264 



progress in meeting environmental goals, should be one of the new Bureau's top pri- 

 orities. 



We also, in our general management review of EPA and in our analysis of propos- 

 als to elevate EPA to Cabinet status, raised questions about an appropriate organi- 

 zational structure for EPA and about the need for a unified environmental statute 

 that might eliminate some of the conflicts and inconsistencies among many environ- 

 mental statutes for which EPA is responsible. Because EPA was created under an 

 executive reorganization plan, it has no formal, overarching legislative mission. In- 

 stead, its statutory responsibilities are set forth in a dozen or so separate pieces of 

 legislation that tend to assign pollution control responsibilities according to environ- 

 mental medium (such as water or air) or category of pollutant. These numerous leg- 

 islative mandates have led to the creation of individual program offices that have 

 tended to focus solely on reducing pollution within the particular environmental 

 medium for which each office has responsibility than on reducing overall emissions. 

 If, however, EPA's statutory responsibilities were consolidated into a single unified 

 environmental statute, the agency might find it easier to set priorities and allocate 

 resources in response to its evolving understanding of environmental issues. A com- 

 mission to study this possibility could provide an important public service by finding 

 answers to these questions. 



We also believe it would be worthwhile for a study commission to consider the 

 most appropriate and effective organization for the department. For example, in an 

 examination of alternative enforcement organizations for EPA,^ we argued that the 

 choice of an organizational structure for enforcement at EPA ought not to be made 

 in isolation but in conjunction with an examination of the future organizational 

 structure of the agency as whole. We therefore continue to support the creation of a 

 study commission that the Congress can call upon for ideas about how to organize 

 the whole department, including the enforcement functions. The commission might, 

 for example, consider whether to reorganize the department entirely by function, so 

 that instead of having program offices dedicated to environmental media, the de- 

 partment might have a single office of regulatory development, an office of enforce- 

 ment, an office of science and research, and so Alternatively, the department might 

 be organized by pollution sectors — industry, transportation, and municipalities, for 

 example. The commission could also consider the roles and responsibilities of head- 

 quarters and regional offices. 



Conclusion 



In summary, we believe that elevating EPA to Cabinet status would affirm the 

 prominence and permanence of the Federal role in environmental protection. With 

 the additions proposed under S. 171, a Department of the Environment could ulti- 

 mately provide the United States with a far more effective organization for address- 

 ing the difficult environmental agenda awaiting us in the years Eihead. 



Prepared Statement of Amoco Corporation 



On behalf of the Amoco Corporation and its operating companies, we appreciate 

 the opportunity to provide comment on the issues surrounding the elevation of the 

 U.S. Environmental Protection Agency (EPA) to Cabinet level, and specifically on S. 

 171, the "Department of the Environment Act of 1993." Amoco has recently com- 

 pleted a joint study with the EPA to evaluate pollution prevention opportunities at 

 Amoco 's Yorktown, Virginia refinery, which we believe provides insights for legis- 

 lative and regulatory policy affecting environmental management and environmen- 

 tal innovation. Our statement highlights the findings of this study as it relates to 

 specific concerns of the Congress and of the EPA as it takes up the EPA Cabinet 

 elevation. 



Amoco is aware of the continuing dialogue over whether EPA Cabinet legislation 

 should be pursued simply as a "clean" piece of legislation (i.e., elevate EPA to Cabi- 

 net with no other legislative provisions addressed) or whether Congress should use 

 this legislative opportunity to pursue further Agency reforms including those to pro- 

 mote: good data generation; sound use of risk assessment and other risk manage- 

 ment tools; procedural reforms; use of "green" environmental technologies; pollu- 

 tion prevention; and development of a national environmental strategy. Amoco sup- 



^ Environmental Enforcement: Alternative Enforcement Organizations for EPA (GAO/RCED- 

 92-107, Apr. 14, 1992). 



