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editorial How to tackle the EPA credibility gap I f there is one piece of environmental information that consistently impinges on the editorial staff of ES&T, it is that no one seems to know exactly what ”the feds” are doing. Or if, by some miracle, some- one does know what, he doesn’t really know why. On the face of it, this looks like a sheer case of poor public relations for which the public rela- tions departments of EPA and the other federal agencies should be rapped hard on the bureaucratic knuckles. But there is more to it than that. The fact is, what the government is doing and why it is doing it changes al- most weekly, in response to a bewildering array of pres- sure groups, ranging from militant environmentalists to the Oftice of Management and Budget. It is sad, but nevertheless true, that EPA has spent much of the two years it has been in existence trying to outguess its many critics and (unsuccessfully) trying to get a jump on what it might be asked to report on/study/analyze/ implement next. For instance, our September story on effluent guidelines (page 786) described how the EPA water programs people are currently working up per- formance standards that will be needed under terms of an act that hasn’t even been passed yet (or hadn’t at press time). Without this jump, the EPA people feel they couldn’t possibly meet the time requirements in the law. Of course, if requirements in that law change drastically, EPA may yet be caught flatfooted. Part of the blame for this sorry state of affairs can indeed be laid at the door of EPA people themselves. By failing to raise- publicly and under- standably- the technical issues that lie behind regula- tory (i.e., political) decisions they have unwittingly aided and abetted the perpetrators of the myth that all things are technically possible. And by burying technical ex- pertise under stifling layers of nontechnical bureaucrats and political appointees, EPA‘S top management has done a disservice to the whole technical community and the country at large. Behind the agency’s bureaucratic facade, there are- or should be--technical voices pleading to be heard Congress, too, must shoulder some of the blame for a situation in which the executive branch of the government cannot adequately explain to those it regulates the whys and wherefores of its regulations. On the one hand, it has effectively tied EPA’S hands, as in the 1970 Clean Air Act amendments where per- centage reductions in automotive pollutant emissions were mandated without benefit of a clear technical basis that EPA could use tojustify its regulations. On the other, Congress has shown a disturbing penchant for writing into law vague terms such as “best practicable tech- nology” and “zero discharge.” Frankly, we feel that some better means of communication than we now have is urgently needed. The Federal Kegister may be fine for lawyers, but it is inadequate for almost everyone else. To this end, we are happy to present in this month’s ES&T two feature articles (pages 884 and 890) written by technical personnel in EPA. Both are aimed at explaining why the agency did what it did in two instances in- volving technical expertise and judgment. We think that they deserve reading by all who think the agency acts arbitrarily and by those who genuinely are con- cerned over the lack of visible justification for federal regulations. In the final analysis, it will take a major effort both within and without EPA to ensure that every- one understands both what the agency is doing and why it is doing it. ES&T will, of course, continue to try to interpret for readers, as we have in the past, but su” ;cess may ultimately depend on the skill, perseverance, and sheer guts of technical men and women in govern- ment service. We wish them well. Volume 6, Number 10, October 1972 861

Editorial. How to tackle the EPA credibility gap

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editorial

How to tackle the EPA credibility gap

I f there is one piece of environmental information that consistently impinges on the editorial staff of ES&T, it is that no one seems to know exactly what ”the feds” are doing. Or if, by some miracle, some- one does know what, he doesn’t really know why.

On the face of it, this looks like a sheer case of poor public relations for which the public rela- tions departments of EPA and the other federal agencies should be rapped hard on the bureaucratic knuckles. But there is more to it than that. The fact is, what the government is doing and why it is doing it changes al- most weekly, i n response to a bewildering array of pres- sure groups, ranging from militant environmentalists to the Oftice of Management and Budget. It is sad, but nevertheless true, that EPA has spent much of the two years it has been in existence trying to outguess its many critics and (unsuccessfully) trying to get a jump on what it might be asked to report on/study/analyze/ implement next. For instance, our September story on effluent guidelines (page 786) described how the EPA

water programs people are currently working up per- formance standards that will be needed under terms of an act that hasn’t even been passed yet (or hadn’t at press time). Without this jump, the EPA people feel they couldn’t possibly meet the time requirements in the law. Of course, if requirements in that law change drastically, EPA may yet be caught flatfooted.

Part of the blame for this sorry state of affairs can indeed be laid at the door of EPA people themselves. By failing to raise- publicly and under- standably- the technical issues that lie behind regula- tory (i.e., political) decisions they have unwittingly aided and abetted the perpetrators of the myth that all things are technically possible. And by burying technical ex- pertise under stifling layers of nontechnical bureaucrats and political appointees, EPA‘S top management has done a disservice to the whole technical community and the country at large.

Behind the agency’s bureaucratic facade, there are- or should be--technical voices pleading to be heard

Congress, too, must shoulder some of the blame for a situation in which the executive branch of the government cannot adequately explain to those it regulates the whys and wherefores of its regulations. On the one hand, it has effectively tied EPA’S hands, as in the 1970 Clean Air Act amendments where per- centage reductions in automotive pollutant emissions were mandated without benefit of a clear technical basis that EPA could use tojustify its regulations. On the other, Congress has shown a disturbing penchant for writing into law vague terms such as “best practicable tech- nology” and “zero discharge.”

Frankly, we feel that some better means of communication than we now have is urgently needed. The Federal Kegister may be fine for lawyers, but it is inadequate for almost everyone else. To this end, we are happy to present in this month’s ES&T

two feature articles (pages 884 and 890) written by technical personnel in EPA. Both are aimed at explaining why the agency did what it did in two instances in- volving technical expertise and judgment. We think that they deserve reading by all who think the agency acts arbitrarily and by those who genuinely are con- cerned over the lack of visible justification for federal regulations.

In the final analysis, it will take a major effort both within and without EPA to ensure that every- one understands both what the agency is doing and why it is doing it. ES&T will, of course, continue to try to interpret for readers, as we have in the past, but s u ” ;cess may ultimately depend on the skill, perseverance, and sheer guts of technical men and women in govern- ment service. We wish them well.

Volume 6, Number 10, October 1972 861