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area and so little support for students who will be the environ- 

 mental professionals of the future. Basic research is particularly 

 important in the environmental field because the systems that we 

 work on are so complex and relatively unexplored. I am sure that 

 the chairman realizes that until recently this country had no com- 

 prehensive research program that explored the complex relation- 

 ship between human civilization and environmental quality. Until 

 recently, we had very little systematically derived information on 

 the occurrence of contaminants in water, air, and soil. 



More importantly, we are just now learning about the mecha- 

 nisms and processes that operate in the natural ecosystems that 

 account for transport and transformation of natural and anthropo- 

 genic substances on the planet and that are responsible for the ef- 

 fect of these substances on living species. The more we delve into 

 these process, the more appreciate how complex they are. 



Our present environmental management structure, based on 

 command and control strategy, quite naturally places a high degree 

 of emphasis on action, even in the absence of complete understand- 

 ing about the system to be managed. Indeed, there are many who 

 seem to feel that complete knowledge of the system is not needed, 

 that environmental action can be effected even in ignorance. While 

 this is viewed by some as true, it is true only on a superficial level. 

 This position cannot be maintained indefinitely. It is simply not 

 profitable to manage this complex civilization and protect nature 

 without further information on how the system works. 



To use an analogy from the medical field, the history of environ- 

 mental protection is replete with examples of how we tried to fix 

 the patient without having a good understanding of the anatomy, 

 prescribed drugs that were in fact toxins, and in the process ran 

 up an extraordinary bill that the public had to pay. 



Mr. Chairman, I have in my testimony made some specific sug- 

 gestions with regard to EPA's role in the Nation's environmental 

 R&D apparatus. I will not go through those in detail. They are 

 there for your critical review. I would like to say, however, that the 

 points I am making are, in brief, that EPA needs to separate its 

 R&D establishment at least in part from its program offices. It 

 needs to reward its scientists and engineers more. 



And it needs to structure its R&D apparatus in such a way that 

 it makes better utilization of the people who are in the external 

 community, particularly in academia, but also in other places such 

 as national laboratories, and to create a climate within EPA where 

 the people who are in the laboratories — line scientists and engi- 

 neers — are respected and given the appropriate kinds of rewards. 

 It means respect and intellectual freedom to pursue research in the 

 way it is done in the best places in the world. We do not find that 

 in abundance in EPA laboratories at the present time. 



Moreover, research administration at EPA needs to be revamped. 

 It needs to be revamped in a way where there is better peer re- 

 view, where the people who are administering it are actually sci- 

 entists, engineers, and policy analysts in their own right, and who 

 are not interested in staying in those positions indefinitely. In fact, 

 the system should be set up for them to rotate back out into the 

 external community, and in that way to make EPA's R&D estab- 

 lishment more robust. 



