners. It's a
shotgun wedding. The main reason for
the uneasiness lies, I think, in the conflict
between the way science really works
and the public's thirst for certitude that is
written into EPA's laws. Science, as you
all know, thrives on uncertainty. The best
young scientists flock into fields where
great questions have been asked but
nothing is known. The greatest triumph
of a scientist is the crucial experiment
that shatters the certainties of the past
and opens up rich new pastures of
ignorance.
B
ut EPA's laws often assume, indeed
demand, a certainty of protection greater
than science can provide at the current
state of knowledge. The laws do no more
than reflect what the public believes and
what it often hears from people with
scientific credentials on the 6 o'clock
news. The public thinks we know what all
the bad pollutants are, precisely what
adverse health or environmental effects
they cause, how to measure them exactly
and control them absolutely. Of course,
the public and sometimes the law are
wrong, but not all wrong. We do know a
lot about some pollutants and we have
controlled them effectively using the
tools of the Clean Air Act and the Clean
Water Act. These are the pollutants for
which the scientific community can set
safe levels and margins of safety for
sensitive populations. If this were the
case for all pollutants, we could breathe
more easily (in both senses of the
phrase); but it is not so.
When I left EPA over 10 years ago as
its first Administrator, we had the Clean
Air Act, the Clean Water Act, a solid
waste law, a pesticide law and laws to
control radiation and noise. Yet to come
JULY 1983
-------
were the myriad of laws to control toxic
substances from their manufacture to
their disposal—but that they would pass
was even then obvious.
When I departed a decade ago, the
struggle over whether the Federal
Government was to have a major role in
protecting our health, safety and
environment was ended. The American
people had spoken. The laws had passed,
the regulations were being written. The
only remaining question was whether the
statutory framework we had created for
our journey made sense or whether, over
time, we would adjust it.
Ten years ago I thought I knew the
answer to that question as well. I
believed it would become apparent to all
that we could virtually eliminate the risks
we call pollution if we wanted to spend
enough money. When it also became
apparent that enough money for all the
pollutants was a lot of money, I further
believed we would begin to examine the
risks very carefully and structure a
system which forced us to balance our
desire to eliminate pollution against the
costs of its control. This would entail
some adjustment of the laws, but really
not all that much, and it would happen
by about 1976. I was wrong.
It may be that God is repaying me for
my error by causing me to be
reincarnated as Administrator of EPA.
Whether God or President Reagan is the
cause this time around, I am determined
to improve our country's ability to cope
with the risk of pollutants over where I
left it 10 years ago.
It will not be easy, because we must
now deal with a class of pollutants for
which a safe level'is difficult, if not
impossible, to establish. These pollutants
interfere with genetic processes and are
associated with the diseases we fear
most: cancer and reproductive disorders,
including birth defects. The scientific
consensus has it that any exposure,
however small, to a genetically active
substance embodies some risk of an
effect. Since these substances are
wide-spread in the environment, and
since we can detect them down to very
low levels, we must assume that life now
takes place in a minefield of risks from
hundreds, perhaps thousands, of
substances. No more can we tell the
public: you are home free with an
adequate margin of safety.
This worries all of us, and it should.
But when we examine the premises on
which such estimates of risk are based,
we find a confusing picture. In assessing
a suspected carcinogen, for example,
there are uncertainties at every point
where an assumption must be made: in
calculating exposure; in extrapolating
from high doses where we have seen an
effect to the low doses typical of
environmental pollution; in what we may
expect when humans are subjected to
much lower doses of the same substance
that caused tumors when given in high
doses to laboratory animals; and finally,
in the very mechanisms by which we
suppose the disease to work.
One thing we clearly need to do is
insure that our laws reflect these
scientific realities. The Administrator of
EPA should not be forced to represent
that a margin of safety exists for a
specific substance at a specific level of
exposure where none can be
scientifically established. This is
particularly true where the inability to so
represent forces the cessation of all use
of a substance without any further
evaluation.
It is my strong belief that where EPA or
OSHA or any of the social regulatory
agencies is charged with protecting
public health, safety or the environment,
we should be given, to the extent
possible, a common statutory formula for
accomplishing our tasks. This statutory
formula may well weigh public health
very heavily in the equation as the
American people certainly do.
The formula should be as precise as
possible and should include a
responsibility to assess the risk and to
weigh that, not only against the benefits
of the continued use of the substance
under examination, but against the risks
associated with substitute substances
and the risks associated with the transfer
of the substance from one environmental
medium to another via pollution control
practices.
I recognize that legislative change in
the current climate is difficult. It is up to
those of us who seek change to make the
case for its advisability.
I did not come here today to plead for
statutory change. My purpose is to speak
of risk assessment and risk management
and science's role in both. It is important
to distinguish these two essential
functions, and I rely here on a recent
National Academy of Sciences report on
the management of risk in the Federal
government. Scientists assess a risk to
find out what the problems are. The
process of deciding what to do about the
problems is risk management. The
second procedure involves a much
broader array of disciplines, and is aimed
toward a decision about control.
Risk management assumes we have
assessed the health risks of a suspect
chemical. We must then factor in its
benefits, the costs of the various
methods available for its control, and the
statutory framework for decision. The
NAS report recommends that these tWo
functions be separated as much as
possible within a regulatory agency. This
is what we now do at EPA and it makes
sense.
I think we also need to strengthen our
risk assessment capabilities. We need
more research on the health effects of
the substances we regulate. I intend to
do everything in my power to make clear
the importance of this scientific analysis
at EPA. Given the necessity of acting in
the face of enormous scientific
uncertainties, it is more important than
ever that our scientific analysis be
rigorous and the quality of our data be
high. We must take great pains not to
mislead people regarding the risks to
their health. We can help avoid confusion
both by the quality of our science and
the clarity of our language in explaining
the hazards.
I intend to allocate some of EPA's
increased resources, which everyone
seems determined to give us, toward
these ends. Our 1984 request contains
significant increases for risk assessment
and associated woTJT. We" nave~ rtst|Ue°sle6!
$31 million in supplemental
appropriations for research and
development and I would expect that risk
assessment will be more strongly
supported as a result of this increase as
well.
I would also like to revitalize our
long-term research program to develop a
base for more adequately protecting the
public health from toxic pollutants. I will
be asking the advice of the outside
scientific community how best to
focus those research efforts.
Despite conflicting pressures, risk
assessment at EPA must be based on
scientific evidence and scientific
consensus only. Nothing will erode
public confidence faster than the
suspicion that policy considerations have
been allowed to influence the
assessment of risk.
Although there is an objective way to
assess risk, there is, of course, no purely
objective way to manage it, nor can we
ignore the subjective perception of risk in
the ultimate management of a particular
substance. To do so would be to place
too much credence in our objective data
and ignore the possibility that
occasionally one's stomach is right. No
amount of data is a substitute for
judgement.
Further, we must search for ways of
describing risk in ways the average
citizen can comprehend. Telling a family
living close to a manufacturing facility
that no further controls are needed on
the plant's emissions because, according
to our linear model their risk is only 10-6,
is not very reassuring. We need to
describe the suspect substances as
clearly as possible, tell people what the
known or suspected health problems are
EPA JOURNAL
-------
and help them compare that risk to those
with which they are more familiar.
~"To effectively manage the risk, we
must seek new ways to involve the
public in the decision-making process.
,_Whether we believe in participatory
democracy or not it is a part of our social
regulatory fabric. Rather than praise or
lament it, we should seek more
imaginative ways to involve the various
publics impacted by the substance at
issue. They need to be involved early on
and they need to be informed if their
participation is to be meaningful. We will
be searching for ways to make our
participatory process work better.
For this to happen, scientists must be
willing to take a larger role in explaining
the risks to the public—including the
uncertainties inherent in any risk
assessment. What we need to hear more
of from scientists is science. I am going
to try to provide avenues at EPA for
involvement in the public dialogue in
which the scientific problems are
described. Our country needs the clear
unbiased voice of science.
Lest anyone misunderstand, I am not
suggesting that all the elements of
managing risk can be reduced to some
neat mathematical formula. Going
through a disciplined approach can help.
It will assist in organizing our thoughts to
include all the elements that should be
weighed. We will build up a set of
precedents that will assist later
decision-making and provide more
predictable outcomes for any social
regulatory programs we adopt.
It is clear to me that in a society in
which democratic principles so dominate,
the perceptions of the public must be
weighed. Instead of objective and
subjective risks, the experts sometimes
substitute "real" and "imaginary" risks.
There is a certain arrogance in this — an
elitism which has ill served us in the
past. Rather than decry the ignorance of
the public and seek to ignore their
concerns, our governmental processes
must accommodate the will of the people
and recognize its occasional wisdom. As
Thomas Jefferson observed:
"If we think (the people) not enlightened
enough to exercise their control with a
wholesome discretion, the remedy is not
to take it from them, but to inform their
^discretion."
/ Up to this point I have been suggesting
how risks should be assessed and
managed in EPA. Much needs to be done
toxogrdinate the various EPA programs
to assure a consistent approach. I have
established a task force with that charter.
I further believe we should make
uniform the way in which we manage
risk across the Federal regulatory
agencies. The public interest is not
Administrator William D. Ruckelshaus addresses National Academy of Sciences in
Washington, D.C.
served by two Federal agencies taking
diametrically opposed positions on the
health risks of a given toxic substance
and then arguing about it in the press.
We should be able to coordinate our risk
assessment procedures across all Federal
agencies. The risk management strategy
that flows from that assessment may
indeed differ, depending on the agency's
statutory mandate or the judgment of the
ultimate decision maker.
But even at the management stage
there is no reason why the approaches
cannot be coordinated to achieve the
goal of risk avoidance or minimization
with the least societal disruption
possible. In the last few weeks I have
been exploring with the White House and
the Office of Management and Budget
the possibility of effecting a better intra-
governmental coordination of the way in
which we assess and manage risk.
" To push this one step further, I believe
it is in our nation's best interest to share
our knowledge of risks and our approach
to managing them with the other
developed nations of the world. The
--environmental movement has taught us
the interdependencies of the world's
ecosystems. In coping with the legitimate
concerns raised by environmentalism we
must not forget that we cope in a world
with interdependent economies. If our
approach to the management of risk is
not sufficiently in harmony with those of
the other developed nations, we could
save our health and risk our economy, !
don't believe we need abandon either,
but to insure it does not happen, we
need to work hard to share scientific data
and understand how to harmonize our
management techniques with those of
our sister nations.
* # * *
I want to help achieve a better
conceptual, statutory and societal
framework to cope with risk in our
country.
To do that we need to get the emotion
out of and the scientist into the process:
I need science's help.
I'll try to make it easier to access what
we're doing at EPA.
But if I can't do that, I need your help
anyway.
What I'm after is a government-wide
process for assessing and managing
health, safety and environmental risks.
This will take coordination, cooperation
and good will within EPA, within the
Executive Branch agencies and between
the Congress and the Administration.
In other words, this will take a miracle.
Now I know science doesn't believe in
miracles, but I need your help if this
one's going to happen.
What's at stake is no less than whether
this country works. It's worth the effort of
all of us.
JULY 1983
-------
"Picture what you are doing or
saying as being on a billboard
that you pass on the way to
work. As you pass that billboard,
if you look up and see what you
are doing or saying and it
embarrasses you, then don't do
it or don't say it. "
Administrator Ruckelshaus testifying.
Ruckelshaus
Outlines
Major Issues
Administrator William D. Ruckelshaus
communicated his views on key issues in
testimony before the Senate Committee on
Environment and Public Works, at his
swearing-in ceremony, and in various public
comments.
Significant statements he has made
include the following:
EPA's Mission:
"EPA was not created to deal with the usual
mix of social problems whether they be
poverty, jobs, housing, education, crime
In a real sense EPA's mission transcends
all of these. That mission is the
preservation of life itself."
* » * *
"I will endeavor to re-instill in the
employees of EPA a sense of mission and a
dedication to excellence. I will try to
convince them that EPA's mission must be
carried out by people who recognize they are
servants of the public and not their masters,
and by people who are as dedicated to
fairness and civility to others as to excellence
in themselves. An Agency steeped in this
tradition is a legacy to which I will aspire."
* * * *
Public Commitment:
"To the American people, protection of
public health and our natural environment is
a terribly important and enduring imperative.
The survey I have seen, and my own experi-
ence, strongly indicate that Americans feel
more deeply committed to the protection of
public health and the environment than any
people on earth.
"Our country, acting through federal, state
and local governments, over the last two
decades, has translated that commitment
into a massive network of laws and regula-
tions to protect the health of our people and
the air, water and earth we all share. Those
laws attest that the debate in this country
over whether we are going to protect public
health and our environment has long since
passed.
"I completely share our nation's commit-
ment to the values of public health and the
environment. Since first coming to EPA in
1970, I have participated in the national
dialogue about how to translate those values
into achievable goals. I intend to continue to
participate in that debate. . . ."
Keeping Trust:
"I can say to you, Mr. President, and to the
Congress which confirmed me that I appre-
ciate your support and trust. As I pursue the
public interest, which is often so elusive at
EPA, your support will sustain me. And in
that pursuit I pledge to you, to the Congress
and to the American people, I will never
break your trust."
Administering The Laws:
"Mr. President, while we both think the
basic laws of EPA can be made to work
better, we recognize the final arbiter of the
shape of the law in our country is the
Congress.
EPA JOURNAL
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Senate Majority Leader Howard Baker testifying in support of the
Ruckelshaus nomination, in background is Sen. John Chafee,
who also supported Ruckelshaus.
Senator Robert T. Stafford, chairman of the Senate Environment
and Public Works Committee, presiding at the Ruckelshaus hearing.
" That body • . . makes the laws. It
is my job to enforce them—as written.
"I have pledged to the Congress . . . that I
will consult closely with them in seeking to
administer and refine our statutory base.
"Hopefully, we at EPA can regain the trust
of Congress and achieve the administrative
flexibility I believe is essential if the public
interest is to be served."
White House Overruling:
"They can't do that. The law is very clear. It
gives me the responsibility to ultimately make
most of the decisions as they affect EPA.
And where that law is clear and where it has
given me the responsibility it is up to me to
carry it out. If I can't do that, there's no
reason for me to try to function as the
Administrator."
Presidential Support:
"Most important, Mr. President, you have
pledged to me your total support in taking
on this job. Without your support I cannot
succeed and with it I will not fail."
EPA Career Employees:
[""EPA's greatest resource today is the same
/ as when we started —its people. If they are
| trusted, included in, and given clear guidance
as to what is expected of them they will
perform to a very high standard. I will work
hard and they will work hard toward our
I common objective."
# # # #
". . . EPA has impressive professionals
with a high dedication to their mission. Many
of the able people of EPA were there when
we started over 12 years ago. We have much
to learn from their collective wisdom and
with their help this country can continue to
progress toward our environmental and
health goals. ... it is my sense that the
people of EPA who have stayed with it from
the beginning are there because of their
belief in the fundamental importance of their
mission."
"The career people of EPA recognize, better
than the rest of us, the necessity of harmon-
izing their mission with the essentials of life
they are trying to preserve. They know the
single-minded pursuit of any social goal to
the exclusion of all others can cause severe
societal distortions. They are willing, and
uniquely able, to help our country avoid
these distortions if so charged. You have so
charged us today, Mr. President. You have
told us to pursue our mission with wisdom
and dispatch. We accept your direction."
* * * »
First Priority:
"I discussed the nature of the Administrator's
job with the President and his immediate
staff before he asked me to serve. We agree
that people and resources to do the job were
essential ingredients of success. My first
priority will be to recruit the best people I
can find to manage the Agency."
EPA's Enforcement Policies:
(FIFRA) was already enacted, but only since
I left has EPA established the basic structure
to control the manufacture, distribution, use
and ultimate disposal of toxic substances.
We have in place a complex set of laws and
regulations to deal with the toxic substance
problems. I have no preconception whether
these laws or regulations or the resources we
have committed to their implementation are
adequate. I do know that the wise and
aggressive implementation of these laws
must be a very high priority of mine and it
will be."
Law Compliance:
"The existing laws will be administered as
written. ! will continue to bring to this
Committee's (Senate Committee on the
Environment and Public Works) attention
recommendations for change where I believe
change is warranted but in the meantime
(we) remain a nation of laws and not of
men, and the laws will remain supreme.
"Much has been said and written in criticism / "' intend that EPA wil1 operate forthrightly
of EPA's enforcement policies. The questions! and honestly. We will attempt to communi-
seem to focus on three aspects of enforce-
ment—will, capacity, and organization.
"As to will, let me disabuse anyone who
believes EPA, while I am there, will not have
the requisite determination to enforce the
laws as written by Congress. The environ-
mental laws of this country were passed by
Congress and were meant to be taken
seriously by the administering authorities. I
do take the Congressional charge seriously
and if I'm confirmed EPA wil! take that
charge seriously. We will enforce the laws of
this country. We will be firm and we will be
fair. We must never forget that in a time of
high emotion such as we now face where
the public interest demands firmness in the
enforcement of our laws, the public good,
mirrored in the Bill of Rights, demands that
due process not be abandoned. The EPA I
head will adhere to both principles."
Toxic Substances:
"The whole issue of toxic substances is of
much greater prominence than when I was
first at EPA. The law to regulate pesticides
with everyone from the environmental-
ists to those we regulate and we will do so
openly as possible.
"I will seek the best advice I can get on
how to deal with the terribly complex prob-
lems EPA must confront. I will seek help
from scientists, environmentalists, econo-
mists, industrialists and the general public. I
hope to engage former Administrators of
EPA in a constant dialogue to take advan-
tage of their collective wisdom.
"Lastly, I hope to engage this Committee
(Senate Environment and Public Works), this
Committee's staff, and other Committees of
Congress and their staffs in a joint effort to
improve our nation's ability to respond to the
mix of health and environmental problems
facing EPA. Recognizing the important over-
sight function Congress must play, I intend
to make a better dialogue and increased trust
between the legislating and administering
authorities in this area a high priority."
JULY 1983
-------
"There will be no hit lists.
There will be no big P political
decisions and there will be no
sweetheart deals."
Environmental Progress:
"But I have looked at some of those
(economic and other) studies and I believe
that the overall effort that we have made in
the last 13 years . . . has resulted in appre-
ciably better air and water quality over much
of the country.
"We have made remarkable progress in
the last decade and a half in cleaning up the
environment. As a country we really ought
to take hope from that. We really ought to
be feeling pretty good about where we have
come. That is not to suggest that we do not
have more problems that . . . crop up every
day. In this toxic area, they certainly have
accelerated since I was here several years
ago."
Industry-Government Relations:
"... if there is one question I have been
asked more than any other, it is what does it
feel like to have changed sides. ... I never
thought of myself as being on the other side
when I was in government.
"My own belief as a lawyer and as a
representative of a major American corpora-
tion is that my client's interests and corpora-
tion's interests were best served when it was
possible to identify those interests with the
public interest. When that is not possible,
they are in trouble.
"I can cite examples where I have told
people at Weyerhaeuser and others that . . .
if the government were to move against
Weyerhaeuser and it caused Weyerhaeuser
to spend some money and the public interest
was benefitted, that is too bad for
Weyerhaeuser.
"In response to the question . . . whether
there were expenditures made beyond where
the benefits were accruing, if the govern-
ment moved against a company like Weyer-
haeuser, forcing Weyerhaeuser to spend
some money, and there was no public benefit
associated with it, in my view that is too bad
for the country, not too bad for Weyer-
haeuser, and that is a distinction which I
think is sometimes lost.
« * * *
"... I do not believe you can be effective
in or out of government untess you are able
to view the world from the other person's
The crowded Senate hearing room, with William D. Ruckelshaus at the witness table
Hanked by Senators Henry M. Jackson (left) and Slade Gorton.
perspective. Unless in this country we are
capable of narrowing the gap that exists
between government and the private sector,
I believe very strongly that we are in trouble
in the world. . . . Uniquely among the indus-
trial nations of the world we have this chasm
between the public and private sector. . . .
We stand there and throw rocks at one
another. There are chasms between other
sections of our society . . . the general
public, the environmentalists, management
and labor. I just do not think we in this
nation can any longer afford the endless,
constant strife . . . that I think ultimately
works to the detriment of much of what our
nation stands for.
"To the extent I can help narrow that gap
in coming to EPA, I think i will have
performed a service.
State Responsibilities:
"Mr. President, you have charged me with
some specifics . . . help sort out the role of
the Federal and State Governments so the
people at both levels can stop second
guessing one another and get on with their
job."
Relations with Congress:
". . . The final arbiter of the shape of the
law in our country is the Congress. That
body . . . makes the laws. It is my job to
enforce them —as written. I have pledged to
the Congress . . . that I will consult closely
with them in seeking to administer and refine
our statutory base. Hopefully, we at EPA,
can regain the trust of Congress and achieve
the administrative flexibility I believe is
essential if the public interest is to be
served."
Acid Rain:
"My understanding now is that there is no
question that there is a problem of acid
deposition that impacts on certain lakes
in the northeastern part of this country
and in Canada and that a major
contributor to the cause of that is man-
made. Now, how you would go about
fashioning a program, a program for relief
that would make sense for the country to
reduce the impact of acid deposition,
whether wet or dry, on these lakes with low
buffering or areas with low buffering
capacity, is where it is unclear, at least to
me, as to exactly how you would do it."
Clean Air Act:
"I will be working very closely with Congress
to get some language, some reauthorizing
sections in that law that everybody can agree
with and get that law passed ... as quickly
as we can. Now, whether it is possible this
year, I don't know and frankly neither does
anyone else."
EPA JOURNAL
-------
New EPA Team
Begins to Take Shape
Howard M.Messner
Lee M. Thomas
Samuel A. Schulhoi
Emesta Ballard Barnes
Two Assistant Administrators have been
nominated, one Associate Administrator
has been chosen and one Regional
Administrator selected as the first of
several new appointments expected at
EPA.
Nominated by President Reagan as
EPA Assistant Administrator for
Administration is Howard M. Messner, a
former EPA official.
Proposed by the President for the post
of EPA Assistant Administrator for Solid
Waste and Emergency Response is Lee
M. Thomas.
Administrator William D. Ruckelshaus
has appointed Samuel A. Schulhof as
Associate Administrator for Regional
Operations and Ernesta Ballard Barnes as
Regional Administrator for the agency's
Region 10, headquartered in Seattle.
Messner had been serving since March
of this year as Controller of the
Department of Energy. Previously he had
been Assistant Director for Management
Improvement and Evaluation of the
Office of Management and Budget
1977-83. From 1975 to 1977 he served as
Assistant Director for Management
Programs at the Congressional Budget
Office.
Messner was Deputy Assistant
Administrator for Administration at EPA
1971-75 and served as a management
analyst in the Office of Management and
Budget 1965-71. Messner received the
William A. Jump Memorial Award for
distinguished service in public
administration in 1971.
Thomas, who has been acting head of
the Solid Waste and Emergency
Response office since February, also
served for a brief period earlier this year
as Acting Deputy Administrator of EPA.
He was an Associate Director of the
Federal Emergency Management Agency
before his nomination to a post at EPA.
Thomas managed FEMA's disaster relief
efforts and was chairman of the
President's Task Force on Times Beach,
Mo. He held a number of posts in the
South Carolina state government before
joining FEMA in 1981.
In the new post of Associate
Administrator for Regional Operations,
Schulhof will coordinate headquarters and
regional activities and help in
implementing Administrator Ruckelshaus'
plan to give Regional Administrators
greater autonomy.
He had previously served as EPA's
Deputy Assistant Administrator for
Administration. Before joining EPA in 1981
he was an assistant director of recruitment
and communications at ACTION.
In her post as the new regional
administrator for Region 10, Barnes will
be responsible for administering and
enforcing all EPA programs in the states
of Washington, Oregon, Idaho and
Alaska.
Barnes has worked in both the private
and public sector. Before her EPA
appointment she was a branch
administrator with the Seattle Trust and
Savings Bank where she was responsible
for the management of retail banking
activities.
From 1976 to 1978, she served as the
director of public service for the
Municipality of Metropolitan Seattle
(METRO). She was the budget director
for the University of Washington in
Seattle from 1974 to 1976. In the
mid-1970's, Barnes was an incorporator
and founding board member of Sound
Savings and Loan Association in Seattle,
owned and organized by women.
JULY 1983
-------
Sunlight Policy Guides
EPA Officials
In a memorandum to all EPA employees
and in other actions, EPA Administrator
William D. Ruckelshaus has established
basic principles to ensure that Agency
activities are conducted in an open
manner.
"When I recently appeared before the
Senate Committee on Environment and
Public Works, I promised that EPA would
operate in a fishbowl," Ruckelshaus told
Agency employees. "I said 'we will
attempt to communicate with everyone
from the environmentalists to those we
regulate and we will do so as openly as
possible.'"
In addition to providing guidance for all
EPA employees, Ruckelshaus has also
had his legal staff set up a system to
avoid conflicts of interest, or the appear-
ance of them, in EPA dealing with firms
in which the Administrator had an interest
or with public institutions with which he
was associated.
At Ruckelshaus' direction, all Agency
matters in which he recuses (excuses)
himself from taking part to avoid conflict
of interest under this system will be made
public.
The following is the full text of the
Administrator's memorandum to Agency
employees on dealing in an open manner
with the public:
"When I recently appeared before the
Senate Committee on Environment and
Public Works, I promised that EPA would
operate 'in a fishbowl.' I said, 'We will
attempt to communicate with everyone
from the environmentalists to those we
regulate and we will do so as openly as
possible.' Therefore, I believe it is impor-
tant to set out for the guidance of all EPA
employees a set of basic principles to
guide our communications with the public.
"In formulating these principles I
considered more stringent restrictions on
contacts with those outside the Agency
than those described below. At my
request, my staff met with staff members
of the Administrative Conference of the
United States to discuss these issues.
This organization is an independent
agency that develops improvements to
the legal procedures by which Federal
agencies administer their programs. Based
on the recommendations of the staff
members of the Administrative Confer-
ence and those of the Office of General
Counsel, I am convinced that restrictions
beyond those set out below would unnec-
essarily inhibit the free flow of information
and views. In adopting these flexible
procedures I am relying on EPA employees
to use their common sense and good
judgment to conduct themselves with the
openness and integrity which alone can
ensure public trust in the Agency.
General Principles
"EPA will provide, in all its programs, for
the fullest possible public participation in
decision-making. This requires not only
that EPA employees remain open and
accessible to those representing all points
of view, but also that EPA employees
responsible for decisions take affirmative
steps to seek out the views of those who
will be affected by the decisions. EPA will
not accord privileged status to any special
interest group, nor will it accept any
recommendation without careful critical
examination.
Appointment Calendars
"In order to make the public fully aware of
my contacts with interested persons, I have
directed that a copy of my appointment
calendar for each week be placed in the
Office of Public Affairs and made available to
the public at the end of the week. The
Deputy Administrator, and all Assistant
Administrators, Associate Administrators,
Regional Administrators, and Staff Office
Directors shall make their appointment
calendars available in a similar manner.
Litigation and Formal Adjudication
"EPA is engaged in a wide range of litiga-
tion, both enforcement and defensive in
nature. All communication with parties in
litigation must be through the attorneys
assigned to the case. Program personnel
who receive inquiries from parties in matters
under litigation should immediately notify the
assigned attorney, and should refer the caller
to that attorney.
"Formal adjudications, such as pesticide
cancellation proceedings, are governed by
specific requirements concerning ex parte
communications, which appear in the various
EPA rules governing those proceedings.
These rules are collected and available in the
Office of General Counsel, Room 545, West
Tower. I will conduct myself in accordance
with these rules, and I expect all EPA
employees to do the. same.
Rulemaking Proceedings
"In either formal or informal rulemaking
proceedings under the Administrative
Procedure Act, EPA employees must ensure
that the basis for the Agency's decision
appears in the record. Therefore, be certain
(1) that all written comments received from
persons outside the Agency (whether during
or after the comment period) are entered in
the rulemaking docket, and (2) that a
memorandum summarizing any significant
new factual information or argument likely to
affect the final decision received during a
meeting or other conversations is placed in
the rulemaking docket.
"You are encouraged to reach out as
broadly as possible for views to assist you in
arriving at final rules. However, you should
do so in a manner that ensures, as far as
practicable, that final decisions are not taken
on the basis of information or arguments
which have not been disclosed to members
of the public in a timely manner. This does
not mean that you may not meet with one
special interest group without inviting all
other interest groups to the same meeting,
although all such groups should have an
equal opportunity to meet with EPA. It does
mean, however, that any oral communication
regarding significant new factual information
or argument affecting a rule, including a
meeting with an interest group, should be
summarized in writing and placed in the
rulemaking docket for the information of all
members of the public."
EPA JOURNAL
-------
JULY 1983
1 !
-------
Eagles, Other Birds Thrive
After EPA's 1972 DDT Ban
Visitors to many of the U.S. Fish and Wildlife national
refuges this summer will find that populations of such
relatively rare birds as the bald eagle, the brown pelican, the
osprey and the peregrine falcon are now increasing. A major
reason for their comeback is the ban on most uses of the
pesticide DDT, put into effect in 1972 by William D.
Ruckelshaus during his first service as EPA Administrator. U.S.
Fish and Wildlife Service researchers proved that DDE, a
breakdown product of DDT, was responsible for the
eggshell thinning which caused sharp population declines
among certain bird species. The research showed that the
species most seriously affected by DDT were those that
preyed on fish and other small animals that had been
exposed to DDT.
Peregrine fa/con released
12
Brown pelicans in waters off Fisherman's Warf at San Pedro, CaliL
EPA JOURNAL
-------
An osprey soaring over Maryland's eastern shore.
'
Bald eagle screams from a tree branch.
JULY 1983
13
-------
Changes
Help Speed
Hazardous
Waste
Program
EPA is carrying out a series of sweeping
policy and administrative changes to accel-
erate the cleanup of hazardous waste sites
in the United States.
Lee M. Thomas, Assistant Adminis-
trator for Solid Waste and Emergency
Response, said the changes are being
made to respond to Administrator William D.
Ruckelshaus' goal to "develop momentum in
these programs."
He explained that the new policies are
being set in place to accelerate site cleanups
under EPA's Superfund program and to
improve hazardous waste regulatory controls
under the Resource Conservation and
Recovery Act.
Superfund changes include the following:
• Transfer of greater decision-making
authority to the field staff, thereby allowing
decisions on certain immediate Superfund
cleanup actions to be made in regional
offices rather than just the Agency head-
quarters;
• Evaluation of all 419 Superfund priority
sites, which are candidates for long-term
cleanup actions, to determine which may be
made less hazardous through limited
"removal" action while options for
longer range solutions are developed.
"Removal" can be initialed more quickly
and does not require EPA to wait for
matching state funds;
• Elimination of the requirements for states
to pay 10 percent of the cost of studies and
designs to develop cleanup options for
priority sites, thus allowing the investigation
and assessment of sites even in states
suffering financial difficulties;
• Efforts to accelerate the investigation of
possible additional Superfund sites by states
using funds specially appropriated by
Congress for that purpose;
• Emphasis on recovering costs from
responsible parties after government has
taken cleanup action, thereby avoiding
delays in inducing private parties to
perform cleanup in these cases;
• Delegation of authority to regional
administrators to initiate and approve
hazardous waste enforcement cases which
was formerly held only by the Assistant
.
• •
Technicians wearing respirator masks and rubber gloves move barrels of toxic wastes.
Administrator for Solid Waste and Emer-
gency Response;
• Strengthened relations and communica-
tion with other federal agencies which have
key roles in the success of the Superfund
program: the Corps of Engineers with
responsibility to manage contracts for
cleanup; Centers for Disease Control, which
perform health assessment work in evalu-
ating site hazards; the Federal Emergency
Management Administration, which adminis-
ters relocation; and the Coast Guard, which
is the lead response agency for spill response
in certain parts of the country; and the
Department of Justice, the federal govern-
ment's trial lawyer in enforcement cases;
• Establishment of a target of 50 new
enforcement cases at sites where Superfund
monies are unlikely to be employed;
• Issuance of a community relations policy
which recognizes the concerns of persons
potentially exposed to hazardous sites, and
their need for timely and accurate informa-
tion on hazards, and opportunities for mean-
ingful involvement of citizens as cleanup
alternatives are being developed and
implemented.
Improvements in the hazardous waste
regulatory controls program include:
• Increasing the pace of granting permits to
facilities which handle hazardous waste under
the Resource Conservation and Recovery
Act. Permits—issued after public hearings-
require adherence to design and operating
standards more stringent than those which
apply during "interim status."
• Using enforcement powers to require
timely submission of technical information
needed to make permit decisions. Facilities
which cannot qualify for permits will be
required to close in conformance with regula-
tions designed to assure that hazards to
health and the environment are averted.
• Strengthening the capabilities of
states to attain "authorization" under
RCRA, while at the same time developing
contingency plans for EPA operation of
the program when plans are not
submitted or are inadequate. (By law
states must demonstrate equivalency to
the EPA program by January I985 or lose
their authority to operate programs.
• Recognizing in policy and guidance
that Congress will hold EPA finally
responsible for reasonable national
uniformity of implementation, quality
control, and comprehensive national
information which can be used to make
independent evaluations about the
success of the program.
1/1
EPA JOURNAL
-------
How Many MPG?
Let's Be Realistic
EPA will hold a public hearing Juiy 26-27 in
Ann Arbor, Mich., on proposed regulations
designed to adjust EPA laboratory vehicle
testing data to provide more realistic miles
per gallon information for consumers.
The hearing will be conducted at the Ann
Arbor-Huron High School in Ann Arbor,
Mich., where EPA's vehicle testing labora-
tory is located.
The Agency's mileage estimates are based
on testing under laboratory conditions for
comparison purposes. The testing is also
conducted to determine if the vehicles meet
air emission standards.
Because of the many different conditions
in which cars are operated, comparison data
are not intended to predict actual in-use
mileage. !n September, 1980, EPA reported
to Congress that, on the average, mileage
figures on new car stickers were higher than
the actual miles per gallon provided by cars
on the road. This discrepancy has resulted in
some consumer dissatisfaction.
Before the 1979 model year, EPA required
new car stickers to show both highway and
city mileage figures. When it became
apparent that consumers were using EPA
estimates as predictors of the actual mileage
they would achieve, the agency ordered only
the lower, city figure to be displayed as the
EPA estimate.
The proposed regulations would restore
the EPA highway mileage figure, but would
adjust both figures to make them more
realistic. The Agency would mathematically
adjust the mileage figures obtained in the
laboratory to match average figures expected
on the road. The city test value would be
multiplied by .90 and the highway test by
.78.
These factors were derived by comparing
reported in-use mileage figures for past
model years with the EPA label figures for
those years.
Charles L. Elkins, Acting EPA Assistant
Administrator for Air, Noise and Radiation,
explained:
"The public uses EPA mileage figures
when it goes out to buy a new car. We are,
therefore, proposing a formula so that the
numbers we come up with are our best
estimates of the actual fuel economy that
motorists can expect.
"However, I must caution everyone that
the calculations we make will still not predict
the exact mileage that will be achieved by
every individual driver and every individual
car. Factors such as weather conditions,
driving habits and road surfaces will still
affect the mileage any particular motorist will
get."
The proposed regulations would also
require that the mileage numbers appearing
on new car stickers be recalculated at the
middle of the model year and at any time a
design change is made that significantly
affects fuel economy.
Automobile emissions and gasoline usage
are checked in EPA's Motor Vehicle Emis-
sions Test Laboratory in Ann Arbor, Mich.
JULY 1983
15
-------
The Return of
"An Extraordinary
Public Servant"
"EPA was fortunate to have, as its first
Administrator, an extraordinary public
servant who gave direction and
momentum to the fledgling
environmental agency."
—President Reagan describing
William D. Ruckelshaus, May 18, 1983.
In taking office again recently as EPA
Administrator, William D. Ruckelshaus
assumed the first position in the federal
government that he has held since his
celebrated resignation as Deputy
Attorney General from the Justice
Department back in the Watergate days.
The irony of returning to the EPA
where he served as the first
Administrator has been lost on no one,
least of all himself: "I am a little older. I
don't see quite as well as I once did.
Hopefully, I'm a little wiser, although you
would have to check with my wife on
that," he told an enthusiastic audience of
agency employees prior to his
confirmation, "At any rate, here we go
again."
Some things don't change. In his
first interview, granted to the
Washington Post, Ruckelshaus is quoted
as saying, "One of the things that strikes
me in coming back here again [to EPA] is
how hard these decisions are, particularly
the ones that get up here, and how
difficult it is to decide how [to) strike this
balance."
Other things do change, however,
particularly when compared to the recent
past. Morale among employees, for
EPA employees reach to shake hands with
Administrator William D. Ruckelshaus on his
return to the Agency.
16
EPA JOURNAL
-------
instance, has steadily improved since the
new Administrator's arrival. His
appointment calendars are made public
on a weekly basis. The agency again is
endorsing full public participation in
decision making. New appointees are
slowly moving in, and some old ones are
going.
One point that Ruckelshaus has made
very clear is that he received the backing
of President Reagan upon resuming the
job of running the EPA. "The President
has convinced me that he wants no
abandonment of the goals of protection
of the public health and of our natural
environment," he has said.
Prior to returning to EPA, Ruckelshaus
worked for Weyerhaeuser, a forest
products company, in Tacoma,
Washington, as senior vice-president for
law and corporate affairs, responsible for
policy setting and coordination of the
company's key external relationships and
its legal service functions.
Commenting on his return to EPA,
Ruckelshaus said, "My job as EPA
Administrator is the same today as it was
when I held that job before and that is to
represent the public interest to the best
of my ability."
Ruckelshaus has been careful to excuse
himself from any area of EPA that might
create a conflict of interest with his prior
activities. "Under the laws that have
been passed in recent years," he said,
"it's necessary for me to fill out more
forms than EPA has paper. There are
conflict of interest forms, financial forms,
FBI checks. I ought to be able to pass
that. When I left the FBI, I took my file
with me," he joked. (Ruckelshaus served
as acting Director of the FBI when he
first moved to the Department of
Justice in 1973.)
President Reagan described
Ruckelshaus as a man who "EPA was
fortunate to have as its first
Administrator, an extraordinary public
servant who gave direction and
momentum to the fledgling
environmental agency. His assignment,
not an easy one, was performed with
dedication, integrity and a balanced
understanding of the Nation's needs. He
soon became known—and with good
reason— as 'Mr. Clean.'"
Ruckelshaus was born in Indianapolis
in 1932 and was graduated cum laude
from Princeton University in 1957. His
daughter Cathy—one of five children in
his family—recently graduated from his
Alma Mater. The new Administrator
obtained his law degree from Harvard in
1960. Thereafter he practiced law and
stayed active in politics back in Indiana
until national politics beckoned.
The return of Ruckelshaus' wife Jill has
generated almost as much ink in the
Washington newspapers as his
return. She is also a lawyer and
remains politically active, serving on the
U.S. Civil Rights Commission. She enjoys
a reputation for being independent
minded. When asked on a network
morning news show about any possible
differences of opinion between the
President and Jill, the EPA Administrator
diplomatically responded that he wasn't
going to be baited into that trap.
Old-time EPA hands have noted that
Ruckelshaus looks trimmer and healthier
than ever before. In fact, he has become
an avid jogger. He also "gets away from
it all" through bass fishing.
Surely a part of the reason
Ruckelshaus elected to leave Seattle—a
city to which he and Jill had become
attached—was a genuine affection for
EPA and its employees and a sense of
pride in the agency's accomplishments.
As he told the New York Times in an
early interview, "There is no question
that the air and water are appreciably
cleaner than they were in 1970, and
orders of magnitude cleaner than they
would have been if there had been no
laws."
Yet, he consistently has voiced a need
for constructive regulatory reform:
"Protecting human lives and our
environment cannot be done in a
vacuum," he's said. "Protection must be
harmonized with other social goals, with
goals involving our economy and the
production of adequate energy . . . The
issue today isn't whether we are going to
clean up, but how."
In his speech to the employees, the
new Administrator returned the warmth
that had been bestowed by his
overwhelming reception and gave yet
another clue as to why he had given up
so much to come back: "My real reason
for asking you here today is to start to
convince the American people what I
know in my heart—there is no finer
group of public servants in this country
than the employees of the EPA. It was
true at the beginnng, and it's true now."
Back Cover: A young osprey on its
Chesapeake Bay nest stares intently at
EPA photographer Steve Delaney.
-------
United States
Environmental Protection
Agency
Washington 0 C 20460
Postage and
Fees Paid
Environmental
Protection
Agency
EPA 335
Official Business
Penalty for Private Use $300
Third Class
Bulk
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