United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 14
Number 7
November December 1988
&EPA JOURNAL
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Copyright 1988 by Herblock in The Washington Post.
-------
Our Environmental Priorities:
What Should They Be?
How can tin; nation
establish and implement
priorities for action out of
what sometimes seems to he
an overwhelming number of
environmental problems?
This issue of KPA Jourmil
explores the question and
also includes articles on
related items such as a
proposal for a world Karth.
Day in 1990 to establish
environmental concerns as a
global priority.
The first article discusses a
basic concern: how well do
our present institutional tools
serve us in the setting and
carrying out of environmental
priorities? It is by Mike
Gruber, an lil'A staffer on a
temporary assignment to the
Washington State Department
of Natural Resources and a
long-time environmental
writer.
In the second feature, six
observers ranging I mm a
leader of a national
environmental group lo a
Western (iovernor explain
what their approach to
environmental
priority-setting would he il
they were advising the new
.Administration.
Next, the public speaks. In
this feature, I 7 people in
different occupations in
states from California to New
Jersey say in interviews what
they believe the country's
environmental priorities
ought to be.
Then Alvin Aim, a former
EPA deputy administrator,
explains the
recommendations that a
working committee he chairs
Remember flower power?
Celebrating nature and its
riches on the first Earth Day
(April 22, 1970), an estimated
25 million Americans took
part in the largest organized
demonstration in human
history. See article on page 34
proposing a global Earth Day
in 1990.
has made for research
strategies to help solve urgent
environmental problems of
the next decade and beyond.
whatever they may be. The
report was requested by
EPA's Administrator. Next an
Agency writer, Jack Lewis,
sunnnari/.es environmental
progress and challenges
generally, based on a recent
EPA report.
An article by an Agency
official, Jerry Kotas, explains
a shift in KPA's priorities
toward prevention of
pollution before it gets into
the environment. And an
article by another EPA
staffer, Ron Brand,
portrays an innovative
approach to a typically
complex, modern-day
pollution control task.
ensuring that the thousands
of underground storage tanks
around the country don't
harm the environment and
people's health.
Taking a global
perspective, author Denis
Hayes, who was coordinator
of the first Karth Day,
proposes a similar event
globally in 1990. two decades
after the first observance on
April 22, 1970. He argues
that environmental priorities
must now become a greater
concern everywhere, backed
by public understanding and
will.
Next is a letter to the editor
taking issue with an article in
a recent Journal. The
magazine then concludes
with a regular feature,
Appointments, o
Patrick Bums photo The New York limes
-------
United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 14
Number 7
November December 1988
&EPA JOURNAL
Lee M. Thomas, Administrator
Jennifer Joy Wilson, Assistant Administrator for External Affairs
R.A. Edwards, Acting Director, Office of Public Affairs
John Heritage, Editor
Karen Flagstad, Assistant Editor
Ruth Barker, Assistant Editor
Jack Lewis, Assistant Editor
Marilyn Rogers, Circulation Manager
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.
The KPA 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.
Contributions and inquiries should
be addressed to the Editor (A-107),
Waterside Mall, 401 M St., S.W.,
Washington, DC 20460. No
permission necessary to reproduce
contents except copyrighted photos
anil other materials.
Are Today's Institutional
Tools Up to the Task?
by Michael Gruber 2
Setting Environmental
Priorities: Six Observers
Speak 7
—A Congressional Advisor
by John H. Gibbons g
—An Environmental Leader
by Peter A. A. Berle KJ
—An Industry Official
by Bruce W, Karrh 12
—An Elected Official
by Governor Roy Romer 14
—A Public Policy Specialist
by Milton Russell if,
—A Scientist/Engineer
by Raymond C. Loehr if)
Setting Environmental
Priorities: The Public
Speaks 20
The Need to Think Ahead
by Alvin L. Aim 23
Environmental Problems:
The Situation
by Jack Lewis 27
Pollution Prevention: Getting
a Higher Priority
by Jerry Kotas 30
Borrowing an Idea from
Big Mac
by Ron Brand 32
Proposing a Global Priority:
Earth Day. 1990
by Denis Hayes 34
Letter to the Editor 38
Appointments 39
Design Creciits:
Ron rarroh;
/times fl. l)]»ram;
Robert Fleimiouji.
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-------
Are Today's Institutional Tools
Up to the Task?
by Michael Gruber
Despite the substantial achievements
scored in environmental protection
in the United States over the past two
decades, policy-making in this field
generally takes place against a
background of disappointment. There is
a pervasive sense in the nation at large.
and even within the ranks of 1-11'A, that
we should be doing belter, (hat there is
a continuing and even expanding gap
between expectation and ivhat KPA can
deliver.
Certainty no other regulatory agency
is in tin; news and before Qmgress so
frequently or, by and large, through four
administrations, so often pilloried in
both places. It cannot be just politics or
bureaucratic sloth that causes this. The
problems are inherent. In other words,
EPA is a creature of its laws, the state of
science, and the public will, and its
problems arise from the fact that these
do not always pull it in the same
direction.
First, the laws. Ml'A, arguably the
most important federal regulatory
agency, is also the only one without a
comprehensive organic statute;. No
legislation tells its .Administrator simply
to protect the whole environment in the
most effective way. Instead, El'A
administers nine separate statutes and
parts of lour others. These different
statutes have different kinds of goals
and, in large measure, quite different
intellectual antecedents. Some arise
from the conservation ethic, the desire
to protect the natural world. Some arise
from a concern about human health.
Others stem from observations ol the ill
effects of pollutants on economic or
aesthetic values. Kach statute has given
rise to a virtually independent program,
and each program lias staked out an
environmental problem that it is
required to "fix" according to its
particular statutory mandate.
Unfortunately, the real environment is
not so neatly divided. All parts of the
environment are in some way
connected, It follows that the control of
pollution should be integrated across
program and disciplinary lines, so as to
increase the efficiency of control from a
whole-environment perspective and to
prevent the unwanted transfer of
pollutants from medium to medium.
There is a pervasive sense in
the nation at large, and even
within the ranks of EPA, that
we should be doing better ....
This was one of the original reasons
EPA was established in 1972, hut the
Agency's legal structure (and the
administrative organization that arises
from it) has made a cross-media
approach nearly impossible. Pollutants
"eliminated" from one environmental
medium (such as the air) show up
unexpectedly in another (such as water).
The acid rain problem is one example of
this effect.
This non-integration has deep roots in
the Agency. EPA was formed by
combining different organizations,
which had not only different statutory
mandates but also quite different
professional values. Thus, even if we
were able to institute a perfectly
integrated program from a legal and
organizational standpoint, even if the
Agency were empowered to move more
effectively than it now can. there would
remain the problem of what to do in the
face of varying degrees of scientific
uncertainty.
In exercising, its great powers over our
national life, EPA is obliged to act
according to the best available scientific
knowledge, but scientific uncertainty is
pervasive in environmental
decision-making to an extent that is
difficult for the public to comprehend.
We are hardly ever sure about how
pollutants affect human health or
environmental values, about the
movement and transformation of
pollutants after release, or about the
actual distribution of pollutants in the
environment.
EPA's efforts at dealing with this
uncertainty have been hampered
because different members of the
environmental protection community
typically display different attitudes
about the level of understanding
required before action takes place. For
example, people trained in public
health are predisposed to act
"protectively"—that is. on the basis of a
fair probability of harm, a bent that is
specifically authorized in most of EPA's
statutes. Also, many of these laws
demand decisions for which no firm
scientific basis exists. As a result, those
in the scientific community who do not
have this public health background may
be uncomfortable with some part of
what EPA does; this is one reason why
scientific issues concerning
environmental protection often wind up
for resolution in the courtroom rather
than the laboratory.
EPA JOURNAL
-------
Wetlands such as this
peaceful bayou in Louisiana
often are doomed to be
drained or filled for human
activities. The author believes
that protection of natural
values should rank high on
the scale of EPA concerns
along with public health.
The lawyers tend to pull in the
opposite direction. EPA is a legal as
well as a scientific: entity. Lawyers need
enforceable standards that will hold up
under court challenge. They tend to be
impatient with scientific uncertainty
and skeptical about control measures
that depend on tentative conclusions or
doubtful calculations.
Engineering solutions have often been
used to get around such problems—in
the sense that it becomes less important
to know the precise effect of a pollutant
on health if you are committed to
removing that pollutant through
application of the best available
technology. Engineers tend to look
narrowly at efficiency: i.e., is this the
best way to remove this substance from
a particular medium? Historically, they
have been less concerned with
calculating the effect of removal on
some value, such as human health, or
with intermedia transfers.
Economists (and public policy
managers generally) are interested in
comparing quantified values. They seek
to connect the cost of a cleanup with
some quantifiable benefit derived from
it. But although simple sets of numbers
(such as costs and risks) may be easy to
compare, such comparisons often bury
the uncertainties underlying them and
may supply an impression of accuracy
that is entirely illusory.
One result of this disparity of values
is that when the Agency presents its
decisions to the public:, many people
have a hard time distinguishing between
what is science (pollutant X has YZ
effect) and what is policy (all things
considered, it is probably in the public
interest to keep exposure to such a
pollutant below a certain level).
Paradoxically, most
Americans espouse a style of
life that is, in fact, highly
polluting.
This uncertainty makes the public
uneasy, as does the appearance of
environmental problems that were
supposed to have boon "fixed" but
which, partly because of the Agency's
piecemeal approach, have popped up
again in another guise. This unease has
resulted in an almost continual flood ot
mandates—both new laws and
amendments to old ones—each one
designed to patch a particular leak. This
is a recipe for failure. At present, the
simple fact is that the EPA cannot
possibly do all the things its various
mandates tell it to do. After a brief spurt
of rapid growth in the early 1970s, tin:
constant dollar budget of EPA has
changed only marginally in purchasing
power. During the last three
administrations it has hovered around
$1 billion, exclusive of sewage
construction grants and the Superfund.
If this size represents the effective
national consensus on how large the
federal environmental effort should be,
then it is too small for the present
mission. It is difficult to imagine a
plausible political scenario that would
make it large enough.
For example, EPA has been told to
eliminate water pollution, eliminate all
risk from air pollution, prevent
hazardous waste from reaching ground
water, establish standards for all toxic
drinking water contaminants, and
register and "reregister" all pesticides.
None of these things has yet been
accomplished. The scale and complexity
of the problems involved arc simply too
large.
And even if EPA's resources were
more suited to its mission, and even if it
knew exactly how to accomplish this
mission, it is not at all clear that the
radical restructuring of American life;
that such a mission implies would be
accepted. The American people are
strong supporters of environmental
protection. In virtually every national
poll taken during the past 15 years, they
have declared by substantial majorities
that the environmental effort should he
expanded, and that they are willing to
make economic sacrifices to control
pollution. The desire to control
pollution is particularly strong where
toxic substances an; involved. We may
surmise, in fact, on the evidence of
innumerable public moot ings, that the
tolerance of the American public, for
risks from contamination by toxic
substances is virtually nil.
Paradoxically, most Americans
espouse a style of life that is. in fact.
NOVEMBER/DECEMBER 1988
-------
highly polluting. They want cheap
energy and a society based on
automobile travel, with plenty of roads,
parking lots, and shopping malls. They
want plentiful, cheap, attractive
foodstuffs. They want the convenience
and economy afforded by it large and
growing selection ol chemical-based
industrial and consumer products. They
want to be able to throw things away.
What they don'l want is a Jot of
federal government interference in their
personal choices—where to live, what to
build, what to drive, how to drive it.
and so on. The failure of the noise
program and ot transportation planning
to control pollution, the
near-impossibility of siting hazardous
waste facilities, and the difficulty we
still have in controlling land use to
protect wetlands are examples.
In going from the rhetoric of
environmental law to the realities of
environmental protection, KPA is forced
to make innumerable compromises. It
has no clear guide on how to make
these compromises. The laws and
public opinion tend to cast the Agency
as an uncompromising environmental
advocate; the facts of economic life and
the realities of operations on the state
and local levels demand the brokering
of different interests. The Agency often
finds itself in the position of being
wrong whatever it does. This situation
docs not encourage boldness and
alacrity in those subject to it.
Today it seems that the
natural world—the planetary
ecology—is less in danger
from high technology than
from low.
Thus the general problem confronting
KPA: a patchwork legal structure, an
unsure scientific base, and an impatient
public: that is nonetheless ambivalent
about the true lifestyle costs of a
pollution-free society. This problem is
riot going to go away anytime soon, but
as a first step in dealing with it
straightforwardly the Agency might
adopt the following three principles.
These principles—and the policy
changes that flow naturally from
them—could become the basis for a
more effective and efficient
environmental policy for the United
States, a policy that would be flexible
enough to cope with the future.
• Environmental protection policy must
recognize the, interconnectedness of the
environment and emphasize
multi-media approaches to pollution
control.
This means that when we require that
pollution he removed from one
environmental medium, we are obliged
to determine where it goes and what it
does when it gets there, in quantitative
risk terms, whenever possible.
Naturally, the stability and rationality of
the Agency's operations would be
greatly enhanced if it had only one
statute to administer and a smaller set
of Congressional committees to deal
with. The friends of the environment
might do well to encourage Congress to
move in this direction.
Meanwhile, integration is easier to
talk about than to do. Currently, efforts
at integration within EPA have to swim
against the stream of single-media
program rules and legislation. An
integrated approach, for example,
requires a quite different sort of
information than does a set of
quasi-independent media-specific:
programs. Yet it is the programs that do
the bulk of the information-collecting.
Information-collection budgets being
always tight, these programs are
resistant to collecting information not
specifically required by program needs.
For this reason, retrospective
integration, which reviews a program
decision for cross-media impact prior to
a regulatory decision, is clumsy and
inefficient: there may be enough
information to stir suspicions that, for
example, risk is being transferred across
media lines, but usually not enough to
EPA JOURNAL
-------
Americans generally espouse
a lifestyle that is highly
polluting. Among other
things, they want plentiful,
cheap, cosmetically attractive
food products that depend on
the use of chemicals in
agricultural production.
propose an alternate policy. Risk-based
cross-media analysis must become
prospective, and the programs must be
given a positive responsibility to
generate the information that will make
this a reality.
• We must accept that the main
business of environmental protection is
the reduction of risk.
The EPA should therefore endeavor to
understand (in quantitative terms,
where possible) the risk-reduction
consequences of every individual action
as well as those of all our actions taken
together. "Risk" should be broadly
defined. It means human health risk in
the literal sense, of course, but it must
be extended to include damage of all
types, to all organisms, to natural
systems, and to other environmental
values. We must re-emphasize that
while EPA is a public health agency, it
is not just a public health agency. The
preservation of ecological values may
not make headlines, but if EPA is not
strong in this area, no one else will be,
and we will all suffer for it in the long
run.
While it is perhaps impossible to find
a common metric that will tie all these
values together, it is quite possible to
communicate the sum of what we have
accomplished in terms of the various
"risks" we have reduced, and to justify
the balance among risks of various types
within this sum.
The familiar uncertainties associated
with risk calculations ought not to
prevent EPA from adopting a strategic:
approach based on risk-reduction in all
of its programs. A true strategic
approach means the concentration of
resources on a few obtainable,
measurable objectives. Given the
inevitable limitation of resources, it
carries with it the implication that less
important objectives will not be
completely carried out. It also implies
the transfer of personnel and budget
Environmental protection
efforts frequently involve
scientific uncertainty, which is
inherent even in the most
sophisticated risk assessment.
The public prefers certainty.
It is difficult to see how
significant progress can be
made by a continuation, or
even a substantial expansion,
of business-as-usual.
between programs and the creation of a
much more flexible agency than has
existed in the past. EPA will have to
defend these choices on the basis of risk
calculations, or at least some explicit
comparative statements about the extent
to which various options prevent
damage to environmental values. This
in itself would be a major change and
extremely valuable as a HUMUS of
communicating with the public and
Congress.
To support this risk-based effort, the?
EPA could replace or at least
supplement its traditional measures of
achievement with measures based on
risk. Although a count of permits issued
and site cleanups started, for example,
is a useful indicator of administrative
progress, it is essential to get a better
grasp of what these programmatic
indicators mean in terms of substantial
environmental benefits. EPA's
accountability system could be modified
to hold program managers responsible
for developing measures to reflect real
environmental objectives and for
progress in achieving them. A stronger
focus on avoiding the inter-media
transfer of pollutants is a necessary part
of such an approach, since its goa! is to
reduce, rather than transfer, risk.
Changing policy emphasis from
"pollution control" to "reduction of
risk" (where "risk" includes measurable
environmental damage) requires new
forms of regulation. It is important to
recognize that technology-based,
command-and-control regulation is less
valuable in dealing with the final
increments of pollution and with toxics
than it was in managing the gross
pollution for which it was first
designed. The reason is not just that
command-and-control is often overly
expensive for the benefit achieved, and
difficult to implement. The scale of the
problem--the number of pollutants, tin;
number of diverse sources, and so
on—militates against a purely
command-and-control system having a
substantial effect on the problem except
in the very longest run.
The alternative is to adopt policies
that will turn the interests of polluters
against polluting. Incentives based on
risk reduction, supported by a really
comprehensive and reliable monitoring
system, are worth trying on a significant
scale. States have used I'm1, systems for
hazardous waste disposal, for example,
and constructed them so as to favor the
safest forms of disposal and to penalize
the production of particularly hazardous
wastes.
It will be argued that alternatives to
command-and-control allow die,it ing.
Of course some cheating will occur, lint
the essential question is how to reduci1
the damage done by pollution in tin;
shortest time, with something like the
present level of enforcement resources.
What we are doing now is not working
at all well. The system is marked by
substantial non-compliance, delay,
consent decrees, and the other
apparatus of legalistic: combat, rather
than bv a steadv reduction in toxic
NOVEMBER/DECEMBER 1988
-------
exposure. It seems reasonable that the
same forces that operate in the
marketplace should be given more of a
chance to operate to limit pollution than
they have in the past.
The most difficult aspect of the EPA's
mission is that it is expected to be
simultaneously the national advocate for
a better environment and the agent
responsible for balancing environmental
goals against other social values.
Credibility is the key to accomplishing
this mission. If the Agency is seen as
bold and swift in the location and
reduction of substantial risks, it is likely
to be granted the leeway it needs to
perform the appropriate balancing
judgments, even when this requires
declining to control certain minor risks.
The success of this approach will
depend on its demonstrated superiority
in actually reducing palpable excessive
risk (as opposed to issuing regulations
designed to "control" this or that type of
pollution). It will be difficult to do this
if environmental policy continues its
traditional reliance on
command-and-control regulation, since
EPA and the states will never have the
resources actually to enforce every such
regulation on every source.
Environmental policy must begin to
move toward an incentive/penalty
approach based on severity of the risk
generated by polluters.
• The relation between the federal
environmental e//ort and (hose of the
various states must be redefined.
Where risks affect local populations,
remedial solutions should be tailored to
fit the local situation, and state and
local governments should play a major
role in doing this. A credible approach
of this type requires three things:
— It must be well-understood that
pollution havens will not be allowed.
— The federal authority must be
vigorously applied if it appears that a
locality is suffering from pollution
produced in another locality.
— The technical resources of EPA must
be to some extent re-focused to support
locally designed risk reduction.
The relationship of the federal
environmental effort to those of the
states must therefore be redefined.
EPA's media programs spend an
inordinate amount of time checking up
on what state programs have done, and
approving changes in those programs.
Such policies arise from the need to
check that federal resources are being
properly spent, which is reasonable, and
from the program oversight functions
built into the statutes. These statutory
oversight provisions are based largely
The EPA should re-focus its
resources, and concentrate on
the big problems again, both
those that remain in the
United States, and those of the
global community.
on the continuing suspicion that, left to
themselves, some states will become
pollution havens. Although states vary
in their enthusiasm for environmental
protection, there is no evidence that this
has ever translated into differential
choices on the part of firms. This is a
large and diverse country, and
flexibility in implementing programs
seems an obvious necessity.
Elaborate second-guessing of states
uses resources that might better be spent
doing things that the states can not do at
all—controlling interstate movement of
pollution, for example. States also have
a limited ability to perform intensive
and costly monitoring in areas
particularly susceptible to
environmental risk, and EPA could help
here as well. In general, EPA could
increase its ability to supply state
governments with the information base
for effective and efficient control of
particular local pollution problems.
Can such changes really occur?
Perhaps not, and certainly not all at
once. But it is difficult to see how
significant progress can be made by a
continuation, or even a substantial
expansion, of business-as-usual. Over
the past five years, policy-making at
EPA has been dominated by the struggle
to control relatively small increments in
the incidence of a single human disease:
cancer. Cancer tends to dominate
environmental debate now, not only
because it is dreaded and widespread
but because a technical peculiarity of
risk assessment, the inability to set a
threshold (i.e., an exposure level at
which there is zero risk) for many
carcinogens, ensures that when some
exposure is found, some risk can be
calculated. This calculated risk then
galvanizes a public outcry and thereafter
the policy-making process.
This is a long way from the original
ideal of the environmental movement,
which was nothing less than to bring
technological society into harmony with
the natural world. Today it seems that
the natural world—the planetary
ecology—is less in danger from high
technology than from low. Half the
world's people still have firewood as
their only fuel. In some places this
dependence has disastrous
consequences for local
ecosystems. Economic development in
many countries proceeds in a manner
that is wholly oblivious to
environmental effects. In the Amazon,
an area of rain forest the size of Austria
is destroyed each year. This destruction
may have global consequences.
It appears that we may experience
planetary warming in the next few
decades due to the production of
greenhouse gases by technological
civilization. Major changes in this
civilization may be necessary to keep
this trend from developing into
widespread catastrophe.
On the health front, we might wonder
why we are willing to spend millions of
dollars to (perhaps) avoid a fraction of a
case of cancer each year, when each day
about 25,000 people throughout the
world die of easily preventable
water-borne diseases or from the effects
of insufficient water. Obviously, we do
not yet know how to deal with global
problems. But, just as obviously, 20
years ago we did not know how to deal
with national problems, and we have
dealt successfully with many of them.
In the EPA the nation forged an
instrument that was able to confront
national pollution problems of
staggering complexity and to avert what
many saw as inevitable disaster. The
EPA should re-focus its resources, and
concentrate on the big problems again,
both those that remain in the United
States, and those of the global
community, o
(Gruber is an EPA staffer on temporary
assignment to the Department of
Natural Resources in the State of
Washington under an Intergovernmental
Personnel Act program. He is a
long-time environmental observer and
writer.]
EPA JOURNAL
-------
Richard Freer phoro. National Park Semce
John H. Gibbons
Environmental concerns
ranging from global ivarming
to medical waste disposal to
poor air quality in major
cities hart; caught the neivs
headlines repeatedly in
recent months, Manv of these
same concerns ivere also
reflected in the campaigns of"
both Presidential candidates.
What should be the top
environmental priorities for
the new Administration find
Congress, and lion- should
our decision-makers go about
setting these priorities? EPA
Journal asked six prominent
observers in the
environmental arena for their
opinions. Their comments
follow:
Milton Russell
Raymond C. Loehr
-------
A Congressional Advisor
by John H. Gibbons
Planting alternating strips of
corn and small grains
protects this Maryland farm
from erosion. Such steps can
help safeguard water quality.
The specter of global
warming heightens our
awareness ot environmental
problems long brewing—acid
rain, urban and regional air
pollution, species extinction.
water degradation, human
dislocation—and highlights
their international
characteristics. Relations
between Canada and the
United States suffer from
acid rain; Brazil must deal
with conflicts between
national development and
preservation of tropical
forests critical to the globe's
health; carbon dioxide,
methane.
chlorofluorocarbons, and
other molecules that threaten
climate and the protective
It may be timely and
appropriate for the
Agency to assume a
larger role in
protecting the national
and global
environment.
ozone layer do their work
regardless of where they
come from or who they
affect.
These seemingly disparate
issues share a similar root:
inejificienl use of resources.
Many pollution problems are
directly linked to inefficient
use of fossil fuels, yet U.S.
policy sends mixed signals
on implementation of energy
conservation methods that
have proven cost-effective.
Similarly, some companies
have shown that investment
in resource-efficient
processes that result in
hazardous waste reduction
can he profitable, but lew
companies have followed
their lead, and national
policy does little to
encourage them. Overall, our
environmental policies reveal
a commitment to clean up
the messes we make, but also
inadequate reflection upon
ways to avoid those messes
in the first place,
A top priority for the
nation is an environmental
policy reorientation toward
programs that emphasize
resource efficiency as well as
improved pollution
prevention and control, and
that consider the global
commons as well as local
problems. A drive to slow the
flow of energy and mineral
resources required to produce
a given level of goods and
services would
commensurately reduce
pollution, even in the
absence of more stringent
clean-up requirements. Such
a comprehensive approach to
policy requires coordination
of the many federal and state
agencies that play roles in
national environmental
policy. Congress could
designate a major role for
EPA in such a policy
revision.
EPA traditionally plays the
part of regulatory taskmaster
of emissions limits and
pollution cleanup. But recent
developments indicate that it
may be timely and
appropriate for the Agency to
assume a larger role in
protecting the national and
global environment. Global
warming presents
extraordinarily complex
issues of science and
international relations that
require immediate national
attention, Warming, which
results largely from burning
fossil fuels, can be slowed or
halted, though it may be
essentially irreversible. More
tractable problems, such as
air pollution and acid rain,
are also closely linked to fuel
consumption. Many national
security costs are attributable
to energy appetites. Work on
any of these problems is
inherently linked to the
others. A resource-efficiency
approach to global
warming—particularly
adoption of energy
conservation policies—could
further the economic,
environmental, and national
security agendas of many
agencies in this nation and
many countries around the
world. Given adequate
funding and authority, EPA
could more effectively
coordinate domestic policy
and work more aggressively
with other agencies, like the
Department of State and
Department of Energy (DOE),
to lead efforts toward
international accords.
More cars and more auto
travel have meant more fuel
use, which, in turn, has
produced more air pollution.
This heavy traffic is
approaching the Oakland,
California, Bay Bridge toll
plaza.
EPA JOURNAL
-------
^WP^WPBB^PWP* ._. . .>;rc
•I
An intensified role in
global issues will still leave
EPA with a plateful of
serious pollution issues at
regional and local levels
within the United States.
Tropospheric: ozone, acid
rain, and indoor air quality
hazards must be addressed
within the framework of a
revised Clean Air Act.
Aquatic resources—marine
and freshwater environments.
ground water,
wetlands—suffer from a
variety of pollutants (farm
and street run-off, industrial
and municipal discharges,
dumping, atmospheric
deposition) that must be
curbed. Decisions and action
are required with respect to
hazardous and municipal
solid waste, particularly to
encourage the prevention of
waste generation at its
source.
Using technology to
improve resource efficiency
can help solve many of these
problems. Urban and regional
air pollution results mainly
from fuel use; thus EPA's
enforcement of the emissions
limits required by the Clean
Air Act would be much
simpler if less energy were
consumed. The goal of clean
air could best be reached,
then, by coordination of
EPA's activities with those of
the Department of
Transportation, which
enforces fuel economy
standards, and DOE, which
enforces appliance efficiency
standards and could
encourage energy
conservation in all economic;
sectors. In another medium,
EPA's efforts to enforce the
Clean Water Act, which are
beginning to reduce
point-source pollution, could
be enhanced in the area of
nonpoint sources by actions
from other agencies. For
instance, the U.S. Department
of Agriculture could greatly
assist efforts to control
nonpoint-source pollution by
implementing agricultural
policies that discourage
excessive fertilizer and
pesticide use and by
continuing to develop
innovative approaches to
farm waste management. A
clean and productive natural
environment requires policies
that go beyond cleanup and
focus on pollution prevention
and resource efficiency. EPA
could be a key player in
structuring such an approach.
Policy priorities derive
most logically from the
magnitude of a problem's
impact or risk of impact.
Environmental problems are
increasingly global—either in
origin (as with global
warming, loss of
stratospheric ozone, rapid
population growth)—or in
similarity of impact (as with
air pollution, toxic and
hazardous wastes, and
military- or civilian-produced
nuclear waste). The necessity
of local and national cleanup
has demanded most of our
attention to date. But a future
that includes continued
economic growth for us and
Third World development
requires that we also begin to
focus on ways to prevent
pollution and enhance waste
reduction. In other words, it
requires that we make wise
and thoughtful use of our
resources.
Adoption of resource
efficiency as a major
stratagem for achieving a
healthy environment will
require a strong leader. The
stated goals of existing
legislation create an
unspoken but critical role for
EPA to help devise an
integrated approach to
environmental problems. \Yc
should also consider a new
environmental mandate that
specificaiiy recognizes the
interconnectedness of all
human aclivities and
includes authority for KI'A
to:
• Help coordinate
environmental actions of
domestic: agencies.
• Participate more; actively
in international affairs.
• Expend funds not only to
enforce existing programs but
also to research new and
better approaches to waste-
reduction and resource
efficiency.
These directives could
effectively replace the
piecemeal and sometimes
illusory "progress" of the
past, n
(Gibbons is Director of the
Congressional Office of
Technology Assessment.)
NOVEMBER-DECEMBER 1988
-------
An Environmental Leader
by Peter A. A. Berle
For the first time in history,
unprecedented numbers of
people are consuming the
earth's resources in ways and
at a rate that cannot be
sustained. In light of this
collision course of
consumption arid resources,
there are two overriding and
intertwined issues that the
next Administration and
Congress must tackle if the
United States is to reassert its
world leadership role and
make significant progress
toward protecting and
improving environmental
quality of life. These key
issues are:
• h'fu.Tgy. We must make
dramatic gains in energy
conservation, energy
efficiency, development of
alternative renewable energy
sources, and recycling.
• Population. We need to
drastically increase support
to developing nations for
family planning education
and distribution of
contraceptives. In addition,
we must support intensive
research aimed at fostering a
technological leap in safe and
simple contraceptives.
We as a nation must chart
this bold course not only
because it will bring us into
greater harmony with our
natural environment and it
makes sense economically,
but because our national
security is at stake.
Since the end of World
War II, we in the
industrialized world have
viewed national security and
international stability largely
as a bipolar, East-versus-West
struggle played out primarily
in terms of military strength.
That school of thought
persists to this day. However.
the stark reality is that
virtually anywhere we might
look in the world—from the
population crush in Mexico
and Egypt to the
deforestation of Indonesia
and Central
America—nations of strategic
importance are suffering from
environmental and
population problems that
have frightful potential to
destabilize their governments
and their regions. This tends
to be seen as a threat only to
Third World stability. But
now that global warming is
part of this equation, we
must confront the possibility
of major economic disruption
to the United States and
other industrial nations.
This is why addressing the
energy issue must be a high
priority early in the next
Administration. Continuing
to rely heavily on
non-renewable fossil fuels,
with no long-term plan to cut
back our burning of oil and
coal, clearly puts us at risk
both to the vagaries of
Middle Eastern politics and
to the greenhouse effect.
Economic competitiveness
also comes into play here.
For example, our per capita
energy consumption is twice
that of West Germany's.
The moral issue of
practicing what we preach is
also an important factor here
that will greatly affect our
ability to influence both the
First and Third Worlds. This
is best illustrated by the fact
that the United States, with
just 5 percent of the world's
population, consumes 33
percent of the world's
resources and creates 33
percent of the world's
pollution.
Clearly, to be effective as a
world leader on conservation
and environment issues, we
must be sure that the United
States is not asking the
in
EPA JOURNAL
-------
people of the industrialized
world or the Third World to
do something that people in
New Mexico or New York or
California won't do. Thus the
next President faces both a
moral and economic
imperative to take steps that
will significantly decrease
energy consumption in the
United States.
The place to start is with
auto fuel efficiency
standards, for here we can, in
the near term, take concrete
action that will reduce
dependence on imported oil,
protect ecologically sensitive
lands, and begin to reduce:
emission of pollutants into
the atmosphere. Even a gas
mileage increase of 1.7 mile
per gallon over the current
standard, for example, would
save as much oil as may be
found in the Arctic National
Wildlife Refuge.
But of course we need to
improve fuel economy far
more than that. The
technology exists to begin
production in the near future
of comfortable subcompact
cars that get 70 miles per
gallon. Senator Timothy
Wirth has introduced
legislation that would require
new car fleets to average 55
miles per gallon by the year
2010. While available
technology will allow us (o
do much better than that.
Senator Wirth's bill is a good
starting point for discussion.
Hand in hand with auto
efficiency must conn; tougher
mandatory energy efficiency
standards for appliances and
lighting. Significant strides
Drought and constant
trimming for firewood limit
tree growth in the Sahel in
Africa. A conservation ethic
would be conscious both of
the planet's available
resources and the pressure on
them from people.
Population is straining the world's resources. In
some countries, spiraling population is
outreaching even basic necessities. In others, per
capita consumption soars due to affluence.
were made with the
appliance efficiency
legislation unacted in 1987,
but in this area, too, the
technology already exists to
make major improvements.
Another major component
of a national drive toward
energy efficiency and away
from fossil fuel consumption
must be to revitalize the U.S.
effort to develop alternative
renewable sources of energy.
While this will mean a
renewed federal commitment
to support research and
development of things like
solar and wind power, states
can also have a big impact.
California, for example, has
for years successfully
promoted alternative energy
development through its
progressive regulation of
electric and gas utility
companies. This is something
that we, at National Audubon
are urging grassroots
environmental activists to
focus on.
The next President and
Congress also need to
institute a national public
education program aimed at
persuading average citizens
that changes in personal
lifestyle are necessary for the
common good. Such changes
include better insulating our
homes, driving less and using
public transport more, and
turning thermostats down in
the winter and up in the
summer.
Coupled with such
conservation measures,
recycling could allow our
nation to simultaneously
reduce energy consumption,
save forests, and attack the
crises gripping many states
over garbage disposal anil
incineration. The next
Administration and Congress
must speed the drive toward
recycling at all levels.
Even more so than
conservation and recycling
proposals, population control
and family planning arc
obviously issues that touch
directly on cultural and
lifestyle questions. When we
speak of reasserting
America's global leadership,
in no other area is the; nerd
as great. For virtually every
environmental problem has a
direct or indirect relationship
to population pressures. In
fact, it would be difficult to
identify a single
environmental problem that
would not be in some way
reduced or made less severe
if population growth were
curbed.
Therefore re-establishing
the world leadership role
America once held in family
planning is crucial. This
leadership will mean, among
other things, providing far
more support to developing
nations for family planning
education and for
distribution of
contraceptives,
In addition. Congress and
the next Administration need
to provide sufficient research
funds for accelerated
development of l(K)-perc.e,nt
safe and simple,
contraceptives for men and
women. The objective should
be a technological leap over
existing contraceptives in
terms of safety, ease of use,
and reliability.
The inexorable twin
problems of population and
energy pressures, considered
together with growing
concerns over global
warming and the enormous
national security implications
of our energy policies, mean
that our new leaders will
have a tremendous
responsibility in the years
ahead. We as I I.S, citizens
must insist that our leaders
meet this challenge;
otherwise, as citizens of the
globe, we may well fail in
our duty as stewards of the
earth's environmental health
and vitality both for human
generations yet unborn and
for all other animal and plant
species that share this planet
with us. u
(Berle is President of the
National Audubon Society.)
NOVEMBER/DECEMBER 1988
-------
An Industry Official
by Bruce W. Karrh
After 20 years of intense
environmentalist!! in the
United States, I'm struck by a
common perception of little
or no progress. A decade ago,
Time? ran as its cover story,
"The Poisoning of America";
a month ago, ABC broadcast
a TV news special, "The
Poisoning of America."
If anything, the sense of
malaise and crisis has
deepened over two decades.
The environment has proved
to be a moving target, from
silent spring to snail darter to
There must be a
better way. Some
things are riskier than
others, and it's
important to know
which.
Superfund to global warming.
Expectations continue to rise,
but each control measure is
seen not to be the answer but
to pose more questions. This
is true for air quality, surface
and ground water, hazardous
wastes, land disposal, or
toxic substances.
The latest environmental
outcry has apocalyptic
overtones. The earth is
wanning, polar ice caps may
melt, seas will rise and
inundate coastal cities, and
fertile plains could become
barren deserts. With such
alarm bells sounding, it is
difficult to sort through the
scientific: evidence to see
what is happening and why.
How much of last summer's
extreme weather can be
attributed to the buildup of
"greenhouse" gases? Are we
reading long-term
implications into short-term
cyclical changes? We've done
this before. Remember the
cold spell a few years ago.
and warnings of the coming
ice age.
Could the outcry be an
instance of our need and
desire to be stimulated, even
by fear? As individuals and
as a society, we thrive in
tension and seek challenges
and excitement. Witness the
popularity of Stephen King
and of "horror" movies and
fiction in general. From the
beginning of time, some men
and women have cried wolf.
Angry prophets people the
Old Testament, and
Cassandra of Creek
mythology has given her
name to prophets of disaster.
Sometimes they're right.
There have been recent
examples of early warnings
that turned out to be correct.
Asbestos and stratospheric
ozone come to mind. The fact
is that the consequences of a
real greenhouse effect could
be catastrophic. Yet ! detect
other forces at work here:
fears of population growth
and resource depletion that
go back at least to Maithus,
and a bias against progress
and industrial activity that is
of more recent origins.
What we can conclude
with certainty is that the hot
summer of 1988 helped
create a public: and political
climate conducive to rhetoric
and perhaps to actions that
may be potentially useful or
simply wasteful. Setting
priorities becomes most
timely, and I have listed four.
They deal not with areas of
technical concern but with
the social process of
addressing environmental
issues, for that is when; the
problems lie.
• First, we need a better way
to reach informed judgments
about risk and to
communicate these
judgments. This need was
highlighted in 1983 by
William G. Simeral, then an
executive vice president of
Du Pont and chairman of the
Chemical Manufacturers
Association. Others have
identified the same need, yet
today people, their elected
representatives, regulators,
and regulated industries are
buffeted still by waves of
alarm and apathy. As a body
politic, we seem to be either
wringing our hands or sitting
on them. The recent
television program, "The
Poisoning of America," was
such a cacophony of ills and
catalog of villains that the
viewer could only throw up
his hands in despair and
confusion.
There must be a better
way. Some things are riskier
than others, and it's
important to know which.
We must take into account
such "outrage" factors as
voluntarism, catastrophic
potential, and the like, but
we should insist on the
distinction between what
harms and what offends.
Society may choose to
remedy the offensive and
ignore the harmful, but the
electorate and elected
12
officials in particular should
understand and acknowledge
the difference. We must also
overcome the ideological bias
against "man made" versus
natural. Mankind is part of
nature and our handiwork is
"natural" as a spider's web or
beaver's dam.
• Second, priority setting
must receive more titfention
as an ongoing process. A
clearer perception and
consensus about risk should
help in this task, but they
won't do the whole job. They
must be coupled with a
realistic sense of our
resources and of the true and
total cost of environmental
protection and cleanup. Our
wealth is not infinite. It is
not even as great as it used to
be, having been drawn down
by increased oil costs and
international business
competition, and there are
many demands on it:
infrastructure, debt service,
defense, education,
retirement, and other social
programs, to name a few.
Shredded aluminum cans
arrive by rail at a reclamation
plant. They are unloaded, then
fed into a melting furnace.
EPA JOURNAL
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Thousands of Americans collect aluminum
cans daily for cash. Many unretrieved cans
litter the rivers, cities, and countryside.
The goal of priority setting
should be to use our
resources wisely. We cannot
do everything, and certainly
we can't do everything at
once. We should get at the
real sources of pollution, not
at those that are
administratively easy or
politically safe to tackle. The
total bill should be tallied.
including federal money,
state and local funds,
off-budget expenses of
regulatory compliance, and
(if they can be calculated)
opportunity costs. We should
look at environmental
problems across the spectrum
of air, land, and water; and
worldwide.
• Third, for industry.
environmental performance
must be viewed as part of (in
overall economic or
industrial policy. Industrial
activity has a major impact
on the environment, and if
that i.s tlu; sole basis by
which companies are judged
and regulated, their
contribution to the public:
welfare will not be perceived
or nurtured. Current costs of
environmental compliance
are high, and laws already on
The goal of priority
setting should be to
use our resources
wisely. We cannot do
everything, and
certainly we can't do
everything at once.
the books mandate billions
more in costs in the years
ahead.
Some things should cost
more—energy, for example—
at the point of consumption.
This would encourage
conservation, which is one of
our most potent
environmental management
tools. We should work
toward the day when all
product prices will reflect the
full cost of environmentally
acceptable disposal at the
end of the line.
Looking at environmental
regulation in an economic
context could lead to greater
reliance on market
mechanisms versus law
enforcement models for
compliance as well. This
would be more efficient than
the present system, which
tends to punish law-abiding
companies for paperwork
violations while letting
miscreants go undetected
because it is impossible or
expensive to catch them.
« Fourth, for individuals, the
priori!)' should be on paying
the environmental bill and
changing their behavior.
Market mechanisms work for
consumers as well as
businesses, and full
cost-accounting in the form
of product prices, fees, or
taxes could influence habits.
Residential garbage fees
based on the volume and
type of garbage would affect
the number of cans at
curbside and what's in them.
We need to remember that
time and convenience have
value, and price them
accordingly. Government can
facilitate this process through
education and incentives.
If this sounds like a
reference to the hearts and
minds of men, that is
intentional. Over 10 years
ago. President Jimmy Carter
asked us to treat the energy
crisis as the "moral
equivalent of war." We added
some insulation, bought a
wood stove, gave up driving
for a couple of Sundays, and
voted him out of office.
Without passing judgment on
the Carter Administration, let
me say I think he was onto
something about moral
equivalencies. There is an
element of crusade to the
ecological opportunity bclore
us.
I use the word "ecology"
deliberately. It involves more
than environmentalism.
Ecology is defined by
Webster as "the relationship
and adjustment of human
groups to their geographical
environment." That's what
priorities are all about. We're
going to have to choose our
relationship and adjustment
to our geographical
environment. We could
scarcely do better than to
embrace as our first priority
Teddy Roosevelt's objective
when he said, "The nation
behaves well if it treats
natural resources as assets
which it must turn over to
the next generation increased
and not impaired in value."
It's not a new idea, but it is
becoming more apparent and,
it seems to me, more
urgent, n
(Karrh is Vice President for
Safety, Health, and
Environmental Affairs at The
Du Pont Company.)
NOVEMBER/DECEMBER 1988
13
-------
An Elected Official
by Governor Roy Romer
Tin; man who becomes
President next January
will set this tuition's
environmental priorities into
the next century. That is a
daunting task. America in the
21st Century will facie serious
environ men hil challenges,
and the Dukakis or the Bush
Administration will
determine how we begin to
meet them.
I have strong opinions
about what our priorities
must be. But my main
recommendation to the new
Administration is that the
setting of national priorities
must be an inclusive process,
reflecting the diverse
concerns and needs of a
diverse nation. Federal policy
must give a voice to all
regions of this nation.
This is especially
important to Westerners, who
have seldom felt federal
policy reflects their concerns.
In the West, we enjoy many
of this nation's last and
greatest natural assets. We
are proud of them. We are
enriched by them. They are a
part of us, and we define
ourselves by them. To us, the
environment is a
quality-of-life issue.
This relationship to our
environment is the basis of
strong and often competing
Western ethics. We must use
our resources because our
economy depends on them.
But we also want and must
preserve our beauty. We
struggle for a meaningful
blend of use and
preservation.
Westerners hold no single
philosophy on the
environment. We seek
neither benign neglect nor
federal tutelage. What wo
seek is a pragmatic;
partnership with the federal
government.
So my first message is that
national priorities must
reflect the diverse values of
the people and the regions of
this country. In the West,
that means policies which
accommodate both use and
We seek neither
benign neglect nor
federal tutelage. What
we seek is a
pragmatic partnership
with the federal
government.
preservation—policies that
help us reach a pragmatic
blend of competing interests.
In water management, air
and water quality, waste
management, and other
issues, federal policy must be
responsive to Western values.
The challenge for federal
decision-makers must be to
better understand the West.
In the past, the federal
government was a partner in
funding water projects for
our cities and farms. A
decade ago it abandoned this
role in favor of a role as
regulator, and the age of large
Western water projects
seemed to end.
Westerners disagree over
whether this is good or bad.
But most worry that federal
regulators may lack an
understanding of the arid
West and what water means
to places where only a few
inches of rain fall each year.
If federal decision-makers
are to be more involved in
Western water, they must
understand Western water
issues. They must encourage
adequate water storage and
infrastructure for growing
populations. They also must
encourage water conservation
and protect wildlife and
recreation, which are
essential to our economy and
Southwest Resource Centei tor Science and Engineering photo. University of New
-------
lifestyle. It is not a simple
conflict between growth and
preservation, because we
need both.
We also need federal help
with air quality. Federal
deadlines are useful because
they pressure us to take
action to improve the air. But
they mean nothing if we are
not given the tools to
succeed.
Growth, altitude,
meteorology, and a heavy
reliance on automobiles
conspire to harm the air of
some Western cities. In fact,
11 of the nation's 13 carbon
monoxide non-attainment
areas are in the West.
At the same time, the West
is on the cutting edge of air
quality solutions. Colorado
was the first to require
oxygenated motor fuels to
reduce carbon monoxide.
Arizona and Albuquerque,
New Mexico, now have
similar requirements, and
even New York City is
examining our program. We
also are proud of our Better
Air Campaign, a voluntary
program which reduces
driving by up to 10 percent
during our pollution season.
These measures and others,
including emissions
inspections and burning
restrictions, have greatly
improved Colorado's air.
gn Mgtftfen photo, Un/vetsny of Co'o/acfo Media
? .
Federal deadlines are
useful because they
pressure us to take
action to improve the
air. But they mean
nothing if we are not
given the tools to
succeed.
But we cannot do it alone.
We need a federal partner
who recognizes our problems
and who will help us clean
our air.
The clean air amendment
bill which Congress
considered this session
would have virtually ignored
the West. Despite work by
some Western legislators, the
bill appeared likely to focus
Albuquerque, New Mexico, is
enveloped in haze on a
stagnant winter morning. Like
some other high-altitude cities
in the West, Albuquerque is
undertaking measures to
reduce carbon monoxide.
on Eastern ozone and ignore
Western carbon monoxide. In
the probable event that this
Congresss does not enact a
clean air bill, work on such
legislation will undoubtedly
begin early next year. The
new Administration should
be a partner with Western
states in helping Congress
focus on our air quality
needs, such as cold-start
certification and high-altitude
testing.
The West also can learn
from the East on waste
management. News of illegal
ocean dumping and the
infamous garbage barge
highlight the need for
foresight and innovation in
solid and hazardous waste
management. The federal
government must continue to
encourage all slates to pursue
innovative alternatives to
landfills, including recycling,
source reduction, and, where
appropriate, incineration.
State and federal officials
also need to work with
The Western U.S. enjoys
many of the country's greatest
assets, presenting a challenge
to balance protection of scenic
beauty with resource use.
Here, Frederick Zimmer
practices ski turns on a
Colorado slope.
industries which produce
toxic byproducts on ways to
reduce the use ot traditional
Land-disposal methods.
rinally, I am convinced the
next century will see great
global environmental strain.
We must meet the challenge
now. Colorado has begun tin;
Environment 2000 process to
plan for its environmental
needs into the next century.
This two-year process will
involve all interested
Coloradans in discussions
and plans for the future. EPA
is a full partner in this
project—the kind of partner
the federal government must
be in other areas if we are to
meet the ohallongn.
Establishing partnerships
ami understanding this
nation's diversity will be the
keys to environmental
progress under the new
Administration. The West
needs a partnership with the
federal government
consistent with Western
issues and Western values.
The West is ready. The next
Administration must be
ready too. u
(Homer is Governor of
Colorado.]
NOVEMBER/DECEMBER 1988
15
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A Public Policy Specialist
by Milton Russell
The traffic controllers for
environment and natural
resource issues will have a
radar screen full of blips .is
the 101st Congress and a new
Administration come to
Washington in 1989. When
their watch starts, the new
crew will have to decide
some basic questions. Which
blips need only an occasional
glance to see that they tire
staying on course? Which
require careful scrutiny to
make sure the turns
underway are really carried
through, and are they the
right turns? And which ones
will demand intense
attention because it is not
clear how they should move
to avoid future collisions?
Most of the established
programs at EPA will need
only that occasional glance
s« Jong os budgets are
adequate to meet the needs,
and management systems are
in place to assure continued
performance. EPA has done
well on both counts over the
past few years; maintaining
progress and avoiding
complacency are the tasks
here.
On the other hand, new
directions have been set in
drinking water protection,
pesticide regulation,
reduction of CFCs, municipal
waste water treatment,
underground storage; tanks,
waste minimisation,
Siiperf'und and RCRA
implementation, and the
community's right to know
about hazardous substances,
among others. Courses are
set, but the people charged
with doing the tough,
slogging work of putting
these changes in place will
need support and their work
will need attention.
New approaches to getting
environmental results have
also come to the fore. One
example is focusing on risk
reduction opportunities as a
priority-setting device.
Another is paying attention
to cross-media transfers of
There will be four big
categories on the
score card used in the
future to judge those
coming on duty in
1989.
risk and, in general, taking an
integrated view. Still another
is bringing states and
localities closer to full
partnership with the federal
EPA. And progress has been
made in exploiting incentives
as a complement to
"command and control" in
achieving environmental
gains. Here the temptation
will be to downgrade or
discard initiatives identified
with the old crew. Obviously,
the new controllers will want
to assure themselves that
these courses are right for the
environment in the years
ahead. But there is too much
important new work to
warrant fixing things that are
"not broke." Early review of
key elements of these
approaches, followed by
strong affirmation of those
which pass muster, can
assure that the environment
suffers minimally from the
inherent turmoil of
transition.
So, where can the new
crew make its mark? Not on
issues such as acid rain and
hazardous waste which,
while they still require a lot
of work, are on the road to
resolution. Instead, there will
be four big categories on the
score card used in the future
to judge those coming on
duty in 1989. These are:
• How successfully they deal
with ambient air quality,
especially ozone.
• How they use the
opportunities presented by
the intersection of agricultural
policy and environmental
quality.
• Whether progress is made
in protecting and rebuilding
natural systems.
• How they deal with
international challenges.
Ozone pollution will
remain among the most
intractable problems the
it'.
Sieve Williams photo Penn State College ol Agriculture
EPA JOURNAL
-------
••'•'..•' *4«f ' •
country faces. As I have
written elsewhere (Science,
September 9, 1988), whether
legislation passes this session
of Congress or not, the
science and technology of
control are inadequate; the
economic and social costs of
proceeding expeditiously to
attainment are very high; and
at least on current
understanding, some areas
can't achieve success even in
the next century without
unacceptable disruption. One
of the key tasks over the next
four years will be to frame
and participate in a broad
public debate about
environmental goals and
practice when, as is the case
with ozone, science discovers
risks for which the political
system and economic and
technical reality offer no
easy, no rapid, or perhaps
even no feasible solutions.
Dairy herds can contaminate
streams. Agriculture affects
the environment in a number
of complex ways.
Agriculture affects virtually
every aspect of the
environmental enterprise:
pesticides impact wildlife
and human health; chemicals
get in ground and surface
water; land use changes
destroy or create wetlands,
other habitat, and visual and
recreational amenities; silt
Ozone pollution will
remain among the
most intractable
problems the country
faces.
and nutrient run-off degrades
streams, lakes, and estuaries.
There is an opportunity to
take a holistic view of
agriculture and the
environment to see what
makes sense for both
together. Even partial success
in bringing this integration
off would go a long way to
assuring good marks from
future generations.
The quality of life for
Americans in the next
century will be irretrievably
diminished if actions are not
taken soon to enhance and
protect the natural systems
which we enjoy and on
Richard Frear photo. National Park
which we all depend. Main'
of our national parks are
threatened by overcrowding,
and much of the
infrastructure built in the
Great Depression needs
repair. Wilderness is
disappearing. Water bodies
are being degraded by
nonpoint source pollution
that overwhelms the gains
from sewage and industrial
waste control. Urban sprawl
is absorbing the green belts
that add so much to the
amenities of cities. Wetlands
(and other habitat) that help
cleanse the environment and
support fisheries and wildlife
offering recreation to millions
continue to disappear, and
the less there is the more
each acre counts. Investment
will be required to reverse
these trends, of course, but
even more important will be
creative policies that bring
private and government
incentives into harmony with
natural system protection and
enhancement. Ideas abound.
What is needed is a
comprehensive effort to
determine which ideas are
sound, followed with the will
to promote and implement
them.
A quiet hike in Isie Royale
National Park, Michigan.
Often, the scene in pur
national parks is quite
different, with crowds of
people and a lot of activity.
International action will be
crucial. Building on the
success with stratospheric
ozone, the United States wilt
be called on to take a major
role in dealing with the
prospects for global climate
change. On other matters,
initiatives may need to start
in the developed countries,
but the arena for action will
be the developing world
where deforestation,
desertification, the
disappearance of species, and
toxic pollution of the air and
water are global concerns. In
the same class are protecting
the oceans and assuring the
environmental integrity of
Antarctica. For two decades,
the United States has been a
world leader in protecting its
citizens and environment
from threats from within. The
challenge for the 1990s will
be to work with others to
extend and expand that
protection.
A radar screen this full of
issues would daunt any crew
coming on watch. But some
of these blips are more
important than others, and
even for the most crucial
ones, there is time to he
careful in plotting a course.
What is critical to success is
to decide where attention
really will make a difference,
and then to begin. Q
(Russell, formerly Assistant
Administrator of KP.A's
Office of Policy, Planning,
and Evaluation, is currently
Professor of Economics (it liic
University of Tennessee and
a Senior Economist at Oak
Ridge National Laboratory in
Tennessee.)
NOVEMBER/DECEMBER 1988
17
-------
A Scientist/Engineer
bv Raymond C. Loehr
Tlu: basic mission of EPA
is to reduce risks to
human health and
environment that result from
wastes, residues, and
contaminants. To carry out
this mission, EPA
administers a number ol
programs mandated by law.
However, EPA is actually
more than a regulatory
agency. It is also a research
agency responsible for
defining the nature of the
nation's environmental
problems and their possible
solutions. It is a technology
transfer agency responsible
for sharing information. And
it is an education agency
responsible for teaching
people how their individual
actions affect human health
and the environment. All of
these responsibilities depend
on a strong research and
development (K & I))
program, as a means for
priority-setting, along the
lines recommended in a
recent report by the EPA
Science Advisory Hoard
(Fulun; Hisk: Hf;s<>
-------
• Define) the risk at issue and
develop needed control
technology.
• Demonstrate the feasibility
of risk-reduction actions that
are non-regulatory but
consistent with regulatory
requirements.
An appropriate R & D
strategy would first
determine what research and
development activities are
needed to reduce the risk to
human health and the
environment, and second,
indicate the proper timing of
that research and
development. Once the
extent to which the research
(if successful) will reduce
risks to human health and
the environment is identified,
there is a clear basis for
balancing competing research
needs. In addition,
information that can
accomplish risk-reduction
goals should be provided to
state and local governments
and to the public. Education
and technology transfer,
therefore, have an important
place in the research strategy.
Core areas of continuing
risk-reduction research
should be identified. These
EPA and the nation
should have an R & D
strategy that serves to
reduce risk and, as a
first priority, helps
reduce the quantity of
waste being
generated.
core areas would support
broad, comprehensive needs
of EPA and would be
critically reviewed
periodically. The core areas
should include: topics
expected to be relevant for a
long time, areas in which
generic research can support
a number of EPA and state
programs, areas in which
inadequate information exists
for sound regulatory
decisions and guidance, and
areas where research is
unlikely to be conducted by
A/ariona/ Park Setvice photo
others. Examples of
candidate core risk-reduction
research areas are:
• Prevention of pollutant
generation.
• Combustion and thermal
destruction of wastes.
• Separation technologies to
concentrate material that can
be recycled.
• Biological detoxification
and degradation to result in
residues that can be
discharged or disposed of
safely.
• Chemical treatment of
concentrated wastes and
residues.
• Ultimate containment
methods such as
land-disposal options.
• Exposure avoidance.
• Risk communication and
perception.
• Incentives for risk
reduction.
Each American generates
about 25 pounds of trash per
week. This refuse was
collected from Blue Star
Thermal Spring in
Yellowstone National Park.
EPA should develop strong
scientific programs in each
core area, provide facilities
and incentives to attract top
researchers to these
programs, and maintain the
stability of funding needed to
nurture scientific leadership
in these areas.
Strength in the core areas
would place EPA in a sound
position to develop guidance
and approaches for problems
that place human health and
the environment at risk. To
support the regulatory
programs, results from core
research areas would provide
regulatory deliverable that
will meet regulatory
mandates and deadlines.
Investing in risk-reduction
research would reduce
current and future risks to
human health and the
environment, thereby
increasing productivity am)
the quality of life. Such
research is an investment
that protects not only present
but also future
generations. ^
(Dr. Loehr is the
Hussein M. Alliarthy
Centennial Chair tnul
Professor, Environmental ami
Water Resources Prognim. at
the University of Texas at
Austin, lie is Chairman of the
EPA Science Advisory Board
(SAB), served on the SAB
Research Strategies
Subcommittee' that prepared
the September IWifl report
entitled Future Risk:
Research Strategies for the
1990s, and chaired the
Subcommittee's Risk
Reduction Work Group.)
NOVEMBEFVDECEMBER 1988
19
-------
Setting Environmental Priorities^
The Public Speaks
Kenneth Sehres,
Professional Caterer,
New York City
Gary Fells, Acquisition
Agent, Colorado State
Highway Department,
Denver, Colorado
In the public's opinion, ivluit
should be, the top
environmenta/ priorities of
the new Administration
when it takes the helm in
1989? EPA Journal asked a
cross section of citizens in
different occupations from
different ports of the country
to respond to this question.
Here are their answers.
Arriving at the beach to see
this, a family could find its
vacation spoiled. A clean
environment ranks high in
many public opinion polls.
The question has a number of
angles. In New York City, I
live with the obvious
problem of air pollution, and
there has been repeated
postponement of air
pollution standards—for New
York and for other cities
around the country too. The
new administration must take
the necessary steps to enforce
the clean air standards. The
laws are in place, hut the
enforcement is bad.
Part of the problem is that
people cling to their personal
freedoms—such as the liberty
to drive unlimited numbers
of private cars in the
Manhattan business district,
The city should definitely
impose restrictions on private
cars, since the alternative is
gridlock and bad air.
Sometimes it's necessary to
sacrifice certain personal
freedoms in favor of an
environment in which people
can breathe and get around to
do business.
In addition to air pollution.
New York City has all the
other problems: ocean
clumping, toxic waste,
beaches closed for substantial
portions of the summer.
These problems didn't just
happen yesterday. We
definitely need more
foresight on environmental
problems. Something is
wrong when we start
worrying about garbage
problems the day before the
landfill fills up.
I'm very concerned about
acid rain and its effects on
forests, lakes, and streams, so
I'd like to see the acid rain
problem given very high
priority. Also, living here in
Denver, with the kind of air
pollution problems we have,
I'd have to name clean air as
a pretty high priority. I have
seen the air in the Denver
metropolitan area go from
crystal clear to the point
where on bad days you
cannot see the mountains.
For the country as a whole,
the cleanup of hazardous
waste sites should probably
be first on the environmental
priorities list.
In general, my advice to
the new administration
would be: Do not slacken the
environmental standards that
have been set so far. and
don't hold off making those
standards stick. For example,
maybe extensions for meeting
Clean Air Act standards
should not always be
granted. The prospect of a
cut-off in federal funds is a
strong motivation. We're on
the right track, but we need
tight control on
environmental problems that
ultimately can affect nut only
our health but also our
economic well-being.
A series of major disasters
has helped make people
realize that the environment is
in trouble. This is a 1984
photo at the famed Love
Canal hazardous waste site,
where steps are under way to
control the dangers. The pipes
protect monitoring wells.
20
EPA JOURNAL
-------
Jean Brodey,
Assistant Professor of
Journalism,
Philadelphia,
Pennsylvania
Industrial pollution needs to
be a high priority, since it is
polluting our waterways and
our living environment. 1
want to see our rivers and
streams protected from
contamination. It's also
important to preserve our
natural landscape in national
parks, etc.
We're in a transitional
period right now. The most
important thing is to have
some kind of overall plan for
preserving the environment.
Suddenly we've reached a
turning point xvith problems
like waste management,
especially with all the
nondegradable trash that's
prbducedr—like a barge
loaded with garbage floating
all over looking for a place it
can dock.
Unless there is an overall
plan, things will only get
worse; we're on the verge of
leaving a terrible legacy. The
band-aid approach just won't
work. We need real
planning—nothing
haphazard—on the
environment.
Robert Kidwell,
Dentist,
Wilmington, Delaware
Environmental priorities?
Clean up the air and clean up
the water. Regulate the
companies that are
responsible for the pollution.
Big business needs to be held
responsible for what it does
to the environment. Chemical
runoff from the use of
fertilizers and pesticides in
agriculture is another
problem.
The environmental
situation is getting out of
control. In the Pamlico River,
downriver from chemical
discharges, the fish are dying
off and the survivors are
deformed with tumors.
Wilmington, Delaware, is one
of the worst air spots in the
nation. The garbage problem
is another thing. We need a
new focus on cleanup.
Tighten the controls. Impose
fines. Otherwise we'll put
ourselves right out of the
planet.
Janice Warner,
Rancher,
Ten Sleep, Wyoming
Sometimes it seems that the
environmental agencies are
nit picky on some things
when there are other issues
that seem so much more
important, like all the
hospital trash and other
waste being dumped in the
ocean. For example, if one of
the sprays we use on the
ranch is a real danger—if it's
an absolute concern—then I
think the government is right
to prohibit it. But we never
know why a chemical spray
or a dip we use for cattle
becomes an issue all of a
sudden, and sometimes I
wonder how much validity
the issue has.
Of course, I want to keep
the environment in good
shape for cattle ranching. We
abide by the environmental
requirements set by EPA and
the U.S. Forest Service as
best we can. But I think the
big issues should be the
priorities for the
environment, and I don't see
that happening.
i'r i j
NOVEMBER/DECEMBER 1988
Robert Senior photo. New York Slate Department oi Environmental Conservation
Rita Grodt,
Homemaker,
Modesto, California
My own concerns about the
environment are mainly local
issues, such as the safety of
ground water in the Modesto
area, and I can't say how our
local concerns fit into the
national picture. This is a
farming community, and
almost everyone around here
uses well water. I worry
about whether pesticides and
fertilizers from the farming
might be getting into the
ground water. One of the
schools in the area had to go
to bottled water because their
well water became
contaminated.
There are possible links
between health effects and
pesticides to worry about. A
couple of years ago—when
we were expecting a
child—we decided to move
here rather than the Fresno
area because people were
saying there might be a
connection between
pesticides and birth defects
and other health problems in
that area. We just wanted to
be cautious.
I also think it's important
to protect natural resources
such as our national parks.
We just got back from a week
in Yosemite, so I'm struck
with the need to preserve
this kind of resource.
Stuart McDonald,
Director of Economic
Development,
Jamestown, North
Dakota
Balance is the key word in
setting environmental
priorities. Protecting the
environment is very
important, but so are jobs
and development,
particularly when you
consider that American
industry has been shipping
jobs out of the country like
crazy.
The environment is a
global problem. In the United
States, 1 think we make a
21
-------
more serious effort toward
control than the rest of the
world. North Dakota, for
example, is a large producer
of electricity, and U.S.
producers of electricity are
subject to specific constraints
to control sulfur dioxide
emissions. These
requirements involve a real
cost impact that is not shared
by our Canadian competitors,
since Canada has no
comparable requirements.
This puts our producers at a
competitive disadvantage.
I'm in favor of
environmental controls, but
the constraints we put on
American industry have to
have counterparts in other
countries. We need to allow
American industry to
compete.
Dr. Jane Jones,
Psychiatrist,
Summit, New Jersey
The environment generally
should be a higher priority
than it has been so far.
Kveryone seems to wait until
a catastrophe is in front of
them—something real like a
ruined summer at the beach
or a cancer diagnosis. It's
hard to abstract
environmental casualties
before they happen. 1 think
this is a problem for the
public and for our
policy-makers. On the other
hand, I was very pleased to
see EPA and the Surgeon
General take a strong stance
on radon recently.
We have so many
environmental problems that
it's hard to sort them
out—toxic waste sites, the
water supply, you name it. 1
sec a number of patients who
have cancer that could have
environmental causes, and I
am very concerned about the
environment as an urgent
priority. I would do any kind
of volunteer work on
environment*! tasues. I also
think cabinet status should
be created for EPA. I'd like to
sir bolter enforcement of our
environmental laws.
Pam Pope,
Administrative
Manager,
San Diego, California
Probably the Number 1
problem is that people are
not aware of things going on
that damage the environment
and don't really understand
what's involved in
environmental issues. The
average person does care
about keeping the air clean
and the landscape beautiful
but doesn't know what to
do—so the environment is
"some one else's problem."
One priority should be
making people more aware of
environmental pollution
problems and doing a better
job of getting information
across to them. It's a massive
public relations project.
The political clout of
companies that pollute the
environment is also a
problem. A lot of companies
don't take environmental
issues seriously. They hire
lobbyists to influence
political decisions. In fact, I
think companies can use
their clout to influence
public perception, and that's
another reason why people
are confused about
environmental issues.
I'm personally concerned
about the environment, but I
also feel pretty powerless.
There are so many
problems—water quality,
water conservation, industrial
waste. The protection of
national parks would be high
on my priority list.
Richard Ardner,
Director of Public Works
Loch Haven,
Pennsylvania
The first priority should be
Superfund sites—expediting
the cleanup of existing
hazardous waste sites. This
needs to proceed at a
speedier pace than it has in
the past.
Second, it's important to
work more closely with
industry—with the generators
,
II
WARNING
PESTICIDES
FIRE WILL CAUSE
TOXIC FUMES
of hazardous waste—to make
whatever changes may be
necessary to cut down the
output of hazardous waste.
The same principle applies to
the rest of society. If our life
style is damaging the
environment, we may just
have to learn to cut back on
some things.
For instance, if a product
that enhances our life style
introduces a hazardous
byproduct into the
environment, then maybe we
can do without that product.
Maybe we need to think
twice about what we're doing
as consumers. This is a
public education issue, and
EPA should do as much as it
can, where it can, in this
area. With public education.
of course, the place to start is
with children in grade
schools.
A final word on the
environment generally as a
priority: we have been to
outer space, but so far we
have found only one livable
earth.
Elizabeth Denk,
Marketing Services
Director,
Niagara Falls, New York
Living in Niagara Falls, the
top environmental concern
for me is landfills because I
worry about leakage
problems. I worry about
something happening like it
did with Love Canal. I think
we need to take a hard look
at our whole waste disposal
system. It seems we just
don't have the knowledge to
know what's going to happen
down the line once we start a
landfill.
On the environment in
general, I will say that
recently—in the last five
years—there seems to be
more crackdown in enforcing
anti-pollution laws. There
should be a continued
emphasis on enforcement at
the local level. It's OK for
Congress to legislate a clean
environment, but unless
there's somebody looking
over their shoulder, some
companies are not going to
comply with pollution
control requirements.
Another big issue is the
ozone layer and the aerosols
we use. Everyone has some
kind of aerosol product
around the house. Where
there are alternatives to the
aerosol products, I think the
aerosol should be banned.
22
EPA JOURNAL
-------
Dona Krueger,
Independent
Salesperson,
Hastings, Nebraska
The top priori!)' should be
water quality—our drinking
water, our lakes and marine
resources. Among other
things, this means enforcing
the Clean Water Act and
getting serious about cleaning
up Superfund sites. There's a
definite need for more
enforcement of the laws that
are supposed to protect the
environment.
It's time to make the
contaminators of the
environment take
responsibility for the
consequences of their actions
and pay for cleanup. If 1
don't pay my bills, or if
someone is hurt on my
property, I am responsible.
But the same rules don't
"necessarily apply to big
industry. It seems like the
nation as a whole is
intimidated by industry,
afraid to hold big industry
accountable.
It's also hard for ordinary
citizens to get practical
information on the
environmental problems that
affect them in their own
communities. I'd like to see
EPA upgrade its hotline
services in this area.
Kathy Taylor, Student,
(biology major),
Utah State University
Radioactive waste is
definitely a big
priority—especially the
problem of how to dispose of
it. Also, one of the biggest
problems now is the amount
of trash we routinely produce
every day, and a lot of it is
not biodegradable. We need
to stop using plastic (the
plastic hamburger cartons are
everywhere) and return to
paper products. Something
also needs to be done to stop
pollution of the ocean with
all kinds of waste.
There are regulations to
protect the environment from
some of these things, but
they need to be enforced. I
think we need more
enforcement.
Radon gas is another kind
of big environmental
problem. To protect people's
health, I would be in favor of
mandatory testing of public
buildings, maybe even
private homes. At the least,
there should be a strong
program to make people
aware of the health risks.
Vernon Weaver,
Real Estate Inspector,
Baton Rouge, Louisiana
I think the first and foremost
environmental issue is radon,
especially now that it's been
found in water systems.
Second would be the
problem of depleting the
ozone layer, since this could
affect people worldwide.
Third, the seas and coastal
areas have a whole set of
environmental problems. In
the South in particular, we
are losing a lot of coastal
marshes for different reasons,
which means lost
environments for fish.
Acid rain is another
priority issue, probably more
so for people who live in
other regions than the South.
Also, there are still safety
problems with some
pesticides.
Martin Bander,
Hospital Public
Relations Director,
Boston, Massachusetts
We desperately need to find
a safe way to store nuclear
waste. Second, we need to
find out whether we are
entering an age of the
Greenhouse Effect, and if so,
we need to move rapidly to
address the problem. This
has to be done on a
worldwide basis and must
include reforestation, not
deforestation.
My personal belief is that
we need to wage an all-out
war on pollutants of the air,
earth, and water, o
Kathy Chamberlin,
Flight Attendant,
Washington, DC
Flying on a routine basis, I
am struck with the pollution
I see in the sky over so many
cities. Doing as much as we
can to eliminate air pollution
should definitely be a high
priority. Sometimes the air is
so bad over cities like New
York, San Francisco, or
Washington, DC, that all you
see is a layer of dirty smoke,
sort of a black film, as the
plane makes its approach.
I realize a lot of things that
contribute to air pollution are
difficult to control. You can't
stop people from driving, and
you can't make people junk
their older model cars. But
there are things that can be
changed. For one thing,
maybe the technology for
emissions control isn't as
good as it could be.
I also worry about all the
trees being felled all the time.
The more trees that go down,
the more pollution there is.
It'S not really necessary to
bulldoze whole fields in
order to build a housing
development. We need to
stop the heedless destruction
of trees because there could
be more consequences than
we know about.
Jp Lombard,
Piano Teacher,
McLean, Virginia
There are so many
environmental problems, all
inter-related, that it's hard to
separate out particular
priorities. We need action,
not more talk, on lots of
fronts: clean air, clean water,
the ozone layer, the
disappearing rain forests,
waste products (like plastic)
that won't go away. Maybe
the important thing is not the
order in which we list the
problems, but how the issues
are related to each other.
because we have one
environment, one
atmosphere, one earth.
Part of the overall problem
is that our society is not
structured to be responsive to
environmental issues on
principle, but responds
mainly to money issues. We
have a society that can sell
pet rocks and all kinds of
offbeat fads, but can't sell the
idea of teamwork to conserve
the environment. 1 think it
would be well worth the
taxpayers' money to hire a
Madison Avenue public
relations firm to raise
national consciousness about
our common stake in the
environment.
As a society, we need to
start making some changes
that aren't money-makers but
make sense if we want to
preserve the environment, a
{EPA Journal Assistant Editor
Karen Flagstad conducted
these telephone interviews.]
NOVEMBER/DECEMBER 1988
23
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The Need to Think Ahead
by Aivin L. Aim
If the recent barrage of media accounts
is any indication, environmental issues
once again are crowding to the forefront
of the national consciousness. People
today are worried about the skin cancer
that may result from depletion of the
stratospheric o/one layer, and the lung
cancer that may result from
concentrations of radon found in their
homes. This past summer's drought
raised new questions about the possible
long-term effects of global warming
trends. The medical wastes that washed
up on so many East Coast beaches last
summer spotlighted two problems:
Americans are not managing their
mounting piles of solid waste very
effectively, and our near-coastal waters
afe being degraded by a wide range of
pollutants and contaminants. And
despite our past efforts, recent
well-publicized data show that millions
of Americans live in urban areas that
still do not meet national health
standards for ozone and carbon
monoxide.
Which of those problems poses the
most serious health and environmental
risks? Or are the most serious risks
posed by other environmental
problems—like acid rain or pesticides in
ground water—that haven't received as
much media attention recently? I don't
know the answers to those questions,
but I do know this: the long-term
scientific research that is needed to help
answer critical questions related to
environmental quality and public health
is woefully underfunded and
underemphasized in this country. As we
move into the 1990s and beyond, our
national willingness to support
long-term scientific and engineering
research may be one of the most serious
environmental policy issues of all.
Research is an absolutely essential
ingredient in our national effort to
What's killing these trees on
Mt. Mitchell, North Carolina?
Scientists are discovering
links between pollution and
such forest diebacks. Research
aimed at defining potential
environmental dangers before
such damage is done could
help ease the stress on the
planet.
James J MacKenne photo
protect environmental quality. Research
helps us understand the causes and
effects of environmental pollution; it
helps define how and where pollutants
are transported; it characterizes the
mechanisms of human exposure and the
risks entailed; it supports the
development of technologies needed to
minimize, treat, and control pollution.
In short, research gives us the
knowledge we need to protect human
The long-term scientific
research that is needed to help
answer critical questions
related to environmental
quality and public health is
woefully underfunded and
underemphasized ....
health and the environment from the
inadvertent byproducts of our
technologically advanced society.
Environmental research has always
been an important part of EPA's
mission. The "capacity to do research"
was included among EPA's
responsibilities in the Presidential
directive that established EPA in 1970.
In the years that followed, Congress
passed several major laws that required
EPA to protect different elements of the
environment, and each of those laws
required a regulatory system dependent
on the results of environmental
research. Consequently, over time;,
EPA's research program has become
primarily a support for the Agency's
near-term regulatory responsibilities,
Yet, despite the evident success of our
past research and regulatory efforts,
EPA's practice of focusing its research
almost exclusively on near-term
regulatory needs will not be adequate
for protecting environmental quality in
the future. There are several reasons
why:
• EPA's regulations by definition reflect
environmental laws, which in turn
reflect public: concern about various
environmental problems. However,
public concern and federal law are not
necessarily accurate reflections of
real-world health and environmental
risk. Environmental research has to h<;
targeted at the greatest risk.
• EPA's regulations tend to impose
end-of-pipe controls on classes of
pollutant sources nationwide. However,
some of the most serious environmental
problems facing us in the future—like
solid waste and ground-level
ozone—will require us to minimize
pollution before it reaches the end of
the pipe. Environmental research has Jo
be targeted at risk-reduction strategies
like materials substitution, process
redesign, and recycling that can be
initiated voluntarily or as a product of
the regulatory process.
• Minimizing waste and pollution
before they reach the end of the pipe
will require that state and local
governments, private industry, ;md
individual families all take actions to
reduce their contribution to the
problem. Such a decentralized approach
to some environmental problems will
substantially augment EPA's traditional
regulatory role. Environmental research
has to be targeted at control terftniqurs
and strategies useful to all parties
involved.
• EPA's current regulations often result
not in the eradication of a waste or
pollutant, but in its transfer from one
environmental medium to another. Our
past lack of attention to the cross-media
effects of pollution control is
understandable considering the
medium-oriented nature of
environmental laws like the Clean Ait-
Act and the Clean Water Act. lint we
can no longer afford to look at
environmental problems in such a
narrow context. Environmental n;s<;mrlt
has to be targeted not al flic transfer btil
at the elimination of pollution.
• EPA's regulations obviously an;
intended to control environmental
problems that have already been
recognized by the public and Congress.
Yet, as we have learned from the history
of medicine, it is easier to prevent a
disease in the first place than it is to
cure a large number of people afflicted
with it. Environmental research has to
be targeted at the anticipation and
NOVEMBER/DECEMBER 1988
25
-------
prevention of environmental probJems,
not simply their cleanup after the fact.
Over a year ago, EPA Administrator
Lee Thomas requested the Science
Advisory Board (SAB) to advise him on
ways to improve strategic research
planning at EPA. In response to that
request, the Research Strategies
Committee of the SAB prepared a
report, Future Risk: Research Strategies
for the 1990s (September 1988),
that—together with its five technical
appendices—provides clear guidance for
shaping a strong environmental research
program.
The report lists 10 specific
recommendations (see box) that, in a
nutshell, make three major points. First,
EPA's research funding has to be
increased dramatically. Second, EPA's
research program has to be reoriented to
include a much greater emphasis on
long-term research not necessarily
linked to its regulatory programs. Third,
particular emphasis must be placed on
understanding the status and trends of
ecological systems to anticipate
potential future problems. If we can take
the steps necessary to implement those
recommendations, then I am confident
we will have the scientific and
engineering tools we need to solve the
most pressing environmental problems
of the 1990s and beyond, no matter
what they may be. o
(Aim is Chair of the Science Advisory
Board's Research Strategies Committee
and President and Chief Executive
Officer of Alliance Technologies
Corporation.)
Ten Recommendations for the 1990s
In its September 1988 report,
Future Risk: Research Strategies
for the 1990s, the Science
Advisory Board made 10 specific
recommendations that relate to the
long-term goal of preventing and
reducing environmental risk.
These 10 recommendations are
summarized below:
1. EPA should shift the focus of its
environmental protection strategy
from end-o/-pipe controls to
preventing the generation of
pollution. EPA should use a
hierarchy of policy tools that
support national efforts to 1)
minimize the amount of wastes
generated; 2) recycle or reuse the
wastes that are generated; 3)
control the wastes that cannot be
recycled or reused; and 4)
minimize human and
environmental exposures to any
remaining wastes.
2. To support this new strategy,
EPA should plan, implement, and
sustain a long-term research
program. In conjunction with
EPA's program offices and the
external scientific community,
EPA's Office of Research and
Development should develop basic
core research programs in areas
where it has unique
responsibilities and capabilities.
3. EPA needs to establish better
mechanisms to ensure that a
coherent, balanced R&-D strategy is
planned and implemented. EPA
needs to establish an internal
Research Strategy Council to
oversee its R&D program; a
standing committee of the Science
Advisory Board should provide an
independent review of EPA's core
research program; and the
Assistant Administrator for
Research and Development should
be changed from a political to a
career position.
4. EPA must improve its capability
to anticipate environmental
probJems. EPA should explicitly
develop and use monitoring
systems that help the Agency
anticipate future environmental
conditions, and it should create a
staff office that would be
responsible for anticipating
environmental problems and then
recommending actions to address
them.
5. EPA should provide federal
leadership for a national program
of ecological research by
establishing and funding an
Environmental'Research institute.
The Institute would conduct a core
ecological research program,
monitor and report on trends in
ecological quality, and provide a
catalyst for ecological research
efforts funded by other federal
agencies, state governments,
universities, and the private sector.
6. EPA should expand its efforts to
understand how and to ivhat
extent humans are exposed to
pollutants in the real world. To
help improve current understanding
of human exposure, EPA should
place much greater emphasis on the
use of personal monitors and
biomarkers, and it should validate
many of its human exposure models.
7. EPA should initiate a strong
program of epidemiological
research. Such studies should be
designed to support regulatory
efforts and to develop information
on potential new environmental
and health problems.
8. EPA should expand its efforts to
assist all those parts of society
that must act to prevent/reduce
environmental risk. Since state,
local, individual, and private
sector actions will become
increasingly important for
reducing the amount of waste and
pollution generated, EPA needs to
improve the education, training,
technology transfer, and research
programs that support such
actions.
9. EPA needs to increase the
numbers and sharpen the skills of
the scientists and engineers who
conduct environmental research.
EPA should increase grant
programs and initiate training
programs to increase the national
supply of technical personnel, and
it should use existing mechanisms,
such as the Intergovernmental
Personnel Act, to bring about a
closer collaboration between EPA
scientists and engineers and the
external scientific and engineering
community.
10. EPA's R&-D budget should be
doubled over the next five years. If
the nation is willing to spend $70
billion per year cleaning up and
protecting the environment, then it
is reasonable—indeed, barely
sufficient—to spend one percent of
that amount on EPA research that
helps determine how the national
environmental protection budget
can be allocated most effectively.
26
EPA JOURNAL
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Environmental Problems
The Situation
by Jack Lewis
What should be the nation's
environmental priorities as we
move toward the 1990s and the 21st
century? How should we go about the
business of priority-setting? What
criteria should determine our national
priorities on the environment? These are
questions addressed by people with
different vantage points earlier on in
this issue of EPA Journal.
Despite the controversies surrounding
priority-setting, one point is
indisputable: Whatever its outcome, the
priority-setting process must be based
on a firm understanding of the total
universe of environmental problems
now confronting the United States.
EPA's Office of Policy, Planning, and
Evaluation has recently issued a report,
entitled Environmental Progress and
Challenges: EPA's Update, which
summarizes environmental problems
NOVEMBER/DECEMBER 1988
Vf'*.e Bnsson photo
Industries, as well as municipalities
and people themselves, contribute
to pollution. A cleanup is under
way on all fronts, although the
question is whether it will be
enough. In Wisconsin's Fox River
Valley, pictured above on a wintry
day, the paper industry is an active
partner in a pollution control plan.
across the spectrum, describes the
progress made in each problem area,
and outlines the challenges that remain.
Drawing on this August 1988 report,
the following discussion is intended to
provide background information on the
major environmental problems that
compete for finite resources and
attention—with no endeavor to rank
these problems in any order of priority
or importance (and no priority ranking
implied by the order in which problem
areas are discussed).
Water
Water-pollution problems fall into three
basic categories:
• Protection of drinking ivater. More
Americans are receiving safer drinking
water than ever before: the most severe
public health effects from contaminated
drinking water have been eliminated.
However, there are still some less acute
hazards associated with a number of
specific contaminants, such as lead.
radionuclides, microbiological
contaminants, and disinfection
byproducts. These hazards are
particularly troublesome in small
community systems, which have a low
level of compliance with national
drinking water standards.
One challenge facing the Agency is
how to motivate the public to bear the
costs of dealing with the growing
number of contaminants EPA is now
requiring public water systems to
regulate. Another is to overcome the
financial problems faced by these
systems, especially the smaller ones.
In addition, EPA is concerned about
protecting surface and ground-water
sources of drinking water from further
contamination. EPA and the states will
need to continue working to improve
wastewater treatment, as well as to deal
with problems caused by toxic
pollutants. The extent and significance
of contamination by toxics lias not yet
been fully assessed, but the 1<)8(>
amendments to the Safe Drinking Water
Act are requiring water systems to
extend both their monitoring and
treatment.
• Protection of surface and ground
wafer. Protection of America's surface
water has been the focus of concerted
action for many years. Billions in
federal funds have been spent to
construct wastewater treatment plants,
and industry has invested heavily in
equipment to "pre-treat" its toxic
effluents. Today the emphasis of
27
-------
Reflections. A decent, healthy
environment is proving to be
a more complex, elusive goal
than originally realized.
surface-water programs is on
consolidating the gains of the past.
while transferring growing parts of their
management to state and local officials.
There is also a new effort to curb
nonpoint pollution coming from
agricultural and urban run-off.
Ground-water protection is a newer
but ever-growing area of Agency
concern. The major challenge today is to
build capacity among state governments
The nation needs an
integrated long-term waste
management strategy, with
ocean dumping no longer the
"quick fix" alternative to other
options.
and Indian tribes for dealing with
ground-water protection tasks, such as
the safeguarding of wellhead areas. This
is not always easy because of the
scientific and regulatory complexity of
the problems encountered.
• Protection of criticdl (iqiuific li
-------
Mike Bnsson photo
and disposal facilities, EPA is taking
steps with the states to ensure the
proper management of municipal and
hazardous wastes. Many believe that
municipal recycling and industrial
waste reduction should become the
centerpiece of a progressive national
waste management strategy.
• Cleaning up releases of hazardous
substances. One of EPA's most
important responsibilities is to clean up
the worst of the uncontrolled hazardous
waste sites in the United
States. Tremendous efforts will be
required to develop the scientific and
technical expertise needed for
permanent clean-up remedies. The
technical difficulty of cleaning up these
sites can only be overcome by
conducting research, developing
technologies, and gaining further
experience in the detoxification and
destruction of wastes.
• Tackling pollution from underground
storage tanks. EPA is helping the states
to develop programs that will assist in
managing underground storage tanks.
Better tank design as well as leak
detection devices are crucial to these
efforts. The cleanup of areas already
contaminated by leaking underground
storage tanks is another major challenge
that EPA and the states are now facing.
• Emergency Planning and Community
Right-To-Knoiv. The Emergency
Planning and Community
Right-To-Know Act of 1986 has
redefined the way EPA, the states, and
local government must deal with the
presence of chemicals in
NOVEMBER/DECEMBER 1988
individual communities. Better planning
for chemical emergencies is already
underway, and so is the gathering of
information both to assist emergency
planners and inform local
citizens. Ongoing attention to these
problems is certain to be a major EPA
challenge in the years ahead.
There are other problems related to
chemicals in the U.S. environment. EPA
has already devoted a great deal of
attention to toxics such as dioxin,
asbestos, and PCBs; these efforts must
continue in the future. But other
potentially toxic: substances still need to
be evaluated and possibly regulated. In
addition, a new category of substances,
biotechnology products (the new
substances that are now being created
through laboratory gene-splicing), will
require review and regulation as
appropriate.
One broad class of chemicals poses a
particularly pervasive challenge to
human health and the environment:
namely, pesticides. EPA's continuing
challenge is to reduce the health risks
from pesticides. Consumers may be
exposed through their diet, their
drinking water, and their use of
products targeted for home use, while
farm workers and pesticide applicators
are particularly vulnerable to pesticide
exposure. The Agency must also protect
fish and wildlife in habitats threatened
by pesticide contamination.
EPA must continue to place strong
emphasis on reviewing all varieties of
new chemicals, and completing that
review before they are introduced into
commerce—and into our environment.
Integral to that process must be
scientifically valid methods for
determining the health and
environmental hazards each chemical
presents.
Looking Ahead
Any survey this broad can give only a
rough idea of the challenges now facing
EPA. Focusing on one medium at a time
is in itself misleading, for
environmental problems seldom stay
confined to one medium. As a result,
cross-media approaches are becoming
increasingly important. Also, then; is
growing recognition that risks are not
uniformly distributed nationwide, and
that priority-setting must be built on a
consensus not just of federal but also of
state and local officials, as well as
average citi/.ens.
At the moment, there is no clearcul
consensus for the 1990s. As this issue of
EPA Journal illustrates, experts in the
environmental arena and members of
the public, have different views on what
should be tin; top environmental
priorities for EPA and the nation.
(Note: Anyone mt<;rc.s[cd in ohfmnin"
-------
Pollution Prevention:
Getting a Higher Priority
by Jerry Kotas
A new Enhanced Carbon Absorber
System at General Dynamics, Pomona,
California. The $1.2 million system is
95-percent efficient in removing airborne
solvent emissions from the facility's paint
shop and converting them to carbon
dioxide and water.
EPA has launched a major new effort
to reduce the threats posed by
environmental pollution. The newly
created Pollution Prevention Office is
charged with promoting an integrated
environmental ethic stressing the
prevention of pollution before it
becomes a problem.
This new approach is profoundly
simple and yet radically different from
the Agency's past efforts to protect
30
health and the environment. This
approach recognizes that many of the
benefits of controlling pollution have
already been achieved. Further
environmental gains must come from
preventing the release of pollutants.
Recent news reports, from medical
wastes on the beaches to global
warming trends, underscore this new
reality. Our society can no longer ignore
the impacts of our patterns of
production, consumption, and disposal
on the natural resources we depend on
for our survival. We must begin to
develop a unified view of
EPA JOURNAL
-------
fewer and less toxic chemicals into the
environment. Consumers can purchase
fewer disposable products, or recycle
their garbage, or purchase products that
contain recycled materials.
EPA's new Pollution Prevention
Office will be the focal point for the
Agency's prevention activities and a
Many of the benefits of
controlling pollution have
already been achieved.
Further environmental gains
must come from preventing the
release of pollutants.
major impetus behind an integrated,
cross-media approach to pollution
prevention. An important early action of.
the Office will be the publication of a
Pollution Prevention Policy Statement
in the Federal Register. It will announce
the development of the Agency's
multi-media prevention strategy and
commit the Agency to working with
public and private individuals and
organizations to foster the adoption of
this new environmental ethic into our
national culture. The Pollution
Prevention Office will be guided in this
and other efforts by an advisory
committee comprised of senior
representatives from EPA's Headquarters
program offices and regional offices.
State and local governments will be
encouraged to play a leading role in
helping to shift managemenj priorities
of industry and the public. Because the
states will be central to the success of
this policy, one of EPA's primary goals
is to support the development of state
and local pollution prevention
programs.
Other elements of the Office's strategy
include an aggressive outreach program
directed at state and local governments,
industry, and consumers to publicize
the opportunities and benefits of
pollution prevention. A multi-media
clearinghouse will provide educational
and technical information on source
reduction that will be especially helpful
to medium and small industrial
facilities. The new Office will work
closely with EPA's program offices to
identify and address any existing
regulatory barriers to pollution
prevention and to incorporate pollution
prevention into every feasible aspect of
Agency decision-making and planning.
Our agenda is ambitious, but the
stakes—maintaining a livable
environment in the 1990s and
beyond—are high. Pollution prevention
is an idea whose time has come, o
(Kotos heads EPA's newly created Office
of Pollution Prevention within the
Office of Policy, Planning, and
Evaluation.)
environmental media—air, water, and
soil—so as to avoid an "environmental
merry-go-round" whereby regulation of
one medium simply shifts pollution to
another.
There are sound reasons supporting a
cross-media, preventive approach:
• The sheer volume of wastes generated
in the United States is threatening to
overwhelm the absorptive capacity of
our^environment. The nation generates
enough garbage each year to fill a
convoy of 10-ton trash trucks 145,000
miles long.
• Burning all our wastes is not the
ultimate answer. Incineration can
reduce waste in some circumstances,
but it also generates ash which may
need to be managed as a hazardous
waste. ^^
• Pollution prevention can make
economic sense. U.S. industry currently
spends $70-80 billion annually on
pollution control. Preventing pollution
can save a company money through
product and energy cost savings and
lower outlays on pollution control
equipment.
The job of preventing pollution
cannot rest solely with EPA or with
government in general. EPA does not
plan to dictate how each factory should
operate its production processes, nor to
dictate to consumers whether to select
plastic bags or paper bags at the
supermarket checkout line. But we will
be helping all sectors of society to take a
close hard look at how our choices are
affecting the environment, and to
consider ways in which we can create
fewer pollutants.
Industrial managers at the plant level,
for example, can examine materials and
process changes, as well as inventory
control methods in order to release
NOVEMBER/DECEMBER 1988
31
-------
Borrowing an Idea
from Big Mac
by Ron Brand
D
o these issues sound familiar to
vou r
• Constant personnel turnover, low pay,
continual need for training.
• Need to provide and maintain service
at thousands of locations.
• Need to find improved methods of
doing hundreds of different operational
tasks.
These are issues that francJ
operations around the world face every
day. They certainly sounded familiar to
us as we confronted the problems of
administering a program to regulate 2
million underground storage tanks at
some 750,000 facilities in 3,000 counties
across the United States.
In Novemher 1984, Congress passed
Underground Storage Tank (UST)
legislation requiring EPA to set new
.standards for tank design, to ensure the
proper installation of new underground
tanks (roughly 80,000 new tanks are
being installed each year), and to assure
that all tanks subject to federal law have
adequate leak detection and prevention
equipment. In view of the nature and
scope of this regulated universe, KPA
Administrator Lee Thomas and Deputy
Administrator Jim Barnes decided that a
successful UST program could probably
not be designed along traditional lines.
To begin with, 2 million existing USTs
make up a large regulated community.
Moreover, in setting up the UST
program, EPA was dealing with
hundreds of thousands of small
business owners of storage tanks, and
we didn't even know who or where they
all were. For these reasons, I was asked
to head up a Task Force to design a
viable program, within the Office of
Solid Waste and Emergency Response,
under Assistant Administrator Win
Porter.
What was the situation? Of the 2
million existing underground tank
systems, 80 percent or more were
unprotected against corrosion, making
them prone to leakage, and lacked
genuine leak detection safeguards. No
one knew how many were leaking.
Industry said 5 percent; studies from
EPA said up to 35 percent.
Under these circumstances, a federal
program along ordinary lines, with
federal control, federal dollars, and
thousands of federal inspections, was
out of the question. What to do? In fact,
much work was already being clone at
the local and state levels. Tanks were
originally put underground to prevent
fire and explosion hazards. Most fire
departments permit and inspect new
tank installations. Some state
environmental agencies were addressing
problems of leaking tanks, abandoned
tanks, and cleanup of contaminated tank
sites. How could we make allies of these
numerous entities to help build a
nationwide program?
We looked for other "models." Did
situations analogous to ours exist
elsewhere? Who had dealt with
problems of developing a distribution
system, nationwide, with products or
services to be distributed through a
large network of suppliers. Franchisers
do it, but not from one or 10 locations,
but hundreds or thousands of locations.
As we saw it, many franchisers had
been successful on two counts at
thousands of locations:
• Developing services.
• Continuously assessing, maintaining,
and even improving performance.
That looked like the kind of job we
were faced with: how to develop and
improve performance on USTs in 3.000
counties and 56 states and territories.
We invited senior executives of some
of the most successful franchisers in the
country to meet with us, including
Century 21, McDonalds, Service Master,
and 7-Eleven. They spent two days with
our regional program managers and
headquarters managers discussing issues
such at these:
• How do you maintain consistent
service and quality?
• How can you be sun; a Big Mac
served in Fresno will taste the same as
one served in Fort Lauderdale? (By the
same token, how can you be sure a new
tank in each of these same cities will be
properly installed?)
• What are the problems in having
many sites of service? (Fifty states,
3,000 counties for the UST program;
thousands of franchise stores for
McDonalds and 7-Eleven.)
• How do you provide technical
assistance and training for the people
doing the real work of serving the
customers?
• How do you deal with personnel
where jobs tend to be low-paying and
turnover is high?
As we took a closer look at the
franchising concept, the similarities
became more and more evident. We
embraced its principles wholeheartedly,
but carefully selected those aspects
which seemed applicable to our
program.
i;>
EPA JOURNAL
-------
In the Office of Underground Storage
Tanks (OUST), we, like private industry
franchisers, "have to achieve all our
results in the field, in thousands of local
communities." We too see it as our
primary job "to help the local
franchisees (in our case, the individual
states) succeed"; we too "have no cash
registers at headquarters."
We learned some pragmatic lessons.
Most importantly, if you want to be
successful as a franchiser, your
overriding concern has to be helping the
franchisee succeed, and that spirit and
attitude must be the basis of everything
you do. For us, that means helping the
local and state agencies carry out the
actions needed for a successful program.
In OUST we have no alternative—we
can succeed only through our
"franchisees."
The factor critical to our success is
the EPA regional office staff (corre-
sponding to franchiser district offices).
Our OUST regional staff represent EPA
to the states on a day-to-day, year-to-
year basis. The private sector franchisers
all made frequent trips to the
franchisees for assistance and review.
For OUST to do the same, we had to get
significantly higher travel allowances
for our regional program managers and
their staffs.
In the private sector, when district
office representatives visit the
franchisee, they must, as a rule of
thumb, bring something to the table. In
our case, simply bringing grant funds
isn't enough to get the environmental
job done right. Some of the tools we
have developed or are developing for
regional staff to bring to the table
include:
• Pilot projects on improved methods
of cost recovery, site assessment,
corrective action, and priority setting for
site response.
• A computerized system designed to
help states decide on appropriate
clean-up actions (now being tested in
Nebraska, Massachusetts, and Missouri).
NOVEMBER/DECEMBER 1988
• A computerized review of the
regulations, which provides a number of
easy ways to look up any portion of the
regulations and to get additional
interpretation.
• Videos on tank closure and on tank
installation, shot in the field with "real
workers" and made available to the
franchisees, and also broadcast over the
National Fire Protection Association
satellite network to fire stations across
the country.
fust like the franchisers we
have actions that will occur
tens or hundreds of thousands
of times ....
• Handbooks on: Funding Options for
States and Local Governments; Cleanup
of Releases from Petroleum USTs; and
Building State Compliance Programs.
In addition, for the broader community
concerned about tanks, we produced a
simplified, plain-English, illustrated
version of the regulatory requirements
primarily for tank owners and operators,
called "MUSTS for USTS."
We strive to ensure that these are all
distributed through our regional
program managers, and not from
headquarters, thus building their role as
the key contacts for the
states/franchisees.
Finally, like the franchisers, we have
been developing "assembly lines" or
"flow charts" of all the processes
involved in carrying out the -UST
program. For example, the "tank
closure" assembly line has over 75
steps, ranging from deciding whether it
is best to close the tank in place or
remove it from the ground to deal safely
with explosive vapors, to checking the
site for contamination to see if clean-up
action is needed. As we view it, every
step is an "opportunity for
improvement." Because just like the
franchisers we have actions that will
occur tens or hundreds of thousands of
times, and improvements in each step
can mean dramatic improvements when
applied nationwide.
All of this relies on training, training,
training! For us, the focus is on training
state personnel so that they are prepared
to conduct inspections and make
decisions on approving new tank
systems, on completing safe closures,
and on determining clean-up actions.
The successful national franchisers tell
us that training is one of the most
essential and useful services they
provide their nationwide networks. The
headquarters staff don't necessarily do
the training themselves, but provide the
tools and mechanisms (videos,
handbooks, workshops) to make it
happen in the field.
Some of the other things the
franchisers stressed were:
• Doing applied research to make each
task simpler and to ensure quality
control.
• Listening to your franchisees—that's
where most of the ideas for
improvement and new services come
from.
This is an experiment for OUST. We
feel we've already gained a lot from
taking a "franchise approach" to our
work. We still have a long way to go in
building trust and expertise, and
providing tools. But remembering that
there are 2 million underground tanks
out there that can affect 240 million
Americans, we hope one day we'll be
able to say "240 million customers
served." o
(Brand is Director of EPA's Office of
Underground Storage Tanks.}
33
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Proposing a Global Priority:
Earth Day, 1990
by Denis Hayes
f
^
J
John Sotomayor photo. The New York Times
Earth Day—April 22, 1970—was the
largest organized demonstration in
human history. An estimated 25 million
Americans took part. Angry young
women and men shut down 5th Avenue
in New York, poured sen-age on the
carpets of corporate despoilers, pounded
polluting automobiles apart with sledge
hammers, and wore gas masks on the
evening news. The U.S. Congress
formally took the whole day off, as tens
of thousands of schools and
communities held environmental
teach-ins and hosted other events across
the land.
No town was too remote to be
touched. No citizen was too timid or too
radical, too sophisticated or too
politically untutored, to find a role.
We should organize a global
Earth Day, to be held the week
of April 22, 1990, on the 20th
anniversary of the original.
In the supercharged months that
followed, the born-again environmental
movement grounded the SST and
passed a tough new Clean Air Act with
only a handful of dissenting votes in
both houses of Congress. Feeling its
muscle, the movement defeated seven of
a "dirty dozen" Congressmen, forced the
military to halt the use of mutagenic
defoliants in Southeast Asia, and helped
pass a federal occupational health and
safety act aimed at "in-plant pollution."
On Earth Day 1970, the modern
environmental movement leaped onto
the national stage, grabbed the
microphone, and demanded sweeping
changes. The movement was, for a
while, an unstoppable force. It helped to
shape the values and priorities of a
whole generation, and it fundamentally
altered American politics.
Eighteen years now have passed since
Earth Day, and much of the original
vigor has faded. Environmental activists,
scholars, lobbyists, and lawyers have
achieved some wonderful victories
during the past two decades, often
against overwhelming odds. The world
is a better, more healthy place than it
otherwise would have been. Yet, few
environmental victories can be viewed
EPA JOURNAL
-------
as permanent, and too many "solutions"
have been piecemeal and ineffective.
Hundreds of local, state, and federal
environmental laws have been passed.
Tens of thousands of pages of
regulations have been issued. Millions
of pages of environmental impact
reports have been prepared. Huge
environmental bureaucracies have been
established and institutionalized. But it
cannot be seriously argued that the
nation, or the world, is in better shape
today than it was in 1970.
The Issues
Most of the fundamental problems of
1970 still plague us. Moreover, we now
face a huge array of new, complex,
seemingly intractable ills: Greenhouse
gases heat up the atmosphere. The
ozone layer becomes thinner. Deserts
expand. Rain forests shrink. Oil usage
skyrockets. Solar stock portfolios
plummet. Agricultural pests become
resistant to modern chemistry. Garbage
barges navigate the world's oceans,
searching in vain for a welcoming
harbor. Beaches clog with styrofoam and
lethal medical waste. Aquifers fall ever
lower. Ground water reeks of industrial
waste. Endangered species
disappear—forever—at the rate of one
per hour. Human populations explode,
while urban slums implode. And the
image of nuclear winter, with its
concomitant extinction of vertebrate life,
has left its indelible mark on the public ,
consciousness.
Viewed properly, environmental
concerns are gut issues: survival issues.
Homo sapiens is uniquely of this world.
We are designed for it, and are
inextricably linked to it. As the Earth
sickens, we are afflicted. If it dies, so
will we.
The greatest strength, and perhaps the
greatest weakness, of the Earth Day
concept lies with the multifaceted
nature of our environmental problems.
This complexity is a source of strength
because every community on Earth has
some environmental problem—e.g. toxic
wastes, firewood shortages, asbestos,
pesticides, dam inundation, lead paint,
surfeits of garbage, or desertification—in
its own backyard. Organizers can more
easily stir people to get involved in
issues that affect them so directly, and
which they can directly influence.
At the same time, these dozens of
local issues can lead to a diffuseness
that could dilute the impact of a global
event. It is critically important that
narrow issues are linked to broader
concerns. For example, concerns over a
Viewed properly,
environmental concerns are
gut issues: survival issues.
local garbage dump should be linked to
resources policy, recycling, and toxic
wastes. People must understand that
chlorofluorocarbons (CFCs),
manufactured in the United States, that
later escape from a junked refrigerator
in Brazil, are destroying the ozone layer
over Antarctica. Unless the context is
carefully structured, participants and
media alike may fail to communicate a
coherent message.
Public Support
Public opinion polls find the average
American places an extremely high
value on environmental protection.
Indeed, the average man-on-the-street
appears to hold far stronger views than
do many so-called environmental
"leaders."
• Fifty-eight percent of the public
thinks we spend too little on the
environment; 6 percent thinks we spend
too much.
• Fifth-nine percent thinks there is too
little environmental regulation; 7
percent thinks there is too much.
• And—according to a New York
Times/CBS Poll conducted in July
1988—65 percent of the American
public believes that environmental
protection standards "cannot be too
high" and that environmental
improvement should be made
"regardless of costs." Only 22 percent
disagreed with this "Earth First/Deep
Ecology" sentiment. When this "cannot
be too-high" question was first asked
in 1981, 45 percent agreed with the
statement and 42 percent disagreed.
Earth Day: 1990
The time has come to galvanize a new
outpouring of public support for
environmental values, and to enlist a
new generation of activists in the
environmental struggle. Toward that
end, we should organize a global Earth
Day, to be held the week of April 22,
1990, on the 20th anniversary of the
original.
The 20th anniversary of the original
Earth Day provides a superb
opportunity to sum up all that we have
learned in the last 20 years. It provides
an opportunity to explore the ecological
implications of new developments, from
Star Wars defense to an
information-based economy. It will offer
a framework in which to reexamine the
wisdom of past eras, and of diverse
cultures.
Earth Day 1990 offers an opportunity
to reach out to new constituencies; to
build alliances that transcend
boundaries—reaching across countries,
cultures, and continents; to carry the
environmental agenda to the far corners
of the planet. Recent reforms in the
Soviet Union and China have left these
lands more open to environmental
concerns. Numerous leaders in Africa
and South America have begun to resist
the use of their lands as open pit mines
and toxic waste dumps.
The most critical environmental
issues cannot be solved by any single
country acting by itself. Even where the
United States is the largest single source
of a problem, such as oil depletion,
carbon dioxide production, or
ozone-destroying emissions of CFCs,
America's contribution remains only a
fraction of the global problem.
Japan, for example, ranks fourth in
the world in carbon dioxide emissions,
but less than one-third of the Japanese
public is concerned about the
greenhouse effect. Japan experienced the
Minimata disaster, and it suffers much
of the world's worst air pollution. Japan
produces 10 percent of the world's
CFCs, imports a huge quantity of exotic
INUVtlVldttt/UtCtlVltiti-i ISbB
35
-------
Throngs jammed New York's Fifth
Avenue in response to Earth Day's
call for regeneration of a polluted
environment. View is north from
43rd Street with Central Park in the
background.
hardwoods from Southeast Asia, and
continues to harvest whales and
dolphins with little regard lor
international opinion. Internationally.
japan is about to become the world's
largest donor of non-military foreign
aid, yet it seldom takes into careful
consideration the environmental effects
of the projects it funds.
Environmental concerns are viewed as
having little political significance by
japan's leaders, much as they were
viewed by American officials in the late
1960s. A Japanese Karlh Day orgam/.rcl
and controlled by the Japanese and
geared to address their principal
concerns—could fundamentally alter
both the perception and the reality of
environmental politics in that country.
The most critical
environmental issues cannot
be solved by any single
country acting by itself.
Japan's Environmental Agency recently
issued a manifesto urging the nation to
take a leadership position in
international environmental protection
commensurate with the nation's
economic strength. The manifesto stated
that "it is necessary to inculcate people
from their childhood with knowledge
and consciousness about the
relationship of the environment with
daily life."
Rest in peace.
Stevens Institute
students,
Hoboken, New
Jersey, held a
funeral service
for the Hudson
River during
Earth Day
activities in
1970.
HI,
R f wjn.s photo. The New York limes
Similar cases could be made for
boosting emerging environmental
movements in numerous other
countries, including the newly
industrialized countries of East Asia,
much of the European Community,
India, the Soviet Union, Brazil, China,
and Egypt. Of course, none of these
lands would countenance the United
States telling them what to do on
environmental issues. But the mere
existence of an international Earth Day
might catalyze or strengthen effective
indigenous organizations in these and
scores of other countries in which
environmental concerns still have
limited impact.
Global solutions may require global
cooperation. Past international
agreements, such as those governing
whaling, atmospheric nuclear testing,
emissions of CFCs, suggest that there
exists some capacity for nations to set
aside parochial concerns and act on
behalf of the global commons, once an
issue generates a sufficient measure of
international foreboding. A global Earth
Day would be designed to create a
context conducive to ecological
statesmanship.
The Agenda
At the core of the environmental agenda
are some very basic values that seem to
transcend cultures, ideologies, and
politics. Aldo Leopold summarized his
"land ethic" as follows:
A thing is right when it tends to
preserve the integrity of the biotic
community. It is wrong when it
tends otherwise.... We abuse the
land because we regard it as
a commodity belonging to us.
When we see land as a community
to which we belong, we may begin
to use it with love and respect.
The environmental ethic must be
understood to include not just
land but also the air, the water,
other species, and the
interrelationships between and
among them all. It must assume
some specific goals, including:
• A sustainable society, built upon
the efficient use of renewable
energy and recycled resources.
EPA JOURNAL
-------
ck A Sums pftoto The New Yonk rimes
• Human health, dignity, and
freedom.
• Biological diversity.
• Peace and soc:ial justice.
• Respect for nature.
Actions should be evaluated not
just in terms of their impact on
this quarter's bottom line, or this
year's financial statements. Rather,
they must be judged on whether
they are moving the world toward.
or away from, these widely shared
goals.
It should be possible to organize
a massive worldwide event,
perhaps enlisting hundreds of
millions of people, in activities
demonstrating widespread support
for such values and objectives.
Earth Day 1990 should make it
inescapably clear to the world's
leaders that their "followers" are
running out of patience.
If You Want To Get Involved
Earth Day 1990 is currently just an
idea. If it finds fertile soil, it will
take root and evolve organically.
Ultimately, I would expect it to
assemble a diverse international
board of sponsors and largely
autonomous organizations in
scores of countries.
The central coordinating role
might best be performed by an ticl
hoc group set up to catalyze the
event and then dissolve. This
would eliminate potential
jealousies and turf wars with
powerful existing environmental
organizations.
If you would like to be informed
as plans unfold, write to:
Earth Day 1900
P.O. Box AA
Stanford University
Stanford, California
-------
Letter to the Editor
September 12, 1988
Editor
EPA Journal
Dear Sir:
Re: "Hatching an Environmental Battle Plan in
Jacksonville" in the Cities and Environment issue of
EPA Journal.
I recently read this article, authored by Khurshid Mehta
and Jim Manning, and am delighted to see Jacksonville
receiving its due credit for being on the leading edge of
both technology and development of rules on a situation
as subjective as odor. However, I would like to correct
some factual misstatements in the article.
The article mentions that some physiological effects
have been noted but omitted information that the
Health, Welfare and Bio-Environmental Department
(HWB) has that there is no relationship between odor
and these physical problems. The facts are that
Jacksonville is a non-attainment area for ozone, as
reported by HWB [and on the EPA "bad" city list), and
the preponderance of evidence suggests that these
physical symptoms are due to Jacksonville's significant
ozone problem.
The article also states that one of the effects of odors
has been reduced property values. This is absolutely
false and any research into the value of property in
Jacksonville would demonstrate continuing appreciation
of property in all segments of the city.
The authors state that "the odoriferous conditions are
caused primarily by..." and go on to cite several sources;
in fact, those sources inclusively represent less than 40
percent of the odor complaints received by HWB.
While it's true that wastewater from chemical plants
does contain Total Reduced Sulfur (TRS) and terpenes,
the TRS content is typically less than 20 parts per
million (ppm). Collectively, the plants represent about
one-half percent of the effluent sent to the city sewage
plant; it's hard to accept that if 0.5 percent of the
effluent has 10 ppm TRS in it that this could be a major
source of odors at a sewage treatment plant, the type of
facility well known for malodorous emissions.
It's true that Jacksonville now has a "standard" on
odor that says that, within a 90-day period, if any five
people object to any smoke, mist, dust, gas, fume, vapor,
or odor from any property, that property owner is
subject to a $10,000-per-day fine. That sort of criteria is
hardly an objective, technical, scientific standard. It is
an opportunity for vigilantism.
The statement that inspectors obtain data about odor
intensity is patently false. There is no such effort to
measure odor intensity.
The statement that the law provides a regulatory
mechanism that includes the development of
industry-specific emission/work practice standards is
also absolutely untrue.
The authors talk about many steps that pulp mills are
taking on odor abatement, with the implication that
these efforts are due to the new ordinance. These steps
were in motion since the early 1980s and the companies
had committed the funds for these projects years before
the ordinance mentioned in the article was even
discussed.
The authors are also inaccurate in stating that the
chemical plants are the only ones in the United States
using turpentine to derive terpenes. There are a number
of other plants in the United States including two in
Florida and two in Brunswick, Georgia, 60 miles from
Jacksonville.
Glidco is proud that one year before the ordinance
became law (and months before the current Mayor was
elected), we had volunteered with the Mayor's office to
establish a specific program of identifying and
implementing projects designed to eliminate/reduce
malodorous emissions.
I can only assume that this article was written
sometime before it was published because the odor
measurement approaches described by the authors have
proven to be technically unsound and practically
unusable.
Jacksonville is, indeed, the Bold New City of the
South and has made tremendous strides in abating
odors. As a proud corporate citizen here for the last 78
years, SCM Glidco is delighted to have helped our city
achieve its potential as an "all American city."
Sincerely yours,
George W. Robbins
President
SCM Glidco
Jacksonville, Florida
The authors respond:
To the Editor:
The comments in Mr. George Rabbins' letter of
September 12 were brought to the attention of and
reviewed by the Bio-Environmental Services Division of
the City of Jacksonville. The authors continue to stand
behind the veracity of the information presented in the
article. In view of the fact that the technical issues
raised in Mr. Robbins' letter have been addressed in the
past at public meetings, the authors decline to make any
further comment.
Signed,
Khurshid K. Mehta
James L. Manning
Letters to the editor are published at (he discretion of
EPA Journal, which reserves the right fo edit them for
clarity or brevity. As with other articles in (he Journal,
letters express the opinions of the authors, and do not
necessarily reflect EPA policy. The Journal invites
readers to send letters and appreciates the time and
effort that go in(o them. Letters become (he property of
EPA Journal and will not be returned.
38
EPA JOURNAL
-------
Appointments
Alexandra B. Smith has been
appointed Associate Regional
Administrator in Region 4.
Atlanta. Previously she was
Deputy Regional
Administrator in Region 8,
Denver, a post she held from
July 1984 to August 1988.
Smith came to Denver from
Region 10, Seattle, where she
had directed the Air and
Waste Management Division
since 1978.
Between 1977 and 1979,
she was Chief of the
Environmental Evaluation
Branch in Region 10, and
prior to that she directed the
Region's Office of Federal
Affairs. Smith began her
government career in 1972 at
the Department of Housing
and Urban Development,
where she was an employee
development specialist. She
also worked briefly for the
National Park Service in
Harpers Ferry. Before joining
government service she
worked for private companies
in both Colorado and New
York and television stations
in New York and Seattle.
Smith received her
bachelor of arts degree in
government from SI.
Lawrence University in 1967.
her master's degree from
Syracuse University in 1968,
and an M.B.A from the
University of Washington in
1982. She received the Cold
Medal for Exceptional
Service in 1980, Bronze
Medal in 1982, and in 1987
was the recipient of a Senior
Executive Service
Presidential rank award.
NOVEMBER/DECEMBER 1988
Jonathan Z. Cannon has been
appointed Deputy Assistant
Administrator of the Office of
Solid Waste and Emergency
Response (OSWER).
Cannon graduated summa
cum laude from Williams
College and cum iaude from
the University of
Pennsylvania Law School.
After clerking for Judge
David Bazelon on the U.S.
Court of Appeals for the
District of Columbia Circuit,
he joined the law firm of
Beveridge and Diamond. He
was a partner in the firm
from 1980 to 1986, when he
left to join EPA.
In January 1987, Cannon
was named EPA Deputy
General Counsel for
Litigation and Regional
Operations. In August 1987
he became Deputy Assistant
Administrator for Civil
Enforcement in the EPA
Office of Enforcement and
Compliance Monitoring,
which post he held until
joining OSWER.
Cannon is a member of the
D.C. Bar and the Natural
Resources Section of the
American Bar Association.
He has been an Adjunct
Professor of Environmental
Law at Washington and Lee
and a lecturer on the subject
at the University of Virginia
Law School.
Edward E. Reich has been
named Deputy Assistant
Administrator for Civil
Enforcement in the Office of
Enforcement and Compliance
Monitoring. Prior to this
appointment, Reich served as
Associate Enforcement
Counsel for Waste in that
office.
A graduate of Queens
College, City University of
New York, with a subsequent
law degree from the
Georgetown University Law
Center, Reich joined EPA at
its inception in 1970 as a
program advisor in the Office
of Air Programs. He moved
shortly thereafter to the
Office of Enforcement and
General Counsel. In early
1972 he became Chief of that
office's Enforcement
Proceedings Branch, a
position he held until March
1974, when he left the
Agency to become deputy
general counsel for Petroleum
International Associates.
Reich returned to EPA in
1975 as Chief of the
Enforcement Proceedings
Branch in the Office of
Enforcement, In 1976 he
became Director of the
Stationary Source
Compliance Division in the
Office of Air and Radiation, a
post he held until late 1986,
when he joined the Office of
Enforcement and Compliance
Monitoring as Associate
Enforcement Counsel.
Jack W. McGraw is the new
Deputy Regional Manager in
Region 8, Denver, a post he
assumes after five years as
Deputy Assistant
Administrator for the Office
of Solid Waste and
Emergency Response. From
January to August 1985,
McGraw was Acting
Assistant Administrator for
that office.
McGraw, who holds a
bachelor's degree from the
University of Charleston in
West Virginia and a
post-graduate degree from
Texas Christian University,
joined the federal
government in 1972 after
service as a minister and
president of the Community
and Housing Development
Corporation, in 1972 he
became director of the
Housing Recovery Office at
the Department of Housing
and Urban Development
(HUD), and in late 1975
became Chief of the
Preparedness Division for the
Federal Disaster Assistance
Administration in HUD.
Subsequently he held a
number of posts in tin;
Federal Emergency
Management Agency and was
that agency's deputy director
for Emergency Operations
prior to joining EPA as
Deputy Assistant
Administrator for Solid
Waste and Emergency
Response in mid-1983.
Among McGraw's
assignments in the
emergency response field
were planning and
coordinating response
39
-------
activities in major disasters
such as those following
Tropical Storm Agnes and
the Buffalo Creek floods in
1972 and participation on
interagency or White House
task forces involving the fall
of the Russian Skylab
satellite, drought prohlems,
the energy problem, and Love
(".anal.
Dr. Raymond Loehr, a
professor of civil engineering
at the University of Texas at
Austin, has been named
Chairman through 1990 of
the EPA Science Advisory
Board (SAB). He succeeds Dr.
Norton Nelson of the New
York University Medical
Center.
Or. Loehr first became
associated with EPA in 1974
as a Program Advisor for the
Effluent Guidelines Division.
His participation on various
SAB committees and
subcommittees began in
1976. Dr. Loehr has chaired
the Technology Assessment
and Pollution and Control
Advisory Committee, the
Hazard Ranking System
Review Committee, the Risk
Reduction Workgroup of the
Research Strategies
Subcommittee, and the
Environmental Engineering
Committee, and is a member
of the SAB Executive
Committee.
A professional engineer,
Dr. Loehr earned his bachelor
of science degree in Civil
Engineering and a master of
science in Sanitary
Engineering at the Case
Institute of Technology, and
a doctorate in Sanitary
Engineering at the University
of Wisconsin. He taught at
Case Institute, the University
of Kansas, and Cornell before
joining the faculty of the
University of Texas, where
he holds the Hussein M.
Alharthy Centennial Chair in
Civil Engineering.
He has been active on a
number of committees of the
National Academy of
Sciences, National Academy
of Engineering, and National
Research Council, the
International Joint
Commission, the University
of Illinois Advanced
Environmental Control
Technology Research Center,
the United Nations Food and
Agricultural Organization,
and Cornell University. He is
a member of the American
Academy of Environmental
Engineers, the Water
Pollution Control Federation,
the American Society of Civil
Engineers, the Association of
Environmental Engineering
Professors, the American
Association for the
Advancement of Science, and
the Society of Environmental
Toxicology and Chemistry.
Dr. Loehr has written
extensively. He has authored,
co-authored, or edited eight
books on agricultural waste
management practices and
over 160 technical
publications and reports
relating to municipal and
industrial waste management.
He is currently on the
editorial board of Hazardous
Waste and Hazardous
Materials and has been an
editor of other technical
journals. He has served as a
consultant to numerous
industries, trade associations,
consulting firms, and
government agencies.
f/)r. Loehr's photograph is
with the feature earlier in
this issue in which he
authors an article.J
Anna Hopkins Virbick has
been named EPA's Acting
Deputy Inspector General.
Previously, she was an
Assistant Inspector General
for iVfanagement and
Technical Assessment.
Virbick joined the federal
government as an Auditor in
the Civil Division of the
General Accounting Office in
1965, after earning her
bachelor's degree in Business
Administration at Wesleyan
College. Later she earned a
master's degree in Public
Administration at American
University and another
master's degree in Education
from Marymount University.
She became a Supervisory
Auditor in the General
Government Division of GAO
in 1967, moving in mid-1976
to the Department of Housing
and Urban Development,
where she was Director of
Field Audit Operations,
Community Planning and
Development, and GAO
Liaison in the Office of
Audit. In 1983, she joined
EPA- as Director of the
Technical Services Staff in
the Office of the Inspector
General.
Michael S. Alushin, an
Associate Enforcement
Counsel for Air Programs, is
one of six federal managers
selected as charter members
in the Senior Executive
Service's (SES) new
fellowship program. The
program was created by the
Office of Personnel
Management (OPM) to
provide SES members with
an opportunity to travel,
write, lecture, and do
research.
Alushin will spend a year
concentrating on
international environmental
issues, working with a
public-interest group, a
multi-national organization,
and the Department of State.
According to OPM director
Constance Homer, the
program was designed to
"recognize and reward career
members of the SES who
have made significant
contributions to the
development of their
employees," and who "now
deserve the opportunity to
develop further their own
managerial and intellectual
resources." D
40
EPA JOURNAL
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Victoria Falls, Zambia.
It's a big earth. What
is its breaking point
from environmental
abuse?
Mate and Evclyne Bemheim photo, Woodfm Camp, tnc
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