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ORD and labs
Q: You and Al Alm have both pointed out that EPA had a tremendous economic analysis capacity. Do you feel the same way about its scientific capacity, its ORD and lab programs?
MR. COSTLE: I think it was more uneven. Agency research presents a very interesting set of issues. One of the debates the Ash Council had had was over how much direct science research responsibility EPA should have. There was so much relevant research going on throughout government that was arguably environmentally related. For example, studies of wind-blown soil in the Agriculture Department had direct relevance to air transport of pesticides.
There was too much of such related research to collar each piece and bring it into EPA. Roy Ash felt strongly, and the rest of the Council basically agreed, that you had to start with: 1) enough research competence at EPA to know where the outside research was being done, whether in academia or in the government, and 2) sufficient expertise in-house to appreciate the value and quality and quantity of that research. EPA's role would be to act as a kind of wheel to balance that research, spot holes and vacuums, and essentially piece together a holistic approach, recognizing that all the research work would not be done at EPA. I think the Council members underestimated the difficulty of one government agency telling another what to do or what to research. And they clearly underestimated OMB's unwillingness to fund environmental or regulatory-related research. So EPA started out essentially with a minimal scientific organization and a huge regulatory assignment.
There has always been something of a tension between the scientists who want to study next year's problem and the rulemakers, who want an answer right now about this or that issue. As a partial counter, there has always been a certain amount of scientific skill within the program offices. But ORD always had the responsibility, for example, for preparing the air criteria documents and for funding the major studies. I would have liked to have seen a much more generous ORD base in the agency. But unfortunately, one of the first things that gets sacrificed in tight budget times is ORD money. And, by the time President Carter came in, federal budgets were already beginning to shrink.
When you have a court order or a legislative deadline to have a certain rule out in 180 days, your money is going to go to that before it goes to doing research -- which may conclude that you've been looking at the wrong problem all along. Some of this dilemma is solved as our wisdom accumulates. We get better about asking the right questions, targeting R&D dollars. But I think there is probably a need to reexamine how and what research EPA conducts.
The Agency has suffered from the historical ambivalence about its science responsibilities, going back to the Ash Council deliberations. How big a science base does EPA need? It can't have everything, because there's too much scattered around that's relevant. Not only couldn't you consolidate it all, but maybe you want much of it being done elsewhere, where it can perhaps better influence other agencies in their thinking about problems. You want the Agriculture Department to be concerned about air pollution; you want it doing certain of the studies.
So EPA was cast as the balance wheel. I've always thought the Agency needs a stronger science base of its own, but I don't think it necessarily has to be done in in-house labs. It could be conducted in intellectual centers around the country, in universities, for example. But we need to be improving the quality and range and scope of environmental science overall. There's plenty of room for experimentation in terms of institutional arrangements.
I also think that other factors affect EPA's science. Obviously, the resource base is a very important constraint. Another obvious constraint is the tension between the need for short-term results to help the regulatory policymaker make a decision this month, versus longer-term research that, hopefully, will identify what environmental problems the Agency should be worried about four and eight years or longer from now. That tension between the long-term and the short-term fire fighting is just inherent, and you can't do much to stop it. These notions of splitting research off from the Agency, of having a separate science agency, I think would not help at all.
The underlying problem is the nature of the science: trying to get certainty from science, when the science isn't advanced enough to yield it. Meanwhile, you have this public demand for action, so balancing the two is very important. The approach must be a public health approach, which means you don't want to wait. If you delay until dead bodies pile up, you've blown it. That's a mistake you don't want to make as a society.
I always thought that part of the solution was having independent research centers -- on the lines of NIH. They should be subsidized to grow and, ideally, become great institutions, whether they were university-affiliated or not. From them -- perhaps as a quid pro quo for funding -- EPA could buy targeted research and pose certain questions for rapid responses. That would be preferable, I believe, to trying to build a national lab, which may take on a life of its own and may not be all that helpful. Today, when you think about it, the reality is that there is much more environmental research going on than ever before, and EPA has an even harder job keeping track of it.