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ports each of these environmental goals and encourages national dialogue and Con- 

 pessional review, be it within the context of EPA Cabinet elevation or within other 

 legislative or regulatory forums. We look forward to working with Congress and the 

 EPA or Department of the Environment in such endeavors to promote these lauda- 

 ble goals. 



Amoco offers its insights and recommendations from the perspective of an entity 

 that is subject to the full panoply of environmental and other regulatory require- 

 ments. We are fully supportive of the need to stimulate innovative environmental 

 solutions and to further better utilization of good science and good data. As such, we 

 offer the following specific comments regarding S.171: 



I. EPA or the Department of the Environment Should Foster The Development of 

 Innovative Technologies and Solutions to Environmental Problems 



If EPA is elevated to Cabinet level, the responsibilities of the Assistant Secretar- 

 ies should specifically include Environmental Innovation, in addition to those al- 

 ready listed in S.171 and possibly in conjunction with Pollution Prevention, to ex- 

 plicitly emphasize the need for the EPA to foster innovative policy approaches com- 

 bined with innovative technology to solve today 's complex environmental chal- 

 lenges. 



As a means to further stimulate innovative thinking and foster an innovative ap- 

 proach to environmental management, the annual report specified as part of a new 

 Bureau of Environmental Statistics should include information on successes in ap- 

 plied innovation. 



II. A Department of the Environment Should Ensure the Collection of Useful 

 Data for Environmental Risk Prioritization Efforts and Responsible Investment 



The availability and use of good scientific data is critical to the successful achieve- 

 ment of the Department's goals of protecting human health and the environment. 

 With limited resources, both within the Department and in the private sector, the 

 Department must formulate a national environmental strategy that identifies and 

 addresses the highest risks first, and maximizes the environmental benefits ob- 

 tained for the resources invested. 



A. Establishment of the Bureau of Environmental Statistics 



If appropriately structured and with adequate controls, the establishment of a 

 Bureau of Environmental Statistics could be a vital ingredient in the development 

 of good scientific data and sound science. A central clearinghouse of environmental 

 information could open up the opportunity to leverage resources with the private 

 sector. If a Bureau is to be established, the following objectives should be considered 

 in addition to those already in S.171: 



1) In addition to reporting on the amounts and effects of pollutants on the envi- 

 ronment, the Department should include information on the improvements to envi- 

 ronmental quality resulting from the multitude of environmental programs (e.g. 

 from annual TRI reports or voluntary reduction program reports, such as 33/50). 



2) The Department should perform external audits and provide detailed reports 

 on major spending programs which it oversees as a public trustee, such as Super- 

 fund. 



3) The Department should evaluate the quantity and quality of the data currently 

 being collected, to ensure that the right data is being collected to ascertain both ab- 

 solute and relatives risks of reported pollutants, and to ensure that redundant or 

 unnecessary data is not being collected. The Department should evaluate other op- 

 tions for data collection management, such as data collection by industry sector, and 

 data collection of compound groups instead of individual speciations. 



4) Congress should consider establishing a National Environmental Sciences Insti- 

 tute to provide a focused, world class, center of excellence for environmental re- 

 search, in the same manner as the National Institutes of Health provide medical 

 and public health research. 



5) Regarding the implementation of all government-wide and Department infor- 

 mation policies and standards, the Department should evaluate using 4-digit SIC 

 codes for each Federal Register publication to facilitate use of computer technology 

 to deliver, search, and categorize regulations and other information. 



6) In order to ensure the accuracy and completeness of records contained with the 

 Department information systems, the Department should evaluate what systems 

 and guidelines would be required to allow regulated facilities to submit required 

 data electronically. 



B. EPA or the Department of the Environment Should Develop a Sound Basis for 

 Prioritizing Environmental Risks 



Since the goal of the EPA or Department is to protect human health and the en- 

 vironment with the resources available, the ranking of relative risk is an important 

 technique for ensuring environmental protection. 



