Ash Council Memo
EXECUTIVE OFFICE OF THE PRESIDENT
PRESIDENT'S ADVISORY COUNCIL ON EXECUTIVE ORGANIZATION
WASHINGTON, D.C. 20506
April 29, 1970
MEMORANDUM FOR THE PRESIDENT
SUBJECT: Federal Organization for Environmental Protection
This memorandum deals with the organization of anti-pollution programs. A second memorandum, which you will receive shortly, will deal with the organization of natural resource programs.
The President's Advisory Council on Executive Organization recommends that key anti-pollution programs be merged into an Environmental Protection Administration, a new independent agency of the Executive Branch. In your February 10 Environmental Message, you pledged yourself to "...repair the damage already done, and to establish new criteria to guide us in the future." The Environmental Protection Administration will be the principal instrument for the fulfillment of that pledge.
In reaching this conclusion we have explored, but regard as less desirable, several other organizational alternatives (Appendix A):
- Creation of a Department of Natural Resources and Environment;
- Assignment of most anti-pollution responsibilities to a new bureau within the Department of Health, Education, and Welfare;
- Creation of a small standard-setting entity within the Executive Office of the President, or as an independent agency.
The details of our recommendations will follow brief examinations of (1) the environmental crisis; (2) the inadequacy of the present government structures which attempt to cope with it; (3) the organizational concepts we regard as pertinent; and (4) the specific rationale for the Environmental Protection Administration (EPA).
The Environmental Crisis. Pollution is essentially a by-product of our vastly increased per capita consumption, intensified by population growth, urbanization, and changing industrial processes. In the coming years, problems of environmental degradation will rise exponentially.
While our population will increase from 200 to 260 million by the year 2000, pollution will increase much more rapidly. Even if 50 percent of the nation's electric generating capacity is nuclear-powered by the year 2000, pollutants resulting from fossil-fuel generation will double by 1980 and redouble by 2000.
Similarly, a seven-fold increase is expected in industrial wastes produced by the large water-using industries. These wastes are also expected to become more variable, more difficult to decompose, and more toxic. At the same time, our demand for fresh water will increase from 350 to 800 billion gallons a day--considerably exceeding the dependable supply of fresh water now available, some 650 billion gallons daily. More and more clean water will have to be retrieved from progressively dirtier waterways.
Even the fact that Americans annually junk 7 million cars, 100 million tires, 20 million tons of paper, 28 billion bottles, and 48 billion cans, does not reveal the dimensions of the problem. The 7 million cars, for example, represent less than 15 percent of the annual solid waste load. Each year we create 400 to 500 new chemicals. Many are toxic, but their exact ecological effects are not fully understood. We cannot even reliably forecast where or how they will turn up in our environment after they are used.
The enormous future needs for land, minerals, and energy require that the protection of our environment receive a powerful new impetus. In this, the nation will be on the "horns of a dilemma." The economic progress which we have come to expect, or even demand, has almost invariably been at some cost to the environment.
Pesticides have increased the yield of our crops and made it possible for less land to produce more food. They have also polluted the streams and lakes. Automobiles have broadened our economic and social opportunities, even as they have dirtied the air and jammed our highways. Some means must be found by which our economic and social aspirations are balanced against the finite capacity of the environment to absorb society's wastes.
Inadequacy of Present Organization. Our National Government is neither structured nor oriented to sustain a well-articulated attack on the practices which debase the air we breathe, the water we drink and the land that grows our food. Indeed, the present departmental structure for dealing with environmental protection defies effective and concerted action.
The environment, despite its infinite complexity, must be perceived as a unified, interrelated system. Present assignments of departmental responsibilities do not reflect this primary characteristic.
Many agency missions, for example, are designed primarily along media lines--air, water, and land. Yet the sources of air, water, and land pollution are interrelated and often interchangeable. A single source may pollute the air with smoke and chemicals, the land with solid wastes, and a river or lake with chemical and other wastes. Control of the air pollution may convert the smoke to solid wastes that then pollute land or water. Control of the water-polluting effluent may convert it into solid wastes which must be disposed of on land.
Similarly, some pollutants--chemicals, radiation, pesticides--appear in all media. Successful interdiction now requires the coordinated efforts of a variety of separate agencies and departments. The result is a blurring of focus, and a certain Federally-sponsored irrationality.
A far more effective approach to pollution control, in our view, would:
- identify contaminates;
- trace them through the entire ecological chain, observing and recording changes in form as they occur;
- determine the total exposure of man and his environment;
- examine interactions among forms of pollution;
- and identify where in the ecological chain interdiction would be most effective.
Scientists we have consulted tell us that over the next ten years a geometric increase in our knowledge and ability to understand the problem will be required if we are to make wise and economic judgments concerning our environment. The Administration is on the threshold of a major Federal effort. It will not prosper without a sound organizational base.
Organizational Concepts. The special contribution that organization can make to the administration of large-scale enterprise is to mobilize people, ideas, and things in ways best calculated to achieve clearly articulated goals. While good people can sometimes make a poor organizational form work, more to the point is the fact that the system within which people operate can make it difficult for them to reach their institution's objectives. Conversely, good organization can greatly increase the probability of reaching those goals. Organization, therefore, is not a neutral factor. It is a major determinant of the success of almost any enterprise.
There is no perfect structural arrangement which will reconcile all interests or resolve all conflicts. Yet there is no real substitute for clear, logical assignments of functions and unequivocal establishment of centers of responsibility in accordance with sound organizational concepts.
- Opposing interests should be drawn together at the right levels of government, so that the vast majority of conflicts are resolved below the level of the Executive Office.
- The objectives of a proposed agency must be plainly set out, and must respond to a distinct and enduring public need.
- There must be some assurance that the functions to be housed in a single agency not only belong together, but that the package can be managed efficiently.
- The Executive Branch should be so structured that a high order of public interest is served in making policy, rather than a narrower advocacy position.
Rationale for the Environmental Protection Administration (EPA). Almost every part of government is concerned with and affects the environment. But since each agency has a job to do--resource development, transportation, health, defense, urban growth, or agriculture--its view of the environment is likely to be influenced accordingly. Sound environmental administration must reconcile divergent interests and serve the total public constituency. It must appreciate and take fully into account competing social and economic claims.
To bring together under one organizational roof all the Executive Branch entities dealing with the environment is impossible. This practical fact overwhelms the normally sound concept of building line organizations which can make trade-off decisions among competitor groups.
Nor would it help very much, given the large number of departments involved, to affiliate the environmental responsibility, particularly the critical standard-setting function, with any single existing department. That department wold then be called upon to make decisions affecting other departments, when its own objectivity could be called into question. If in HEW, for example, a decision affecting DOT or HUD might well give primacy to HEW's health mission. If in Interior, a natural resource bias might well exist with respect to a matter involving the farmer or the city dweller. In short, no single agency encompasses more than a few of the perspectives requisite to environmental administration.
Given the nature and causes of environmental deterioration, programs to rectify pollution are largely geared to the great concentrations of urban population. The fact further weakens the argument for associating environmental protection with natural resources and less populated areas.
Since the Council believes that the key standard-setting function should be performed outside the agencies whose interests may affect those standards, we regard the EPA as the strongest organizational alternative. The question then becomes one of deciding what other functions such an agency should have to do its job.
We believe the standard-setting function cannot stand alone. We must know that standards are soundly based; thus, a research capability is necessary. We must know if standards are working; thus, we must be able to monitor the environment. And we must be able to offer incentives for compliance and to move against violators. These are the activities that will give effect to the standard-setting function.
The Council also believes that an independent EPA would offer distinct advantages to the business community and to state and local governments.
The Federal Government is not equipped solely or even primarily to effect a turnabout in our environmental situation through its own powers and resources. The business community is an indispensable partner in this process, even though enforcement is needed so that a business which cooperates will not be placed at a competitive disadvantage. The single agency wold simplify the relationship of the private sector whose cooperation and ingenuity are essential if any real progress is to be made.
Federal anti-pollution programs must rely heavily on state and local efforts. The trend toward merger and coordination of environmental efforts at the state and local level is often inhibited by present Federal fragmentation. The EPA will simplify relationships with state and local governments and reduce the need to shop around for grant programs and other assistance.
The Council's Recommendations
The Council on Environmental Quality (CEQ) and the Environmental Protection Administration (EPA). The EPA's specific mission cannot be stated much better than Section 204 of the National Environmental Policy Act of 1969, which states the CEQ mission. Only one major addition, power to establish and enforce standards, is required to equip the EPA to do its job effectively.
The role and functions of the EPA will be:
- To develop and recommend to the President policies to promote environmental quality and to form strategies for carrying them out.
- To establish and enforce environmental standards consistent with national environmental goals.
- To conduct research on the adverse effects of pollution, to gather information on environmental conditions and use it in modifying programs or recommending policy changes.
- To coordinate pollution control activities with state and local agencies and with the private sector, and to take the lead in coordinating among Federal departments on activities which affect the environment.
- To appraise and to assist other Federal agencies in appraising existing and proposed programs, policies, and Federal or Federally-supported projects which may affect environmental quality.
- To prepare reports required by the President and the Congress on the environment or related maters.
The establishment of the Council on Environmental Quality on January 1, 1970, was a forward step, and the Council, under its able Chairman, has gone about its task with commendable vigor. But to avoid duplication and enhance the effectiveness of the environmental effort, the functions of the CEQ and the EPA should be performed by one entity--the EPA. Such a merger would strengthen the environmental thrust by combining the broad powers of the Council with deep operating functions and activities of the agencies merged to create the EPA.
Since the CEQ is required by law to consider the environmental, social, economic, and other goals of the nation in recommending national policy, the EPA will reflect the same factors in coming to its recommendations. This should provide for balance and perspective in arriving at EPA policies.
Finally, we should believe that the proposed merger of functions will permit both the EPA and the Executive Office of the President an efficient and uncluttered arena for interaction. Some issues, both of policy and operation, will undoubtedly arise between the EPA and other agencies of government, which will come to the Executive Office of the President. As in the case of most other domestic issues, these should normally be resolved, depending on their content, by either the Domestic Council or the Office of Management and Budget. Because environmental considerations are so pervasive, we suggest that thought be given to designating the head of the EPA a member of the Domestic Council.
Composition of the Environmental Protection Administration. As the nucleus of the new administration, the Council recommends the merger of key Federal entities dealing with air and water pollution, pesticides registration and regulation, solid waste management, and radiation standard-setting, including their closely related monitoring and research facilities.
Many programs with environmental implications could be seriously impaired by extracting them from their present contexts. We have not proposed, for example, that all pollution-related research be concentrated in the new administration. The technological expertise for controlling a particular pollutant, for example, many well reside with other government entities or with the industry affecting the source. Or a Federal agency such as HEW may have the principal expertise to make the medical input to standard-setting.
We envision the EPA as serving a point of central cognizance for such specialized research, relying on the processes of information and funding transfers to make sure that the total research effort is adequate and well-articulated. Existing departmental skills should be recognized by the EPA in gathering data for the formulation of standards.
In some cases the new Administration will set standards applicable to some portions of the private sector under the cognizance of another agency--emissions from nuclear power plants, for example, the Administration cannot rely solely on research results or the publication of abstract criteria to influence other agencies. It must have standard-setting authority and a strong institutional base of people and money if its job is to get done.
We should not be read, however, as downgrading the importance of research in this field. Indeed, it is a vital and sustaining function. Research will identify the important problems and provide a basis for establishing standards and measuring progress. It will determine the nature of ecological systems and the interaction of health, economic, technological, and other factors in pollution control.
In addition, the EPA will gather data on trends which are affecting, or which may affect, the environment. With this information the Administration should be able to recommend changes in program and national policy well in advance of the expected consequence of the trend.
The functions assigned to the EPA are not the only determinants of its effectiveness. Performance will be helped or hindered by the way the programs and functions which make up the EPA are structured within the new organization. We have rejected, for example, trying to achieve the EPA's objectives by organizing around:
- Media, i.e., air, water, land. This alternative fails to deal with the fact that forms of pollution tend to be interrelated and interchangeable.
- Sources of pollution, i.e., agriculture pesticides, manufacturing, automobiles, and people. This alternative produces extreme fragmentation and fails to come to grips with the environment as an entity.
- Effects of pollution on national goals, i.e., health, natural beauty, economic output, and the like. This alternative would cause serious administrative overlap and also misses the need to treat the environment in terms of its interdependent relationships.
- Location of pollution, i.e., in cities, rural areas, ocean and coastal zones. This alternative would diffuse the attack on the problem and create both administrative and geographic fragmentation.
In our opinion, the EPA should be designed around its major functions--monitoring, research, standard-setting, enforcement and assistance. This organizational structure would:
- Recognize the interrelated nature of pollution problems;
- Address the fact that pollutants cut across media lines;
- Encourage balanced budget and priority decisions between component functions;
- Permit more effective evaluations of total program performance.
In summary, and setting aside the special case of the Environmental Science Services Administration (ESSA) discussed in the next section, we recommend the following transfers to the Environmental Protection Administration:
- Federal Water Quality Administration (Interior);
- National Air Pollution Control Administration (HEW);
- Environmental Control Administration (HEW);
- Pesticides Research and Standard-Setting Programs of the Food and Drug Administration (HEW);
- Pesticides Registration Program of the Agriculture Research Service (Agriculture);
- Elements of the Radiation Protection Standards function (AEC).
A description of these organizations, including ESSA, and the functions to be transferred is attached (Appendix B). These transfers may be effected by legislation or reorganization plan.
With these transfers the EPA would, on the basis of FY 1971 estimated expenditures, have a budget of $821 million and employ about 6,000 people.
Inclusion of ESSA
The Council is of two minds as to the wisdom of including the Environmental Science Services Administration of the Department of Commerce within the EPA. ESSA is something of an organizational anomaly and in the Council's opinion it could be located in any one of a number of agencies without damage to its mission. On the merits, however, some members are unconvinced that the transfer of ESSA is essential to the EPA's mission. Interagency arrangements for necessary services could, these members believe, be worked out, as in the case of other agencies which use ESSA services, such as DOT and HEW.
Other members point out that ESSA is basically an environment-oriented agency, and believe that its institutional base would be a valuable core for the EPA's monitoring functions, particularly as they expand in the future.
All agree, however, that the dominant factor in this decision is political rather than substantive, the question being whether EPA needs ESSA in order to make the impact and have the visibility which the Administration may feel necessary.
If ESSA is transferred to the EPA, however, the Coast and Geodetic Survey, the only part of ESSA which is primarily resource-oriented, should be transferred to the Department of Natural Resources (DNR). This recommendation will be explained in more detail in our pending report to you on natural resources. That report will also consider whether ESSA as a whole belongs in the DNR.
With the transfer of ESSA (less Coast and Geodetic Survey) the EPA would, on the basis of FY 1971 estimated expenditures, have a budget of $974 million and 13, 150 personnel. (The parallel Coast and Geodetic Survey figures are $45 million and 2,560 people.)
In conclusion, we agree with your expressed view that the nation must adopt a new environmental ethic that assigns great weight to the task of protecting and enhancing our physical environment. The establishment of an Environmental Protection Administration will provide you with a strong and flexible instrument for reaching that goal.
The President's Advisory Council
on Executive Organization
Roy L. Ash
George P. Baker
John B. Connally
Frederick R. Kappel
Richard M. Paget
Walter N. Thayer
|1 The Council is divided on the desirability of including ESSA (less C&GS) in the Environmental Protection Administration.||NOTE: This chart shows the principal functions to be performed by the EPA, and the agencies or programs to be merged.|
Other Organizational Alternatives
Organizations and Functions
Other Organizational Alternatives Explored
The creation of a comprehensive Department of Natural Resources and Environment embracing the full range of development, management, preservation and protective functions affecting our physical resources. The rationale of this alternative is that air and water are two of our natural resources, and anti-pollution would be brought under common responsibility with land and water management, energy development, parks and recreation, and marine technology activities. It would, however, subject the standard-setting function to the inherent bias of that department, to the relative disadvantage of other departments with equally important perspectives of the problem. That department would be called upon to make decisions bearing on the authority of other departments when its own objectivity could be called into question.
The assignment of environmental protection responsibilities to the Department of Health, Education, and Welfare, forming a distinct administration in this agency for this purpose. Such a plan would stress the important health-related objectives of anti-pollution programs and would capitalize on the public and personal health expertise of HEW in formulating and administering standards. It would have the same disadvantages as the foregoing alternative.
The creation of a small standard-setting agency in the Executive Office of the President which would establish or validate standards governing pollution abatement, leaving operational air, water, and soil responsibilities either in their respective departments, or putting them in a Department of Natural Resources. The first alternative would likely be least disruptive to present functional assignments, but would not produce the centrally managed anti-pollution operations so urgently required. In the second alternative, separation of standard-setting from a strong institutional and functional base would simply mean yet another coordinating entity of sorts, without the manpower and money to give its functions the necessary drive.
Organizations and Functions Transferred
1. Federal Water Quality Administration (FWQA) - Interior. This administration was transferred from HEW to Interior in 1966. Charged with the control of pollutants which impair water quality, it is broadly concerned with the impact of degraded water quality on ecological balance, aesthetics, and recreation. FWQA performs a wide range of functions, including research, standard-setting and enforcement, construction grants, and technical assistance These functions, as well as its financial incentives, are indispensable to the EPA. It is recommended for transfer in toto.
Water pollution control has constituted the major portion of the Federal Government's pollution reduction efforts thus far. Expenditures for FY 1970 are estimated to be $258,040,000. The appropriations requested for FY 1971, however, reflect your proposed $4 billion Federal waste treatment grants program. Employment now totals 2,290.
Research and standard-setting relating to the health effects of water pollution ins located separately in HEW's Bureau of Water Hygiene, discussed below. It is proposed that this program also be transferred to the new environmental administration, thus bringing together water quality standard-setting authority.
2. National Air Pollution Control Administration (NAPCA) - HEW. This administration is the principal Federal agency concerned with air pollution. NAPCA conducts research on the effects of air pollution, operates a monitoring network, and promulgates criteria which serve as the basis for setting emission standards. Its research and regulatory functions are similar to those of the Federal Water Quality Administration. NAPCA is responsible for administering the provisions of the 1967 Air Quality Act, and a large portion of the agency's effort is devoted to designating air quality regions, approving state standards, and providing financial and technical assistance to state control agencies to enable them to comply with the Act's provisions. We recommend that NAPCA be transferred to the new environmental administration and be merged with the other major pollution control programs. HEW would continue its basic environmental health research at the National Institute for Environmental Health Sciences and would make its findings available to the new administration for appropriate consideration in setting air pollution standards.
NAPCA's estimated FY 1970 expenditures total $81,400,000 and its employment is 1,020.
3. Environmental Control Administration (ECA) - HEW. This administration is the focal point within HEW for evaluation and control of a broad range of environmental health problems, including water pollution, radiation, solid waste accumulation and disposal, noise, occupational hazards caused by pollution, and unsanitary community conditions. It performs basic and applied research, develops recommended state standards and codes covering sanitary requirements, and provides planning and demonstration grants.
The ECA was created in 1968 by an internal reorganization order, drawing together several science-based, environment-oriented units of Public Health Service which were either too small or too specialized to be included elsewhere. ECA now consists of five bureaus: Solid Waste Management, Water Hygiene, Radiological Health, Occupational Safety and Health, and Community Environment Management. The administration's estimated expenditures in FY 1970 totaled $51,428,000, and employment is 1,865.
We recommend that ECA's Bureaus of Solid Waste Management and Water Hygiene be transferred in their entirety to the new environmental administration. We also recommend the transfer of the Bureau of Radiological Health, with the exception of its activities dealing with the regulation of radioactive emissions from consumer products. Similarly, we recommend that the environmental programs of the Bureaus of Occupational Safety and Health and Community Environmental Management be transferred to the new environmental administration. Programs related to consumer product safety and workmen's accident prevention and safety would remain in HEW.
4. Pesticides Research and Standard-Setting Programs of the Food and Drug Administration (FDA) - HEW. HEW's pesticides program includes research on the adverse effects of pesticides in the environment and comprehensive regulatory authority for pesticide residues in food. It is located in the Food and Drug Administration, an independent agency within the Public Health Service, whose overall mission is regulation of the safety of foods, drugs, and certain consumer products.
The pesticides research program represents an attempt to evaluate the total environmental effects of pesticide use. For example, a large portion of the current research effort is devoted to community studies to determine the extent and sources of human exposure to pesticides. Estimated expenditures for FDA's pesticides program in FY 1970 totaled $3,500,000 and employment is 82.
Pesticides are now considered a major class of pollutants. They are present in and travel through all media, of which food is one. Nevertheless, pesticide research and regulation has been a most fragmented program. We recommend that FDA's authority to set standards for pesticide residues in food be transferred to the new administration, along with the research program necessary to provide the scientific base for standard-setting. These functions would be merged with the pesticide registration program of the Department of Agriculture (discussed below).
We recommend that the new administration consider redelegating to FDA the actual enforcement of pesticide residue standards, since this would ensure full use of FDA's existing field inspection staff and avoid unnecessary duplication.
5. Pesticides Registration Program of the Agricultural Research Service (ARS) - Agriculture. The Department of Agriculture is currently responsible for two distinct functions related to pesticides use. It conducts research on the efficiency of various pesticides used for agricultural or other purposes, and it administers the Federal Insecticide, Fungicide, and Rodenticide Act. The Act is aimed at regulating "economic poisons" in the environment affecting man, animals or plant life.
The Agricultural Research Service registers pesticides for safe use, based on information furnished through interagency agreement by the FDA and the Bureau of Sport Fisheries and Wildlife in the Interior Department. The FY 1970 estimated expenditures for the pesticides registration program of the ARS totaled $4,268,000 and staff is 286.
We recommend that the Department of Agriculture's pesticides registration function be transferred to the EPA and merged with the pesticides research and standards-setting programs being transferred from HEW. This would give the new administration comprehensive regulatory power over the introduction of pesticides into the environment.
The Department of Agriculture would continue to conduct research on the economic effectiveness of pesticides, and furnish this information to the EPA, which would have the responsibility for actually licensing pesticides for use after considering their environmental and health effects.
6. Elements of the Radiation Protection Standards Function (AEC). The AEC has broad regulatory authority over the operations of all civilian nuclear facilities and uses of nuclear materials. This includes setting standards for the control of the release of radioactive emissions from civilian nuclear facilities, medical and industrial uses of isotopes, and the transportation and storage of radioactive wastes.
Radiation emission standards are presently issued by the AEC's Division of Radiation Protection Standards, and are based principally on broad guidelines recommended to the President by the Federal Radiation Council (FRC). The total expenditures involved in this standard-setting function are estimated to be $500,000 in FY 1970 and employment is 20 people.
We propose transferring to the EPA the authority to set standards for those emissions which introduce radiation into the general environment. This would include, for example, standards for radioactivity released into the atmosphere by a nuclear power plant, the release of radioactivity into a stream, or the disposition of nuclear wastes.
We also recommend that the FRC be abolished, and its functions transferred to the EPA. Radiation is a major pollutant and may be present in all media. If the new administration is to have a comprehensive environmental protection capability, it must have the authority to establish radiation standards.
The authority to set standards relating to occupational hazards and medical uses of radioactive materials should remain with the AEC. The AEC would also retain responsibility for the enforcement of all standards--occupational and environmental--through its general licensing authority.
7. Environmental Science Services Administration (ESSA) - Commerce. The Environmental Science Services Administration is primarily an environmental data collection and information dissemination service. Its information on atmospheric and water conditions is available to and used by the private and public sectors. Organized five years ago, ESSA has as its five divisions:
- Weather bureau (real-time observation, measurement, understanding, and forecasting the atmospheric and hydrologic environments);
- Coast and Geodetic Survey (geodesy, geophysics and cartography);
- Environmental Data Service (archival storage of environmental data);
- National Environmental Satellite Center (observation of the global environment from instrumentation satellites);
- Research Laboratories (applied research to further the long-range missions of the other four divisions).
ESSA's estimated FY 1970 expenditures are $192,615,000 and its personnel total is 9,056.
Through its nationwide field network of air and water monitoring stations and international and interagency cooperation, ESSA observes and records current environmental conditions. It applies its skills to forecast weather changes, river flows, floods, and water supplies. ESSA also collects basic atmospheric physical data (e.g., carbon dioxide concentrations, ozone levels, and turbidity) in order to describe the "normal" state of the atmosphere. It maintains special air quality stations which monitor pollution concentrations in selected urban localities. Research is conducted in basic meteorological and hydrological dynamics, as well as improved instrumentation, data analysis, and communications techniques. In recent years ESSA has also begun weather modification programs, such as studies leading to an ability to disperse "super-cooled" fog at airports. Since climatic conditions strongly influence pollution levels, the ability to forecast or modify weather in an important factor in pollution control.
The Coast and Geodetic Survey conducts geophysical and marine activities that include aeronautical, earth, and marine charting and mapping. This information is needed for mineral and oceanic development, and other activities such as navigation and surveying. If ESSA is transferred to the EPA, we recommend that the Coast and Geodetic Survey be transferred to the proposed Department of Natural Resources, rather than remain with the bulk of ESSA. ESSA's telecommunications functions would be assigned to the proposed telecommunications sciences agency in the Commerce Department.