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-
wide benefits from the Guidance. Smith compared only these estimated cancer risk reduction benefits to basinwide cost estimates to construct his cost-benefit ratio, omitting other relevant benefit categories. Smith calculates the alleged "error" in EPA's benefits estimates by comparing the values EPA used to his own estimates, which are derived from faulty analysis of limited data. The following are the major sources of error in Smith's critique. 1. Smith attributes a 310% "error" to EPA's overestimated fish consumption rate. In calculating his "error," Smith excluded tributaries to the Great Lakes and used a 25% edible fish yield when study results show yields as high as 50%. 2. A 250% "error" is attributed to EPA's use of concentration data based mostly on lake trout, Smith asserts. However, no lake trout data were used for Lake Erie and for Ontario and Superior lake trout data were not used for all pollutants. 3. A 200% "error" resulted, according to Smith, because EPA assumed steady state for non-steady state conditions. Whether fish concentrations are in steady state for all contaminants regulated by the Guidance is unknown. EPA accounted for the lag in realization of benefits by using 10- and 20-year phase in periods for benefits. 4. Smith attributes a 630% "error" to EPA's overestimate of total loadings from point sources. To arrive at this result, Smith compares total (nonpoint and point) loading estimates of DDT from one study conducted in the mid-1980s to point source estimates derived in the mid-1990s. 5. A 3200% "error" was attributed to EPA's use of an overly protective cancer slope factors (CSFs). CSFs are developed and applied as standard methodology used by EPA in the estimation of risks, and are intended to be protective of human health. Note that recent research indicates that PCBs, dioxin, organochlorine pesticides, and other chemicals may have reproductive and developmental toxicity through processes such as endocrine disruption. In addition to considering the problems noted above with Smith's interpretation of the whole watershed analysis, it is even more important to recognize that the more appropriate evaluation is the case study assessment. For these more complete benefits analyses, Smith
observes benefits that are commensurate with costs. Moreover, human health benefits, on which his criticisms are focused, constitute a limited portion of total benefits for the case studies. A detailed rebuttal of Smith's article can be found on the World Wide Web (http: / /www.epa.gov/OST/Events/ glakes.html) or by calling Mark Morris at (202) 260-0312. E. CASTILLO, M. MORRIS, R. RAUCHER, M. BARRON, J. PARKER Hagler Bailly Consulting, Inc. Boulder, CO 80306-1906 Dear Editor: Daniel Smith advocates in his recent Policy Analysis paper that the Great Lakes Water Quality Initiative (GLI) "should be reconsidered as its costs will likely dramatically exceed its benefits." His objections to the GLI coincide with his funder's, the Occidental Chemical Corporation. Unsuccessful in opposing EPA's final approval of the GLI in 1995, industry groups are attempting to block the GLI in federal court and weaken required implementation by the eight Great Lakes states. Having insisted that cost-benefit analysis must be part of the regulatory process industry representatives now exploit inherent weaknesses in such analyses Smith accepts EPA's estimates of compliance costs for the GLI of $60 million to $380 million per year. In 1995, however, Smith endorsed claims that the GLI "could cost billions of dollars annually" [ES&T 1995, 29, 42A). Such fanciful claims were sharply criticized as excessive by the state of Michigan in a letter from Department of Natural Resources Director Roland Harmes to EPA (Sept. 8, 1993), which concluded that "the cost of implementing the GLI in Michigan at existing facilities will not be significant " Smith laboriously dissects many of EPA's assumptions regarding its benefits analysis, especially those benefits attributed to cancer risk reduction. Context is ignored: The GLI's "principal benefits," EPA points out, are indirect and difficult to forecast because they occur in the future and are largely ecologic in nature. Smith notes that the Michigan Environmental Science Board (MESB) concluded that EPA's default methods probably overestimate cancer risks from consuming PCB-contaminated fish. The same report, however, stresses risks of noncancer endpoints, particularly the "higher
vulnerability of the fetus to the neurobehavioral effects of PCBs" (MESB, Lansing, Mich., September 1995). Recent studies elevate this concern. These findings have caused EPA and the U.S. Department of Health and Human Services to warn Michigan Governor John Engler that the MESB report likely underestimates public health risks from exposure to Great Lakes pollutants in fish (letter from Perciasepe, R. et al., Oct. 9, 1996). The findings heighten the importance of securing all feasible reductions in releases of persistent toxic pollutants. To critique the GLI based primarily on a scrutiny of cancer risks overlooks benefits impossible to quantify, including pollution prevention, ecologic improvement, protection of cultural heritage, and reduction in noncancer endpoint health risks. Congress enacted the GLI in 1990 to ensure that the Clean Water Act conforms with our commitments in the U.S.-Canada Great Lakes Water Quality Agreement of 1978. Our nation's policy is that "the discharge [into the Great Lakes system] of any or all persistent toxic substances be virtually eliminated." In 1986, governors of the eight Great Lakes states endorsed this goal and a commitment "to continue reducing toxics in the Great Lakes Basin to the maximum extent possible " These public policies express values that transcend myopic cost-benefit analysis. The people of the Great Lakes region have decided that the GLI is consistent with these values. WAYNE A. SCHMIDT Great Lakes Natural Resource Center National Wildlife Federation Ann Arbor, MI 48104 Author's Response I share the goals of EPA to protect the Great Lakes. It is in this spirit that I have called for more rigorous peer review of EPA's work to promote "an open and honest attempt to value" the worth of the GLI. Based on my review of the GLI, it is clear that EPA has placed undue focus on toxic chemicals, especially the toxicologically negligible masses emanating from point sources. The unfortunate result is that much more pressing environmental and human health concerns are being neglected at the federal level In response to the assertion by Castillo et al. that my review "placed undue focus on the 'whole-water-
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