LETTERS ORD mired in bureaucracy Dear Editor: According to the feature article by Jeff Johnson on EPA's Office of Research & Development ("Rebuilding EPA Science" November 1996, p. 492A), ORD is mainly comprised of scientists who have forgotten how to do research and are straining themselves to follow reforms instituted by Assistant Administrator Robert Huggett. Budget cuts by the 104th Congress and Republican administrations beginning with President Reagan are blamed for EPA scientists "losing their edge " ORD scientists are highly qualified but hamstrung. They haven't been provided a single undisputed mechanism by which they can hire and supervise technicians, or through which they can interact with scientists outside the agency. Budget cuts are irrelevant when scientists have no way to use funds to build viable research teams. As suggested by my commentary {Nature, 1996, 381, 731-32), the current ORD administration has simply failed to see the overall picture of the weaknesses in the science underpinning environmental regulations, chart a course to rectify the situation, and work with Congress to give its scientists the tools and encouragement to get the job done. Problems with EPA's science, therefore, do not originate with Republican elected officials, but with poor leadership from top ORD administrators. Huggett's reorganization has mired ORD in bureaucracy and his voracious grants program has further isolated EPA scientists from their peers A new survey of 1600 ORD employees echoes this point. "Within ORD itself," the survey stated, "respondents were very critical of ORD senior management, blaming ORD's leadership for a broad range problems . . . ORD's reorganization, respondents generally believe, has created more central bureaucracy and failed to alter significantly the attitudes of senior management." The
report also noted the negative effects of Huggett's grants program on the agency's in-house science. Huggett's remarks to ES&rthat he would like to send ORD scientists back to college to learn how to be scientists again reflects an arrogance that ORD scientists have long resented. As one scientist in the survey remarked: "It is intolerable that the [assistant administrator] for ORD publicly classifies its scientists as 'second class.' " Carol Browner no sooner took the oath of office before she was publicly denouncing EPA managers for a cesspool of mismanagement in the agency. Now Huggett seems to think that it is his official duty to degrade EPA scientists among their peers in the scientific community. No administrator will ever build an organization by publicly demeaning its employees. Frankly, I do not think the present ORD administration can recover from this situation gain the confidence of its scientists and build a good research program DAVID L. LEWIS Athens, Ga.
Changing statutes Former EPA assistant administrator Terry Davies is quoted in a recent ES&T news story as saying "It is time to quit fussing around with pilot programs and to change statutes" ("Critics doubt Clinton's second term will advance reg reforms," December 1997, p. 524A). It is not clear how he believes environmental statutes should be changed. If one reviews the actions of the Republican Congress during the first Clinton administration, the conclusion could be drawn that the way to correct the unnecessary environmental legislation of earlier Democrat-controlled Congresses is to try to get around EPA's statutory mandates. Terry Davies suggests that this is improper. It is evident that President Clinton will veto any Republican attempt to moderate such overblown legislation as the 1990 Clean
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Air Act Amendments or Superfund. The answer is not to completely eliminate the 1990 Clean Air Act Amendment or the Superfund laws. If these laws can't be amended, EPA must find ways to realistically administer these programs. EPA has begun to move in this direction. CURT B. BECK Pampa, TX 70065-4010
Great Lakes dispute Dear Editor: Daniel W. Smith argues that EPA's Great Lakes Water Quality Guidance "should be reconsidered as its costs will likely dramatically exceed its benefits" (Environmental Policy Analysis, January 1997, p. 34A). Smith's critique reflects critical misinterpretations of EPA's analysis, placing undue focus on the "whole watershed" study, which considered as benefits only carcinogenic human health risk reductions. EPA worked diligently with all stakeholders throughout the Great Lakes Basin to develop the final Guidance and an accurate assessment of the costs and benefits that can be expected once it is implemented. EPA believes it demonstrated that the Guidance will produce benefits in protecting and restoring the waters of the Great Lakes Basin, and that these benefits will be commensurate with its costs. EPA's assessment was based primarily on the comprehensive case studies, in which a broad array of site-specific benefits were assessed and costs and loadings reductions examined with greater precision. Furthermore, Smith's review includes errors, misinterpretations, and limitations resulting in an exaggerated portrayal of the discrepancy between EPA's estimated costs and benefits for the final rule. Smith compares one of many categories of benefits expected to accrue from the Guidance to the entire estimated costs of the rule. The estimated reductions in human health risks from carcinogens for the basin were in no way intended to represent total basin-
