306 



effects of toxicants on both plants and animals); ecological restoration; ecological 

 risk assessment and management; and environmental monitoring. 



Q. 36: C) Would it be possible to better coordinate the work of other natural 

 resource agencies, such as the Fish and Wildlife Service, NOAA, and the Army 

 Corps of Engineers? 



A. 36: C) Yes, it is possible to have better interagency coordination. This should be 

 accomplished through all levels of communications and cooperation. We are doing 

 several things to promote this. High-level management meetings involving these 

 and other Federal agencies on an ongoing basis are helping to improve coordination 

 and consistency and particularly helpful in resolving environmental disputes which 

 cross jurisdictional lines. For instance, I now meet personally on a monthly basis 

 with the Secretary of the Department of the Interior, the Department of Agricul- 

 ture, and the Department of Energy, to foster this tjrpe of collaboration, and our 

 respective staff meet weekly. 



Interagency cooperation/collaboration can be further expanded in efforts such as 

 joint regulatory responsibilities, mutual science and research projects, information 

 management systems and data sharing, monitoring and assessment strategies, and 

 other opportunities. EPA participates in interagency efforts for ecological protection 

 in leadership capacities, as equal partners, or simply in a supportive role. Interagen- 

 cy partnerships are also well suited for implementation at the regional office level, 

 and are occurring in all EPA regions. 



Memoranda of Understanding (MOUs), like the one signed between my predeces- 

 sor William Reilly and John Turner of the Fish and Wildlife Service, and long-term 

 personnel exchange programs involving relevant agencies also enhance agency coop- 

 eration and should be pursued. Other programs like EPA's Environmental Monitor- 

 ing and Assessment Program (EMAP) maintains more than 20 MOU's and Inter- 

 agency Agreements (lAGs) with 12 Federal Agencies. Additionally, conferences like 

 Watershed '93, which was sponsored by EPA gmd 13 other Federal agencies, will im- 

 prove coordination. Other examples include the National Estuary Program, which 

 involves interagency coordination to address priority problems in our Nation's estu- 

 aries. In the dredge material management programs, the EPA and Army Corps of 

 Engineers are working closely together on several technical guidances and a strate- 

 gy to address management of dioxin-contaminated dredged materials. 



Q. 37: A recent National Law Journal study, released on September 21, 1992, re- 

 ported that superfund cleanup activity began from 12 percent to 42 percent later 

 at minority sites for over half of the ten autonomous reg^ions. How does Region 5 

 compare with those statistics and what other comments do you have on this 

 matter? 



A. 37: The National Law Journal (NLJ) reported that in six of EPA's ten regions, 

 the pace of EPA action from discovery of the site to the beginning of cleanup is 

 from eight percent to 42 percent faster at white sites than at minority sites. The 

 NLJ found that in one EPA region, the pace of cleanup for minority and white sites 

 was even, and that in three Regions, the cleanup began more quickly at minority 

 sites. For Region 5, the NLJ found the pace of cleanup from discovery to cleanup 

 was 13.8 years for minority sites compared to 9.7 years for white sites (42 percent 

 longer at minority sites.) 



There are several methodological flaws in the NLJ's work that call into question 

 these results. For example, the NLJ relied on the ZIP codes as a surrogate for loca- 

 tion to determine the demographics around a site. In some cases, ZIP codes repre- 

 sent a mailing address but not the actual location of a site. Another example is the 

 use by the NLJ of discovery dates that were well before the Superfund law was 

 passed and therefore before Superfund action was possible. Also, the NLJ did not 

 look at other site variables that affect cleanup decisions such as type of site. 



It is important to note that these flaws in the NLJ analysis do not completely 

 explain why the NLJ found cleanup activities take longer at minority sites in some 

 regions. The NLJ has raised an important issue that needs to be examined careful- 

 ly. For this reason, EPA is making a serious commitment to determine whether 

 racial inequities exist in the Superfund program. We are using the most current 

 and reliable data available to study the demography around Superfund sites, and 

 comparing these data with the historic performance of the Superfund program. By 

 this summer, we plan to link minority status with site variables such as time from 

 discovery to first removal activity, and type of remedy selected to determine wheth- 

 er there are biases in the program. 



In addition, the Agency is taking a proactive approach to equity by providing site 

 decision makers with demographic information early in the site identification proc- 

 ess. We believe that getting this information out early will provide opportunities for 

 EPA to improve communication with members of minority communities. 



