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Protecting the Earth:
Are Our Institutions Up to It?
As the 1980s draw to a
close, environmental
problems are taking on new
dimensions. Stratospheric
ozone depletion and the
Greenhouse Effect, for
example, transcend national
boundaries and threaten the
long-term health of our
planet. Are existing
institutions up to the task of
dealing with the
unprecedented challenges
that confront us? This issue
of EPA Journal explores this
question.
An article surveying the
condition of environmental
clean-up efforts nationally
and around the world sets
the stage for this issue. It is
by GlacKvin Hill, former
environmental correspondent
for The New York Times. A
piece by William K. Reilly.
EPA's Administrator, follows,
suggesting changes to help
the Agency perform more
effectively.
A feature by Jessica
Tuchman Mathews, Vice
President of the World
Resources Institute, specifies
how some institutional,
social, and political barriers
to global environmental
protection might be
overcome. The piece is
adapted from a recent
Mathews article in Foreign
Ajjairs magazine,
Environmentalist Barry
Commoner spells out how
pollution prevention—a
widely acknowledged
need—might really be
accomplished.
Arthur Koines of EPA's
Regulatory Integration
Division depicts the dilemma
of the average person trying
to be a good citizen in the
face of the increasing layers
of environmental regulation
at various government levels.
Frances H. Irwin of The
Conservation Foundation
explains a model
"Environmental Protection
Act" developed as a working
draft by the Foundation in
order to stimulate discussion
on ways to streamline,
integrate, and simplify the
current mass of
environmental laws.
Ideas for enhancing EPA's
role as a lead environmental
institution on the world
scene are presented in a
piece by James Gustave
Speth, President of the World
Resources Institute.
An industry view of some
necessary environmental
actions is discussed by John
W. Rowe, head of the New
England Electric System.
Steps the states can take are
suggested in an article by
Robert Hendick, Rhode
Island's Director of
Environment Management.
And the question whether
pollution clean-up agencies
must be a Big Brother is
addressed in a piece by
James M. Lents, Executive
Officer with the South Coast
Air Quality Management
District in Los Angeles.
Two long-time figures on
the environmental
scene—former U.S. Senator
Gaylord Nelson and former
Deputy EPA Administrator
John Quarles—speak out on
the question: Is it possible to
apply the crisis-oriented
approach of the past in
dealing with the
environmental problems of
today and tomorrow?
The need for consumers to
make some basic: changes in
lifestyles and mindsets is
argued by Jay D. Hair.
President of the National
Wildlife Federation. Retired
Senator Robert T. Stafford, a
long-time environmentalist in
a key institution, the U.S.
Congress, writes about
changes in approach which
that legislative body may
need to take as it faces the
crowded agenda of
environmental problems.
And Thomas E. Lovejoy,
Assistant Secretary for
External Affairs at the
Smithsonian Institution,
focuses on changes needed in
the thinking of well-off
nations toward the Third
World if the global challenge
of a decent environment is to
be met.
Michael Gruber, an EPA
staffer detailed to
the state of Washington's
Department of Natural
Resources, writes about the
most fundamental
question—now that there is
growing agreement that major
steps need to be taken if the
planet is to be saved, how do
we get there?
This issue of the: magazine
concludes with a regular
feature—Appointments, n
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United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
&EPA JOURNAL
Volume 15
Number 4
July/August 1989
William K. Reilly, Administrator
John Heritage, Editor
Karen Flagstad, Assistant Editor
Jack Lewis, Assistant Editor
Ruth Barker, Assistant Editor
Marilynftogers, 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.
EPA journal is published by the
U.S. Environmental Protection
Agency. The Administrator of EPA
has determined that the
publication of this periodical is
necessary in the transaction of the
public business required by law of
this agency. Use of funds for
printing this periodical has been
approved by the Director of the
Office of Management and Budget.
Views expressed by authors do not
necessarily reflect EPA policy.
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
and other materials.
A Management Job for
the Human Race
by Gladwin Hill
The Greening of EPA
by William K. Reilly @
Tackling the
Institutional Barriers
by Jessica Tuchman
Mathews
Let's Get Serious
about Pollution Prevention
by Barry Commoner
Under the Environmental
Regulation Layer Cake
by Arthur Koines
Could There Be
a Better Law?
by Frances H. Invin
EPA and the World
Clean-up Puzzle
by James Gustave Speth
From a "Polluter's" View
by John W. Rovve
Next Steps the States
Could Take
by Robert Bendick
Making the Smog Cleanup
Happen in L.A.
by James M. Lents
Can We Win with the
Crisis-Oriented Approach?
Two Observers Speak
Changing from "Consumers"
to Citizens
by Jay D. Hair
Lessons about
Environmentalist!
in Congress
by Robert T. Stafford
The Third World's
Environment:
A Global Dilemma
by Thomas E. Lovejoy
How Do We Get There?
by Michael Gruber
Appointments
^
Front Cover: Earth as seen from
the moon. Photo taken on the
voyage of Apollo 10. From the
photo files of the National
Aeronautics and Space
Administration.
Design Credits:
Ron Farrah;
James H. digram:
Robert Flanagan.
The text of EPA Journal is printed
on recycled paper.
The next EPA Journal ivill focus on
coastal issues.
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-------
A Management Job
for the Human Race
by Gladwin Hill
After a century, the message first
enunciated by John Muir is sinking
in: "When you dip your hand into
nature, you find that everything is
connected to everything else." But until
recently, few comprehended the
implications of the naturalist's words.
Muir's message was graphically
illustrated just 20 years ago, when the
astronauts landed on the moon and
pointed their television camera buck at
earth. There it was: a pathetically small
ball of rock, spinning solitarily in vast
space, with 5 billion people clinging to
its surface—5 billion people completely
dependent for survival on the planet's
thin veneer of fragile, interdependent
resources.
It was three years more before the
message first found institutional
expression on a global scale in the 1972
United Nations Conference on the
Human Environment at Stockholm.
There 130 nations solemnly
acknowledged a mutual obligation in
maintaining a livable global
environment. They promulgated a host
of recommendations for steps that
should be taken. But they created no
comprehensive mechanism or procedure
for realizing the measures
recommended.
Some important measures have been
implemented. But meanwhile new
environmental problems with global
ramifications have surfaced faster than
problems have been resolved.
It has taken an ominously accelerating
succession of calamities, accidents, and
incipient crises—the diminishing
stratospheric o/one layer and the
Greenhouse Effect, Chernobyl and
Bhopal, desertification and
deforestation, famines and oil spills—to
remind us forcefully that the
implications of Muir's words as
reinforced by the astronauts' television
camera and the good intentions of
Stockholm have not been effectively
heeded.
EPA JOURNAL
-------
Muir Woods National Monument
is graced by 200-foot tall
redwoods.
An outer-space observer with
wondrous vision, scrutinizing the earth
in environmental terms, might see
something like the scattered pieces of a
jigsaw puzzle: myriad clusters of people
of assorted races, creeds, and colors,
frantically scrambling—in slow
motion—to put out environmental
brushfires (and, in the confusion,
igniting others).
We flatter ourselves on having
recognized, if belatedly, the
stratospheric ozone danger and having
taken collective steps to mitigate it; and
on having at least awakened to the
greenhouse threat. But we are still in a
reactive mode, avoiding collective
action until it is forced upon us. Despite
the repeated eruption of problems we
didn't anticipate, there is a palpable
chronic complacency—a delusion that
each exigency will he the last one, a
tacit assumption that there are no more
environmental shoes to drop.
A little reflection will suggest how
wrong this may be, for there is much
evidence that so far we have seen only
the tip of the iceberg of possible global
environmental problems:
• Before us lie large areas of ignorance.
We have no certainty of the degree of
ongoing contamination of the planet's
oceans; if ignored, it could suddenly
develop that their function of
revitalizing the air and supporting vital
food chains had been critically
impaired.
• We have no precise knowledge of the
impacts of the constant discharge of
hundreds of industrial and agricultural
chemicals on the earth's air, land, and
water.
• Nor do we know just how far we have
gone in upsetting, through extinctions,
the earth's primal balance of animal and
plant species.
• Through the use of pesticides and
antibiotics, we have engendered scores
of resistant species whose potential for
spreading disease and blight remains
unassessed.
• And .we have maintained a cavalier,
there's-no-tomorrow outlook regarding
the depletion of minerals and other
natural resources.
These are just a few of the more
obvious facets of the environmental
iceberg. They point to a scarcely
arguable need for concerted
international steps to envision, and
A global organization to
coordinate international action
against global threats would
seem to be an imperative ....
avert, major global environmental
perturbations.
Increasingly, one hears advanced the
view that environmental imperatives are
rapidly transcending armaments as the
pivotal element in security among
nations.
Looking in the Mirror
Although Americans tend to bask in the
notion that we are environmentally
progressive, in truth the United States is
in many ways a mirror of global
environmental problems—a story of too
little and too late, of disarray and
confusion, of human welfare treated as a
shuttlecock or left to the problematical
mercies of "the marketplace."
The United States did move quickly,
as the Environmental Revolution
dawned in the late 1960s, to enact
constructive measures: the epochal
National Environmental Policy Act,
laws to abate air and water pollution
and even noise, laws to deal with solid
waste, to protect wildlife, to save coasts
from degradation, and more. But the
ensuing years have painfully
demonstrated that environmental
quality is much easier sought than
achieved. Although we have been
spending roughly $85 billion a
year—$340 per capita—on pollution
controls, we are far short of our goals of
clean air and water. Disposal of
everyday solid waste has become a
nightmare. Raw sewage and worse
despoil our shores.
Meanwhile new problems have
continued to erupt—acid rain, the
discovery of thousands of toxic dumps,
radon, pesticide scares ....
Even while harboring pretensions to
leadership in international
environmental progress, the United
States has been contributing heavily to
environmental problems. For instance,
we exceed most nations in production
of chlorofluorocarbons, in per-capita
energy consumption, and in consequent
emissions of carbon dioxide (five tons
per capita compared to a worldwide
average of less than one ton).
The United States exemplifies the
worldwide conflict of interests standing
in the way of environmental reforms:
the conflict between professed desires
for environmental quality versus an
addiction to lifestyles that are
environmentally destructive in every
aspect from industrial activity to forest
destruction and the reckless use of
chemicals.
The recent controversy over the
pesticide Alar was a poor testimonial
concerning our regulation of chemicals.
Not only did the dispute raise
problematic questions about chemical
testing and risk assessment, but as
regulations presently are entangled, it
seems that a chemical that might be
summarily banned if newly developed
may be well-nigh impossible to dislodge
once it gets on the market.
While we are chiding other nations
for destroying forests, in the United
States we are stripping large expanses of
federal land for wood to sell to )apan.
Mining on public lands is governed by
the diaphanous provisions of a
117-year-old law—an exercise in
antiquity it would be hard to match in
Europe.
Lack of a coherent national energy
policy has contributed to problems
JULY/AUGUST 1989
-------
extending from the Alaska oil spill to
Detroit auto manufacturing, and from
acid rain in the Adirondacks to a
stymied nuclear power industry from
coast to coast.
For 20 years, ever since the Santa
Barbara oil spill, the oil industry and
federal authorities have been trumpeting
about technological and strategic
progress in oil spill control measures
and mechanisms. Yet when the crunch
came in Alaska, we didn't even have the
proverbial seven maids with seven
mops.
Last November a group of leading
organizations presented then
President-elect Bush with a list of no
fewer than 700 environmental matters
they said needed Executive attention.
One observer asked if such a list would
be any longer in Zaire.
The Nations Act
To date, the 1972 Stockholm conference
has been the world's closest approach to
collective action in dealing with
environmental problems. The 10-day
assemblage far exceeded the
expectations of many, while
disappointing the wistful hopes of
some.
Under the masterful helmsmanship of
Canada's Maurice Strong, the 130
participating nations formally assumed
responsibility for the earth's
environmental welfare and endorsed an
"Action Plan" of some 109 items to be
pursued. The Action Plan was long on
scope, but short on commitments. In
deference to national sovereignties, the
109 items largely were couched in terms
of "recommendations to governments,"
and many called simply for "studies" or
research.
Yet the concrete results were many.
They included programs for worldwide
monitoring of critical environmental
factors—the impetus for the current
apprehensions concerning the
stratospheric ozone layer and global
warming. Other Action Plan items set in
motion unprecedented scientific
collaboration, such as the teamwork
between American and Russian
specialists, which has grown steadily
without regard to diplomatic
vicissitudes. A "heritage" program was
initiated for preserving—on behalf of all
nations—sites and areas of unique
environmental significance. The
conference laid the groundwork for a
number of regional pacts for
ameliorating pollution of the
With environmental populism
gathering such momentum, it
seems only a matter of time,
and not too long a time, until
it brings significant changes in
national lifestyles....
Mediterranean, Baltic, and Caribbean
seas and other ocean areas.
The conference stopped short of
creating a permanent international
organization with authority to oversee
global environmental developments,
formulate collective policies, and exert
telling influence on implementation of,
and adherence to, such policies.
Yet conference organizers considered
it a signal achievement that
delegates—and later the United Nations
General Assembly—were persuaded to
create an ongoing agency to be some
sort of focus of international
environmental activities: the United
Nations Environment Programme
(UNEP).
Conspicuously deprived of muscle,
UNEP was placed under a 58-member
governing board bound to reflect the
tensions and schisms within the United
Nations itself. It was situated
inaccessibly in Nairobi, Kenya, and
given minuscule financing. (Its budget
recently has been around $30 million a
year—amounting to less than one cent
for each of the world's citizens whose
interests the agency is expected to
further.)
Given these limitations, UNEP has
functioned impressively. It has served
as an information clearing-house;
instigated progressive environmental
programs in selected areas; organized
multi-national collaboration on specific
problems; and strived to elicit
cooperation from the array of U.N.
affiliates such as the World Health
Organization and the Food and
Agriculture Organization that have
environmental overlaps.
Yet UNEP comes nowhere near
encompassing the collective concerns
and aims embodied in the Stockholm
conference -itself. In addition, UNEP is
not in a position to achieve vigorous
implementation of the Action Plan.
What Next?
A global organization to coordinate
international action against global
threats would seem to be an
imperative—an idea whose time has
long since come, albeit whose
realization has so far eluded us.
On the eve of the Stockholm
conference, the eminent Indiana
University environmental scholar, Dr.
Lynton Caldwell, foresaw a need for a
compact international council of no
more than 25 members, empowered to
delineate global environmental priorities
and policies. He suggested that such an
agency might well be under the aegis of
the United Nations. But Stockholm and
the ensuing years have indicated that
such an arrangement would simply
subject international environmental
initiatives to another layer of politicking
and to the United Nations' procedural
ponderousness.
Apart from the United Nations, it
seems most unlikely that the world's
nations will be disposed to cede
sovereignties to the degree necessary to
create any sort of global environmental
"super-agency" with definitive
authority.
But such a quantum leap may not be
necessary.
The problem of galvanizing,
coordinating, and integrating
international activities to cope with
global environmental threats suggests, in
EPA JOURNAL
-------
Aboui half of the earth's
rainforests, which provide
habitat for ocelots and many
other species, have been
destroyed by cutting and
burning. Such habitat losses,
together with illegal poaching
for fur, threaten the ocelot with
extinction.
Cart Hansen photo, SITES. Smithsonian Institution
massiveness and complexity, nothing as
much as the international effort
mounted in prosecuting World War II.
It may seem the height of irrelevance
or impracticaiity to suggest that the war
effort offers guidelines for the
environmental realm. But there are
common elements.
The war was pursued by the free
world in a classic autocratic pattern,
with policies dictated by national
leaders—principally Roosevelt,
Churchill, and Stalin—and the reins of
implementation extending mainly from
the desk of General George C. Marshall
in the Pentagon. That hardly is a model
that can be emulated in peacetime
affairs.
But let us look a little deeper. The
essential task in World War II was
harnessing and coordinating the efforts
of a wide assortment of Allied nations
and peoples, with widely disparate
parochial interests and capabilities.
There was no way these participants
could be geared into a united force
simply by military edict. It required
many forms of suasion, and the most
important ingredient of all: consensus
on the common goal of defeating the
Axis.
A consensus regarding environmental
protection and progress survived a test
flight at Stockholm. Since then, that
consensus has been gathering mass and
momentum at the grass-roots level
virtually every day.
The Green Light
In the last decade, a wave of
environmental populism has swept
across western Europe. Under the loose
generic appellation, "the Greens." the
movement has become an important
The Green Wave that is
changing the face of politics in
Europe nas the potential to do
the same thing in other parts
of the world....
political force in a score of nations,
drawing support from both the left and
the right.
Greens have been elected to
legislative bodies in West Germany,
France, Italy, Austria, Luxembourg,
Switzerland, Belgium, Finland, and
Portugal. Some 3,000 Greens have been
counted in the federal, state, and local
legislative bodies in West Germany
alone. "Environmentalists have become
Europe's most formidable and
best-organized pressure group," a
correspondent wrote in June.
In recent months both Prime Minister
Margaret Thatcher in Britain and
France's President Francois Mitterand
have been impelled to make
conspicuous leaps onto the
environmental bandwagon, convoking
conferences on-global problems and
making other genuflections to the cause.
"The environment has been rising
pretty steadily as one of the most
important issues facing Britain today," a
leading English pollster, Robert
Worcester, commented recently.
And Raymond Von Errnen, Secretary
General of the European Environmental
Bureau in Brussels, has said: "In every
one of the European Community
countries, the environment is a major
issue, and in every one it is growing."
Despite the long prevalence in
America of old-line organizations like
the Sierra Club and the Audubon
Society, the Green movement is getting
a portentous foothold in the United
States. Its original spawning ground in
New England is reported to have
expanded to 200 chapters throughout
the country. There is even a chapter in
the San Fernando Valley of Los Angeles,
often considered a bastion of bourgeois
materialism.
Currently the American movement is
eschewing the hard-ball political
activism of Europe in favor of
educational activities, promoting
"grass-roots consciousness." But
meanwhile some of the Green ideals are
being furthered in this country by
organizations such as the Los Angeles
area's "Tree People," recently honored
by UNEP for its overseas forestation
program, and Kansas City's "Trees for
Life," which has been planting fruit
trees in India.
"The nation once again is undergoing
the national soul-searching that
JULY/AUGUST 1989
-------
accompanied the first Earth Day in
1970," Russell Train said recently.
Train, former head of EPA and the
Council on Environmental Quality, is
chairman of the Conservation
Foundation and the World Wildlife
Fund. "Public concern," he continued,
"is so strong that we can be said to be
experiencing a fresh wave of
environmentalism. There is a sense that
pollution is inadequately controlled,
that natural systems are being degraded,
that we are generating more waste than
In the United States, we have
the machinery for
implementing the mounting
sentiment for environmental
progression. But some of it is
creaky, some obsolescent, and
some rusty.
we can handle, that chemicals are
creating dangers we can hardly
imagine."
In recent public opinion surveys, two
Americans out of three said they
believed that "protecting the
environment is so important that
requirements and standards cannot be
too high, and continued environmental
improvements must be made regardless
of cost."
With environmental populism
gathering such momentum, it seems
only a matter of time, and not too long a
time, until it brings significant changes
in national lifestyles that are
conspicuously inimical to
environmental quality. Such
conspicuous habits include demands for
gas-guzzling cars, a voracious pattern of
energy consumption, throwaway
consumerism, recreational vehicles
designed to ravage deserts, the equation
of growth with good, and all the rest.
The Green Wave that is changing the
face of politics in Europe has the
potential to do the same thing in other
parts of the world—knitting the political
muscle and consolidating the
all-important consensus.
The pollster Louis Harris has
ventured, on the basis of his evolving
opinion-sounding over the years, that by
1992 or 1996 the United States may
have a president "chosen and elected
with a pro-environment stance as his
primary identification."
Meanwhile, Squeaky Wheels
In the United States, we have the
machinery for implementing the
mounting sentiment for environmental
progress. But some of it is creaky,
some obsolescent, and some rusty.
The compartmentalized approach to
dealing with air and water pollution
U.S. Army photo.
and dealing with wastes which seemed
so logical in the 1970s is now widely
recognized as technically and
administratively a blind alley. Radical
revisions are needed to permit an
integrated attack on these problems.
In addition to its fragmented
legislative mandate, EPA is
handicapped by its implicitly
subordinate status in the federal
structure. The scope of its
responsibilities and concerns has
inexorably broadened to involve critical
dealings with all the principal federal
departments, and it needs equal,
cabinet-level rank with them.
Congress—the source of
environmental statutes and
financing—is a patchwork of
contradictions. In the mold of such
figures as Gaylord Nelson, Edmund
EPA JOURNAL
-------
The Normandy invasion. During World War
II, Allied nations mounted a massive,
coordinated effort to win against a shared
threat. An international mobilization of
another kind may be required to protect the
world environment.
Muskie, and the late Scoop Jackson,
its membership includes paragons of
environmental enlightenment. Two
decades ago, Congress acted with
dispatch to meet perceived
environmental imperatives. But since
then, in terms of collective action,
Congress has lapsed into a 19th-century
pace, dawdling for years in
unproductive wrangling over updating
environmental legislation, seemingly
having lost its sense of the pace of
national and international developments
and the pitch of public sentiment.
A legislative body that has
foot-dragged for seven years amending
the Clean Air Act will not recover its
due role in environmental progress until
it takes to heart the recent words of
Thomas E. Lovejoy, Assistant Secretary
at the Smithsonian Institution. Referring
to conditions worldwide, he said:
"Massive intervention in society is
required over a very short time
span—perhaps Jess than 10 years." (See
article on page 42.)
Finally, there is the Council on
Environmental Quality. Conceived as an
elite advisory body for the President
and Congress, it produced much of the
substance of the nation's initial burst of
environmental reform. But it has been
relegated to unheeded, faceless
obscurity, from which the national
interest demands that it be reactivated
as soon as possible.
A Test of Statecraft
If life on earth survives its current
travail, people will look back on the
present as the horse-and-buggy days of
environmental management, with global
activities ridiculously fragmented and
crises met with a succession of ad hoc,
panic-button, transitory coalescences of
effort.
"The recent quickening of
international environmental
conferences, treaties, and protocols and
of environmental speeches by world
leaders is an encouraging sign," Russell
Peterson, former head of the Council on
Environmental Quality and of the
National Audubon Society, said
recently. "But these are only words. We
need action. What needs to be done
worldwide is already known—use
energy more efficiently, develop
alternate sources of energy, plant trees,
recycle materials, further family
planning, practice more sustainable
agriculture, establish and support more
restrictive environment laws, presume
new chemicals guilty until proven
innocent. The resources to do the job
// life on earth survives its
current travail, people will
look back on the present as
the horse-and-buggy days of
environmental management..
are available. What is required is the
political will to allocate the resources."
In the 1988 State of the World report
of the Worldwatch Institute, Lester
Brown, a leading eco-economist,
estimated that the earth's current
environmental decline could be halted
with an international expenditure of
$150 billion a year—a fraction of the
world's $900 billion annual military
expenditures. But to do it, he added,
would call for "a wholesale reordering
of priorities, a basic restructuring of the
global economy, and a quantum leap in
international cooperation."
None of these requisites seems near to
realization. But to make a start, as
Russell Peterson noted, requires
"political will." And that is steadily
crystallizing under the pressures of
environmental populism and rapidly
broadening public comprehension of the
non-military threats to the earth's
security.
The New York Times reported from
Washington on May 15 that "the world's
deteriorating environment has become a
top economic concern of the United
States and other industrial nations,
along with Third World debt and trade."
William Nitze, the State Department's
top environmental official, says
environment "is now an issue of
consequence that has risen to the top of
the international agenda."
And Tennessee's Senator Albert Gore,
jr., told a recent Washington conference:
"In the not-too-distant future, there will
be a new 'sacred agenda' in
international affairs: policies that enable
rescue of the global environment. The
task will one day join with, and even
supplant, preventing the world's
incineration through nuclear war as the
principal test of statecraft."
An encouraging sense of urgency is
reflected in the United Nations' decision
not to wait for a traditional 25th
anniversary of the Stockholm
conference, but to convene a 20th
anniversary sequel in 1992 to take stock
of global problems and consider new
steps to deal with them.
Who can say that, considering the
recent upsurge in international
environmental concern, the world will
not be ready to consider a stronger
structure for international collaboration
than was envisioned in 1972? For each
year that passes brings added evidence
that the earth's thin mantle of resources
is not divisible into manageable bits and
pieces but must be dealt with as a unity
in which "everything is connected to
everything else." a
(Hill is the former national
environmental correspondent of The
New York Times. Copyright Gladvvin
Hill.)
JULY/AUGUST 1989
-------
The Greening of EPA
by William K. Reilly
Point Reyes National Seashore in California—symbolic
natural treasure. New thinking and new attitudes are i
protect our resources from environmental threats, many of
which are heedless of national boundaries.
EPA JOURNAL
-------
II future historians," predicts former
I National Security Advisor
Zbigniew Brzezinski, a careful observer
of international events, ''will almost
certainly hail the last years of this
century ... as a watershed in world
affairs."
As events in China, Russia, Eastern
and Western Europe, and Latin America
suggest, change—rapid, even
revolutionary change—has clearly
becorrifc the watchword for the closing
years of the 20th Century.
What do political changes of global
magnitude have to do with the
environment? Just this: as Dr. Brzezinski
points out, the breathtaking upheavals
in the world today present the United
States with an unprecedented array of
"challenges begging to be exploited as
opportunities."
And nowhere are these
challenges—and opportunities—greater
than in the-area of environmental
protection. People everywhere are
expressing concern over a deteriorating
global environment. The term "national
security" is being redefined to include
security from environmental, as well as
military, threats. Environmental issues
were highlighted at the recent Western
economic summit in Paris as never
before in the 15-year history of the
event. The environment, in other words,
has moved from the margins to the
mainstream.
What's more, our understanding of
environmental problems is changing. No
longer are our concerns over pollution
defined by geographic boundaries or
specific environmental media. Global
problems like the Greenhouse Effect,
deforestation, stratospheric ozone
depletion, and acid rain already are
beginning to usher in a new era of
cooperative international action.
What must we do, as individuals and
as a society, to meet the challenge of
political and environmental change in
the 1990s? Above all, we must be
willing to change—to adjust to the new
realities of our age, to think about the
environment from a fresh perspective, to
give up outmoded assumptions and
"black-hat, white-hat" preconceptions of
the past in favor of cooperative,
innovative approaches to environmental
protection. New ways of thinking about
the environment can lead to
significantly more effective ways of
protecting it.
A good place to start fostering these
new attitudes and approaches is right
here at EPA and at other institutions
New approaches to
environmental protection—like
market incentives and
pollution prevention—mean
that EPA, too, must change.
and organizations responsible for
protecting the global commons.
Government and private institutions
alike must begin to move beyond
traditional environmental protection
programs, which—despite past
successes—no longer offer solutions to
today's problems.
One example of a new approach that
shows great promise for enhanced
environmental protection is market
incentives, incorporated in President
Bush's recent proposal to amend the
Clean Air Act. The President's proposal
establishes tough standards and
deadlines for reducing emissions of
toxic chemicals and other pollutants. It
also contains a number of market
incentives that should encourage
industries to participate much more
willingly—and effectively—in pollution
control efforts.
Under the President's plan, the
private sector will have much of the
responsibility for defining how and
when harmful air emissions are cut. As
long as overall targets are hit, industry
is given considerable flexibility in
deciding, for example, if greater
emissions reductions should be made at
one plant in exchange for lesser
reductions at another.
This approach—combining traditional
"command-and-control" regulation and
vigorous enforcement with a flexible,
market-based system of incentives and
tradeoffs—can be applied to many other
issues besides clean air. Senators John
Heinz and Tim Wirth outlined many of
them last year in their comprehensive
"Project 88" report on market-based
environmental initiatives.
I find the market-incentive approach
especially appealing for two reasons: it
makes the private sector a partner,
rather than an adversary, in controlling
pollution and reducing environmental
risk; and it leverages the government's
limited resources by exploiting market
forces to achieve environmental goals.
Incentives also can be used to
advance another much-needed
approach: pollution prevention.
Programs to control pollution at its
source—be/ore it enters the environment
and becomes subject to traditional
end-of-pipe controls and cleanup—are
now a top priority at EPA.
Pollution-preventing ideas are beginning
to take hold throughout the
environmental and business
communities as their advantages in
reducing environmental and health risks
become more and more obvious.
Like the market-incentive approach,
pollution prevention offers both direct
and indirect benefits to participating
industries. Not only can it save a
company money by promoting
production efficiencies and reducing the
costs of hazardous waste disposal, but it
also can contribute to community
goodwill. What better message could a
plant send its neighbors than that it has
been able to reduce greatly the amount
JULY/AUGUST 1989
-------
of hazardous substances it uses and
releases into the community?
The movement toward pollution
prevention is complicated by the fact
that current environmental law tends to
require media-specific, if not
pollutant-specific, controls. Make no
mistake—laws like the Clean Air Act,
the Clean Water Act, the Safe Drinking
Water Act, and the Resource
Conservation and Recovery Act were
landmark achievements that have made
remarkable progress cleaning up the
environment over the past two decades.
But nearly 20 years' experience has
shown us that single-medium laws
based on containment and treatment of
individual pollutants have limitations.
They usually don't remove pollutants
from the environment, but merely shift
them from one environmental
medium—air, water, land—to another.
And current laws provide little or no
incentive for industries to develop
creative, cost-effective methods of
eliminating or reducing pollution at its
source, or to adopt environmentally safe
methods of recycling those pollutants
which cannot be eliminated.
The time has come to consider
applying market incentive/pollution
prevention approaches to environmental
programs across the board. With that in
mind, we are considering asking
Congress for limited authority to use an
integrated, multi-media approach to
reducing health and environmental
risk—one that would give EPA the
flexibility to look at a facility's total
emissions to all environmental media,
and then impose controls that would
result in the greatest risk reduction at
the least cost.
I know this is a controversial
proposal. Some environmentalists and
members of Congress may be
uncomfortable with the idea of giving
EPA the authority to waive pollution
controls set by law. Yet if EPA can show
that such an approach can reduce risks
and costs at the same time, then I
believe it is a proposal well worth
pursuing—especially if we see results
that would transform our understanding
of what will be needed to fight
pollution in the years ahead.
New approaches to environmental
protection—like market incentives and
pollution prevention—mean that EPA,
too, must change. We will have to
develop new skills, and broaden our use
of old ones, as we work in a climate that
emphasizes regulatory flexibility,
multi-media pollution prevention, and
decentralized decision-making.
For example, the ability to listen to
the public's concerns and to
communicate effectively with citizens
on issues related to environmental risks
and tradeoffs will become an
increasingly valuable attribute in the
EPA of the 1990s. Communication skills
also will be important as we increase
our emphasis on consumer
education—making individuals and
families aware of the environmental
risks of life in an industrial society. EPA
must improve its efforts to help people
understand how we all contribute to
pollution and what we can do to
eliminate it from our daily lives.
In this, we at EPA must serve as
examples as well as advocates. As we
urge citizens and communities to
separate and recycle their wastes in
order to relieve the pressure on our
nation's overburdened landfills, EPA
itself has to practice what it preaches.
Each of us has to participate in
Agency-wide efforts to recycle paper,
purchase recycled supplies, cut back on
the use of non-degradable products and
products with excessive packaging, and
so forth. What better place to begin
changing this country's "throw-away"
mentality than right here at EPA?
In short, my vision of EPA in the
closing years of the 20th Century
consists of two related images—a
clenched fist, representing our
continued emphasis on controlling
pollution and vigorously enforcing our
nation's environmental laws; and an
open hand, symbolizing our receptivity
to new ideas, our desire to work with
the public and other organizations to
develop new and better ways of
reducing environmental risk, and our
willingness to help citizens get the
information they need to protect
themselves and their families from
environmental risks in their homes and
communities.
A new EPA—an EPA that is equally
proficient at employing an open hand as
well as a clenched fist—will be well
prepared to respond to the momentous
changes taking place in the world
around us. And we will be well
prepared to exploit all the opportunities
those changes will bring, a
[Rettly is Administrator of EPA.)
10
EPA JOURNAL
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Tackling the
Institutional Barriers
by Jessica Tuchman Mathews
The following article is adapted from
Mathews' essay entitled "Redefining
Security," which appeared in the Spring
1989 issue of Foreign Affairs.
The 1990s will demand a redefinition
of what constitutes national security.
In the 1970s, the concept was expanded
to include international economics
Global developments now suggest the
need for another analogous, broadening
definition of national security to include
resource, environmental, and
demographic issues ....
Environmental strains that transcend
national borders are already beginning
to break down the sacred boundaries of
The majority of environmental
problems demand regional
solutions which encroach upon
what we now think of as the
prerogatives of national
governments.
national sovereignty, previously
rendered porous by the information and
communication revolutions and the
instantaneous global movement of
financial capital. The once sharp
dividing line between foreign and
domestic policy is blurred, forcing
governments to grapple in international
forums with issues that were
contentious enough in the domestic
arena ....
Individuals and governments alike are
beginning to feel the cost of substituting
for (or doing without) the goods and
services once freely provided by healthy
ecosystems. Nature's bill is presented in
many different forms: the cost of
commercial fertilizer needed to
replenish once naturally fertile soils; the
expense of dredging rivers that flood
their banks because of soil erosion
hundreds of miles upstream; the loss in
crop failures due to the indiscriminate
use of pesticides that inadvertently kill
EPRI Journal photo
insect pollinators; or the price of
worsening pollution, once filtered from
the air by vegetation ....
Moreover, for the first time in history
mankind is rapidly—if
inadvertently—altering the basic
physiology of the planet. Global changes
currently taking place are
unprecedented in both their pace and
scale. If left unchecked, the
consequences will be profound and,
unlike familiar types of local damage,
irreversible ....
Moreover, environmental decline
occasionally leads directly to conflict,
especially when scarce water resources
must be shared. Generally, however, its
impact on nations' security is felt in the
downward pull on economic
performance and, therefore, on political
stability. The underlying environmental
Arco Solar's Carissa Plains site, near San
Luis Obispo, California, is connected to the
Pacific Gas and Electric system. The author
calls for a 10-year U.S. energy policy aimed
at more efficient energy production with
less damage to the environment.
cause of turmoil is often ignored;
instead governments address the
poverty and instability that are its
results ....
Millions have been forced to leave
their homes in part because of the loss
of tree cover, the disappearance of soil,
and other environmental ills that have
made it impossible to grow food.
Wherever refugees settle, they flood the
labor market, add to the local demand
for food, and put new burdens on the
land, thus spreading the environmental
stress that originally forced them from
their homes. Resource mismanagement
JULY/AUGUST 1989
11
-------
is not the only cause of these mass
movements, of course. Religious and
ethnic conflicts, political repression,
and other forces are at work. But the
environmental causes are an essential
factor.
A different kind of environmental
concern has arisen from mankind's new
ability to alter the environment on a
planetary scale. The earth's physiology
is shaped by the characteristics of four
elements (carbon, nitrogen,
phosphorous, and sulfur); by its living
inhabitants (the biosphere); and by the
interactions of the atmosphere and the
oceans, which produce our climate.
Mankind is altering both the carbon
and nitrogen cycles, having increased
the natural carbon dioxide
concentration in the atmosphere by 25
percent. This has occurred largely in the
last three decades through fossil-fuel
use and deforestation. The production
of commercial fertilizer has doubled the
amount of nitrogen nature makes
available to living things. The use of a
single, minor class of chemicals,
chlorofluorocarbons (CFCs), has
punched a continent-sized "hole" in the
ozone layer over Antarctica, and caused
a smaller, but growing loss of
stratospheric ozone around all the
planet. Species loss is destroying the
work of three billion years of
evolution ....
Serious enough in itself, stratospheric
ozone depletion illustrates a worrisome
feature of man's newfound ability to
cause global change. It is almost
impossible to predict accurately the
long-term impact of new chemicals or
processes on the environment. CFCs
were thoroughly tested when first
introduced, and found to be benign.
Their effect on the remote atmosphere
was never considered.
The lesson is this: current knowledge
of planetary mechanisms is so scanty
that the possibility of surprise, perhaps
quite nasty surprise, must be rated
12
Louis J Mete photo. U.S. Forest Service
rather high. The greatest risk may well
come from a completely unanticipated
direction.
Absent profound change in man's
relationship to his environment, the
future does not look bright. Consider the
planet without such change in the year
2050. Economic growth is projected to
The United States, in
particular, will have to assign
a far greater prominence than
it has heretofore to the
practice of multilateral
diplomacy.
have quintupled by then. Energy use
could also quintuple, or if post-1973
trends continue, it may grow more
slowly, perhaps only doubling or
tripling. The human species already
consumes or destroys 40 percent of all
the energy produced by terrestrial
photosynthesis, that is, 40 percent of the
food energy potentially available to
living things on land.
While that fraction may be
sustainable, it is doubtful that it could
keep pace with the expected doubling of
the world's population. Human use of
80 percent of the planet's potential
productivity does not seem compatible
with the continued functioning of the
biosphere as we know it. The expected
rate of species loss would have risen
from perhaps a few each day to several
hundred a day. The pollution and toxic
waste burden would likely prove
unmanageable. Tropical forests would
have largely disappeared, and arable
land, a vital resource in a world of 10
billion people, would be rapidly
decreasing due to soil degradation ....
Happily, this grim sketch of
conditions in 2050 is not a prediction,
but a projection, based on current
trends. Like all projections, it says more
about the present and the recent past
than it does about the future. The planet
is not destined to a slow and painful
decline into environmental chaos. There
are technical, scientific, and economical
solutions that are feasible to many
current trends, and enough is known
EPA JOURNAL
-------
about promising new approaches to be
confident that the right kinds of
research will produce huge payoffs.
Embedded in current practices are
vast costs in lost opportunities and
waste, which, if corrected, would bring
massive benefits. Some such steps will
require only a reallocation of money,
while others will require sizable capital
investments. None of the needed steps,
however, requires globally unaffordable
sums of money. What they do demand
is a sizeable shift in priorities ....
But if the technological opportunities
are boundless, the social, political, and
institutional barriers are huge.
Subsidies, pricing policies, and
economic discount rates encourage
resource depletion in the name of
economic growth, while delivering only
the illusion of sustainable growth.
Population control remains a
controversial subject in much of the
world. The traditional prerogatives of
nation states are poorly matched with
the needs for regional cooperation and
global decision-making. And ignorance
of the biological underpinning of human
JULY/AUGUST 1989
Erosion in South Carolina. Soil erosion and
other kinds of resource depletion are not
taken into account in Gross National
Product calculations for the United States
or most other countries.
society blocks a clear view of where the
long-term threats to global security lie.
Overcoming these economic and
political barriers will require social and
institutional inventions comparable in
scale and vision to the new
arrangements conceived in the decade
following World War II. Without the
sharp political turning point of a major
war, and with threats that are diffuse
and long-term, the task will be more
difficult. But if we are to avoid
irreversible damage to the planet and a
heavy toll in human suffering, nothing
less is likely to suffice. A partial list of
the specific changes suggests how
demanding a task it will be.
Achieving sustainable economic
growth will require the remodeling of
agriculture, energy use, and industrial
production after nature's example—their
reinvention, in fact. These economic
systems must become circular rather
than linear. Industry and manufacturing
will need processes that use materials
and energy with high efficiency, recycle
byproducts, and produce little waste.
Energy demand will have to be met
with the highest efficiency consistent
with full economic growth. Agriculture
will rely heavily upon free ecosystem
services instead of nearly exclusive
reliance on man-made substitutes. And
all systems will have to price goods and
services to reflect the environmental
costs of their provision.
A vital first step, one that can and
should be taken in the very near term,
would be to reinvent the national
income accounts by which gross
national product (GNP) is measured.
GNP is the foundation on which
national economic policies are built, yet
its calculation does not take into
account resource depletion. A country
can consume its forests, wildlife, and
fisheries, and its minerals, clean water
and topsoil, without seeing a reflection
of the loss in its GNP. Nor are
ecosystem services—sustaining soil
fertility, moderating and storing rainfall,
filtering air, and regulating the
climate—valued, though their loss may
entail great expense. The result is that
economic policymakers are profoundly
misled by their chief guide.
A second step would be to invent a
set of indicators by which global
environmental health could be
measured. Economic planning would be
adrift without GNP, unemployment
rates, and the like, and social planning
without demographic indicators .. .
Among these new approaches,
perhaps the most difficult to
achieve will be ways to
negotiate successfully in the
presence of substantial
scientific uncertainty.
would be impossible. Yet this is
precisely where environmental
policymaking stands today ....
On the political front, the need for a
new diplomacy and for new institutions
and regulatory regimes to cope with the
world's growing environmental
interdependence is even more
compelling. Put bluntly, our accepted
definition of the limits of national
sovereignty as coinciding with national
boundaries is obsolete ....
The majority of environmental
problems demand regional solutions
which encroach upon what we now
think of as the prerogatives of national
governments. This is because the
phenomena themselves are defined by
the limits of watershed, ecosystem, or
atmospheric transport, not by national
borders. Indeed, the costs and benefits
of alternative policies cannot often be
accurately judged without considering
the region rather than the nation ....
Dealing with global change will be
more difficult. No one nation or even
group of nations can meet these
challenges, and no nation can protect
13
-------
itself from the actions—or inaction—of
others. No existing institution matches
these criteria ....
The United States, in particular, will
have to assign a far greater prominence
than it has heretofore to the practice of
multilateral diplomacy. This would
mean changes that range from the
organization of the State Department
and the language proficiency of the
Foreign Service, to the definition of an
international role that allows leadership
without primacy, both in the slogging
work of negotiation and in adherence to
final outcomes.
Above all, ways must be found to step
around the deeply entrenched
North-South cleavage and to replace it
with a planetary sense of shared
destiny. Perhaps the successes ofjhe
U.N. specialized agencies can be built
upon for this purpose. But certainly the
task of forging a global energy policy in
order to control the Greenhouse Effect,
for example, is a very long way from
eradicating smallpox or sharing weather
information ....
Today's negotiating models—the Law
of the Sea Treaty, the Nuclear
Nonproliferation Treaty, even the
promising Convention to Protect the
Ozone Layer—are inadequate. Typically,
such agreements take about 15 years to
negotiate and enter in force, and
perhaps another 10 before substantial
changes in behavior are actually _
achieved .... Far better approaches
will be needed.
Among these new approaches,
perhaps the most difficult to achieve
will be ways to negotiate successfully in
the presence of substantial scientific
uncertainty. The present model is static:
years of negotiation leading to a final
product. The new model will have to be
fluid, allowing a rolling process of
intermediate or self-adjusting
agreements that respond quickly to
growing scientific understanding. The
recent Montreal agreement on the
stratospheric ozone layer supplies a
useful precedent by providing that
one-third of the parties can reconvene a
scientific experts group to consider new
evidence as it becomes available.
The new model will require new
economic methods for assessing risk,
Einstein's verdict that "we
shall require a substantially
new manner of thinking if
mankind is to survive" still
seems apt
especially where the possible outcomes
are irreversible. It will depend on a
more active political role for biologists
and chemists than they have been
accustomed to, and far greater technical
competence in the natural and planetary
sciences among policymakers. Finally,
the new model may need to forge a
more involved and constructive role for
the private sector ....
International law, broadly speaking,
has declined in influence in recent
years. With leadership and commitment
from the major powers it might regain
its lost status. But that will not be
sufficient. To be effective, future
arrangements will require provisions for
monitoring, enforcement, and
compensation, even when damage
cannot be assigned a precise monetary
value. These are all areas where
international law has traditionally been
weak.
This is only a partial agenda for the
needed decade of invention. Meanwhile,
much can and must be done with
existing means. Four steps are most
important: prompt revision of the
Montreal Treaty, to eliminate
completely the production of
chlorofluorocarbons no later than the
year 2000; full support for and
implementation of the global Tropical
Forestry Action Plan developed by the
World Bank, the United Nations
Development Programme, the Food and
Agricultural Organization, and the
World Resources Institute; sufficient
support for family planning programs to
ensure that all who want contraceptives
have affordable access to them at least
by the end of the decade; and, for the
United States, a 10-year energy policy
with the goal of increasing the energy
productivity of our economy (i.e.,
reducing the amount of energy required
to produce a dollar of GNP) by about
three percent each year.
While choosing four priorities from
dozens of needed initiatives is highly
arbitrary, these four stand out as
ambitious yet achievable goals on which
a broad consensus could be developed,
and whose success would bring
multiple, long-term global benefits
touching every major international
environmental concern.
Reflecting on the discovery of atomic
energy, Albert Einstein noted,
"everything changed." And indeed,
nuclear fission became the dominant
force—military, geopolitical, and even
psychological and social—of the
ensuing decades. In the same sense, the
driving force of the coming decades may
well be environmental change. Man is
still utterly dependent on the natural
world but now has for the first time the
ability to alter it, rapidly and on a global
scale. Because of that difference,
Einstein's verdict that "we shall require
a substantially new manner of thinking
if mankind is to survive" still seems
apt. D
(Dr. Mathews is Vice President of the
World Resources Institute.)
14
EPA JOURNAL
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Let's Get Serious
about Pollution Prevention
by Barry Commoner
On January 19, 1989, a moment in
history marked by the end of the
Reagan Administration, then EPA
Administrator Lee M. Thomas published
a statement in the Federal Register that,
in future histories, is likely to
overshadow even Mr. Reagan's
departure. The Pollution Prevention
Policy Statement acknowledged that
much of EPA's past effort "has been on
pollution control rather than pollution
prevention" and that "EPA realizes that
there are limits as to how much
environmental improvement can be
achieved under these [control]
programs, which emphasize
management after pollutants have been
generated."
Mild as it sounds, this statement
actually calls for a major reorientation
of the nation's environmental programs,
for until now they have been based on
laws that trigger regulation only after
pollutants are produced. Prevention has
occurred rarely and only in response to
very special circumstances. It is
important, therefore, to examine the
justification for such a sweeping change
in policy, to understand how it relates
to the present regulatory program, and
to consider the actions required to
implement it.
The evidence concerning the
ineffectiveness of the present pollution
control program not only justifies the
new preventive policy, but demands it. I
presented a good deal of that evidence
in a speech given at EPA Headquarters
on January 12, 1988, entitled "The
Environmental Failure" as a means of
encapsulating the overall outcome of the
present control-oriented program.
Consider the existing data on the degree
to which the emissions of various
pollutants had been reduced over the
last 10-15 years. In nearly every case,
the improvement has been at best
modest—on the order of 10-20
percent—and, at worst (for example,
nitrate in ground water) negative. The
environmental levels of only a handful
of pollutants have been reduced 70-90
percent—the kind of improvement in
environmental quality envisioned in
environmental legislation.
Every pollutant on the very short list
of real improvements—airborne lead,
DDT and related pesticides, PCB,
mercury in the Great Lakes' fish, and
strontium 90—reflects the same
remedial action: production of the
pollutant has been prevented. Lead has
been largely removed from gasoline;
DDT and PCB have been banned;
chloralkali plants responsible for
mercury pollution have eliminated that
metal from their processing;
atmospheric nuclear bomb tests that
produce strontium 90 have been halted.
In each case, the production process
that originally generated the pollutant
The prevejnb'o/i strategy
recognizes that pollutants
originate in production
processes and that these must
be changed in order to
eliminate the pollutant.
has been changed. In the production of
gasoline, lead has been replaced by new
unleaded octane boosters; in cotton
production, where most DDT was used,
DDT has been replaced by other
insecticides; in transformer
manufacturing, PCB has been replaced
by new insulating fluids; in chloralkali
plants, semipermeable diaphragms are
now used in the electrolytic cells
instead of mercury. In sum, the
prevention strategy recognizes that
pollutants originate in production
processes and that these must be
changed in order to eliminate the
pollutant.
Alar, the treatment for enhancing the
marketability of apples, provides a
recent, particularly instructive example
of what prevention means. Like many
other petrochemical products, Alar
presents a health risk; it induces cancer
in test animals. As in many other cases,
there has been controversy about the
resultant hazard to people, especially
children, and about what standards
should be applied to limit exposure to
"acceptable" levels.
Alar broke out of this pattern when
the manufacturer, Uniroyal, decided
that regardless of the toxicological and
regulatory uncertainties, Alar would be
taken off the market simply because
parents were unhappy about raising
their children on apple juice that
represented any threat to their health.
Food, after all, is supposed to be good
for you.
This illustrates the advantages of
prevention; banishing Alar from apple
production reduces the cancer risk to
zero and puts an end to the technical
Kenneth Ga/rerr, Woodfrn Camp, fnc-
Plane spraying
pesticides. The ban
of DDT in 1972 is
cited by the author
as an example of
pollution
prevention. DDT
was once widely
used in spray
applications.
JULY/AUGUST 1989
15
-------
and administrative controversies. The
Alar story also illustrates the role that
public opinion can play in preventing
environmental hazards. Parents were
not inclined to argue about how much
Alar was tolerable; they wanted none of
it in apples, and Uniroyal responded by
an action to ensure exactly that.
Pollution prevention means less
environmental bureaucracy and more
environmental democracy. Pollution
prevention means identifying the source
of the pollution in a production process,
eliminating it from that process, and
substituting a more environmentally
benign method of production. Once a
pollutant is eliminated, the elaborate
system of risk assessment and standard
setting—and the inevitable debates and
litigation inherent in control-based
environmental regulation—becomes
irrelevant.
How can current environmental
programs, which, as EPA Administrator
Reilly has pointed out in recent
Congressional testimony, "stress
treatment and disposal after pollution
has been generated" relate to a program
of pollution prevention?
To the individual polluter, there is an
unavoidable conflict between
prevention and control; one course or
the other must be chosen. For example,
organic farming—agricultural
production without the use of
petrochemical pesticides and chemical
fertilizer—is a very effective way of
preventing the serious environmental
effects of these agricultural chemicals.
To the farmer, the choice between
prevention and control is unavoidable:
either the farm uses the chemicals,
subject to the present system of
regulation and controls, or it does not
use them and the entire administrative
control structure becomes irrelevant.
In the same way, a printing company
that wishes to prevent the
environmental hazards of the volatile
chlorinated hydrocarbon solvents used
to clean its presses can do so by
switching to water-based inks and
detergent cleansers. The company must
choose between controlling emissions of
the chlorinated pollutant, or eliminating
it by changing the printing process. Yet,
detergents are themselves
pollutants—albeit less hazardous than
chlorinated hydrocarbon solvents—and
Used aluminum
cans at this
Newark, New
Jersey, center
will be crushed
and reprocessed.
Recycling is an
important aspect
of pollution
prevention.
ALCOA photo
they too must be controlled. The next
preventive step might be to eliminate
the entire press-cleaning problem by
switching to a new, perhaps laser-based.
method of printing. Prevention is clearly
the preferable means of achieving
environmental quality; assiduously
applied, it can progressively reduce the
need for controls in the national
environmental program.
Mr. Thomas' statement and Mr.
Reilly's testimony emphasize recycling
as an important aspect of prevention.
The issue of trash disposal is an
illuminating example. In a sense, a
trash-burning incinerator is a control
device; it is a means of treating trash
after this pollutant has been generated
in an effort to reduce its environmental
impact.
Incineration itself involves a series of
controls: on incinerator stack emissions,
on the landfill to which the residual ash
is consigned, and on the landfill
leachate. By converting components that
would otherwise become trash into
useful materials, recycling prevents all
li,
EPA JOURNAL
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these pollution problems and eliminates
the need for such controls. And again, it
is necessary to choose between the
control strategy and the preventive one.
Some 80 percent of the trash
components can be either burned or
recycled, but obviously not both.
Moreover, as a recent pilot test done by
the Center for the Biology of Natural
Systems showed, 84 percent of the
household trash stream can be
recycled—a disposal capacity even
greater than that of the incinerator,
which is about 70 percent.
EPA has recently confronted the
choice between prevention and control
in trash disposal. This choice arose in
connection with a proposed
trash-burning incinerator in Spokane,
Washington. Opponents argued that
according to the Clean Air Act, the
facility must employ "best available
control technology" (BACT), which the
Act defines to include existing means
for the removal of potential pollutants
from fuel. In practice, this would mean,
for example, removing and recycling
nearly-all of the trash components, for
most of them contribute to the
pollutants generated by incineration.
Citing the Thomas statement, EPA
Region 10 agreed with this position and
referred it to the Administrator for
decision. He had a momentous
opportunity to signal EPA's turn toward
prevention by supporting the Region 10
position. Unfortunately, the decision
has given us the wrong signal.
Apart from legalisms, the decision to
disagree with Region 10 and deny the
petition makes only one substantive
argument: that the experimental
evidence does not support the
conclusion that separating potentially
polluting materials from trash will in
fact reduce toxic air emissions. The
experiment cited showed that removal
of metals and glass from trash clearly
reduced the toxic metal content of flue
gas be/ore it entered the emissions
control system. But the decision
concludes that the study does not show
"that there would be a reduction in
pollutant emissions had conventional
pollution control devices been in
operation."
This conclusion is unwarranted;
simple logic tells us that when the
amount of toxic metal entering a control
device is reduced, if it works, even less
will leave it. More serious is the
decision's failure to recognize a major
point in the Thomas statement: that
prevention avoids a serious fault in the
control strategy—the problem of shifting
pollutants from one medium to another.
This is precisely what an incinerator
emissions control system does: it shifts
heavy metals and other toxic materials
from emissions to the deposited fly ash.
Clearly this problem is avoided when
separation reduces the toxic metal
entering the incinerator. I am afraid that
this decision misconstrues the facts and
Evidently, the entry of the
prevention strategy into the
nation's environmental
program is not likely to be
particularly smooth or
un con tro versial.
seriously weakens the role of prevention
in EPA policy.
Evidently, the entry of the prevention
strategy into the nation's environmental
program is not likely to be particularly
smooth or uncontroversial. Another
example is President Bush's Clean Air
bill. Just before announcing the bill, Mr.
Bush proclaimed himself not only an
environmentalist but also a
preventionist. In reporting the
President's June 9 address, the
Washington Post said that "his goal will
be prevention, not just cleaning up,
environmental problems."
Yet a few days later Mr. Bush
announced that polluters will be
encouraged to buy and sell the right to
pollute. This is of course a perverse
parody of the "free market," in which
instead of goods—useful things that
people want—being exchanged, "bads"
that nobody wants are traded. Clearly a
market in pollutants cannot operate
unless the market is provided with what
it is supposed to exchange—pollutants.
This proposal not only fails to prevent
pollution but actually requires it. But
there are ways to prevent air pollution.
Smog was created when
high-compression engines were
introduced to power the large
post-World War II cars; running hot, the
engines generate nitrogen oxides which
trigger the photochemical smog reaction.
Preventing smog calls for new engines
that produce little or no nitrogen
oxides—for example, the stratified
charge engine or electric motors.
Applied to the acid rain problem,
prevention calls for energy conservation
and non-burn power sources such as
photovoltaic cells.
The most serious hindrance to the
prevention strategy is implementation; it
will be much more difficult to persuade
farmers and manufacturers to change
the way they grow corn or construct
automobiles than to attach controls to
their tractors or smokestacks. Current
methods of production are the
presumably profit-maximizing responses
to economic forces, and there will be a
good deal of resistance to changing
them.
This is a hurdle that can be
surmounted only by government action.
The federal government could overcome
the auto industry's resistance to
producing new kinds of cars and trucks
by specifying smog-free engines in the
$5 billion of vehicles it buys annually.
With that large an incentive, the engines
will surely be built and take over the
private market. Similarly, if the federal
government placed an order for some
$0.5 billion of photovoltaic cells to be
installed in government facilities, their
price would drop by more than 90
percent and open up a vast new market
for these pollution-free sources of
electricity.
As we approach the 20th anniversary
of the birth of environmentalism in
1970, it is fitting that we should review
what has been done and from it learn
how to improve the nation's thus-far
failing environmental record.
Reorienting the environmental program
toward prevention can assure that in the
next 20 years we can at last accomplish
the purpose set forth 20 years ago in the
National Environmental Policy Act:
"to promote the efforts that will
prevent or eliminate damage to the
environment and biosphere." D
(Dr. Commoner is Director of the Center
/or the Biology of Natural Systems at
Queens College, City University of New
York.)
Editor's Note: Dr. Commoner's speech,
"The Environmental Failure," given at
EPA headquarters on January 12, 1988,
as part of the Office of Radiation
Programs' Environmental Seminar
Series, will be one of eight speeches by
guest speakers included in a
forthcoming EPA publication.
JULY/AUGUST 1989
17
-------
Under the
Environmental Regulation
Layer Cake
by Arthur Koines
The distant traffic light turns a pale
green against the hazy afternoon sky.
A young attendant clad in a grey jump
suit waves the next car into the testing
area. The endless line of cars behind it
creeps forward like a lazy, summer
caterpillar. As I release the brakes, my
own car inches over the hot pavement
to close the space between it and the car
directly in front. Waves of heat rise
from the roadway, obscuring my view of
the instruction sign: "Put car in neutral.
Turn off air conditioning. Depress gas
pedal . . . ."
Rehearsing the test procedure helps to
pass the time momentarily, but after a
few practice runs, my mind wanders in
search of relief from the growing
boredom. Absent-mindedly, I tune in
the car radio to the news:
And in the national news today,
Environmental Protection Agency
Administrator William Reilly
expressed optimism about the
possibility this year of
reauthorizing the Clean Air Act . . .
The Clean Air Act. Those words
revive me with memories of simpler
times. I remember Earth Day 1970. We
stood in the warm, April sunshine to
celebrate the dawn of a new era of
environmental responsibility. The Clean
Air Act, enacted by Congress later that
same year, promised to improve some of
the nation's most visible environmental
problems.
. . . with tough, new requirements
for coal-fueled electric utilities . . .
Then, in 1972, Congress passed the
Clean Water Act to rescue the nation's
rivers and lakes from decades of neglect.
In 1974, the Safe Drinking Water Act
was enacted, and in 1976, the Resource
Conservation and Recovery Act.
In all, Congress enacted 10 major
environmental laws in the 1970s. State
legislatures throughout the country
followed quickly by passing their own
environmental laws empowering state
governments to manage the major new
environmental programs created by
federal legislation.
. . . and new technology standards
for industries emitting toxic
chemicals into the air . . .
The laws sought to protect our air,
water, and land from the excesses of a
modern society. But the administration
of those laws has fostered another
modern illness: a large, redundant
bureaucracy. Federal, state, and local
agencies were formed to implement the
laws. Countless pages of regulations
were written to sharpen the meaning of
the statutes for those who had to
comply with them. Thus the simple
intent of environmental laws found
expression in complex, new institutions.
The federal government kept a
vigilant eye on the actions of state and
local governments to ensure consistency
in the way federal laws were
implemented. The states, sensitive to
their own individual needs, chafed
INSPECTION STATION
Drawing by Bob Flanagan.
18
EPA JOURNAL
-------
under the federal yoke. Efforts at
defining and redefining the federal-state
relationship took precious energy away
from the common task of protecting the
environment.
. . . and construction sanctions for
cities unable to attain national
standards/or ozone ....
Today's environmental bureaucracy is
something of a Rube Goldberg
organization. It is most imposing when
viewed from the local level, where three
layers of law, regulation, and
bureaucracy vie for jurisdiction. For
example, here the individual person or
business discovers how a simple permit
request can involve red tape from
several government agencies.
The emissions testing area is now in
plain view. Succumbing to the heat, a
car in line ahead stalls out, bringing the
slow procession to a temporary halt.
After a couple of awkward minutes,
doors on two nearby cars swing open as
their drivers step out to help move the
disabled vehicle out of line.
The news continues:
And in local news, city officials
have expressed concern over the
limited capacity of the city's aging
municipal ivasteivater treatment
plant ....
Local economic growth has placed
increasing demands on environmental
services in some places; local economic
decline has eroded tax bases, causing a
shortage of funding for such services in
others. Local governments everywhere
are straining against the competing
social goals of economic development
and sustained environmental quality to
find the right balance for their own
communities.
With the planned phaseout of
EPA's construction grants
program, city officials must look to
local sources, such as tax
increases, to finance the future
facility.
Environmental protection is costly.
Much of the money for it comes out of
local government budgets and is used to
construct basic infrastructure for
providing environmental services. A
municipal waste incinerator can easily
cost a city $500 million to construct. A
public drinking water system for a
medium-sized city adds up to
construction costs of $100 million. Even
a small municipal sewage treatment
plant costs an average of $15 to $20
million.
Decisions concerning how to fund
these facilities and where to site them
are nearly always politically unpopular
and thus are avoided, if possible, by
elected officials. But delay has its own
costs. Today, it is common to find
municipal governments confronting
several such costly, politically sensitive
decisions. Twenty years of close federal
and state oversight has made local
governments reluctant environmental
decision-makers.
Only three cars are now ahead of me
in line. I can see the state insignia on
the sleeve of the jump suit worn by the
young, female attendant. I need be
patient only another few minutes.
The news continues:
And on the international scene,
President Bush today announced
plans for a conference of world
leaders to discuss deepening
concern over the apparent
warming of the earth's
atmosphere . • •
The changing global climate has
robbed us of our optimism about the
future. Public confidence has been
shaken by revelations of environmental
problems not even imagined by the
organizers of Earth Day 1970.
. . . which could cause a melting
of the polar ice cap and result in
future flooding of some major
coastal cities.
Who will find the wherewithal to
meet these new challenges? How can we
do a better job of addressing the old
ones? In a world of limited financial
resources, a decision to address one
environmental problem generally
implies a decision not to address
another. We can't do everything, yet we
try. We've stretched the fabric of
environmental protection in this
country so thin that it seems as if it
must soon come apart. Holes are
beginning to appear at the local level,
where bureaucracy, budget shortfalls,
and competing social goals have
combined to frustrate our efforts toward
improved environmental quality.
The traffic light turns a bright green. I
lift my foot from the brake pedal one
last time, allowing rny care to drift into
the testing area. Settling back in my
seat, I turn off the radio to enjoy the
crystal clarity of one final thought:
The system for providing
environmental protection is on
overload, and it isn't going to improve
on its own. Our episodic efforts as a
society to respond to environmental
threats have led to institutions lacking
in unified direction and efficient
organization. To improve them, we must
establish common environmental goals
and set realistic priorities.
It's time to get it together, and the
local level is a good place to start. After
all, here businesses live and die on the
implications of words printed in
environmental regulations; the average
American pays his water, sewer, trash
collection, and utility bills; and here 1
sit in line at the automobile emissions
testing station, o
(Koines is a Branch Chief in the
Regulatory Integration Division of EPA's
Office of Policy Analysis.)
JULY/AUGUST 1989
19
-------
Could There Be a Better Law?
by Frances H. Irwin
What if, instead of multiple
environmental statutes, there were
a single, comprehensive pollution
control law governing environmental
protection in the United States? Would
the institutional capacity of this country
to protect the environment be
significantly improved? To explore
these kinds of questions, and generally
to stimulate debate concerning more
integrated approaches to environmental
problems, The Conservation Foundation
has drafted a "model" law called The
Environmental Protection Act.
Let me make clear at the outset that
the model environmental statute is not
intended as a bill for proposal as such
to Congress. Rather, it is a working draft
document intended as a research tool
for exploring possibilities for
As the 200-page Act shows, it
is indeed conceptually
possible to deal with all forms
of pollution within the
framework of a single law.
restructuring environmental law. Partly
funded by EPA, the preparation of the
model statute is part of The
Conservation Foundation's New
Environmental Policy Project, which
concerns the nature and extent of
cross-media environmental problems
and how to deal with them.
Currently, separate laws govern EPA's
efforts to protect air, water, oceans, and
drinking water; to clean up waste sites;
and to regulate waste management
practices, pesticides and other toxic
substances, and noise. All of these
environmental responsibilities are
interrelated, as stressed in the
reorganization plan that first established
KPA in 1970; however, in the
intervening 20 years, the Agency's
separate program areas have each boon
strengthened under separate new laws.
Progress has in fact been made using
this approach. However, the
compartmentalization of environmental
programs has demonstrated drawbacks:
• There is a tendency, under separately
mandated programs, to transfer
pollutants from one part of the
environment to another, as opposed to
finding long-term solutions to
environmental problems or curtailing
pollution in the first place. Existing
laws frequently apply differing
standards to control the same pollutants
in different environmental media. In
other cases, a pollutant may be
controlled in some media but not others.
As a result, pollutants may be
"removed" to the least protected part of
the environment. For example, water
may be cleaned up by encouraging
volatile pollutants to evaporate into the
air; this practice has turned some
wastewater treatment plants into major
air polluters.
• New environmental problems are
generally not recognized and acted on
promptly because no one is responsible
for asking, for instance, what ultimately
happens to pollutants such as
chlorofluorocarbons, which we now
know deplete the ozone layer, or the
sulfur and nitrogen oxides that are
damaging forests and fisheries.
Moreover, existing problems may not be
adequately controlled because the
sources are not identified. For example,
deposition of pollutants from the air is a
significant source of pollution in many
bodies of water. Efforts to clean up
surface water pollution will inevitably
be unsuccessful unless this source is
taken into account.
• It is difficult to set priorities and
make budget decisions concerning
separate programs without a common
goal and common denominator for
comparing the potential of program
initiatives for protecting health and the
environment.
• Some existing research shows that
pollution controls for facilities, such as
a new coal-fired power plant, would
cost significantly less to construct and
operate if designed as part of a system,
rather than added on as an afterthought
to meet the separate requirements of air,
water, and waste control standards.
• The basic goal of protecting the
environment is sometimes lost in the
extraordinary complexities and
technicalities of the existing legal
structure. Each law establishes its own
procedures for collecting information,
granting permits, and taking
enforcement actions, for example.
The working draft of the
Environmental Protection Act proposes
ways to cut through the current
fragmentation of environmental statutes
in order to overcome basic obstacles to
protecting the environment. As the
200-page Act shows, it is indeed
conceptually possible to deal with all
forms of pollution within the framework
of a single law.
The Environmental Protection Act is
set up in terms of functions that include
research, information-collection and
monitoring, permitting, standard-setting,
and enforcement, for instance. These
are, of course, familiar components of
existing environmental laws, and to
some extent, the model law can be
considered a codification of existing
V
EPA JOURNAL
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Lake Mich 'itoyt Lakes are threatened not only by point- and nonpoint-source
water pollution, but aloO by the deposition of airborne pollutants originating hundreds
of miles away. A "cross-media" approach is therefore needed to solve the Great Lakes'
water quality problems.
laws. However, the model law combines
these provisions from different statutes
and, in the process, standardizes the
procedures governing, for example, the
gathering of information, the granting of
permits, and enforcement actions for
environmental violations.
In addition to standardizing
regulatory procedures, the model statute
includes provisions that would
encourage or require consideration of
the environment as a whole in all
decisions—regardless of how local or
media-specific the problem seems—in
an effort to alleviate compartmentalized
decision-making. To begin with, the
model law would establish a
Cabinet-level Department of
Environmental Protection, likewise
organized by pollution-control function.
EPA's current mission is a combination
of the goals of the disparate laws it
administers (which means that
functions such as research, for example,
are driven largely by the individual,
separately mandated programs). The
proposed Department of Environmental
Protection would have a single mission
to improve the overall quality of the
JULY'AUGUST 1989
environment as effectively and
efficiently as possible.
The Environmental Protection Act
proposes a single standard for all
environmental decisions, regardless of
the source or location of the
pollutant—making it less likely that
pollution would be simply shifted
among different parts of the
environment. The standard proposed is
"prevention of unreasonable risk," with
six factors to be considered when
applying this criterion to specific cases:
• Risk to humans and the environment
• Economic costs to society and the
distribution of those costs within
society
• Effects on technological innovation
• Existence of substitute products or
methods
• Feasibility of implementing proposed
actions
• Potential effects on other nations.
While this overall standard calls for
consideration of costs and benefits, the
model makes it clear that quantitative
Mike Brtsson phoJo
cost-benefit analysis would not be a
fixed formula for decision-making:
Nothing in this section shall be
construed as requiring the
Secretary [of the proposed
Department of Environmental
Protection] to perform quantitative
cost-benefit analysis. In exercising
the judgment necessary to decide
whether an action under this Act
should be taken, the Secretary
shall give the greatest weight to
the benefits of the proposed action.
To avoid "paralysis by analysis," the
proposal also gives the Secretary the
discretion to determine the amount and
type of analysis to be conducted for a
particular decision, in proportion to the
importance of the decision.
Consider, for example, how the
overall standard might apply to
decisions concerning point sources.
Limits on releases would be set for
various categories of point sources
based on the best technology to prevent
unreasonable risk from total releases
from the source. The factors considered
21
-------
in determining these limits would
include the best technology available,
the environmental impacts of applying
it, and the efficiencies that could be
achieved by considering the
relationships among all forms of
pollution.
The limits on releases from point
sources might be expressed in terms of
totaJ amount of a substance released (for
instance, the total number of pounds of
toluene released from a facility by all
pathways]; alternatively, the limits
might be expressed as amounts or
Highlights of "The Environmental Protection Act'
• A Cabinet-level Department of
Environmental Protection,
organized by function and with a
single mission: to improve the
overall quality of the environment
as effectively and efficiently as
possible
• One primary standard
(prevention of unreasonable risk)
for taking environmental action,
regardless of the source of the
pollutant or the location into
which it is discharged
• A shift from media-specific
concerns (e.g., air, water, solid
waste) to a broader focus on
releases to all media from the four
types of sources: mobile sources,
point sources, nonpoint sources,
and substances and articles
• A comprehensive, integrated
system for regulating substances
including new and existing
pesticides and other chemicals
« A single-permit system
governing permissible releases of
pollutants to all parts of the
environment for major facilities
• No permit issued unless the
applicant uses, to the maximum
extent practical, available methods
for reducing total releases to the
environment
• Integrated grant assistance to
state and local governments to
help deal with cross-media
environmental problems.
22
Netherlands Board of Tourism photo.
concentrations discharged into
particular pathways (pounds released to
air). A combination of these approaches
might also be used. In any case, the
limits would be applied to a facility
through a single permit, rather than by
separate permits for air, water, and
waste releases.
There is also a provision in the model
law that would give some force to
pollution reduction. This proposal
would make the issuance of a permit for
environmental releases contingent on a
finding that the applicant was using, or
would use to the maximum extent
practical, the available pollution
reduction methods.
In another significant change, the
model act would make it illegal to
discharge any pollutants without a
permit unless the pollutants or source
have been explicitly exempted from
regulation.
Under the model law, nonpoint
sources would be controlled through
management programs developed by the
states. The nonpoint source pollution
control programs called for by the
Environmental Protection Act are
somewhat similar to the programs
mandated by the 1987 amendments to
the Clean Water Act, except that all
media are covered, not just water. The
EPA JOURNAL
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The Netherlands and other European
countries are developing and experimenting
with integrated approaches to
environmental problems. Rather than
focusing separately on air, water, and
waste, the Netherlands has adopted an
integrated planning process focusing on the
sources of pollution in ail environmental
media.
management programs would identify
types or categories of nonpoint sources,
best management practices for dealing
with them, and means for achieving
these practices—such as enforcement
and technical assistance.
Under the model law's provision
concerning high-risk or persistent
pollutants, standards could be set
limiting the total amount of a particular
substance, such as a metal, permitted to
enter the environment. The limit could
be zero or background level; it might be
set on a geographical basis or made to
apply to particular sources; limits could
also be set in terms of allowable
concentration in a particular
environmental medium.
It is important to point out that the
Environmental Protection Act does not
exist in a vacuum. For the immediate
prospect, certain initiatives take steps
toward achieving a more integrated
approach to environmental issues in the
United States. For example, legislation
has been introduced in Congress which
would mandate waste reduction defined
in terms of all media. Also, EPA is
looking at options for improving its
enforcement by developing more
consistent procedures across program
lines. And following the
recommendation of a recent report, a
significant amount of research is likely
to be targeted to overall risk-reduction
across media.
Obviously, fundamental change in
U.S. environmental law will not occur
overnight; rather the prospects for such
change are longer-term. In 1969,
concerns about the inability of the
existing system to solve pressing
environmental problems led The
Conservation Foundation to sponsor the
Law and Environment Conference that
helped give impetus to the development
of environmental law. One indication of
the need for rethinking the field 20
years later comes from a recent survey
of environmental law professors. Those
who teach environmental law believe
that efforts enmeshed in the details of
the present laws, such as the Resource
Conservation and Recovery Act and the
Superfund law, are failing to address
the fundamental causes and cures of
environmental problems.
Moreover, in rethinking existing
systems, we need to think globally, not
just nationally. The World Commission
on Environment and Development and
the Organization for Economic
Cooperation and Development have
both identified the fragmentation of
institutions as an obstacle to effective
environmental protection worldwide.
The European Community noted the
same problem in its fourth
Environmental Action Programme.
Changes are now occurring in Europe.
For instance, the United Kingdom is
introducing legislation that would apply
"best available technology not entailing
Consolidating
Environmental Laws
The integrated statute drafted as a
research tool by The Conservation
Foundation consolidates
provisions from the following
laws:
• The Clean Air Act
• The Clean Water Act
• The Safe Drinking Water Act
• The Comprehensive
Environmental Response,
Compensation, and Liability Act
("Superfund"), as amended by the
Superfund Amendments and
Reauthorization Act of 1986
• The Resource Conservation and
Recovery Act
• The Federal Insecticide,
Fungicide, and Rodenticide Act
• The Toxic Substances Control
Act
• The Marine Protection,
Research, and Sanctuaries Act
• The Noise Control Act.
excessive cost" for pollutants released
from major facilities to all media. The
Netherlands has developed an
integrated planning process that focuses
on the sources of environmental
problems and their effects, rather than
separately on air, water, and waste. The
Netherlands is also experimenting
further with integrated permitting.
Under the Swedish Environmental
Protection Act, the Swedes already
control pollutants at major facilities
through single permits, rather than
multiple permits governing allowable
releases into specific media.
In the Federal Republic of Germany,
some lawyers are exploring the
longer-term possibility of an
environmental code based on
Vorsorgeprinzip, the principle of
foresight or precaution.
In closing, let me emphasize again
that the Environmental Protection Act is
a working draft, intended to propose a
framework for restructuring and
integrating pollution control laws. As
such, it helps in overcoming the first
obstacle to the status quo: the
conception of alternatives to the present
fragmented system. Pilot projects
implementing some of the model
statute's proposals on an experimental
basis, such as single permits instead
of multiple permits governing
environmental releases, could help
overcome a second obstacle: a lack of
data on the application of integrated
environmental programs in the real
world. Q
(Irwin is a Senior Associate with The
Conservation Foundation's
Environmental Quality Program.]
JULY/AUGUST 1989
23
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EPA and the World
Clean-up Puzzle
by James Gustave Speth
Twenty years ago, the U.S.
government responded vigorously to
a rapidly growing public concern about
the environment. New national policies
were declared; EPA and other agencies
were created; and major pollution
clean-up and resource management
initiatives were launched.
It is customary to think of that fertile
period as giving birth to modern
environmentalism in America, but that
is only partly true. The period from the
mid-1960s to the mid-1970s also
represented something else: a shift in
environmental initiative from the state
and local level to the national level. The
focus of leadership changed because the
environmental challenges of the day
could only be tackled successfully on a
national basis.
Today, we are seeing a remarkably
similar surge in environmental interest.
Once again, the media are full of stories,
and environmentalists are full of
proposals. But there is a basic
difference. Today the shift in attention
is from the national level to the
international.
The environmental concerns now
gaining prominence encompass the
life-supporting systems of the planet's
biosphere. They include the alteration
of climate and biogeochemical cycles,
the destruction of earth's ozone shield,
the loss of tropical forests and
biodiversity, the spread of traditional
pollutants beyond urban-industrial areas
and across national borders, and the
erosion of the natural resource base in
developing countries. Increasingly,
environmental concerns are
transcending national laws and are
intersecting international economic and
security interests in powerful ways.
The emergence of environmentalism
in recent decades—first local, then
national, and now international—has
much to do with the successes and
failures of economic activity. The 20th
Century has witnessed explosive
growth. World population has tripled to
five billion, and today's world economy
is 20 times larger than in 1900.
One result is that pollution and waste
generation are occurring on a vast and
unprecedented scale. Global fossil fuel
use, for example, has increased ten-fold
in this century, and the resulting
emissions have likewise grown: sulfur
dioxide, six-fold; nitrogen oxides,
ten-fold; carbon dioxide, ten-fold.
Meanwhile, human demands on
biological systems have grown to the
point that we consume about 40 percent
of the world's total terrestrial
photosynthetic productivity, and much
of this is occurring in a way that is not
biologically sustainable. For the first
time, human impacts have grown to
approximate those of the natural
processes that control the global
life-support system.
The future could hold more of the
same—a lot more. The scale and
momentum of economic activity on the
planet today are difficult to
comprehend. It took all of human
history to grow to the $600-billion
world economy of 1900. Today the
world economy grows by more than this
amount every two years. By the middle
of the next century, a scant lifetime
away, our human world of five billion
people will likely double to 10 billion,
and our global economy of $12 trillion
likely will be five times as large as
today.
Societies near and far have set two
long-term goals for themselves—
improving environmental quality and
achieving large increases in economic
activity. Reconciling these two goals
will be one of the dominant
USDA photo.
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challenges facing political leaders on all
continents in the 1990s and beyond.
The United States should be a leader in
meeting this challenge, but whether we
lead or follow, we will have to respond.
For EPA, this new reality will require
major changes in two areas:
international activities and technology
transformation.
International Activities
Several factors are pushing
environmental concerns increasingly
into the international arena. More and
more, pollution is transboundary and
even global in scope. Pressures on
shared resources, such as river basins
and coastal fisheries, are mounting.
Resource deterioration in many nations
is so extensive that other countries are
affected, for example, when ecological
refugees flee across borders. As
international trade increases,
commodities and merchandise become
the carriers of domestic environmental
policies that must be rationalized.
It is not just that there are more
environmental problems like ozone
depletion that must be dealt with at the
international level; it is also that the
line between national and international
environmental problems is fast
disappearing.
Nitrogen oxide emissions, for
example, must be regulated locally
because of ground-level ozone
formation, regionally because of acid
rain, and globally because ground-level
ozone is an infra-red trapping
"greenhouse" gas. Methane and,
indirectly, carbon monoxide also
contribute to the Greenhouse Effect.
In these instances, domestic and
global environmental concerns push in
the same direction. On the other hand, a
major move to methanol as a substitute
for gasoline could increase the global
warming risk. A car burning methanol
made from coal would result in perhaps
twice the carbon dioxide emissions per
mile as one burning gasoline.
Environmental diplomacy is the
logical outgrowth of the desire to
protect one's own national environment,
to minimize environment-related
Erosion control on an Iowa farm: When
corn is planted in the residue of last year's
soyoean crop, no tilling is required. The
author proposes a special panel to
recommend ways in which major sectors of
the economy, such as agriculture, might be
redesigned to meet economic needs
without degrading the environment.
conflicts with other countries, and to
realize mutual benefits, including
economic progress and the protection of
the common natural heritage of
mankind. As such, it is not entirely
new. The register of international
conventions and protocols in the field
of the environment has grown steadily
in this century: the main multilateral
treaties today number about 100, many
of them having to do with the
protection of the marine environment
and wildlife.
What is new is the prospect that
environmental issues will move from a
secondary to a primary international
concern and increasingly crowd the
diplomatic agendas of nations. And
these diplomatic agendas in turn will
increasingly affect domestic
environmental policy. U.S.
environmental policy will more and
more be set in concert with other
nations.
It is not fully discernible what the
challenge of "internationalization"
means for EPA in practical terms.
Eventually, major policy and
institutional innovations will be
required. Certain preliminary initiatives
seem highly desirable, though.
Elevating the head of EPA's Office of
International Activities to Assistant
Administrator status was a
commendable step in the right
direction. Efforts to give international
dimensions a higher priority within the
Agency should continue. Even more
important is ensuring that domestic and
international activities are actually
coordinated internally.
EPA also needs a world-class capacity
to follow relevant developments in
other countries and in international
institutions, to understand and analyze
the various approaches to
environmental protection being taken
abroad, and to anticipate future needs
and developments at the international
level.
Beyond EPA's internal workings, new
patterns of relating to other federal
agencies seem desirable. Neither global
nor local atmospheric issues are likely
to be solved unless energy and
environmental policy are made together
in the future. As environmental
diplomacy increases, finding
appropriate patterns of interaction with
the Department of State will become
imperative.
Moreover, the future is likely to bring
increasing efforts to link environmental
objectives and trade policy. For
example, should the United States
restrict imports of products that are
manufactured by processes that harm
the environment, much as we restrict
imports of endangered species and
harmful products? Should we import
copper from countries where smelters
operate without serious pollution
control?
Much of EPA's international activity
in the past has focused on the
Organization of Economic Cooperation
and Development and other
trans-Atlantic matters. In the future, the
North-South and East-West dimensions
will rival the North-North ones in
importance. It already seems clear that
solutions to the most serious global
environmental challenges will require a
series of vital understandings between
the industrial and the developing
countries.
For example, the developing countries
will expect the industrial countries to
take the first and strongest actions on
global warming. They will want to see
the seriousness of the threat validated,
and they will conclude, quite correctly,
that the industrial countries are largely
responsible for the problem and have
the most resources to do something
about it.
But a tragic stalemate will occur if
this argument is carried too far.
Developing countries already account
for about a fourth of all "greenhouse"
gas emissions, and their share could
double by the middle of the next
century. Increasingly, all countries will
be pressed to adopt energy and forestry
strategies that are consistent with
containing the Greenhouse Kffoct within
tolerable limits.
The United States and EPA need to
build a new set of relationships with
developing country officials so that
confidence and trust are built for the
challenging times ahead. One major step
in this direction would be for the
United States to initiate a new program
of international environmental
cooperation with developing countries.
Such a program would not be limited
to AID-eligibla countries but would
extend to countries like Brazil and
Mexico. It would provide technical
assistance, training, access to
information and expertise, and planning
grants all aimed at increasing the
capacity of developing countries to
manage their environmental challenges.
EPA should also begin to think
creatively about how international
environmental regulation should be
done in the future. The ad hoc
processes that have led to the
JULY/AUGUST 1989
25
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stratospheric ozone layer convention
and other agreements will need
eventually to be replaced by a more
expeditious, permanent mechanism that
can function across a broad range of
issues.
It is interesting to ask whether the
evolution of environmental
decision-making in the European
Community offers lessons for other
contexts. What happened in Europe,
where both economic integration and
transboundary pollution led to
coordinated environmental policies, is
actually happening more slowly on a
world scale as the world economy
expands and becomes more integrated.
Technology Transformation
A second major challenge is for EPA to
organize to promote rapid and
far-reaching technological change.
Imagine, just as a simple thought
experiment, what would happen if
"greenhouse" gases, industrial waste,
and other pollutants increased
proportionately with the five-fold
expansion in world economic activity
projected for the middle of the next
century. That would indeed happen if
this growth merely replicates over and
over today's prevailing technologies,
broadly conceived.
Seen this way, reconciling the
economic and environmental goals
societies have set for themselves will
occur only if there is a transformation in
technology: a shift, unprecedented in
scope and pace, to technologies—high
and low, soft and hard—that facilitates
economic growth while sharply
reducing the pressures on the natural
environment.
We need the technology for a new
agriculture, one redesigned to be
sustainable both economically and
ecologically, which stresses low input of
commercial fertilizers, pesticides, and
energy. And we need new technology to
transform industry and transportation
from an era of materials-intensive,
"high-throughput" processes to an era
that uses fuel and material with great
efficiency, generates little or no waste,
recycles residuals, releases only benign
products to the environment, and is,
hence, more "closed."
Guiding and speeding the application
of solution-oriented technologies will
also require institutional innovation at
EPA. What if EPA were organized not
strictly by air pollution, water pollution,
pesticides, and so on, but by
transportation, manufacturing,
agriculture, energy, and housing? These
great sectors of economic services are
technology-based and
technology-driven. In the past EPA has
tended to stand "outside," imposing
external pollution control standards.
In the future, EPA must come
"inside," and environmental factors
must be integrated into the basic design
of our transportation, energy, and other
systems. A new type of cooperation
among the private sector, EPA,
traditional Cabinet agencies, and
environmental advocates must be
formed. Together, we must work
upstream to change the products,
processes, policies, and pressures that
give rise to pollution.
IF THETEVER
FIX THE
INTH
To start this process, the President
and EPA could establish a distinguished
panel from within and outside
government to recommend long-term
goals for meeting the following
challenge: how can the major sectors of
the U.S. economy—manufacturing,
agriculture, transportation, housing, and
energy—be redesigned in the years
ahead so that they fulfill economic
needs without destroying our national
and global environments?
What are the critical technologies in
each sector, and how can they be
further developed and promoted? The
panel would examine what America's
longer term goals should be in these
areas, and it would explore how "seeing
the future" can be used to enhance
American exports and promote other
national goals.
A new federal center associated with
EPA could be created to work as a
catalyst within the federal system and
between government and the private
sector. The center would have a policy
research budget and would carry out a
variety of research, convening,
coordinating, and educating functions. It
would try to define a series of win-win
options and stimulate public and
private action to promote these options.
Alternatively, EPA could create an
Assistant Administrator for Technology
and Strategy with a staff of scientists,
engineers, business managers,
economists, and others organized by
economic sectors. Similar offices should
be established in other federal agencies
and given mandates to cooperate with
EPA in promoting patterns of
environmentally sustainable
development.
Environmental protection began as a
local and national concern, but the
challenges ahead are such that it must
become a major international concern as
well. It began on the periphery of the
economy, bottling up some pollution
here, saving a bit of landscape there, but
it must spread a creed and code to the
core of economic activity. By moving
ahead to address these new realities,
EPA can perform an immense public
service, n
(Gus Speth is President of the World
Resources Institute, an environmental
research and policy institute in
Washington, DC.J
Repttnted by permission Tribune Media Services
EPA JOURNAL
-------
From a "Polluter's" View
by John W. Rowe
Few industries have been more
directly affected by environmental
laws and regulations than the electric
utility industry. The industry's power
plants and generating units burn large
quantities of fuel and produce
significant amounts of pollutants, but
they deliver a particularly useful form
of energy to homes and businesses
across their service areas.
A natural target for pollution control
strategies and environmental
regulations, utilities have been called
upon to make and have, in fact,
achieved a significant contribution to
improving the environment since major
environmental legislation was first
If we are not careful, we may
find ourselves spending more
and more on environmental
controls for less and less
benefit, without fully
addressing the key
environmental issues of the
day.
enacted 20 years ago. Our experience at
New England Electric indicates that the
integration of energy-conservation
programs with the more traditional,
technological approaches to emissions
reduction can be an important means
for achieving President George Bush's
recently enunciated clean air goals.
Over the past 20 years, the record of
New England Electric illustrates the
kind of commitments required to
achieve environmental goals. Before
1970, we burned coal at several
generating stations. When the Clean Air
Act was passed, we switched to oil to
achieve lower costs and compliance
with air emissions regulations. But after
the oil price shocks of the 1970s, we
converted the units back to coal and
spent more than half of the $300 million
investment involved on new pollution
control equipment. As a result, we are
burning coal with significantly lower
particulate and sulfur emissions than
we emitted with oil.
Our experience was an economic and
environmental success, but it also
illustrates a flaw in the current
approach to environmental regulation.
Under this approach, the primary
regulatory objective has been to
minimize emissions levels at individual
point sources by using costly technology
to capture emissions "at the end of the
pipe."
In general, environmental costs have
been factored into project decisions by
utility companies only insofar as the
company's compliance strategy required
additional investments or operating
expense outlays. Moreover, the
regulatory standards in existing
environmental laws tend to result in
increased investment or expense
associated with each emissions
source—to the point where any
economic benefits of an individual
proposal are sharply limited, even if the
proposal would reduce emissions over
existing facilities.
But the environmental foCus is now
beginning to shift away from
point-source controls to the total impact
The New England Electric System has
designed energy conservation programs to
provide customers with the same electric
service while using fewer kilowatt-hours.
One method includes installing
energy-efficient lighting in customer
buildings, a practice pictured here.
of emissions on the atmosphere. At the
same time, technological, point-source
solutions are running headlong into the
law of diminishing returns. If we are not
careful, we may find ourselves spending
more and more on environmental
controls for less and less benefit,
without fully addressing the key
environmental issues of the day.
A new approach to today's
environmental issues may be necessary.
We need to move from the present
solution of minimizing emissions from
specific sources to minimizing
emissions from the mix of sources used
to provide electric service.
President Bush's approach to acid
rain appears to move in the right
direction with its focus on a least-cost
concept that maximizes flexibility in the
way emissions reductions are achieved
and expressly rejects a "command and
control," end-of-the-pipe approach to
the acid rain issue. Moreover, the
JULY/AUGUST 1989
27
-------
President's program acknowledges the
impact that conservation and
load-management programs can have in
meeting our national acid rain goals and
other environmental objectives.
Over the past several years, New
England Electric has implemented major
conservation and load-management
programs to provide our customers the
same electric: service with fewer
kilowatt-hours. Under these programs,
we pay the costs of new conservation
measures in the homes, factories,
schools, and businesses across our
service territory. This year alone, we are
spending about $40 million to install
energy-efficient lights, insulate water
heaters, improve industrial efficiency,
and weatherize electrically heated and
cooled buildings.
By 1991, we expect our programs to
save 300 megawatts of power required
to meet peak demands. Over the next 20
years, conservation should save over
1,000 megawatts of capacity and meet
one-third of the load growth projected
in our service territory.
These programs will provide our
customers the same electric service they
now receive, but with fewer
kilowatt-hours. And, they will provide
the same electric service with reduced
emissions into the environment.
The emissions savings are impressive.
For example, one energy-efficient light
bulb saves about 400 pounds of coal or
one barrel of oil over its lifetime. Bv
New England Electric photo.
introducing such conservation measures
to our customers, we will produce
significant environmental benefits
throughout New England.
These conservation-related emissions
savings have not been taken into
account under the traditional approach
to environmental regulation. These
emissions reductions have not been
credited by the regulatory process, so
their environmental benefits would not
be seen as creating economic savings in
an emissions control compliance
strategy. Thus, the true economic and
environmental value of such programs
has been understated. To achieve our
environmental goals more efficiently,
the new regulatory approach should
provide the incentives and flexibility
necessary to encourage reduction of
total emissions in the overall plan, not
just at specific point sources.
This kind of approach is now being
tried in Massachusetts. Under the state's
acid rain law and recently issued
regulations, utilities are allowed
emissions credits for
conservation-related reductions as we
work to achieve state-imposed acid rain
compliance targets. We understand that
the Bush administration is considering
allowing meaningful credits for
demand-side programs that may provide
real economic benefits to utilities for
conservation programs in their
compliance plans. Such credits will
provide the power industry with the
direct economic incentives necessary to
achieve the nation's environmental
objectives most efficiently.
The President also has correctly
rejected the fee approach suggested by
Since 1979, the New England Electric
System has employed load management
and conservation programs in its
three-state service area. Here, a
representative of the company's ' Partners
in Energy Planning" program wraps a
home water heater.
some in the ongoing acid rain debate.
Customers of the New England Electric
system companies, for example, should
not have to pay to clean up other
utilities' emissions, particularly when
they have already supported our
company's environmental investments.
Moreover, those evaluating future
expenditures on control projects should
include all costs of control in their
attainment strategies. Subsidies for
certain environmental investments, but
not others, tends to encourage bias
toward expensive end-of-the-pipe
solutions. By reflecting the full value of
demand-side conservation and
load-management programs and by
avoiding subsidization of costly
controls, we can assure that all parties
have the flexibility and incentive to
accomplish emissions targets efficiently
and effectively. This is especially
important when investment in
conservation efforts may well avert a
much greater investment in high-priced
technology.
In sum, we must do a better job of
integrating economic and environmental
objectives in our overall resource
planning. This can be achieved by
establishing overall emissions targets
and allowing flexibility in resource
decisions to achieve these targets, rather
than simply adding more capital
investment at the end of the pipe.
By creating a system of credits for
energy conservation programs, we can
assure that the economic and
environmental values of such efforts are
reflected in our resource plans. This
strategy will allow utilities to achieve
environmental targets through
investments in conservation that
provide better service to our customers
rather than end-of-the-pipe controls that
only add costs to our products. 'J
(Rowe is President and Chief Executive
Officer of the New England Electric
System.)
28
EPA JOURNAL
-------
Next Steps
the States Could Take
by Robert Bendick
During the medical waste scare of the
summer of 1988, a prescription
bottle that had washed up on a Rhode
Island beach was turned in to the State
Health Department. The bottle was one
of few such items of medical refuse that
displayed legible printed information,
and criminal investigators from Rhode
Island's Department of Environmental
Management were able to trace it to a
woman in the Borough of Queens in
New York City. The investigators hoped
that the woman would remember where
she had disposed of the bottle and that
this information would lead them to a
waste hauling firm, hospital, clinic, or
other culpable entity that had dumped
medical waste in the Atlantic Ocean.
The woman from Queens must have
been astonished when detectives
confronted her with questions about a
seemingly ordinary item of garbage. To
everyone's dismay, however, she was
unable to shed light on how the pill
bottle had ended up in the Atlantic.
In retrospect, the investigation of the
pill bottle from Queens seems excessive,
but like other, similar cases it illustrates
the pressure on government to find
someone or some evil conspiracy to
blame for environmental problems.
Toward the end of last summer, when
the evidence strongly indicated that the
plastic medical refuse reaching
shorelines east and west of New York
City probably came from New York's
storm sewers, its littered shorelines, and
its major landfill, there was a sense of
public frustration. People were skeptical
and disappointed when a bad guy
couldn't be found and strung up for
spoiling summer at the beach.
In state government, where most
front-line environmental regulation and
permitting takes place, this syndrome is
all too familiar. Citizens, outraged by
continuing environmental problems,
demand that public officials "do
Environmental policy-making at the local
level. New York City Councilwoman Susan
Molinari proposes stringent tracking of
medical waste from medical and dental
practices too small to be covered by the
state's medical waste tracking law. At this
Midland Beach press conference, she
presents a chart of combined sewer and
storm-water outfalls, which, she declares,
deposit medical waste on local beaches.
JULY/AUGUST 1989
something." In response, each person
elected or appointed to office reaffirms
the crusade against polluters and
dumpers of toxic waste.
It is not surprising that the public
envisions bad guys behind
environmental problems. Environments
/ believe we are reaching a
point of diminishing returns in
pursuing new and more
detailed environmental
regulatory programs.
action in this country has been driven
by a series of discoveries of terrible
wrongs done to our land, air, and water
by people who knew or should have
known better. However, I believe we are
I AL WASTE DEBR
FLOWCHART
reaching a point of diminishing returns
in pursuing new and more detailed
environmental regulatory programs. I
say this despite the fact that I have
directed a state environmental
regulatory agency for seven years,
personally supervising a successful team
of criminal investigators of
environmental crimes.
A great deal of environmental damage
comes from many small, individual
actions of families and businesses. This
damage will not be alleviated through
regulatory enforcement alone. People
must become voluntary stewards of the
environment. They must better
understand that not all environmental
problems are "someone else's fault."
Only changes in the way we live, spend
our time, use our land, spend our
money, and cooperate with and sacrifice
for each other will preserve acceptable
Rob So/tert photo, Staten Island Register
-------
environmental conditions.
To bring about such changes, state
government must begin by changing the
way it manages the environment by
adding new approaches to the
environmental programs which have
been successful so far. In particular, the
following deserve consideration:
• We should use economic incentives
to modify individual and corporate
behavior at levels that are not amenable
to regulation.
This will mean new roles for state
regulators of public utilities. It will
require, among other things, new
programs to make recycling mandatory
(and to sustain markets for recycled
material). Deposit-and-return
requirements for environmentally
harmful products also warrant
consideration.
Public utility regulators have
traditionally set water, sewer, and
electric rates to ensure that the public is
protected from excessive rate increases
by utility monopolies. Utility
commissions are generally not
considered environmental agencies.
However, since water, sewer, and
energy use are effectively influenced by
rate structures, environmental goals
should be given weight in rate
decisions. This would require new
formal channels of communication
between utility regulators and
environmental agencies and
collaboration on decisions such as the
disposition of any windfall revenue
derived from environmentally driven
rate setting.
As the first state to implement a
mandatory statewide solid-waste
recycling program, Rhode Island has
found that, while citizens are
remarkably cooperative, economically
successful recycling does not happen by
itself. It is necessary to restructure
manufacturing in several industries to
accept vast quantities of recycled
material in order to achieve the
often-stated goal of recycling 25 percent
of the nation's solid waste stream.
This goal can be accomplished only if
recyclables are collected and marketed
in a standardized way. State agencies
must move to organize collection,
ensure quality control, and work with
other states to develop reliable markets.
Deposit-and-return legislation may be
an effective economic means for
achieving safe disposal or reuse of
certain environmentally harmful
products. With deposit systems, unless
Many state transportation
departments still see
environmental concerns as
secondary to the goal of
achieving desired levels of
transportation service.
an item (say a car battery or tire) is
returned to the dealer and then to the
manufacturer, the deposit required at
the time of purchase is lost.
Deposit-and-return systems encourage
manufacturers to develop ways of
reusing or reprocessing returned
materials. Given the questionable
success of hazardous waste tracking
laws, a deposit-and-return system might
even make sense for industrial
chemicals.
• State transportation and public lands
policies as well as local land-use
planning should be integrated with
environmental goals.
Automobile use has profound, direct
impacts on air and water quality. Public
investment in roads and mass transit
alternatives is crucial in influencing
land development decisions. However,
many state transportation departments
still see environmental concerns as
secondary to the goal of achieving
desired levels of transportation service.
The basic approach to state
transportation planning must be
changed within the nation's urban
corridors so that environmental
improvement becomes an explicit
purpose of transportation investment
that makes use of state and federal
funds. This would require governors to
restructure transportation
decision-making in most states to give
environmental agencies much more say
in transportation policy at every level.
We have learned that natural systems
such as forests and wetlands can help
preserve the quality of air and water.
Wetlands process pollutants; vegetated
buffer zones protect water from
nonpoint sources of pollution. Green
areas can reduce air pollution and
separate conflicting land uses. While
many states have wetlands protection
laws, few use the acquisition and
management of park and forest land as
part of pollution-control strategies. As
with transportation, progress in
integrating public lands policies with
environmental goals will require new
kinds of cooperative action among state
agencies.
Most land-use regulation remains in
local hands. This is unlikely to change,
but local decision-makers could become
much more informed about the
environmental implications of land-use
decisions. States could use tools such as
Rhode Island's statewide computerized
Geographic Information System to
provide local officials with information
on ground water, surface water,
wetlands, and other environmental
concerns, in order to improve the
quality of local land-use actions.
• Environmental data-gathering within
regulatory programs needs to be
simplified and integrated in a way that
allows regulated industries and public
officials to better understand the nature
and impacts of industrial wastes.
Despite all the discussion of the need to
address environmental problems in a
unified way, states are required by
federal legislation and EPA regulations
to collect and analyze data from
industry in accordance with each
separate air, water, and hazardous waste
program. Businesses are thus confronted
with a dizzying variety of forms to
document their compliance with
pollution-control legislation. All of this
helps perpetuate the problem of
pollutants being moved from water to
air to land, without sufficient thought
being given to overall pollution
reduction.
30
EPA JOURNAL
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Rhode Island Solid Waste Management Cotporation photo.
If states were given more freedom by
federal legislation, they could develop
single standardized reporting forms for
industry. Such standardized forms
might then be used by reorganized state
monitoring agencies and by the
businesses themselves to aid real
reductions in overall environmental
impacts.
• New regional relationships among
states are needed to deal with the
environmental problems of large natural
systems.
Physical and natural boundaries (rather
than political jurisdictions) must be
used as the basis for environmental
programs; this means far more regional
cooperation among states. The ozone
problem in the northeast corridor, the
continuing water quality problems of
Saving the environment requires innovation
and ingenuity. Here, Thomas E. Wright,
Executive Director, Rhode Island Solid
Waste Management Corporation, stands
next to a flare that burns methane gas to
control odors at New England's largest
landfill, thus reducing the amount of landfill
gases released to the atmosphere.
Beginning in the spring of 1990, the methane
gas will be converted into enough electricity
for 20,000 homes.
Chesapeake Bay, and efforts to clean up
and protect the Connecticut River all
demonstrate that states can better
address problems facing a natural
resource by banding together to take
action appropriate to that resource.
Regional efforts can no longer be
vague, ceremonial expressions of good
will. For example, the northeast air
directors, through an organization called
Northeast States for Coordinated Air
Use Management, have brought
eight states together in lowering
gas volatility regulations to reduce
ozone formation in the Northeast.
Similarly, the Chesapeake Bay states are
working together to solve the bay's
problems. A whole new series of
interstate compacts is needed to achieve
regional ends.
• States rnusl fake an active role in
restructuring municipal sewer and
water districts to ensure that they have
the fiscal and technical resources to
meet increasing environmental
demands.
In general, citizens have shown a
willingness to pay more for
environmental protection. However,
recent studies by EPA reveal that the
costs of upgraded wastewater and
drinking-water treatment fall
disproportionately on smaller
communities and those with a high
proportion of low-income people. Small
districts also often lack the technical
expertise to operate sophisticated
treatment plants and supporting
environmental programs such as
industrial pretreatment. In addition, as
water consumption and use behavior
have become recognized as important
factors in waste treatment, there are
more reasons to integrate water and
sewer management within watershed
areas.
These trends suggest a need for state
governments to take an active role in
examining the established patterns of
water, sewer, and other environmental
districts, with the objective of
combining jurisdictions to balance costs
to individuals and businesses and to
improve environmental performance.
Each citizen and industry-might then
feel treated fairly and be willing to pay
more and do more for environmental
protection.
Recently I stopped by the home of a
young engineer, one of my brightest and
most conscientious colleagues, to try to
convince him not to leave state
government. He said he was tired of
being an environmental regulator, of
always being in the middle, of being
distrusted and abused bv both citizens
Local decision-makers could
become much more informed
about the environmental
implications of land-use
decisions.
and representatives of industry. He was,
I believe, tired of trying to resolve issues
and conflicts, through narrow regulatory
procedures, which the society as a
whole has not resolved.
If we are to continue to make
environmental progress in the 1990s,
Americans must move beyond the idea
that only a few individuals or
corporations are to blame for
environmental problems and that the
way to solve these problems is for
government to apportion blame and
then extract retribution.
At the state level, strict regulation
will always be a necessary part of
environmental protection; however,
through new strategies such as those
described in this article, we can broaden
the base of environmental responsibility
so that concerns about the future of the
air, water, and land of our planet
become an integral part of the decisions
we make in every aspect of our lives. D
(Bendick is Director of Environmental
Management for the State of Rhode
Island.J
JULY/AUGUST 1989
31
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Making the Smog Cleanup
Happen in L.A.
by James M. Lents
It's daybreak in Southern California,
and millions of people rise to begin a
daily routine of unconscious polluting
amidst forecasts of another smoggy day.
Each household cooks breakfast on a
gas stove that has an ever-burning pilot
light, after spraying aerosol cooking oil
into an egg-poaching pan. In the
bathroom, peopie shower and reach for
the aerosol deodorant.
Then they each hit the road for a solo
car commute in bumper-to-bumper
traffic. At lunchtime, everyone hops in
the car again, visits a drive-up
automated banking machine, then lines
up and idles at a drive-through
restaurant.
In the evening, they all fill their
lawnrnowers with gasoline, cut the
grass, and drench the barbecue charcoal
briquets with lighter fluid.
While each person adds a only tiny
bit to the area's air pollution, the result
adds up to make the South Coast Air
Basin the Super Bowl of smog.
The basin is home to 12 million
residents (more than the individual
populations of all the states except
California, New York, and Texas), 8
million motor vehicles (three times as
many as in all of India), and the world's
largest gasoline market. It includes Los
Angeles, Orange, and Riverside counties
and the metropolitan portion of San
Bernardino County. And it has the
worst air quality in the nation,
exceeding one or more federal health
standards on 232 days in 1988.
In the South Coast Air Basin, the
federal ozone standard was violated 178
days in 1988, and the carbon monoxide
standard 61 days. The basin exceeds the
fine participate matter standard by 100
percent in some areas and is the only
place in the nation that still fails to
meet the federal nitrogen dioxide
standard.
Emissions controls on the largest
industries and motor vehicles over the
years have helped cut pollution, with
peak ozone levels steadily declining
from .68 parts per million (ppm) in
1955 to .35 ppm in 1988. The nation's
strictest tailpipe emissions standards
have resulted in today's cars emitting 10
percent or less of the pollutants emitted
by the typical mid-1960s car.
This progress, however, is being
slowed. And if present trends continue
unchecked, the gains we have made will
soon be reversed by population growth,
more motor vehicles and more driving,
Smaller cars, microwave
ovens, and water-based house
paints have been widely
accepted without
revolutionary lifestyle
changes. What the AQMD is
advocating is much along the
same lines.
a proliferation of small businesses, such
as dry cleaners, and lifestyle habits that
promote dirty air.
Residential and commercial sources
account for 280 tons, or 22 percent of
the 1,246 tons of reactive organic gases
emitted daily, and 142 tons, or 14
percent of the 1,040 tons of nitrogen
oxides, both prime contributors to
ozone. Use of domestic aerosols and
other consumer products alone accounts
for more than 93 tons a day of reactive
organic gas emissions, or 8 percent of
the total.
Mobile sources emit 52 percent of the
basin's reactive organic gases and 72
percent of the nitrogen oxides. The
South Coast Air Quality Management
District (AQMD) projects that the
number of vehicles in the basin will
increase by 35 percent and that miles
traveled will increase 68 percent by
2010, if nothing is done.
Therefore, to continue down the path
to clean air, the South Coast AQMD
must not only tighten industrial controls
but also change some of the behavior
patterns of millions of Southern
Californians.
On March 17, 1989, the AQMD board
of directors adopted a three-tiered plan
to achieve the nitrogen dioxide and
carbon monoxide standards by 1997 and
those for ozone and fine participates by
2007.
During Tier I, the first five-year phase,
127 measures will be considered: 15 on
oil companies, 24 on other businesses
and industries, 23 concerning paints
and solvents, 52 traffic and mobile
source measures, and 13 residential and
agricultural measures. Tier II, five to 10
years out, further tightens these
measures, and Tier III, 10 to 20 years
out, calls for total conversion of the
basin's vehicle fleet to extremely
low-polluting technologies, such as
electric motors powered by fuel cells or
batteries, highly controlled methanol or
natural gas vehicles, and industry use of
light-curable surface coatings.
Some complain this plan will require
Big Brother tactics. But the Orwellian
analogy could not be further from the
truth.
First, rather than alienating the
basin's citizenry, AQMD is seeking to
involve people in the debate over
cleaning up the air.
Second, AQMD is working to educate
people so they can help clean up the
basin's air through informed personal
choices, such as carpooling. Recent
polls indicate these educational efforts
are having results, with the
overwhelming majority of basin
residents saying they are willing to
make such personal changes.
Third, many changes will be largely
invisible to consumers as long as the
zero- or low-polluting alternatives
perform up to the consumer's
expectations, whether this be cars,
lawnrnowers, deodorants, or barbecues.
As long as we get where we want to go,
mow the lawn, cook the steaks, and
have deodorized armpits, most
consumers will not mind. Big Brother
will not be watching. In fact, only zero-
and low-polluting products will be sold
in the basin.
Smaller cars, microwave ovens, and
water-based house paints have been
widely accepted without revolutionary
Find polluting vehicles. Stop them. Issue
citations and advise drivers how to "clean
up their act." That sums up the mission of
the eight-member California Highway
Patrol's smog enforcement team, which
operates throughout Southern California.
The white patrol cars bear the South Coast
Air Quality Management District logo.
32
EPA JOURNAL
-------
lifestyle changes. What the AQMD is
advocating is much along the same
lines.
Cleaning up the air involves an
incremental, multi-pronged effort, All
sectors of our society contribute to the
air pollution problem, and all must
contribute to the solution.
AQMD must continue to tighten
pollution control requirements for major
industries as better technologies become
available. Moreover, controls must be
extended to smaller businesses, such as
the 4,000 auto body paint shops in the
basin, and crafted in a way that will not
cause undue economic hardships.
We must join with leading engineers
and scientists, both here and abroad, to
develop cleaner fuels for cars and
industry, cleaner industrial process
technology, and ultimately
non-polluting materials. To push
technology, AQMD's technology
advancement office is funding research
and demonstration projects through its
five-year, $30.4-million matching grant
program.
To reduce emissions generated by
indirect sources of pollution, such as
shopping centers, AQMD must
encourage development and use of
alternate means of transportation.
AQMD is already far along in
implementing its ridesharing program
requirements. By mid-1991, some 8,500
major employers will be required to
provide strong incentives for their
employees to car pool or use alternate
modes of transportation, such as public
In the evening, cut the lawn
with an electric mower and
start the patio barbecue with
parafin-treated briquets while
gazing in the fading sunlight
at the purple mountains 60
miles away.
transit or vanpools. This regulatory
program is coupled with an aggressive
public information campaign to promote
the clean air benefits of ridesharing and
other congestion relief measures.
In other educational areas, AQMD is
developing a model curriculum on air
pollution for local schools and an
exhibit on the causes of pollution for
the Los Angeles Museum of Science and
Industry.
As AQMD proceeds with its plan, it is
writing a new chapter in the history of
clean air in this basin—and a slightly
different routine as millions of southern
Californians arise at daybreak to radio
forecasts of another clear day. That
routine will be roughly as follows.
Brew coffee on an electronic-ignition
gas stove, and spray a light mist of
cooking oil onto the pan from a
pump-spray bottle.
Take a shower drawn from a
solar-assisted water heater, and reach
for the stick deodorant.
Carpool in a methanol-powered car or
catch the vanpool group in its electric
van, thereby saving fuel and auto
insurance. Walk to a nearby eatery in
the office park for lunch.
In the evening, cut the lawn with an
electric mower and start the patio
barbecue with parafin-treated briquets
while gazing in the fading sunlight at
the purple mountains 60 miles away, a
(Dr. Lents is an Executive Officer ivitli
the South Coast Air Quality
Management District.)
JULY/AUGUST 1989
California Highway Patrol photo, Ontario, California
33
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John Quarles
Can We Win with the
Crisis-Oriented
Approach?
Two Observers Speak
New environmental laws and
policies have typically come
about in the wake of crises
and disasters—the Donora,
Pennsylvania, air pollution
episode; the gross pollution
of Lake Erie; the gas leak at
Union Carbide's plant in
Bhopal, India. However,
environmental problems of
another kind are now
emerging, threatening
disastrous global
consequences for the
Jong-term future, such as the
ramifications of the
Greenhouse Effect. Will the
"reactive" environmental
approach work in dealing
with the new generation of
environmental problems
con/ronting us? EPA Journal
asked two respected
observers on the
environmental scene—former
U.S. Senator Gaylord Nelson,
the founder of Earth Day,
and John Queries, former
Deputy Administrator of
EPA—to comment. Here are
their answers;
Can we continue to wait
until the wolf is at the
door in dealing with
environmental problems,
especially when we face
serious new challenges to our
global ecology? Pragmatically
speaking, perhaps a better
question would be: Do we
have any choice?
The answer to either
question may ultimately
depend on which problem
we are talking about. It
depends on how serious they
turn out to be. It depends on
what consequences we are
willing to accept.
Before jumping to
conclusions on either side of
these questions, we should
reflect on what results we
have achieved in this country
during the past two decades
since the environmental
awakening of the late 1960s.
We have recorded some
impressive successes. Our air
and our water are cleaner,
despite continuing growth in
population, industrial
activity, and auto usage. Lake
Erie is no longer dead, and
the Cuyahoga River will not
again catch fire.
We have achieved progress
on a broader front as well. As
one indicator, the alligators,
for example, have come back.
Greater Cleveland Growth Association photo
The threat of resource
constraints hobbling our
future also seems less
imminent today than when
the Club of Rome Report was
issued [The Limits to Growth:
A Report for the Club of
Rome's Project on the
Predicament of Mankind
(Washington, DC: Potomac
Associates, 1972)], and the
risks of drastic shortages in
energy supply, for now at
least, seem more remote.
There are many reasons for
this progress, all relevant to
our capacity to respond to
crises in the future. American
ingenuity and
resourcefulness deserve
much of the credit: we have
found new ways to gauge the
risks and control them. Our
economic prowess also serves
us in good stead. The same
industrial engine which
caused so many
environmental problems has
also provided the resources
to redress them. Our
institutions have
demonstrated a similar
capacity to respond: the
regulatory apparatus which
EPA implements, and indeed
the existence of EPA itself,
reflect on our capacity to
meet new challenges.
There are definite limits to
our successes. Where
problems persist, we should
examine the reasons. Often
the fault lies not in a failure
to address the problem soon
enough but rather in the fact
that once we began, we did
not try hard enough. The
"intractable" problem of
ground-level ozone provides
an example. Though the
ozone problem is complex
and many factors intertwine,
the simplest explanation for
continuing conditions of
nonattainment is that the
public has been unwilling to
• jyahoga River,
.toriety by
, is now clean
.ailed an
success story.
34
EPA JOURNAL
-------
Gaylord Nelson
support the measures
required for success. The
traumas of auto inspection
and maintenance, the
resistance to many other
methods of control, and the
continuing love affair of
Americans with their
cars—all testify to the fact
that we have missed
opportunities to reduce levels
of ozone, even after that
problem was clearly
recognized.
But environmental abuse
often does leave a permanent
scar. Despite the massive
investments in water
which disregard its ecological
underpinnings. Part of that
price can be redeemed
through special efforts, but
certain wounds cannot be
easily healed.
Obviously, it helps to get
on the right course at the
start. It helps to see the
serious problems coming. But
even more important is the
strength of our response. As a
general rule, even where
problems have become
serious, we have been able to
overcome them if we have
been committed to that
result.
The regulatory apparatus
which EPA implements, and
indeed the existence of EPA
itself, reflect on our capacity
to meet new challenges.
pollution control, and the
noteworthy progress those
efforts have brought to our
rivers and lakes, the
sediments are still loaded
with nasty compounds. At
many sites the soils and
ground water are
contaminated beyond a
likelihood of rehabilitation.
Vast areas of wetlands are
gone forever, and, for miles
along our coastlines,
beautiful natural sand dunes
have been permanently
replaced with concrete
bulkheads.
In fact, it is in the use of
land (and the establishment
of our transportation systems)
that many of our most
irrevocable mistakes cast a
long shadow into our future.
When one flies the course of
the "megalopolis" from
Washington to Boston, the
landscape that unfolds is
packed with such dense
development that many a
child will seldom stroll in a
meadow.
From this quick review, it
is possible to conclude that
nature has a great redemptive
capacity, and that human
progress has made it possible
for us to lend a helping hand.
Even so, we pay a price for
those practices of civilization
When the focus shifts to
global concerns, the difficulty
of the problems increases,
and the limitations on our
ability to act are more severe.
But whether it be
stratospheric ozone
depletion, deforestation,
global warming, or some
other emerging trend that
threatens the future of
"spaceship earth," many of
the same factors that have
affected American response
to ecological danger will
operate similarly in the
international sphere. The
democracy among nations,
like the democratic character
of our own political system,
will require that world
opinion be mobilized to bring
sufficient pressure for change
in established practice.
This dynamic means that
we will have little alternative
than to wait until
environmental problems
assume proportions of reality
before major efforts can be
launched to bring relief.
Doubtless we will incur
permanent damage to certain
attractive and important
features of our world-wide
environmental and resource
base. Let's hope we can
nonetheless react in
sufficient time and with
sufficient intensity to avert
catastrophic effects.
For those who feel that this
prognosis does not provide
sufficient satisfaction, let me
reiterate the fundamental
point that we are operating in
a democracy. In placing
liberty and equality at the top
of our priority list, we may
forego a theoretical capability
to anticipate every problem
and achieve ideal protection.
What our system does
provide, however, is an
adaptive capacity to correct
our past mistakes. By giving
effective force to the power
of public opinion, we can
enjoy the benefit of a
dynamic corrective process.
But the success of that
process requires first that we
as citizens see the need and
second that we unite to
respond to it. In America, the
security of our future
depends on all of us.
(Queries, currently a partner
in the Washington Office of
Morgan, Lewis and Bockius,
served as EPA's first General
Counsel and was Deputy
Administrator of EPA from
1973 to 1977.)
The 20th anniversary of
Earth Day 1970 is just 10
months away. Twenty
million people participated
in that dramatic event.
The main purpose of Earth
Day was to organize a •
nationwide, grassroots
demonstration of public
concern for the environment
that would get the attention
of the politicians and force
the environment issue into
the mainstream of political
dialogue. The politicians got
the message, and they
responded with major
legislative initiatives at the
national, state, and local
levels.
While we have made some
significant progress here and
there since Earth Day, a
continuance of efforts at
current levels will fall far
short of what is needed and
will not prevent continued
steady environmental
decline.
The resiliency of the living
planet has already been
dangerously compromised. It
is rapidly losing its capacity
to renew itself. The insults to
the land, water, and air are
too many and too massive.
In short, threads of the net
that hold the world
ecosystem together are
breaking and unravelling.
Only a massive, coordinated
worldwide effort will save
what is left of the natural
world and give nature a
chance to repair some of the
damage we have caused.
If this sounds like alarmist
talk, it is, because the
situation is nothing short of
alarming.
Plans for a worldwide
Earth Day in 1990 are well
underway. Indications are
that this will be the largest
grassroots demonstration in
history.
The single most important
objective of this 20th
anniversary celebration is a
worldwide public
demonstration so
overwhelming that it literally
shakes the political
leadership of the world out
of its lethargy and galvanizes
JULY/AUGUST 1989
35
-------
it into a monumental,
cooperative effort to stop the
deterioration of the planet
and begin its restoration.
It is time our leaders
recognize that the state of our
environment is far more
important than the threat of
nudear war, missile gaps,
star wars, crime on the
streets, communism in
Nicaragua, world hunger,
national economies, or any of
a dozen other issues that
occupy the front pages of our
daily newspapers.
It is time for our political
leaders to recognize an
important truth: the fate of
the living planet is the most
important issue facing
mankind. No other issue,
now and for all centuries to
come, is more relevant to our
way of life than the status of
our resources—air, water,
soil, minerals, scenic beauty,
wildlife habitat, forests,
rivers, lakes, and oceans. It is
the resource base that
determines how we live and
defines our habitat and the
limitations for survival of all
species: plants, animals, and
man.
What is needed right now
is strong, vigorous,
imaginative leadership from
President Bush and President
Gorbachev. They have it in
their power to alter
dramatically the course of
history, if they will but grasp
the opportunity.
The cause is right. The
time is ripe. The world is
ready. Mr. Bush and Mr.
Gorbachev should begin by
formally declaring an end to
reduction in military
expenditures and a
reallocation of resources to
the environment and other
socially productive
enterprises.
President Bush would
inspire the world and give it
the dramatic leadership it
yearns for if he would
propose that the United
States and the Soviet Union
It is time for our political
leaders to recognize an
important truth: the fate of the
living planet is the most
important issue facing
mankind.
the cold war and the
beginning of a new era.
The Soviet economy is a
shambles. It desperately
needs relief from the burden
of unproductive military
expenditures. So does the
United States. The national
debt overhangs the economy,
saps the vitality of our whole
economic and social system,
weakens our competitiveness,
and distorts national
priorities. Both nations
would benefit from a drastic
mutually reduce military
expenditures by 50 percent
in the next 10 years and
another 50 percent in the
following decade, with half
the annual savings allocated
to husbanding the ecosystem
of the planet. Under this
proposal, everyone is a
winner—there are no losers.
This not unilateral
disarmament; it is not
idealism run amok; it is,
plainly and simply,
hard-nosed realism. How
much longer are we and the
Soviet Union going to expend
a total of $600 billion a year
on weapon systems that put
us both in greater jeopardy
while degrading and
destroying the very resource
base that sustains us?
Once Mr. Bush and Mr.
Gorbachev reach an
agreement in principle, the
iron curtain countries,
western Europe, and most
other countries could be
persuaded to follow because
it would also serve their own
best interests.
Very few Presidents are
afforded the opportunity to
achieve greatness. Those who
did, achieved it because they
successfully met a major
threat to the security of the
nation: war, social turmoil,
economic chaos. These were
the challenges faced by
Washington, Lincoln, and
FDR.
Now, for the first time in
history, the nation is
confronted with a challenge
far more serious than any
war or economic depression.
Mr. Bush is the first
president in contemporary
times to define himself as a
conservation president. He
has a golden opportunity to
grasp this issue and lead the
world. The United States is
the largest industrial
power—and the world's
greatest polluter. This nation
has an obligation to set an
example.
Whatever else President
Bush does in his presidency
will fade into distant
memories, but if he
successfully initiates the
battle to preserve the
integrity of the planet, he
will be remembered as long
as history is written, n
(Nelson, a former U.S.
Senator, is Senior Counselor
for the Wilderness Society.]
As part of the 10th anniversary
celebration of Earth Day in
1980, enthusiasts carried a
"Save the Humans" whale
around the Mall near the
Washington Monument.
Bern/e Boston phoro, The Washington Suar Copyright Washington Post, repr
n/ss/on of the DC Public Libiary
36
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Changing from
Consumers'" to Citizens
by Jay D. Hair
Everything we do has an effect on the
environment. Was your morning
orange juice in a plastic container? It
will probably become one of the
640,000 plastic containers dumped
carelessly into the ocean every clay. Last
Sunday, did you read the morning
newspaper? If you simply tossed it out
without recycling it, you contributed to
the demise of more than 500,000 trees
used to produce 88 percent of the
Sunday newspapers that are never
recycled. Did you use your auto air
conditioner this week? If so, its
emissions of chlorofluorocarbons are
helping to destroy the earth's protective
ozone layer.
Clearly, our thoughtless
environmental choices are affecting the
environment. We, as consumers, are
turning America the Beautiful into
America the Polluted. Moreover, as
other articles in this issue of EPA
journal make clear, the environmental
consequences of our actions reach
beyond our national boundaries to the
global ecology. We are surely and not so
slowly destroying the conditions needed
for life to thrive on earth. And all of us,
as consumers of products that
contribute to this destruction, must
instead become part of the solution.
There is some good news, and
evidence that a change in attitude is
occurring, albeit slowly. A 1986 Louis
Harris poll found that when given a
choice, the American public would not
opt for jobs over a clean environment.
Currently there are over 121 million cars in
the United States. Collectively, they emit
about 600 million tons of carbon dioxide
each year. Are you carpooling?
When asked if they would pay $75 more
in taxes in order to achieve tougher
enforcement of anti-pollution laws, they
said yes—by a margin of more than two
to one. Most recently, a Media
General-Associated Press poll found that
75 percent of the 1,084 adults polled
said laws against pollution are too
weak, and 87 percent said they would
It seems puzzling that despite
this powerful evidence of
public concern about
environmental problems,
reckless habits continue
destroying the environment.
favor measures requiring them to sort
their garbage for recycling.
Poll after poll has come up with
similar results. Whenever the public is
asked about environmental issues, the
returns almost always and nearly
unanimously point in one direction:
deep concern and worry about the
country's environment.
It seems puzzling that despite this
powerful evidence of public concern
about environmental problems, reckless
habits continue destroying the
environment. It may be that people feel
the job is just too large—that one person
can hardly make a difference.
Don't believe it. There are people who
know from experience how important
personal, individual sacrifice is and just
how much of a difference each of us can
make.
In Illinois, 39-year-old jerry Paulson
has made a career of changing laws and
regulations to solve environmental
problems. For more than a decade, he
has actively organized volunteers to
participate in the regulatory process,
and his efforts have led to the
protection of a number of important
wetlands in Illinois.
In Bethesda, Maryland, Marjorie
Smigel has become one of the state's
most tenacious conservation activists—a
major force behind the passage of the
first state law in the country mandating
health and environmental safeguards by
commercial lawn services—and all from
the modest beginnings of the Springfield
Garden Club.
Jim Murray in Detroit has made clean
water his business. The 45-year-old
conservationist grew up on the banks of
the Rouge River in Detroit, and he has
made a career of pursuing cleaner water
for the region through hard work and
sacrifice. Of all his efforts, Murray is
perhaps most pleased with his success
at organizing a Rouge River monitoring
program made up of high school science
classes. Students sample the river's
water, rate its quality based on a
37
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Gardeners can improve their crops by using
compost made from leaves, grass, and
vegetable waste to enrich the soil. This
also saves valuable space in landfills.
National Science Foundation index, and
then share the results through a
computer network.
Jan Carton is keeping the wetlands in
Kansas alive; Art Aylesworth in western
Montana is working to save the
bluebird; and New York's Hudson River
is cleaner, thanks to determined
conservationist Robert Boyle, who for 20
years has made protection of the
Hudson an obsession by founding the
Hudson River Fishermen's Association.
Acting as river watchdogs, their first
victory, in 1969, stopped a railroad
company from piping its waste oil
directly into the Hudson.
The situation now is just as
urgent as it was during World
War II.
These stories of environmental
activism provide inspiring examples.
They illustrate the kind of deep-seated
commitment and awareness of the
environmental consequences of our
individual actions that are so
desperately needed. There are no easy
answers and there is no magic—just
good, old-fashioned hard work and
individual sacrifices.
Not everyone can be an
environmental leader, but everyone can
make individual lifestyle changes to
help preserve the environment from
further degradation.
Where to begin? There must be a
realization that the job isn't too large. A
good example would be the sacrifices of
those during World War II who saved
string, metal, and tin foil while going
without so many "extras." The situation
now is just as urgent as it was during
World War II. We must work just as
selflessly for peace, only this time the
goal must be peace with the
environment.
There is so much each of us can do
and it wiJJ make a difference. Here are
just a few of the most obvious steps to
take:
• Cut down on your trash. Reuse and
repair. Americans produce 150,000 tons
of solid waste per year. The average
U.S. household discards 1,800 plastic
items; 13,000 individual paper items;
500 aluminum cans; and 500 glass
bottles yearly. New York alone produces
26,000 tons of waste each day.
• Use household chemicals completely
before tossing their containers. Solvents
and cleaners in landfills seep into the
ground water. Never throw chemicals
down the drain; take them to a
hazardous waste center.
• Use cloth diapers instead of
disposables. Each year we are throwing
away 18 billion disposable diapers,
which are filling up our landfills at an
alarming rate. Did you know that diaper
services are much less expensive than
buying disposables?
• Put grass clippings, leaves, and
vegetable waste into a compost heap.
Every year we dispose of 24 million
tons of leaves and grass clippings,
which could be composted to conserve
landfill space. Did you know that 10
years ago, there were over 18,000
municipal landfills across the country?
Now, because they're filling up, we're
down to 9,000, and more are closing
daily.
• Don't leave water running needlessly.
It has been shown that up to 50 percent
of the water wasted in the home is
attributable to taps that run
unnecessarily. Also, install a
water-saving device in your toilet or,
better yet, have a low-flush or
air-assisted toilet installed. These toilets
can save 60 to 90 percent of your water.
• Reuse grocery bags and ask for paper,
not plastic. Use mugs instead of paper
cups; rags, not paper towels; cloth, not
paper napkins. Just remember to choose
products that will last. If it's disposable
and convenient, it is filling our
landfills. And if it is made from a
petroleum-based material (plastics,
foam), it is creating "greenhouse" gases
and other pollutants.
• Use public transportation or car
pools. There are now more than 121
million cars on the nation's roads—over
4 million more than in 1986. Each of
those cars emits an average of nearly 5
tons of carbon dioxide into the
atmosphere, which is the major
"greenhouse" gas. That means we're
putting about 600 million tons of carbon
dioxide into the atmosphere annually
just by driving.
• Plant a tree. Trees are the primary
absorbers of carbon dioxide, and
tragically, the rate of deforestation in
this country has exceeded one acre
every five seconds since 1967. Every
tree in your yard saves in heating,
cooling, and soil erosion costs. Besides
looking nice, they also absorb
pollutants.
• Don't buy endangered plants,
animals, or products such as furs, ivory,
reptile skin, or tortoise shell, which are
made from over-exploited or endangered
species.
And let's not forget our role as voters.
We must elect government leaders who
espouse an environmental ethic.
Consider what happens when we do.
Last March, the Suffolk County, New
York, legislature, in an effort to reduce
solid waste, approved a plan to outlaw
the use of plastic grocery bags and
plastic food containers. The bill, one of
the most comprehensive of its kind,
EPA JOURNAL
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USDA photo
comes just in time: by 1990, all Long
Island townships must close their
overburdened landfills to safeguard
their threatened ground-water supplies.
In Nebraska, the legislature passed a
bill that will outlaw the sale of
nondegradable diapers by 1993,
realizing that these throwaway,
single-use products cannot be recycled,
devour landfill space, and threaten
ground water with chemicals and
disease.
Over the next four years, the state
governments of Wisconsin, Illinois,
Florida, and Minnesota will enforce
statewide bans prohibiting landfills
from accepting leaves, brush, and grass
clippings, which make up about a fifth
of the garbage in most municipal
landfills. New Jersey has already banned
leaves but not grass clippings from its
landfills, and Pennsylvania and
Connecticut are preparing to do the
same. In addition, cities and towns in a
number of states, including New York
and California, have begun programs to
keep leaves and grass out of local
landfills.
Finally, in Los Angeles, voters are
seeing their taxpayer dollars at work.
Members of the California Highway
Patrol have turned into "Smog Busters,"
ticketing anyone who is contributing to
the country's filthiest air—namely in
Los Angeles, Orange, Riverside,
and San Bernardino counties. In order
to meet federal clean air standards, the
South Coast Air Quality Management
District also plans to require
cleaner-burning fuels, such as methane
and compressed natural gas; expand
current incentives for car popling;
outlaw free parking; and use part of
parking fees to encourage the use of
mass transit and limit the number of
vehicles per household. Inconvenient,
you say? Remember the consequences of
inaction and apathy.
As the environment becomes one of
the hottest political issues of the 1990s,
let's guard against those who suddenly
have an "election-year conversion" to
environmentalism in order to capture
the green vote. In the polling booths, we
must be more active in electing
environmentalists to public office and
put forth candidates from the
environmentalist community.
My message is quite simple. It is time
to harden the edge. It cannot be
business as usual. Our mission is
urgent. Time is running out. As Adlai
Stevenson said, "We travel together,
passengers on a little spaceship,
dependent on its vulnerable resources of
air and soil; all committed for our safety
to its security and peace; preserved from
annihilation only by the care, the work
and—I will say—the love we give our
fragile craft."
If you would like a more complete list
of personal changes you can make to
preserve the environment, write to the
National Wildlife Federation, 1400 16th
St., NW, Washington, DC 20036. u
(Dr. Hair is President o/ the National
Wildlife Federation, the nation's largest
conservation organization, with more
than 5.8 million members and
supporters and 51 affiliate
organizations nationwide. A private,
non-pro/it organization, the Federation
was founded in 1936.J
JULY/AUGUST 1989
39
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Lessons about
Environmentalism in Congress
by Robert T. Stafford
For more than two decades, Congress
has set the course for our nation's
quest for clean and healthy air, water,
and land. The House and Senate have
enacted an extraordinary number and
variety of laws that have helped to keep
our environment safer than it would
otherwise have been.
But if we are to help mankind achieve
its eternal and universal goals of
happiness and prosperity, we shall have
to change our approach in the future.
We shall have to put more emphasis on
anticipation than on response. We shall
have to concentrate more on prevention
than on cleanup. And we shall have to
extend our environmental concerns
beyond the boundaries of our nation.
To those ends, we shall have to
guarantee that environmental
considerations be a major part of all
significant policy decisions, in and out
of government. If we are to continue to
encourage the kind of orderly growth
and development that bring prosperity,
we must recognize that our efforts to
provide at the same time a safe
environment will require new ways.
Needed will be legislation that
anticipates the use of a variety of
processes, ranging from regulation to
conservation, to changes in lifestyles, to
forcing the development and use of
technology.
The twin pressures of global
population growth and the ambition for
a better life by struggling billions in
developing countries call out for the
United States to assume a position of
world leadership in the necessary effort
to secure a safe environment. Congress
must play a critical role in this effort.
In the early 1960s, we spent much of
our time trying to learn as much as
possible about our environment and
about ways to deal with threats to that
environment. As we learned those
things, we quickly became aware of how
important it was—and still is—to get the
public involved in environmental
issues. We found very quickly that the
public demanded margins of
environmental safety far stricter than
industry thought was reasonable and
politicians thought practicable.
Emboldened by this public support,
Congress moved slowly to engage an
40
ill-defined adversary. We authorized
development of the expertise needed to
understand the scope of environmental
problems. We established programs to
measure the development of state and
local regulatory programs. We set up
modest federal enforcement capability
to deal with environmental problems
that crossed jurisdictional lines.
Our knowledge expanded. The public
became more aware of environmental
problems. As a result, Congress
attempted to respond to public demand
for a higher level of performance
dealing with pollution control. The
landmark Clean Air Amendments came
in 1970, followed by the 1972 Clean
Water Act.
It seemed then like such an
ambitious effort. But, in
reality, it was a limited
environmental agenda.
These laws had—and still have—two
basic objectives: first, to establish
specific regulatory requirements and
precise timetables to achieve those
requirements and, second, to establish
long-term policy goals for
environmental programs.
To justify this federal intrusion into
the environmental process, we focused
on protection of human health in our
efforts to control air pollution. That
concern for health has become the
hallmark of most of the environmental
legislation that followed, and the Clean
Air Act and Clean Water Act have
evolved as among the most important
public health laws of this nation. Public
health standards became the scientific
basis for pollution controls, and a body
of law based on health protection has
developed in the United States. These
laws continue to enjoy overwhelming
and increasing public and, thus,
political support.
It seemed then like such an ambitious
effort. But, in reality, it was a limited
environmental agenda. It has been said
we asked for too little in the 1960s and
too much in the 1970s. The truth is, of
course, that we have not done enough.
Our early environmental concerns did
not include toxics, hazardous wastes,
acid rain, or ground-water
contamination, each of which has
generated massive problems in our
country. Nor did we spend much time
thinking about the Greenhouse Effect
and resulting climate changes, depletion
of the ozone layer, desertification,
deforestation, or species extinction, all
of which affect not only our nation, but
our entire planet.
Our early efforts came in response to
dramatic events—a smog that killed,
water pollution that closed beaches,
chemical dumps that leaked into water
supplies, and toxic releases from
factories.
The laws we wrote in those responses
were imperfect, but they were superior
to the enforcement and support they
received from the regulators at both the
state and federal levels. Too many
waivers were issued, and too many
deadlines were allowed to pass.
But we have learned that we do not
have unlimited time to meet the
environmental problems of the future.
We have also learned that we are all
inhabitants of a single ecosystem of a
fragile planet and that we had better pay
more attention to each other's habits,
policies, and ambitions.
It is in our own national interest to
assume world leadership of the effort to
prevent environmental catastrophe. This
decade has seen the four hottest years in
recorded history. The planet's ozone
shield is three percent thinner because
it has been weakened by manmade
chemicals. Levels of ozone closer to the
earth's surface have doubled.
There is a growing consensus among
scientists and more and more
policymakers that these and other
circumstances pose a potential threat to
human survival that must be addressed
now. Humanity has moved closer to the
edge of an environmental abyss, and we
will surely plunge over it unless we
change our ways.
To permit and encourage our nation
to assume the world leadership required
to prevent environmental disaster, the
federal government will have to develop
a new spirit and system of cooperation
that will make environmental concerns
an integral part of all national—and
even international—planning.
EPA JOURNAL
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Pennsylvania's Homer City electric
:ing plant burns coal from a nearby
ivironmental impact of
from electric utilities continues to
.•rial concern.
National Coal Association photo
Congress can take the lead by ending
its competing interests and jurisdictions
among its various committees dealing
with the environment, energy,
commerce, agriculture, development,
and finance. Improved cooperation will
have to be forged among the private
sector, environmental and industry
advocates, and EPA and other agencies
of the government. We no longer have
the luxury of taking the time to impose
environmental regulation after the fact
of contamination; environmental
concerns must be made a part of all
basic processes. It is time to recognize
that the true costs to human society are
the costs of pollution—not the costs of
pollution control.
Laws and regulations—and even
international treaties—will have to force
technological development and changes
in lifestyles. The Montreal Protocol on
reducing the use of chlorofluorocarbons
(CFCs) is a good start. We may have to
provide incentives to the economy as
we seek to control—even to
end—pollution. We cannot require
developing nations to forego the benefits
of technology because the industrialized
nations have fouled the environment
through the enjoyment of those benefits.
Likewise we can no longer permit the
investment of American funds in
developing nations without regard for
the environmental consequences of that
investment. We will also have to attack
pollution through source reduction,
waste minimization, improved energy
efficiency, and methods to be developed
in a new spirit of cooperative effort.
We will not have to reinvent the
wheel to accomplish these goals. The
technology already exists to build a
power plant that converts nearly
one-half of its energy to electricity while
putting nearly two-thirds of the rest of
the heat to a useful purpose. It is
possible to build refrigerators and to
make electronic chips without using
CFCs. Our country has developed very
highly efficient gas turbines, and other
countries have built functional
automobiles that travel between 80 and
100 miles per gallon of gasoline. The
challenge is to find the way to extend
these limited successes throughout the
world.
New reports from virtually every
corner of the globe tell us that the
inhabitants of this planet increasingly
are demanding protection for their
environment. These same news reports
'tell us that more and more politicians
are responding to those demands. The
challenge is great, but the opportunity is
even greater if only we dare to learn
from the past and to change our ways in
the future, n
(Stafford, a former Republican Senator
from Vermont, was the Chairman of the
Senate Environment and Public Works
Committee from 1980 to 1986 cincf
ranking minority member of the
Committee for the remainder of his
service. He retired from Congress in
early 1989. Stafford is a long-time
leader on environmental issues.)
JULY/AUGUST 1989
41
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The Third World's Environment
A Global Dilemma
by Thomas E. Lovejoy
By any measure, the planetary
environmental crisis is at
hand—whether in our accelerating loss
of biological diversity or the changes in
the chemistry of our atmosphere,
altering the physics of the earth. These
indicators say very clearly that the way
human society as a whole is living, we
are exceeding the carrying capacity of
the planet.
To these problems must be added the
likelihood of a doubling in population
by the middle of the next century,
mostly in the developing world.
Nonetheless, the nations of the
developing world understandably aspire
to achieve the living standards of
industrialized nations.
We clearly face a challenge of a scale
and immediacy unlike any we have had
before. With so many exponential
adverse trends, I personally believe we
have less than 10 years to effectively
address the situation. The problems
cannot be dealt with by nibbling at their
edges. Business-as-usual will not work.
Nothing short of massive intervention
into the forces causing environmental
deterioration will be adequate.
Humanity as a whole must develop a
wartime mentality to mobilize society to
make the necessary changes. We are in
fact at war with ourselves and our
future, and only a similarly strong
counter-response can save the day.
The socio-economic problems of
poverty and population pressures are
inextricably interrelated to the
environmental problems of our planet.
The population issue is so emotionally
charged and so delicate that people and
politicians often are reluctant to address
it. Yet it is utterly obvious that any set
of measurements drawn up to address
the environmental problems is bound to
Even a modest increase of
energy consumption per-capita
in China could produce CO2
emissions that would put the
Greenhouse Effect beyond
reach of a solution.
fail if it does not include consideration
of human population growth.
The problem of Third World
development is an integral part of any
solution to the impending
environmental crisis. The aspirations for
economic development of those nations
cannot be overlooked or denied. Yet at
the same time, if every person in the
world were to rise to the same
per-capita level of energy consumption
as the United States, environmental
disaster would be inevitable.
The answer then must lie in
improving the economies of Third
World nations and making the
industrialized nations, particularly our
own, far less wasteful and energy-greedy
in the future. The challenge is for
developing nations to find ways to
move toward development that can
bypass the environmentally destructive
ways of the industrialized northern
nations.
The role of the wealthier nations, the
United States in particular, is critical.
We certainly are in a position to help
other countries, but it must be borne in
mind that our example is at least as
important as our assistance. If the
wealthiest nation on earth, alone
responsible for 20 percent of the annual
increase of carbon dioxide, is not seen
to grapple with reduction of energy
consumption, it will be very hard to
expect nations of far less wealth to
undertake vital environmental measures.
If we fail on that front, we give credence
to accusations of ecological imperialism
and the notion of a conspiracy to
prevent the poorer nations from their
rightful development. On the other
hand, if we develop an effective
national biological survey, for example,
and protect our biological diversity
through effective land use policies and
programs, the United States could set a
style and example for other nations.
The ultimate challenge is that the
nature and the magnitude of the
environmental crisis require a solution
that is inherently international.
Consider the emissions that exacerbate
the Greenhouse Effect, for example.
Chlorofluorocarbons (CFCs) can be
replaced by other products that are
environmentally benign, but the
participation of all nations is required
Bangladesh. A
crowded country on
an increasingly
crowded planet.
42
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(whether big consumers like ourselves
or aspiring manufacturers like some
developing countries) to effective!}'
phase out the CFCs.
The situation with respect to carbon
dioxide (CO2) emissions is more
complex and difficult. Just keeping CO2
emissions in the atmosphere from
growing beyond the current level of 3.5
billion tons per annum, directly affects
the fossil fuel dependence of a large
part of industry and transportation. For
a nation like China, there seems little
alternative but to use its massive coal
reserves for energy. At the same time,
even a modest increase of energy
consumption per-capita in China could
produce CO2 emissions that would put
the Greenhouse Effect beyond reach of a
solution.
As a temporary, remedial measure,
the world's forests offer a means for
partially counterbalancing COZ
emissions because growing forests
convert CO2 into wood, whereas
burning forests produce CO2. A
conservative estimate puts the annual
contribution from human-caused forest
burning at about 20 percent of the
annual net increment of C02 in the
atmosphere. Reforestation on the order
of a million square kilometers or so,
spread around the world in countries
north and south, could achieve about a
one-third reduction in the annual net
increment of CO2. Moreover, if
unnecessary forest burning were
stopped concurrent with reforestation
initiatives on this scale, the annual CO2
addition to the Greenhouse Effect could
be reduced by about half. Vigorous
energy conservation and energy
efficiency measures could go a long way
toward reducing the rest of the current
net increment.
What about the needs and aspirations
for increases in fossil fuel use by
developing nations? If China presses
forward with its coal-fired utility plants,
it could help balance the equation with
massive tree planting. Moreover, a
nation like ours could help by taking a
new, relaxed attitude toward technology
transfer where environmental issues are
concerned. This approach to balancing
the annual sources and sinks (storage
mechanisms) of CO2 is not a permanent
solution because growing forests store
carbon at significant annual rates for
only about 30 years. However, it does
buy time to work out a better energy
scenario.
The cost of addressing these huge
Reprinted with permission from the Lincoln Journal. Lincoln, Nebraska
problems, and addressing them
promptly, is nothing short of staggering.
Essentially, this is because we have
treated the environment as a free
commodity and have not paid the full
price for our ways of life. Now the bill
has arrived and it is huge, although less
than it will be if we do not right our
course. As a practical matter, we must
look for the most efficient way to pay
this bill by harnessing market forces
under the right set of rules.
We need to look for resources that are
commensurate with the environmental
Brazil is in a position through
Amazonian deforestation to
pull an ecological rug out from
oeneath itself, the region, the
continent, and perhaps the
world.
problems the planet faces. In many
cases, there is nowhere to turn but the
international debt, at least for the
environmental problems of many
developing nations. Debt restructuring,
including debt-for-nature swaps (which
involve purchasing dollars at great
discount and subsequently redeeming
the money at much higher value in local
currency), offers special opportunities.
Debt swaps for commercial purposes
(debt-for-equity swaps) have occurred in
considerable volume in many countries.
Debt-for-nature swaps have occurred in
only a few countries, but there seems to
be growing interest.
Curiously, an objection frequently
raised is that debt-for-natum swaps are
inflationary because thev dump large
amounts of local currcucy into an
economy, thus "cheapening" the
currency. Ironically, such objections are
rarely raised about commercial debt
swaps, suggesting few people yet realize
how seriously environmental impacts
can affect an economy.
One approach to avoid inflation is to
convert debt into interest-bearing
instruments such as bonds. This has the
added benefit of providing stability to
programs and institutions just as
endowments do. The debt, in any case,
is the only resource available on the
scale needed and may represent our
only fiscal chance to address these huge
problems. It would be folly to let this
opportunity escape our grasp.
The global environmental crisis
requires both international and national
solutions. There clearly is no place for a
planetary Big Brother, and no nation is
environmentally perfect in its behavior.
Yet some nations have a bigger
responsibility than others—none more
than ourselves, for with our 20 percent
annual contribution to global CO2
emissions, our action will significantly
influence whether the ecological rug is
pulled out from under the world
through climate change.
Brazil is in a position through
Amazonian deforestation to pull an
ecological rug out from beneath itself,
the region, the continent, and perhaps
the world. Other nations are astride
other ecological levers. Those very same
nations are the ones that can contribute
important environmental leadership at
the time it is needed most. The
opportunity and challenge are clear, o
(Dr. Lovejoy, a tropicaJ ecologist, is
Assistant Secretary /or External Affairs
at the Smithsonian Institution.)
JULY/AUGUST 1989
43
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How Do We Get There?
by Michael Gruber
The i
Princi; > .
Steps to fj
Solutions to the environmental
problems we face for the remainder
of this century require not primarily
technique, but political will and,
perhaps, important changes in our
national culture. The vexing question is
not "what is to be done?" but "can we
do what is required?"
For it is now clear that the kind of
regulatory program that EPA has
traditionally fostered, a regulatory
program based largely on "pollution
control," is, by itself, inadequate to deal
with these problems. Regulation alone is
not going to clean the air or the waters
in this country, nor will it stop the
destruction of major ecosystems or deal
with global wanning.
If we wish to do these things (without
first enduring catastrophic loss, that is),
then environmental protection in its
broadest sense must become a more
important part of our national life. The
first step in making it so is to admit
how relatively insignificant and
peripheral a role it now plays. The
environment is more often than not an
afterthought in both business and
politics, like the tip one leaves for the
waiter after a hearty meal. In public life,
the important things are national
security, in the sense of military and
international relations, and economics.
These are what make and break
administrations; environmental issues
do not, and political leaders understand
this very well.
In the private sector, with few
exceptions, firms regard environmental
concerns as a cost to be minimized by
lobbying and legal maneuver. In general,
industry does not get rich on
environmental protection.
But still we have those poll results.
What can it mean when The New York
Times says that around 80 percent of
Americans want a cleaner environment
no matter what it costs? When we
observe how our citizens act, rather
than what they report to pollsters, we
must conclude that our pattern of
desires and our motivations are out of
touch with what we say our values are.
In other words, while we want clean
air, in principle, we also want to drive
to work in large fast cars burning cheap
gas, and we want lots of cheap
electricity to run our appliances and
heat and cool our houses. We want an
end to hazardous waste dumps, in
principle, but we don't want the
Regulation alone is not going
to clean the air or the waters
in this country, nor will it stop
the destruction of major
ecosystems or deal with global
warming.
infrastructure necessary to run an
effective hazardous waste recycling
program built anywhere near where we
live. We abhor toxic chemicals, in
principle, but we buy great quantities of
the paints, plastics, wrappings, and
consumer chemicals that use such
substances, and we demand flawless,
cheap fruits and produce.
Our efforts at cleaning our
environment have not, as yet, cut very
deeply into this lifestyle. Our
concentration on the control of
pollution by the manufacturing sector
has meant that pollution control costs
were passed on to the public in small
doses. Although the total cost to society
has been substantial, the impact on
most individuals is barely noticeable.
This will no longer be the case if
environmental protection becomes a
more important part of national life. It is
going to pinch.
This is because really protecting the
environment means preventing
pollution, and preventing pollution does
not mean merely setting up an office
with that name at EPA. It means making
significant changes in production, in
types of products, and in daily habits. It
means paying the true environmental
cost of everything we use or buy.
This is already starting to happen.
The cost of solid waste disposal, which
a decade ago was only $5 to $10
a ton, is $125 per ton in some places
and rising. The people of Boston have
started to put money instead of just
sewage into their harbor; sewage utility
rates have risen fourfold as a result.
When costs go up like this, one result is
to focus the mind wonderfully on
preventing waste in the first place,
using less, and making products that are
recyclable or reusable.
This process must be made to
continue at an accelerating rate. The
way to do this is to build environmental
protection into the heart of the market
economy itself, to make it an inherent
part of the great advantage that market
economies have over all their rivals: the
enormous flux of information they can
bring to bear on resource decisions,
information generally expressed in the
form of prices. Unlike polls, prices tell
the truth about what people really
value.
Here is an example. Because of the
Valdez spill in the Gulf of Alaska and
the subsequent mismanagement of the
initial cleanup, the Exxon Corporation
is now the great environmental villain.
Imagine that Exxon now says: "We've
reformed. From now on we're
committed nevrr to spill another drop
of oil on the sea. Our tankers will all be
retrofitted to have triple hulls and
double crews. Each one will travel in
convoy with empty tankers and special
ships full of containment gear and
teams drilled to the peak of efficiency.
This will be very expensive. For this
reason, we will cut salaries and skip a
few dividends, and we will have to sell
our gas for $3 dollars a gallon. But we're
not worried. We know the American
people are for environmental protection
regardless of cost. That's why we don't
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EPA JOURNAL
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NYT Pictures
think skilled people will leave our
employ, and institutional investors
won't dump our stock, and all those
Americans who are environment-lovers
regardless of cost (that 80 percent!) will
flock to buy our gas."
The extreme improbability of this
scenario is evidence that those who run
corporations regard the
environment-cost tradeoff more
realistically than do environmentalists
or the media. They understand that to
get anything serious done in a market
economy, the government must make it
possible for people to become rich by
doing it. This is how we built the
railroads and the military-industrial
complex, and this is how we can build a
clean environment. But it isn't
happening yet, and the way you can tell
is that nobody is trying to compete in
business on the basis of environmental
quality.
Think of the ads on television. Most
compete on image, many on price and
quality. Nobody, however, says (yet)
"Our product costs a little more, but
that's because we have the
environmentally cleanest plant in the
industry."
Regulation has not helped to move
the day of frank environmental
reckoning closer. The theory behind
current environmental law is that
industries will be held to standards,
usually expressed in terms of the
installation of particular technologies.
Plants can pollute up to a certain point,
but no more, and that level is the
subject of elaborate negotiations and,
generally, the result of much legal
action.
The theory assumes further that as
new technology is developed, the
standards will be made more stringent.
And to a limited degree, this has been
true; a new plant is cleaner than the one
it replaces. But industrial manufacturing
pollution makes up a smaller percentage
of American pollution than it once did.
Right now the real problems are in
transport, land use, energy, and
waste—the lifestyle quartet. There is
thus little incentive for industry to
develop new means of pollution control,
since everybody must march in lockstep
to the current technology-based
standards.
Environmental protection should
therefore be massively refocused to
mobilize rather than suppress the
ingenuity and creativity of industry.
This means that we should seek
additional gains in pollution control
(and that includes reductions in
carbon-dioxide emissions) not by
increasing the stringency or technical
specificity of command-and-control
regulation, but by implementing
incentive-based systems. With such
systems, scarce public sector resources
are magnified by tens of thousands of
decisions by individuals and firms.
For example, market-based
approaches will be a necessary part of
any attempt to reduce "greenhouse" gas
emissions. Here the most attractive
options involve improving energy
efficiency. If the world were to improve
energy efficiency by two percent a year.
global average temperature could be
kept to within one degree Celsius of
present levels. Many industrialized
nations have maintained this level of
improvement during the past 15 years.
Efficiency gains may still have to be
promoted by market incentives when, as
now, energy prices lag behind increases
in income. A "climate protection" tax of
$1 per million BTUs on coal and GO
cents per million BTUs on oil is an
example of such an incentive. It would
raise gasoline prices by 11 cents per
gallon and the cost of electricity an
average of 10 percent and yield $53
billion annually, part of which could be
used to fund environmental protection
efforts on a scale that would give
serious, rather than rhetorical, attention
to the goal of our clean air and water
legislation.
Some form of emissions trading
program will be necessary, and on a
much larger scale than has been the
case so far. Emissions trading is a
natural predicate for reductions in
greenhouse gas emissions on a
JULY/AUGUST 1989
45
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national level and even more so on a
global scale.
In such a program, all major sources
of pollutants (including greenhouse
gases, of course) would be issued
permits specifying allowable emissions.
Sources that could reduce their
emissions below the specified level—for
example by investing in
efficiency—could sell their excess
emissions allowance to other sources.
Firms for whom it might be
prohibitively costly to retrofit or build
new plants could meet their permitted
levels through purchases, or could close
down their least efficient plants and sell
the vacated permits to ongoing firms.
Environmental protection will have
really arrived in this country when such
permits are the subject of frenzied
trading in the Chicago Pit—when, in
other words, environment has become a
central concern of business, like finance
and marketing.
Market-based systems are, of course.
not a panacea. There are some
Steve Deianey photo
environmental problems for which they
are clearly inappropriate, such as the
use of unacceptably dangerous
chemicals, or where irretrievable
environmental damage is likely to take
place. Once again, we must lock into
the wealth-producing mainspring of our
enterprise system. This means applying
the major sanctions that are built into
our environmental laws, sanctions that
say, in effect, if people are getting rich
in a way that adds unacceptably to
pollution, we must act to cut off their
opportunity.
The big sanctions have never been
applied. We have not frozen the road
building or the construction permits or
the sewer hookups. EPA's veto power
over Corps of Engineer-supported
projects has rarely been used. This is
why the recent EPA decision halting the
proposed Twin Forks Dam project in
Colorado was so startling. A dam project
that would have supplied the water
necessary for continued growth in the
Denver metropolitan area was
suspended.
While protesting toxic pollution from
chemical manufacturing, people continue to
demand the products of these processes.
This is virtually the first time the
federal government has acted to place
environmental values above what was
seen by its promoters as a major
area-wide economic expansion. There
now is a movement in Congress to
remove this power from EPA. The
sanctions are "politically unacceptable,"
which is a way of saying that when
push comes to shove, the jobs of
construction workers and the fortunes of
mortgage bankers are more important
than environmental values.
As long as such attitudes do not
change, as long as the real motivators of
daily life (like prices and business
opportunities) do not support
environmental values, then all the
command-and-control regulation in the
world will not stop America from
continuing its highly polluting and
wasteful style of life. And, as a result,
our efforts to get the less developed
nations to protect their environment
will be considered mere cant and
hypocrisy, the frightening changes in
global systems will continue, and the
environment will return the favor by
becoming ever more hostile to human
society.
But Americans are capable of
radically redefining what is politically
and economically feasible in the light of
obvious and compelling crises. Pearl
Harbor and Sputnik are the famous
examples. Whether we can accomplish
such a redefinition in response to a
crisis that is more tentative and diffuse,
and where our own desires and material
values are the "enemy," remains to be
seen, n
(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.)
46
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Appointments
F. Henry ("Hank") Habicht II
is the new Deputy
Administrator of EPA.
From 1984 to 1987,
Habicht was Assistant
Attorney General in the U.S.
Department of Justice, a
period in which the number
of civil and criminal
environmental enforcement
prosecutions more than
doubled. He first joined the
Department of Justice in 1981
as special assistant to
Attorney General William
French Smith and served as
Deputy Assistant Attorney
General from 1982 to 1983.
At the Department of
Justice, Habicht directed the
Land and Natural Resources
Division, which handles all
federal government litigation
concerning environmental,
energy, and land and
resources management
matters. He also formed and
chaired the National
Environmental Enforcement
Council, which promotes
coordination of federal and
state environmental
enforcement actions.
Since 1987, he has been
counsel to the Seattle law
firm, Perkins Coie, and was
Vice President of William D.
Ruckelshaus Associates,
Washington, DC, with
responsibility for counseling
on environmental, natural
resources, and energy issues.
He is an alumnus of the
Woodrow Wilson School of
Public and International
Affairs at Princeton
University, where he was
president of the rugby club.
He holds a law degree from
the University of Virginia.
Timothy B. Atkeson has been
nominated by President Bush
to be Assistant Administrator
for International Affairs of
EPA, a new position that
replaces the Associate
Administrator.
When the Council on
Environmental Quality was
created in 1970, Atkeson was
appointed General Counsel
and served there until 1973.
He has been a partner with
the Washington, DC, law firm
of Steptoe and Johnson since
1975.
Atkeson was co-author of
"Superfund Deskbook,"
published in 1986, and
"Superfund: Litigation and
Cleanup," published in 1985.
He has taught environmental
law at Georgetown Law
School, Dartmouth College,
and Catholic University Law
School.
In 1958, he began a
three-year term as Deputy
General Counsel with the
U.S. Development Loan
Fund, followed by a year as
Regional Legal Advisor for
Latin America with the
Agency for International
Development. He was an
associate and partner at
Steptoe and Johnson from
1962 to 1967.
From 1967 to 1969,
Atkeson was the first General
Counsel of the Asian
Development Bank in Manila.
Most recently, he served as
Special Counsel to the High
Level Review Committee at
the Inter-American
Development Bank, in 1988.
He graduated from Haverford
College in 1947, attended
Oxford University as a
Rhodes Scholar from 1947 to
1949, and earned a law
degree from Yale University
in 1952.
Charles L. Grizzle was
reappointed as Assistant
Administrator for
Administration and
Resources Management. He
has served in the same
position since February 22,
1988.
Before joining EPA, Grizzle
had been Deputy Assistant
Secretary for Administration
at the U.S. Department of
Agriculture (USDAJ since
1983. He joined USDA in
1982 as a special
assistant to the Secretary, and
also served as a staff assistant
to the director of the Office
of Operations and Finance.
From 1974 to 1981, Grizzle
was an officer of First
National Bank of Louisville,
Kentucky. He also served
briefly in 1981 as executive
director of the Republican
Party of Kentucky.
He earned his bachelor's
degree in English and
political science from the
University of Kentucky in
Lexington. In 1987, he
successfully completed the
Senior Managers in
Government program at the
Kennedy School of
Government at Harvard
University.
Robert G. Heiss is the new
Associate Enforcement
Counsel for Water, in the
Office of Enforcement and
Compliance Monitoring.
Heiss had been the Deputy
Chief Counsel for Operations
in the Economic Regulatory
Administration at the
Department of Energy before
joining EPA in February of
this year. From 1985 to 1988,
he served as Deputy Special
Counsel in the same agency.
A 1971 graduate of Harvard
Law School, Heiss joined the
Department of Energy in
1975 as an attorney-advisor
in the Office of the General
Counsel. In 1978, he was
appointed Assistant General
Counsel for Enforcement.
Heiss earned his bachelor's
degree in history from
Williams College. After
graduating from law school.
he worked for the
Washington, DC, law firm of
Brownstein, Zeidman, &
Schomer specializing in
franchising law.
47
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Dr. Ralph H. Hazel was
appointed as Senior Office of
Research and Development
Official for EPA's
Environmental Research
Center. The center is located
in Research Triangle Park,
North Carolina.
As Senior Official, Hazel
will be the principal
spokesman for the center and
will direct the Research and
Development Services Staff,
with special emphasis on
enhancing community
outreach programs.
Hazel had been the Senior
Science Advisor to the
Regional Administrator of
EPA's Region 7 in Kansas
City, since 1983. From 1979
to 1983, he was Director of
the Johnson County
Environmental Department in
Kansas.
Hazel earned his bachelor's
degree in chemistry from the
University of Central
Arkansas, his master's degree
in chemistry from the
University of Arkansas, and
his doctorate in
environmental engineering
from the University of
Kansas. He has taught
environmental science at
both the high school and
college levels.
He has also been awarded
two EPA Silver Medals for
Superior Service and a
Bronze Medal for
Commendable Service.
EPA Administrator William
K. Reilly recently announced
the retention of the Regional
Administrators for EPA
Regions 4 through 10. Their
names and brief biographical
sketches follow:
Greer C. Tidwell has been
Regional Administrator for
Region 4, headquartered in
Atlanta, since March 1988.
Previously, he operated his
own environmental
engineering firm. He earned
his bachelor's and master's
degrees in engineering from
Vanderbilt University.
Valdas V, Adamkus has
been Regional Administrator
of Region 5, headquartered in
Chicago, since 1981. He
served as a director of the
Ohio River Basin Regional
Office in Cincinnati before
joining EPA. Bom in
Lithuania, he attended the
University of Munich and
holds a bachelor's degree in
engineering from the Illinois
Institute of Technology.
Robert E. Layton has been
Regional Administrator of
Region 6, headquartered in
Dallas, since February 1987.
A Texas native, Layton
earned a bachelor's degree
from Texas A & M University
in engineering and ran his
own engineering firm before
joining EPA.
Scherer
McGovern
Russell
Morris Kay has been
Regional Administrator for
Region 7, headquartered in
Kansas City, Kansas, since
1982. Kay spent three terms
in the Kansas House of
Representatives, where he
was majority floor leader. A
Kansas native, he earned his
bachelor's degree from the
University of Kansas.
James J. Scherer has been
Regional Administrator for
Region 8, headquartered in
Denver, since April 1987. He
operated his own car rental
and leasing business in
Denver and served two terms
in the Colorado legislature
before joining EPA. An
Indiana native, Scherer
earned his bachelor's degree
from the University of Notre
Dame.
Daniel McGovern has been
Regional Administrator for
Region 9, headquartered in
San Francisco, since
February 1988. Previously, he
served as General Counsel of
the National Oceanic and
Atmospheric 'Administration
and as principal deputy legal
advisor to the U.S. State
Department. He earned a law
degree from UCLA School of
Law.
Robie Russell has been
Regional Administrator of
Region 10, headquartered in
Seattle, since 1986. He served
as Senior Deputy Attorney
General and Deputy Attorney
General for the state of Idaho
before joining EPA. A native
of Idaho, Russell earned a
bachelor's and a law degree
from the University of Idaho.
As EPA Journal reported
last issue, Ted Erickson was
named the Regional
Administrator for Region 3,
which is headquartered in
Philadelphia. A new Regional
Administrator for Region 2,
headquartered in New York,
has not yet been selected.
Recently, President Bush
announced his intention to
nominate Michael Deland,
currently Regional
Administrator for Region 1,
headquartered in Boston, to
be Chairman of the White
House Council on
Environmental Quality. Until
he is confirmed by the
Senate, Deland will continue
to serve as Regional
Administrator, ™
48
EPA JOURNAL
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Sea oats guard the dunes on South
Carolina's coast.
Back Cover: Rio de Janeiro,
Brazil. As human development
spreads across the globe,
existing institutions face
unprecedented challenges.
Photo by Stephanie Ma/e for Woodfm Camp, /nc
Pay Muzika photo. Coastal Photo Service
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