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Reorganization
Q: Since the 1970s, well, since the 1960s really, ecologists, and environmentalists listening to ecologists, have looked for ways to make pollution control cross-media so that by cleaning one pollutant you're not dumping it into another medium. When you came into office, at an event celebrating EPA's 20th anniversary, a couple of former Administrators said that you didn't need to reorganize the Agency along cross-media lines. They counseled you against that and you seemed to have taken their advice. What compelled you to follow their advice? Why didn't you reorganize the Agency along cross- media lines?
MR. REILLY: There are a couple of explanations for my decision not to reorganize the Agency, and the most important and fundamental is reorganization involves tremendous costs in terms of time, organization, and momentum. I didn't know how much time I had and certainly when I began to have some of the conflicts with the White House Chief of Staff, Budget Director, later with the Vice President, I thought my tenure might be short and I didn't want to sacrifice any of that time to reorganization.
The goals of cross-media policy that I cared about, I tried to achieve by making them part of my ten priorities at the Agency by asking questions of our Assistant Administrators in a cross-media way, by having joint teams on a number of task forces and problem-solving exercises. I think the Agency got in the habit of thinking of itself more as a unit, as a coherent entity concerned with the environment as opposed to air, water, waste, or toxics. Raising the ecological profile also had that effect because the ecology is not something that allows you to segregate. It's the place where you see it whole. My ecological initiatives, for the Great Lakes, national estuaries, and the geographic initiatives I championed, these all involved a cross media perspective to administer. And we targeted enforcement priorities on cross media problems by requiring that a significant percentage of enforcement actions involve suits for violations of more than one statute. When the problem posed is not this steel plant or that leaking dump, but the restoration and protection of one of the Great Lakes, it forces you to look at the problem whole, to ask, what is the most effective thing I can do to clean up and protect the lake? One has to look at air, water, enforcement, toxics, voluntary programs, and the contribution that all of them make. That's just the way I like it. One reason I like geographic initiatives and talked about them so much is because that's the way the world is, and certainly the way the public sees it. They don't see it in media compartments.
A second reason for not addressing the cross-media problem by reorganization is that the reorganization would have to be very fundamental. I think it finally should come, but it should come as a consequence of a statute that integrates the various media. I had such a statute Terry Davies had drafted one when he worked for me at The Conservation Foundation and I often discussed with him the possibility of just putting that out for comment, trying to raise attention to it, focus on it, get the community at-large discussing it. He thought, and most others thought, that this was both thankless - it would have had costs in terms of threatening some Congressional committees - and hopeless. There was no way, in the time we had, that the Congress was going to do anything about the cross-media problem.
We set out to move the Agency to a cross-media perspective by the priorities we set, the training and education we provided our staff, and also through some very important and influential demonstrations we conducted. The best known of these was the work we did with the Amoco Company at their refinery in Yorktown, Virginia. The analysis we jointly carried out there proved that by asking the question, "What is the best way to intervene in the process to improve the overall environment?," a better, more cost-effective reduction of critical pollutants can be obtained than by merely marching through the various media making emission and effluent reductions. So I was never persuaded that reorganization is the best way to achieve a cross media orientation, and I'm not sure I would counsel my successor to engage in much reorganization either. Obviously, one can achieve these things differently. Perhaps more personnel movement within the Agency is appropriate at this time, given that there's been a lot of continuity for some time in some of the programs and it might be healthy to open them up a little bit, get people into the habit of dealing with a couple of the media.
We did think a good deal about reorganization. Of the more modest but still important reorganizing moves I made, I should mention that I established a new Science Advisor in the Administrator's office and created the post of Scientific Advisor to each of the Assistant Administrators and the Regional Administrators. Those, obviously, are integrating kinds of functions. But, I can recall talking to Russell Train before I even took over at EPA who said, reorganizations just mean huge interruptions of the forward momentum, the progress of an agency, and one has to have a very large reason to do that to an agency. I'm conscious now what a terrific drain a change of Administrations is. The hiatus that occurs as you try to get new people in place, get their names cleared by the White House, get them investigated by the FBI, get their names up to the Congress and get them confirmed by the Senate. To add reorganization on that at the beginning of a term will leave you with very little to show for your efforts two years out.
You look at the current Administration at EPA and I'm often reminded, by this time on our watch, six months into our term, we had dealt with the Exxon Valdez oil spill, made a decision to begin the veto process of the Two Forks Dam, dealt with the Alar crisis, proposed new food safety legislation, reorganized Superfund, and proposed a comprehensive new Clean Air Act. We also moved a considerable distance towards having a new farm bill. It was a much faster start, and undoubtedly, some of the current slowness is a consequence of a change of Administrations that involves more than just administration, it involves a change of party with all new faces in the top positions, and delays in identifying them and getting them confirmed. The country does pay a price for doing things this way. To add a reorganization onto that as an early order of business is essentially saying to the world, "We're going to take two years off and rethink ourselves, we hope you're still there when we come back." I didn't want to do it.