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3. EPA has expertise and credibility in many areas, such as pollution control and 

 risk assessment, but not in other areas, such as the management of natural re- 

 sources, parks, and public lands. Whereas CEQ has been able to draw on environ- 

 mental expertise from many sources, EPA would either have to hire its own NEPA 

 staff (while under orders to reduce its staff overall) or try to borrow such expertise 

 from other Federal departments and agencies, who will be protecting their "turf." 

 This will create conflicts and weaken EPA's own credibility. 



4. In its early days, CEQ helped draft the legislation to create EPA, and has 

 played an important role in drafting or reviewing subsequent laws and policies now 

 carried out by EPA. From its position in the Executive Office, CEQ has provided 

 support for EPA during the budget process, through the development of Presidential 

 policies, and via interagency dispute resolution. A Cabinet-level EPA will continue 

 to benefit from having an EOP office with the authority NEPA now provides to help 

 develop, coordinate, and oversee environmental policy and to serve the President in 

 a non-departmental advisory role. 



In conclusion I would urge you to proceed with the legislation needed to elevate 

 EPA to departmental status, but not to create difficult problems in environmental 

 law and administrative procedures by attempting to transfer functions to EPA that 

 are better left with CEQ or its successor in the White House. 

 Sincerely, 



Roger E. McManus 



