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Functional organization
Q: One of EPA's early goals was to mount a cross-media attack on pollution by organizing the agency functionally. Why did the agency not continue to pursue that goal? In hindsight, was that the right decision?
MR. ALM: EPA's major legislative enactments are all based on media - the Clean Water Act, the Clean Air Act, et cetera. Therefore, EPA's programs and organization tend to be based very heavily on media. Some of EPA's offices are functional, e.g. Research and Development, Enforcement and Compliance Monitoring and the General Counsel's office. But EPA has always retained media-based programs to mirror legislative authorities.
There has been talk about organizing differently, but I don't expect any fundamental reorganization, unless Congress provides EPA greater latitude in operating its programs. As we stand now, different program deadlines are provided specifically in each major statute. There is no broad legislation that requires you to have an environmental permit by such-and-such a date. Instead, the Clean Air Act sets requirements and deadlines for air emissions and the Clean Water Act sets different requirements and deadlines for water effluents. From a management point of view, organizing functionally in that kind of legislative environment becomes very, very difficult.