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Protecting the Environment: EPA's Role

Philip H. Abelson's editorial "Pathological growth of regulations" (25 June, p. 1859) presents several generally valid and widely shared views about the way the United

. States strives to protect humans and ecosys- tems. However, in highlighting its short- comings, he offers only passing acknowl- edgement of the many strengths and achievements that make the U.S. environ- mental protection effort the best in the world. And. in focusing on environmental "

regulations, he paints a distorted picture of the role of the U.S. Environmental Protec- tion Agency (EPA) .

Before the 1960s. environmental Drotec- tion was primarily the province of conser- vation advocates. The general public paid little attention to potential health hazards associated with environmental pollutants or to the ecological consequences of anthro- pogenic stresses. Even within the scientific communitv. few other than ecologists ad- , , - dressed these issues in a disciplined, com- prehensive manner.

By the 1960s, people no longer could ignore the numerous reminders of envi- - ronmental-degradation: for example, bod- ies of water polluted by human and in- dus'trial wastes, cities blanketed by smog, and wildlife poisoned by pesticides. The problems and the public response inspired a succession of congresses and presidents to enact a series of laws keyed specifi- cally to cleaning up water, air, or land. In most instances, the environmental degra- dation being addressed was so significant that remediation throueh a medium-s~e- - cific, command-and-control, one-stan- dard-fits-all approach was appropriate. Until recently, the scientific community did far more to develop and refine this orientation than to oppose it or offer alternatives.

Now, and for the foreseeable future, environmental protection presents new and more complex challenges, especially in settings where traditional strategies have gone as far as they can. That is why EPA has made a commitment to foster pollution prevention rather than to rely exclusively on end-of-pipe controls. At the same time, EPA is reshaping its envi- ronmental protection efforts to reflect ec- osystem-wide approaches. We are commit- ted to emphasizing public-private partner- ships for vo1untq-y efforts outside regulato-

ry frameworks. Also among our new concerns is environmental justice, so that minorities and other disadvantaged popu- lations will no longer face disproportion- ately large risks from environmental haz- ards. And, to catalyze progress in all these areas, we are promoting a much more aggressive agenda to enhance the public's understanding of environmental issues and of the associated science.

Science clearly is central to all of these issues. Indeed, the needs and opportuni- ties for scientists to make a difference-in refining short-term regulatory require- ments and in pursing long-term strategic goals-are almost unlimited. The Science Advisory Board of EPA has shown invalu- able leadership in this regard, especially through its advocacy for quality science and risk-based priority setting. I look for- ward to the increasing participation of the scientific community in the quest for cost- effective environmental stewardship.

Carol M. Browner Administrator,

U.S. Environmental Protection Agency, Washington, DC 20460

Abelson adds his voice to the growing chorus of opposition to environmental regulation in his editorial "Pathological growth of regulations." After throwing around a host of large numbers of ques- tionable relevance. he concludes that "easy, cost-effective changes have largely been made, and additional federal require- ments will result in diminishing returns." This conclusion is presented without sup- porting arguments, evidence, or studies. Does Abelson truly believe (to take the environment as an example) that there is no more room in this country for environ- mental im~rovements? Or that these im- provements cannot be achieved through regulation? Or that there is no possibility of cost-effective regulation? I find nothing in the environmental literature (including Science's special report "Environment and the Economy" in the same issue) to sup- port any of these conjectures.

Abelson implies that environmental reg- ulations are economically strangling both cities and small businesses. Once again, he provides no real evidence to show that either cities or businesses have been hurt, especially in a way that might offset the tangible benefits of, say, requiring adequate wastewater treatment or ensuring work- place safety.

SCIENCE VOL. 261 10 SEPTEMBER 1993 1373

Finally, I doubt that most of the general public would agree with Abelson's implica- tion that the imposition of "huge fines and jail sentences" for violating environmental law is somehow a symptom of regulatory pathology.

As more and more scientists venture into the arena of public policy they are proving a valuable point: scientists, no matter how expert at their craft, are no wiser than anyone else when it comes to public policy.

David Sarokin 3734 Appleton Street, NW,

Washington, DC 2001 6

As an EPA scientist involved in the de- velopment of regulations, I can sympa- thize with the concerns that Abelson re- fers to in his editorial on the "pathological growth of regulations." His series of edi- torials on EPA-related topics are usually posted on the wall in the office and are widely circulated. Many of his comments are on the mark and well received. In at least one respect, however, I find that this editorial reflects an unscientific attitude.

Quoting a frustrated urban official be- moaning that "EPA rules are written in Latin with Greek footnotes," Abelson

notes, as presumably an illustrative exam- ple, that over 130 chemicals must be mon- itored in the drinking water supply, "some of them in the part per billion or lower range"!

If the standards are too stringent or too many, they should be reevaluated and revised. But this ought to be done on scientific or at least rational grounds. Most average issues of Science probably contain more Latin and Greek than most EPA rules. It would be ironic if a movement to reduce regulations on the grounds that they are too many or the levels too tiny ,found inspiration from an association with the aim of advancing science. Verburn sapientiae sat.

William F. Sette 7 East Walnut Street,

Alexandria, V A 22301

I think most people agree that federal en- vironmental regulations are lengthy, com- plex, burdensome, and expensive. Most also agree that death, taxes, sin, and high dietary fat are loathsome. Wouldn't it be nice if corporations, small business, and people in general respected each other and the environment and we didn't need any regulations.

To the extent that regulations, like roads and bridges, new automobiles, or the latest computer software are imperfect, perhaps they are reflections of the human condition. I don't think it is particularly helpful to complain about the problem without offering constructive solutions.

Gregory C. Pratt 3206 38th Avenue South, Minneapolis, MN 55406

As a reformed regulator and former state natural resources director, I found Abel- son's editorial on EPA regulations curious- ly lacking in vision. The current U.S. approach to environmental protection, a product of the early 1970s, is no match for the environmental and economic chal- lenges that we now face.

Just because cities and towns do not have sophisticated monitoring systems, should we ignore chemicals in drinking water, the most direct route of human exposure? Just because small businesses do not like to keep track of the chemicals they use, should communities not have the right to know about their exposure to chemicals? EPA's regulations have been strict and comprehensive because that is what the law requires. They have done

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much to protect our health and environ- ment.

Is a new paradigm needed for environ- mental governance in the United States, one reflecting a basic shift in emphasis from restriction to incentives and from reacting after the fact to anticipating fu- ture needs and opportunities? As co-chair of the President's Council on Sustainable Development, I believe the timing is right to bring diverse resources together as we stake out new directions. Manv in the environmental and industrial communi- ties agree that the next generation of environmental policy must achieve greater results and do so more efficiently. From now on, our goal must be to prevent pollution by motivating potential polluters to a d o ~ t new .techniaues and technolo- gies. This new approach would harness technology as an environmental ally, stress least-cost solutions, and encourage companies to go beyond the minimum required to meet standards. As it proves itself, this new model should replace the old command-and-control regulation.

Jonathan Lash President.

World Resources Institute, 1709 New York Auenue, NW,

Washington, DC 20006

Corrections and Clarifications

A table in the article "Science elites envy American cohesion" in the special section on Science in Europe (18 June, p. 1738) incor- rectly ranked the National Institute of Stan- dards and Technology (NIST) second among U.S. institutions in terms of citations per chemistry paper. The table was compiled by the Institute for Scientific Information (ISI), which inadvertently used only older papers by authors identified as being from the National Bureau of Standards, NIST's former name, to calculate NIST's cication rate from 1988 to 1992. When more recent NIST papers, which have had less time to be cited, are included, NIST's cication rate drops from 8.94 to 5.27 cites per paper.

An asterisk indicating that he was a correspond- ing author should have appeared next to Mark D. Bednarski's name in the list of authors of the report "Direct colorimetric detection of a receptor-ligand interaction by a polymerized bilayer assembly" by D. H. Charych et al. (30 July, p. 585).

In the table in the article "Can sustainable farming win the battle of the bottom line?" by Bob Holmes (Environment & the Economy, 25 June, p. 1893), the second and third lines in the legend should have read, "Alt. #1: conventional corn-soybean rotation with re- duced tillage. Alt. #2: organic corn-beans- (wheat+clover)-clover-corn rotation with re- duced tillage."

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