Washington, DC — The U.S. Environmental Protection Agency’s new five-year Strategic Plan is heavy on high-flying rhetoric but light on pragmatics, according to comments filed today by Public Employees for Environmental Responsibility (PEER). Notably, its disinvestment in traditional pollution enforcement would likely undermine the plan’s other goals of cleaner air and water and less chemical exposures.
The 86-page plan for guiding EPA activities from 2014-18 was first unveiled for public comment through tomorrow. One of its central features is an embrace of what it labels “Next Generation Compliance” which consists largely of industry electronically self-reporting its pollution discharges. The stated but unsupported rationale for this shift is that enforcement “can have the inadvertent effect of discouraging innovative approaches that could improve compliance.” The plan then projects lower levels of traditional enforcement actions than in recent years, which were below levels in the 1990s.
“EPA’s ‘Next Generation Compliance’ sounds like a fancy term for old-fashioned kid gloves,” stated PEER Executive Director Jeff Ruch, noting that the plan pushes for the prosecution of polluters only when the enforcement incorporates “advanced monitoring technologies.” “In this plan, EPA sounds like it aspires to be the Small Business Administration. Yet, without strict across-the-board enforcement, industry has little incentive to install less-polluting technology. Polluters should not be allowed to escape fines and penalties by promising to invest in upgrading their physical plants.”
The plan also calls for reaching a set of utopian-sounding goals, such as “Cleaning up Communities,” “Ensuring the Safety of Chemicals” and “Protecting America’s Waters” by employing “Cross-Cutting Fundamental Strategies” like “Embracing EPA as a High-Performing Organization.”
“This plan manages to be both self-serving and downright silly at the same time, but it is hardly strategic,” Ruch added, noting the absence of any rigorous analysis of EPA’s ability to affect housing patterns or personal “sustainability choices” among its many goals. “For an agency facing frozen if not shrunken budgets, EPA should be considering strengthening its irreplaceable core functions of regulation and enforcement while jettisoning its questionable public education and community outreach efforts.”
In its comments, PEER also takes the plan to task for, among other shortcomings –
- Failing to address thousands of unregulated chemicals linked to genetic abnormalities and other maladies entering our waters from pharmaceuticals, personal care products and other sources;
- Pushing re-use of industrial wastes, such as coal ash and shredded tires, in consumer and agricultural products without conducting any risk assessments; and
- Dramatically rolling back radiation protections following a nuclear accident.
In contrast to the plan’s lofty environmental goals, many critical environmental measures are moving backward. For example, EPA has estimated that more than half of rivers and streams assessed are impaired. Yet, fewer previously impaired waters were restored to their intended uses and fewer causes of water-body impairment were addressed on an annual basis during the Obama tenure than in prior years.
“This document reads less like a strategic plan and more like a political campaign pamphlet,” Ruch concluded. “EPA’s plan would have us believe that we can achieve across-the-board environmental improvement without any new funding, regulation or a single trade-off.”
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View the draft 2014-18 EPA Strategic Plan
Examine EPA’s imploding criminal enforcement program
Note recent drop in EPA criminal investigators
See rollback of post-accident radiation protections
Look at declining water quality