oversight

Creation of a Department of the Environment (S. 2006)

Published by the Government Accountability Office on 1990-02-08.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                      United States General Accounting OffIce

GAO                   Testimony




For Release           Creation of a Department
on Delivery           of the Environment   is. 2006)
Expected    at
9:00 a.m. EST
Thursday
February    8, 1990




                      Statement    of
                      J. Dexter    Peach, Assistant   Comptroller      General
                      Resources,     Community,  and Economic     Development
                      Division

                      Before   the Committee    on Governmental     Affairs
                      United   States Senate




GAO/T-RCED-90-26                                                     GAO Form 160 (12,‘W
Mr. Chairman            and Members of the Committee:


        We appreciate              the    opportunity             to appear         here    today         to     present
our views            on the creation              of a Department            of the Environment                    and on
Senate      Bill       2006.       Accompanying             me is Richard            L.    Hembra,          Director
for    Environmental              Protection            Issues,     U.S.     General        Accounting             Office
(GAO) .


        Conferring           Cabinet           status     on the Environmental                  Protection
Agency      (EPA) not          only      symbolizes             the growing         importance            of the
agency.         It     is also        an action          that     should,      in the       long      term,
position        the     agency        to address          more effectively                the   complex
environmental            challenges             this     nation     will     face      in coming           years.


        Since        EPA was created               in 1970,        the nation's            understanding                of
environmental            problems         has grown enormously,                     and with        it,        EPA's
responsibilities.                  Today,        EPA's mission,             size,      and scope of
responsibilities               place      it     on a par with             many Cabinet          departments.
From my own involvement                        in GAO's work at the                 Departments            of Energy,
Interior,          Agriculture           and Transportation,                 I am very          aware of the
interplay          between        environmental            issues      and the programs                   of these
departments.


        Elevating         EPA to Cabinet                status      should      help       ensure         that
environmental            policy        is given         appropriate          weight        in relation             to
domestic      and foreign              policies         that      are carried          out by other

                                                           1
Cabinet           departments.                 Conferring          Cabinet     status          on EPA would          also
help       its         head   deal       effectively          as an equal            with     counterparts           in

the    federal             government            as well      as in the        international               community.

Finally,               establishing            the head of EPA as a Cabinet                        member would,
from a long-term                     institutional            standpoint,            make clear          the
organization's                 direct          access      to the        President          on environmental
matters.



           The remainder                 of my statement             expands         on these         points      and
presents           our views             on:
           --     the growth             of EPA and of environmental                         issues;
           --     the      relationship            of environmental             protection              to other
Cabinet           departments             and policies;
           --     other       criteria          by which       to assess        the         elevation       of EPA; and
           --     organizational                and management issues                  identified           in our        past
work which               are reflected             in the proposed             legislation              before     the
                                                            ,
Committee.


GROWTHOF EPA AND ENVIRONMENTAL ISSUES


           It     is     important         to understand             how different              the     EPA of     1990
is    from the             EPA of        1970.       Today,        the    agency      administers           nearly        a
dozen major                environmental             statutes.            Most of these            statutes        had not
yet    been enacted                  when EPA was created--even                       those      that     were on the
books,           such as the             Clean Water Act,                were completely              revamped       in       the
1970s.            From its           first-year         expenditures           of $384 million,                  EPA's

                                                               2
annual       outlays            have risen            to over          $5 billion.            And as-a           percentage
of total          federal          outlays,           EPA's share           has more than              doubled           since
1970.


          Of even greater                    significance            than        federal      outlays,         however,             is
the      effect      of EPA's programs                     on our national                  economy.
Environmental                  cleanup        has cost         the nation            well     over     $700 billion
thus      far.       We now spend over                     $86 billion             a year,        or about         2 percent
of our GNP, on pollution                            control         and regulation.                In fact,            a whole
new sector           of the            economy has grown around                       pollution          control.             In

the      early     197Os,          federal          programs         controlled             the most visible                 types
of pollutants--                 what comes out                of smokestacks                or goes into           sewers.
Since      then,         the     federal         government            has assumed responsibility                            for
regulating           the        less     visible,          but more pervasive,                    aspects         of
pollution:               the     toxic        chemicals         manufactured,                the methods           and
location          of hazardous                waste      disposal,          and the          cleanup      of
chemically           contaminated                lands        and water.


          In the         future,         the     federal        role       in environmental               protection                is
likely       to grow even larger,                        especially          as environmental                  problems
become increasingly                      international.                  While       we have improved                  our    air
and water          quality             in some respects,                 these       problems        continue           to dog
us.       The cleanup              of hazardous             waste        sites       is clearly          going         to
continue          well      into       the     next      century,         as are efforts               to reregister
pesticides.               And even as we move to try                             to get       a handle         on old
problems,          we discover               new ones,          like      global       warming,          toxic         air

                                                                3
pollutants,               and indoor           air     pollution.               Moreover,        the    solutions         to
some of these                problems--         like        global        warming      and the depletion                of
the stratospheric                   ozone layer--will                     require      a degree         of
international                cooperation             that      may be unprecedented.                        To sum up,
the    number,            scope,       and persistence                 of environmental                problems        are
strong          arguments          in favor          of Cabinet            status      for    environmental
issues.


RELATIONSHIP OF ENVIRONMENTAL PROTECTION
TO OTHER DEPARTMENTSAND POLICIES


          As our awareness                    of environmental                 problems       has increased,              and
as EPA's role                has expanded;                 environmental            policy       has steadily           come
to play          a critical            role     in shaping             other      domestic        and foreign
policies.             The President's                  proposed           amendments to the                 Clean Air
Act,      for      example,        calling           for      a switch         to cleaner         fuels       and cleaner
coal-burning                technologies,              are directly              linked      to the         nation's
energy          policies.          The United               States'        participation           in the
international                agreement          to phase out the                  production           of
chlorofluorocarbons                     (CFCs) shows how our environmental                                   policy     has
been integrated                 into     our trade             and foreign           policies.              As we begin
to address            global       climate           change,          we will       have to examine              a host        of
policies,           including           energy,            agriculture,           overseas        assistance,
foreign          trade,       and national                 security,        among others.




                                                                 4
          Because EPA is the                    federal        organization                responsible                for
identifying             and representing                environmental                   interests            before         the

rest      of    the     government,            EPA interacts               regularly             with        the
Departments             of Agriculture,                Defense,         Energy,            Interior,               State,
Transportation,                 and so on.             Compared to many of these                              departments,
EPA's interests                 and responsibilities                    are equally                 wide-ranging.
Furthermore,             its      expenditures            are about             the      same as the                Department
of the         Interior's;            are     larger      than      both        the      State       and Energy
Departments'              (excluding           DOE's atomic             energy           defense         activities),
and are twice                those         of the Commerce Department.


          Moreover,            as demonstrated             by numerous                  GAO reviews,                other
federal         agencies         do not always             provide          the         support         and cooperation
necessary          to    further           environmental            policy         goals.            Instead,
roadblocks            are often            created      by jurisdictional                     conflicts,
organizational                 structures,           and cultures               that      are not            conducive             to
cooperation             with     EPA or that            place       a low priority                   on environmental
protection.              In some cases,                the outcome              of these            problems           has been
serious.           We see,           for     example,      that       years        of ignoring
environmental                consequences            at Defense          and Energy                 Department
facilities            have jeopardized                 the health           of neighboring                    communities

and are likely                 to cost        the    federal        government              tens        of    billions             of
dollars         to correct.                The President's              proposed            budget           for     next      year
suggests         that        cleaning         up federal           facilities             may ultimately                    cost

taxpayers          between         $140 and $200 billion.                          It     is therefore                 important

that      the United            States        have an organization                       at the         federal          level


                                                               5
that      is designed          to ensure         that,       as far          as possible,          agencies             will

consider         and actively          support       national           environmental              policy          goals
as they       make decisions             about      programs           for     which      they     are
responsible.


          In this       regard,       we believe         that      the creation             of an Interagency
Committee         on Global          Environmental            Change,          as called          for      in    S.      2006,
should       provide        a much needed mechanism                     for     coordinating             national
policies         on some of the most                important           environmental              issues
confronting          us today.           We recently            reported         that      the
Administration              does not have a coordinated                         national          policy         on
global       climate        change,      nor has it           tasked          any agency          to provide
overall       directi0n.l             Even agencies             that     might         have served              this
coordinating            function--       including           the Office          of Science             and
Technology          Policy      and the Council               on Environmental               Quality--have
not been very            effective.


OTHER ASSESSMENT CRITERIA


          In recent         years,     when other            agencies          have been proposed                      for
Cabinet       status,         concerns     have been expressed                     that     increasing                 the
number of Cabinet               members reporting                to the         President          would         make the
Cabinet       more cumbersome and less                       useful.           While      these     concerns                 are
not    without       merit,       we believe         that       they     are overshadowed                   by the


1 Global       Warmina: Administration  Aooroach Cautious   Pendinq
Validation       of Threat (GAO/NSIAD-90-63,   Jan. 8, 1990).
                                                         6
importance           of environmental                 issues,           the     significant                 impact          of
environmental            decisions          on our economy,                   the     interrelationship                          of
environmental            issues      and other             national           issues--most                  of which             are
represented           by agencies           with       Cabinet          status--and             the         emerging
international            importance           of environmental                      issues.


          Furthermore,         when consideration                       was being          given            to     creating            a
Department         of Veterans             Affairs         in    the     last        Congress,              the     National
Academy of Public              Administration                   (NAPA) developed                  criteria                 for

evaluating         proposals         for      Cabinet           agencies.             These included
improving         program      visibility              to achieve             a broad          national             goal:
facilitating           the    achievement              of cross-cutting                  national                 policy
goals ; and improving                the      agency's           oversight            and accountability.
In an analysis             we conducted               at the      request            of the Chairman                      of the
House Government              Operations              Committee,          we found             that         the proposal
to     elevate     EPA to Cabinet               status          met many of these                     NAPA-suggested
criteria.          As you will          note          in the      attached            analysis,              we believe
that      a Cabinet        department           for     the      environment             would,             among other
things,        support       a broad        national            goal     that        affects          all         segments            of
society,         and its      structure            would        allow     consolidation                     of functions
now located          in other        executive           branch          agencies.


          Although       we have not           analyzed           the     costs        associated                  with
implementing           the provisions                 of S. 2006,             the     Congressional                   Budget
office       has calculated               that      the costs             of simply          converting       EPA to a
department           would       be relatively              minimal.           The bill          now under
consideration             contains         additional              features          that     could    add to the
Department's           costs--specifically,                        the     Bureau of Environmental
Statistics           and the       Commission             on Improving               Environmental
Protection.            We believe,               however,          that      in light         of some long-
standing       concerns,           which         I will       discuss         in a moment,            such    costs
could,       in the       long     run,        more than           pay for      themselves.


ORGANIZATION AND MANAGEMENTISSUES


          From our reviews                of     individual          programs          at EPA, as well              as a
general       management review                   of the          agency we conducted                 in 1988,2        we
believe       that     several        problems            would      remain          to be addressed           even     if

EPA were elevated                 to Cabinet            status.            Among other          things,       the
agency       needs better           means for             measuring           the     effectiveness           of its
programs,        better       financial             and other             management information
systems,       and better           internal            controls,            as well         as an
organizational             structure             that     is better           able     to reflect         what are
considered           to be the most important                        environmental              problems.



         We are therefore              pleased            to see that           S. 2006 would             establish          a
Bureau       of Environmental                  Statistics           within      the         Department       of the


2 Environmental              Protection Aaencv: Protectina                              Human Health and
the Environment              throuah Imnroved Manaaement                              (GAO/RCED-88-101, Aug.
16, 1988).

                                                              8
Environment,                 as well      as a commission                to     study       organizational                      and
jurisdictional                 issues.          Both       throughout           the     agency            and within
specific          programs,            EPA does not have a base of                               information              that
would       allow       it     to assess           the     effectiveness              of     its         programs         in
improving           or protecting               environmental                quality.              Developing             a
reliable          set        of environmental               indicators,            which           would      allow           EPA to
judge       the     nation's           progress           in meeting           environmental                 goals,           should
be one of the                 new Bureau's           top priorities.


          We have also,                in the       course          of our work,            raised           questions
about       an appropriate                structure           for     EPA and about                  the     need for               a
unified         environmental              statute          that      might      eliminate                some of the
conflicts           and inconsistencies                     among the many environmental                                  statutes
for     which       EPA is       responsible.                A commission               to study             these        issues
could       provide           an important           public          service       in      its       answers         to these
questions.


          Several        other         features           of S. 2006 also               deserve            mention.                 Basei
on our reviews                 of EPA's         financial            and information                     resource
management systems,                     we strongly            endorse          the     designation                 of    a Chief
Financial           Officer          and a Chief            Information            Resources               Officer            for        tke

new Department,                 with     duties           as laid      out      in the           bill.        As you are
well      aware,        GAO is deeply               concerned          about       federal               agencies'
vulnerabilities                 to     fraud,      waste       and abuse,             and weaknesses                     in
agencies'           internal           controls.            By defining            high-level                positions                  witn
specific          responsibilities                  for     two key internal                     control        systems,                 the


                                                               9
bill    sends a strong          message about             their   importance        to the       sound
management of the            new Department.


CONCLUSION


          In summary,        Mr. Chairman,           elevating          EPA is    an affirmation              of
the prominence           and permanence            of the     federal      role    in     environmental

protection.         With     the proposed           additions      that     I have commented on
in my statement,           a Department            of the Environment             could     ultimately
provide       the United      States       with     a far     more effective            organization
for    addressing        the difficult            environmental          agenda that        awaits       us    in

the years       ahead.


        Mr. Chairman,         this       concludes        my prepared       statement.          Mr.
Hembra and I would            be pleased           to respond      to any questions.




                                                     10
ATTACHMENT                                                                                                    ATTACHMEN,



                    JNFORMATION ON ELEVATING EPA TO CABINET STATUS
                                            BASED ON NAPA CRITERIA


                        The following          criteria,          expressed           as 14 questions                 within
five      general         categories,          are taken          directly           from the National
Academy of Public                  Administration's                (NAPA) Evaluation                of       Prooosals
to Establish              a Denartment           of Veterans             Affairs,         published           in   March

1988.          In developing            our    responses,           we have attempted                   to    adhere
closely         to the meaning               apparently          inferred           by the      NAPA evaluation
panel.


I.      Establishinu             a National         Prioritv         for      the Aoencv's              Proqrams


                    Question:               Does the       agency        or set       of programs             serve      a
broad      national         goal      or purpose           not    exclusively             identified           with      a
single         class,      occupation,          discipline,              region       or sector          of society?


                    Resnonse:            We believe          that        a Department            of Environmental
Protection          meets this           criterion.              As much as any other                    Cabinet-
level      issue,         environmental           protection             affects        all     Americans--from
urban     dwellers          who experience             air       pollution           to rural       residents

whose drinking              water      may be affected               by runoff            from pesticides                and

fertilizers.               All     levels      of government              are       involved       in
environmental              regulation,          and they          join       business          and industry            as

                                                           11
ATTACHMENT                                                                                                ATTACHMEFJT

subjects       of environmental               regulation.             In addition,            the        benefits          of

environmental           regulation           are derived       by all           citizens.


                 Question:           Is there          evidence        that      there       is    a significant
need that       is not       now adequately             recognized             or addressed              by EPA, the
President,       or the       Congress         which     would       be better           assessed           or    met
by elevating           the   agency     to a Cabinet           department?


                 Resnonse:           This      question       focuses           on the       ability         of the
agency     to obtain         necessary         resources       for       its     programs.               Looking         at
environmental           programs,       it     seems to us unlikely                   that        outlays         will
be significantly             changed by Cabinet               status.            The appropriate                  level
of   funding     for     environmental           activities            has been a concern                    to     both
the Administration               and the       Congress       for      the past          decade,          as both
environmental           problems      and the budget                deficit       have grown.                The
question       concerning         what level        of resqurces                to devote          to
environmental           programs      will      undoubtedly            persist        in the        years
ahead,     whether       these     programs        are housed            in an independent                   agency
or a Cabinet         department.


                 Ouestion:           Is there       evidence           of      impending          changes         in
needs or circumstances                which      would      be better            addressed          if     EPA were
made a Cabinet           department?            Are such changes                 expected          to continue
in the     future?


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 ATTACHMENT                                                                                                           ATTACHMENT

                      Remonse:            In    our      view,        a Cabinet           department                 would     be ar.
 appropriate           acknowledgment              that         environmental              problems             have become
 long-term,           increasingly             complex,             and also       increasingly
 international            in scope.             As noted             in our testimony                  to the
subcommittee,             the     federal         role         in environmental                 protection,                  which
has expanded            greatly         in the        last          two decades,           is    likely              to grow
even larger            in the      future.            Old problems               of air         and water
pollution        persist.            Cleanup          of hazardous               waste      sites            is now
recognized            as a long-term             problem.              At the       same time,                 our nation            is
discovering            and beginning             to deal             with     the more subtle                   but
pervasive        problems          of toxic           air       pollution,          indoor            air      pollution,
and others.             Some of these              newly-recognized                  problems,                 like     global
warming       and stratospheric                  ozone depletion,                  will         require           a degree
of international                cooperation              that       could      be well-served                   by a
Cabinet       department.


                   Question:             Would a Cabinet                     department          increase              the
visibility         and thereby              substantially                   strengthen          the         active
political        and public             support          for     EPA programs?


                  Resnonse:              EPA's creation                     in 1970 reflected                   the
widespread        concern         for       environmental               protection.               Since          that        time
opinion       polls       have consistently                     demonstrated             that     environmental
concerns,        from the public's                    perspective,               remain         a top         national
issue.        Political          support        for       environmental              issues,            however,             has
                                                               13
ATTACHMENT                                                                                                    ATTACHMENT

not      always        been viewed            as mirroring          public         support.           This      was
especially             true     during        the early         1980's      when the Administration
placed      less        emphasis         on environmental                issues          and political
problems          plagued        EPA.


                       We see conferring                 Cabinet      status        on EPA as enhancing
existing          support        for     environmental             issues      from two perspectives.
EPA'S elevation                 would     be an important                symbolic          gesture,          signalling
that      the Administration                   recognizes          the    longstanding            public         support

for    environmental              protection.              From a political                  standpoint,             the
action      would        ensure        that     EPA is present              to represent              environmental
issues      during            the development             of national          and international
policies.


                    guestion:             Is there         evidence         that     becoming          a Cabinet
department          would        provide        better      analysis,          expression             and advocacy
of the      needs and programs                   which      constitute             the     agency's
responsibilities?


                    Pesnonse:             In our view,             environmental              issues       deserve         the
attention         of     the     President.          Also,         from a long-term               institutional
standpoint,            the      environmental            protection          organization              should         have
regular       access          to the      President.            As the NAPA panel                 noted,         a




                                                           14
ATTACHMENT                                                                                                     ATTACHMENT

cabinet           department          secretary         often      has better              personal        access       to
the       President         and senior          White         House staff           than      the     administrator
of    an independent                agency.


                      We recognize            that      Cabinet       standing             is no guarantee              of
presidential              interest,         and conversely,              that        independent              agency
status       is     not     automatically             accompanied            by indifference                  on the
President's            part.          However,        as discussed            later,          environmental
issues       play      a critical           role      in our national                and international
policy       decisions.               Placing        EPA on equal            footing          with      the
departments            responsible            for     developing         those            policies       would      help
ensure,       over        the    long-term,           the      integration           of environmental
protection           with       such policies.


II.       Imnrovinu          Prouram        Effectiveness


                     Question:            Is there          evidence         that         elevation       to a Cabinet
department           would       improve        the    effectiveness                of EPA's delivery                 of
services?


                     Resnonse:           Because EPA does not provide                                services,        this
question          does not directly                  apply.        However,          if     one interprets             the
question          to mean the           effectiveness              of EPA programs                   in general,           we
would       conclude         that     elevation          to Cabinet           status          is unlikely,            by
itself,       to bring           improvements.                As we pointed                out during         our
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ATTACHMENT                                                                                                         ATTACHMEXT

testimony,            our general                management          review           and other         reviews       of      EPA
revealed          a number           of    weaknesses           in     the         agency's        management,          such
as:       the     absence           of linkages         between              its     planning         and budgeting
functions,            its      use of activities                    rather          than    outcomes         as measures
of    program         effectiveness,                and the          lack          of good financial
management and information                            systems,           among others.                 Resolution             of
these      types       of      weaknesses           reflect          management commitment                     and
leadership,            not         organizational              placement.


                      Question:             Is     a Cabinet          department                 required     to     better
coordinate            or consolidate                programs          and functions                  which    are now
scattered          throughout              other     agencies            in the executive                   branch      of
government?


                      Resnonse:             Although           current             proposals        do not     call        for
moving      the       functions            of any agency              other          than        EPA to a Department
of Environmental                    Protection,         its      creation             would        nevertheless
provide         the    framework            and thereby              facilitate             the     consolidation                of
other     environmental                   programs,       if     warranted.                 It     has been suggested,
for     example,            that     the National              Atmospheric              and Oceanic
Administration                 (NOAA) and other                 environmental                    research
organizations                be included            in a Department                   of Environmental
Protection.




                                                               16
ATTACHMENT                                                                                                   ATTACHMENT

 III.       Imnrovinu           Prouram Efficiencv


                     Question:            Is there        evidence          that        a Cabinet         department
with      its     increase        in the centralized                 political             authority         of      the

Secretary's            office      would     result           in a more effective                    balance       within
the agency           between       integrated            central       strategic            planning         and
resource          allocation,           and the direct              participation               in     management
decisions          by the       line     officers         who are responsible                      for    directing
and managing            service         delivery?             Would the         staff       officer-line
officer         interaction            be improved?
                                                        and
                     Question:           Is there         evidence        of significant                  structural,
management,           or operational              weaknesses           within        the      agency       that       could
be more easily               corrected       by elevation              to a Cabinet              department?


                    ReSDOnSe:            As noted         earlier        in our assessment,                    the
management weaknesses                    within         EPA that      we have observed                    are not
likely      to be affected               by a change            in its       status;         these       problems
will      need to be addressed                   whether        EPA is elevated                 or remains            an
independent           agency.           We found,         for    example,          that      the       budgeting
process         at EPA is driving                planning        rather       than        the    other      way
around.          The result            is that      resources         are     focused           on traditional
program         activities        rather         than     on what are defined                    as priorities.
Both      GAO and EPA have found                    problems         in the        agency's            financial
management systems,                    and we have both              noted       difficulties              in creating
                                                          17
ATTACHMENT                                                                                                 ATTACHME>lT

and retaining             a skilled        workforce           at EPA.           We also      found        that     EPA
needs to develop                  more effective             working      relationships             with      state
and local            governments,         who are to a great                   extent      responsible             for
carrying         out     federal       environmental               programs.        Better       internal
controls         are needed,           particularly            in the area of contracting,                          which
now takes            up about       a third     of EPA's budget.                  With     effective
leadership,             these      and other       management problems.                  can be addressed
either        by the existing             agency      or a Department               of Environmental
Protection.


                      Question:         Is there        evidence          that     there      are external
barriers        and impediments               to timely            decision       making     and executive
action      that       could       be detrimental             to    improving       the     efficiency             of

‘FPA] programs?                 And would       these         impediments          be removed or
mitigated            by elevation        to a Cabinet               department?


                      Resnonse:         In our view,               the most apparent            external
barrier        faced      by EPA is        the variety              of legislation            from which            EPA
derives        its     statutory        authority.             Because EPA was created                      under        an
Executive            Reorganization           Plan,     it     does not have an overarching
legislative            mission.         Instead,        its        statutory       responsibilities                 are

set   forth          in roughly       a dozen pieces                of legislation.             As we pointed
out   in our EPA management review,                            each of these             statutes          contains

divergent            regulatory       philosophies             and standards.               Such diversity
complicates            agency management and adoption                            of an integrated                 cross-
                                                         18
ATTACHMENT                                                                                                         ATTACHMENT

media environmental                 approach.             As a result,                the     agency          has less
flexibility            in setting           priorities          based on its                 assessment             of        the
risks      presented           by various         environmental                 problems.


                   We recognize
                             .   that,                   by itself,             elevation             to a Cabinet
department         would not resolve                    EPA's difficulties.                         But,      if    Cabinet
status        were accompanied               by an organic                  piece     of legislation,                    it
might      make it        easier      for      EPA to set priorities                         and allocate
resources        in response            to its          evolving            understanding              of
environmental             problems.


                   Question:            Would elevation                     to a Cabinet              department               help
recruit        and retain          better       qualified             leadership             within         the agency?


                   Resnonse:            Cabinet          status        in our opinion                  would        improve
EPA's ability             to recruit,           but      only     to a marginal                degree.              We have
reported        that      EPA has had problems                     in retaining               its      Superfund
workforce,         and like         other       federal         agencies,             can probably                 expect
increased        difficulties            in competing                 for     skilled         personnel             in the
future.         In 1987,         we noted         that     one-third                of the     Superfund             progra-
staff     we surveyed            planned        to look         for         other     jobs     the         following
year.         To the     extent      that       staff      turnover             is    a function             of a
perceived        lack      of commitment              to the          agency--as             may have been the
case in the            early     1980s --then            elevation            of EPA to Cabinet                     status


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may be an important                          signal      that     staff      efforts       are important              and
valued.


                    However,                 you should          be aware that            we have found              pay to
be a major           factor           in retaining               a skilled        Superfund         workforce.                EPA
must      compete        for         staff       with     a growing          private       sector      that        is able
to offer         considerably                  higher       salaries.           Superfund       staff         that         left
EPA in 1985-86                 for      jobs      with      private       industry         received,          on
average,         about         $7,000          a year       more than         they       were earning          at EPA.


                    Looking             at high-level              positions,            we would      share         the      NAPA
panel's        observation               that         Secretary       and Assistant            Secretary
positions         are     customarily                   more attractive            to senior         executives
than     non-Cabinet             officers.                Here too,          however,       executive          pay
levels       may be a deterrent                         regardless        of Cabinet         status.


IV.     Imnrovinu         Federal              Policy      Inteuration


                    Question:                  Is there          evidence       that      a Cabinet      department
would       facilitate           more uniform                   achievement        of broad,         cross-cutting
national        policy         goals?


                    pesnonse:                  We believe          that      a Cabinet       department              would
more effectively                 integrate               environmental           policy      into      a broad         array

of related          domestic             and international                   policies.        In the          President's

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recent         proposal       to amend the                  Clean Air          Act,          in        the      United           States'
negotiations              to phase out               CFC production,                       and in a variety                          of
other     ways,      it     has become evident                        that     environmental                         policy           plays
a critical          role      in our energy,                   transportation,                         trade,         and        foreign

assistance          policies,           among others.                    Having             equal         status           with           the
departments          responsible               for         carrying          out    these              other         policies
would     place      EPA on an equal                       footing       and allow                it      to more easily
represent         environmental                interests              before        the       rest            of     the      federal

government.



                   As we noted                in our testimony,                       it     is        also         important              to
have a vehicle              for      environmental                   cooperation              to ensure                 that          other

federal         agencies,           insofar      as possible,                  will          take         national
environmental              policy       goals         into         account         as they              make decisions

about     their      programs.                In numerous              reviews,              we have found                       instances
where this         has not been the                        case,      sometimes              with         serious             effects.
Years     of     ignoring         environmental                    consequences               at Defense                   and Energy

Department          installations,                   for     example,          have jeopardized                            the        health
of neighboring              communities               and are likely                       to cost            the     federal
government         tens      of billions                   of dollars          to correct.


                   guestion:             Would EPA's elevation                               to a Cabinet                     department
weaken or strengthen                    the     Cabinet             and the         Executive                   Office          of        the

President         as policy           and management aids                          to the              President?


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                  ResDonse:            Although      we have not            evaluated          this         issue,
the NAPA panel            did    draw conclusions.                 In evaluating              the veterans
affairs      proposal,          the panel         noted    that     while     an increased                  number
of Cabinet        departments           dilutes      the usefulness            of the          Cabinet           as an
advisory      body,       the    addition         of one department            would          have     little               if
any effect        on the        operations         of the     Executive        Office          of     the
President        and would         not be reason           enough to reject               a proposal                  for
Cabinet      status.


V. ImDrovinu           Accountability             to Elected        Public     Officials


                  Question:            Would the       elevation         to a Cabinet               department
have a beneficial               or detrimental            effect     on the      oversight             and
accountability            of the       agency      to the     President        and the          Congress?


                  ReSDOnSe:            In our view,          oversight        and accountability
would     be unaffected            by EPA's elevation               to a Cabinet              department.

Although      EPA is       an independent            regulatory          agency,        its     administrator
is confirmed           by the      Senate     and serves           at the     pleasure          of the
President,        as does a Cabinet                Secretary.        Likewise,          a Cabinet
department        would       remain     subject       to the       same established
congressional           oversight        mechanisms          now in place,          such as those
contained        in the       Federal       Managers'        Financial        Integrity             Act,        the
Inspector        General        Act,    and other         such laws.         EPA has been and can
be expected        to remain           subject      to congressional             oversight             through
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statutory        reporting        requirements,            frequent       hearings,      and deadlines
for     agency    activities.         The 1984 amendments to the Resource
Conservation         and Recovery           Act,     for    example,       specified       76
deadlines,        8 of them containing                so-called        "hammer"        provisions          that
would     automatically           result     in certain         actions       if   EPA failed         to
meet the deadlines.                The intensity            of oversight           seems to us to be
more closely         related       to public       and congressional               concern      for
environmental            issues    rather     than     to the type          of organization
responsible        for     the    issues.




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