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STRtNCTHENINC THt RAD INFRASTRUCTURE 65 



would bring into existence a powerful counterbalance to the constant pres- 

 sure from the regulator)' offices for continuous emergency respion^c support. 

 Given the critical needs of the regulatory offices in dealing with science- 

 and technology-driven problems, it does not make sense to separate such 

 a national laboratory from EPA or a Department of the Environment. It 

 is necessary, however, to moderate the surges in demand fc.r support from 

 the regulatory offices. 



Because of its critical mass and its perceived greater importance, 

 a national laboratory should be better positioned to compete for limited 

 resources. At this time, each of the six small R&D laboratories must compete 

 individually for its funds and staff, justification for increased suppon is 

 difficult, given each laboratory's limited mission. 



Finally, because of its improved stature, such a national laboratory 

 would operate on a more equal footing with other major federal laboratories 

 and leading scientific organizations. 



The major disadvantage of combining the six EPA laboratories into 

 a national ecological laboratory is the geographical distribution of the existing 

 laboratories. This decentralization makes overall program management 

 difficult, and it will take some time for the several parts of a new national 

 laboratory to begin working in an integrated fashion. It will also require 

 leadership to develop a vision of a truly national laboratory. 



This problem goes to the heart of the nation's environmental 

 dilemma— how to manage our national environmental resources while re- 

 specting the biodiversity encompassed in the nation. We think that it is 

 more important to fashion an integrated ecological research program under 

 a single administrative entity than it is to attempt to coordinate a highly 

 decentralized system. 



Some may argue that this experiment has already been conducted, 

 and that the attempt foiled. In 197}, EPA's Office of Research and Devel- 

 opment reorganized all of its laboratories into three National Environmental 

 Research Centers (NERCs). One NERC, placed under the direction of the 

 Corvallis laboratory, encompassed most of the ecological effects and processes 

 laboratories identified above. Q>mmunications and coordination among the 

 laboratories and between the NERC headquaners and the Washington-based 

 ORD headquaners were judged to be ineffective. In 1975, the NERCs 

 were abolished, and the ORD laboratory structure returned to its present 

 configuration. 



In our opinion, the NERC experiment failed for several reasons. First, 

 too much was attempted at one time, and the entire ORD organization 

 was thrown into turmoil by the change. Second, the affected laboratories, 

 which had previously operated quite autonomously under the Federal Water 

 Pollution Control Administration, had not been prepared to function as 



