This chapter is about the agency that guards air, water and soil. It says the agency has grown beyond its job. It wants states to take the lead instead. It also wants changes to how the agency uses science, and to how it enforces rules.
The document says “needs to”Who acts: President, CongressHow: legislationp. 417 in the PDF
What the document says
“EPA needs to be realigned away from attempts to make it an all-powerful energy and land use policymaker and returned to its congressionally sanctioned role as environmental regulator.”
This is the chapter's framing proposition. It says the agency's structure and mission should be greatly circumscribed to reflect cooperative federalism and limited government, and that the primary role in making choices about the environment belongs to the people who live in it.
What the document actually says
“EPA needs to be realigned away from attempts to make it an all-powerful energy and land use policymaker and returned to its congressionally sanctioned role as environmental regulator.”
That sentence, in plain words
The EPA has become a maker of energy and land rules. It should go back to guarding the environment.
What this is about
The EPA is meant to protect air, water and soil. The book says it now sets energy and land rules too. It says that goes beyond its job.
The document says “should”Who acts: EPAHow: internal managementp. 420 in the PDF
What the document says
“EPA should build earnest relationships with state and local officials and assume a more supportive role”
The chapter says the agency should share resources and expertise with states, on the principle that the primary role in making environmental choices belongs to the people who live there. It lists this among six principles for restructuring the agency.
What the document actually says
“EPA should build earnest relationships with state and local officials and assume a more supportive role”
That sentence, in plain words
The EPA should work closely with states and towns. It should help them rather than lead.
What this is about
States also protect the environment. The book says they should lead. It says the EPA should help them instead of directing them.
The document says “should”Who acts: EPAHow: internal managementp. 422 in the PDF
What the document says
“EPA should not conduct any ongoing or planned activity for which there is not clear and current congressional authorization”
The chapter asks for a tiered-down approach to cut costs, reduce full-time equivalent positions and eliminate duplicative programs, and says this shift should be communicated in the President's first budget request.
What the document actually says
“EPA should not conduct any ongoing or planned activity for which there is not clear and current congressional authorization”
That sentence, in plain words
If Congress has not clearly approved a job, the EPA should not do it.
What this is about
Congress tells the EPA what work to do. The book says some work was never approved. It says that work should stop.
The document says “should”Who acts: PresidentHow: executive orderp. 436 in the PDF
What the document says
“The new President’s Inauguration Day regulatory review/freeze directives should avoid exceptions for EPA actions.”
The chapter says the freeze should explicitly include quasi-regulatory actions such as assessments, determinations, standards and guidance that have not gone through notice and comment, and which it says may date back years.
What the document actually says
“The new President’s Inauguration Day regulatory review/freeze directives should avoid exceptions for EPA actions.”
That sentence, in plain words
A new president freezes new rules on day one. The EPA should get no exception.
What this is about
A new president usually pauses new rules on day one. Agencies sometimes get let off. The book says the EPA should not be.
The document says “should”Who acts: EPA, CongressHow: legislationp. 437 in the PDF
What the document says
“Several ORD offices and programs, many of which constitute unaccountable efforts to use scientific determinations to drive regulatory, enforcement, and legal decisions, should be eliminated.”
The chapter gives the Integrated Risk Information System as its example, saying it has operated since the 1980s without ever being authorized by Congress, often sets safe levels based on what it calls questionable science and below background levels, and results in billions in economic costs.
What the document actually says
“Several ORD offices and programs, many of which constitute unaccountable efforts to use scientific determinations to drive regulatory, enforcement, and legal decisions, should be eliminated.”
That sentence, in plain words
Some research offices here should be closed. Their science drives rules and cases.
What this is about
One office studies how harmful chemicals are. Its findings shape rules and lawsuits. The book says Congress never approved it. It wants it closed.
The document says “should”Who acts: EPAHow: internal managementp. 438 in the PDF
What the document says
“Reject precautionary default models and uncertainty factors.”
The chapter says that in the face of uncertainty about links between pollutants and health effects, the agency's reliance on default assumptions such as the low-dose linear non-threshold model bakes orders of magnitude of risk into regulatory inputs. It asks that the agency instead default to less restrictive regulatory outcomes.
What the document actually says
“Reject precautionary default models and uncertainty factors.”
That sentence, in plain words
Drop the safety-first models used when the facts are unclear.
What this is about
Sometimes it is unclear how harmful a thing is. The EPA then assumes the worst. The book says that pushes rules too far. It wants a lighter starting point.
The document says “should”Who acts: EPAHow: internal managementp. 438 in the PDF
What the document says
“EPA should embrace so-called citizen science and deputize the public to subject the agency’s science to greater scrutiny”
The chapter names data analysis, identification of scientific flaws and research misconduct as the areas where it wants greater public scrutiny. It contrasts this with what it calls scaremongering risk communications and enforcement activities. The chapter separately lists making all supporting studies public and open to comment among its principles.
What the document actually says
“EPA should embrace so-called citizen science and deputize the public to subject the agency’s science to greater scrutiny”
That sentence, in plain words
Let the public check the agency's science. Ask them to look for mistakes.
What this is about
The EPA uses science to set rules. The book says the public should be able to check it. It wants people to look for errors.
The document says “should”Who acts: CongressHow: legislationp. 439 in the PDF
What the document says
“A high priority should be the repeal or reform of the Global Change Research Act of”
The Global Change Research Act of 1990 established the program that produces the National Climate Assessment. Chapter 2 separately asks that the same program be reshaped by executive order and that its output be critically analyzed and if required refused.
What the document actually says
“A high priority should be the repeal or reform of the Global Change Research Act of”
That sentence, in plain words
One old law should be a top target. Repeal it or change it.
What this is about
A 1990 law set up climate research across government. It produces regular climate reports. The book says the law should be repealed or changed.
The document says “should”Who acts: EPA, PresidentHow: internal managementp. 440 in the PDF
What the document says
“AIO should be significantly elevated as a stand-alone EPA Assistant Administrator office.”
The chapter asks that the office be led by a politically appointed, Senate-confirmed Assistant Administrator, ideally with strong ties to a federally recognized tribe, that it be located in the American West closer to most tribal nations with Oklahoma City, Dallas and other cities suggested, that all tribal grants and matters run through it, and that tribal staff report to it rather than to regional offices.
What the document actually says
“AIO should be significantly elevated as a stand-alone EPA Assistant Administrator office.”
That sentence, in plain words
This office should be raised up. It should stand on its own.
What this is about
One office handles work with tribal nations. It sits inside other offices now. The book says it should stand alone. It should also move out west.
The document says “should”Who acts: EPAHow: internal managementp. 441 in the PDF
What the document says
“OECA attorneys should be moved into OGC.”
The chapter says enforcement attorneys tend to take legal positions to win cases or obtain settlements that may be inconsistent with those of the general counsel and program offices, that it is unacceptable for the agency to hold inconsistent legal positions, and that all attorneys with authority to represent the agency should be housed in the general counsel's office.
What the document actually says
“OECA attorneys should be moved into OGC.”
That sentence, in plain words
Move these lawyers into the main legal office.
What this is about
The EPA has lawyers who bring cases. They sit in their own office. The book says they argue things the agency's main lawyers would not. It wants them moved.
The document says “should”Who acts: EPAHow: internal managementp. 441 in the PDF
What the document says
“Administration should pause and review all ongoing EJ and Title VI actions”
The chapter frames this as ensuring consistency with a forthcoming Supreme Court decision, and says elsewhere that enforcement and the distribution of grants should be based on neutral constitutional principles.
What the document actually says
“Administration should pause and review all ongoing EJ and Title VI actions”
That sentence, in plain words
Pause this work and look at it again. It covers fairness cases.
What this is about
Some EPA work looks at whether pollution falls harder on some communities. The book says that work should pause. It says a court ruling was coming.
The document says “should”Who acts: EPAHow: internal managementp. 420 in the PDF
What the document says
“EPA should foster cooperative relationships with the regulated community, especially small businesses, that encourage compliance over enforcement.”
This is one of six principles the chapter sets out for restructuring the agency, alongside state leadership, measurable results, streamlined process, reducing economic costs on communities, and transparent science.
What the document actually says
“EPA should foster cooperative relationships with the regulated community, especially small businesses, that encourage compliance over enforcement.”
That sentence, in plain words
The EPA should work with the firms it regulates. Help them follow the rules first.
What this is about
The EPA can fine a firm that breaks a rule. The book says it should help firms follow rules instead. It names small firms in particular.
The document says “should”Who acts: EPAHow: regulationp. 429 in the PDF
What the document says
“the repeal and reissuance of new regulations should be pursued.”
The passage concerns the definition of waters of the United States and Clean Water Act section 401, which governs state certification of federally permitted projects. The definition determines which waters and wetlands fall under federal jurisdiction and has been repeatedly revised and litigated.
What the document actually says
“the repeal and reissuance of new regulations should be pursued.”
That sentence, in plain words
These water rules should be repealed. New ones should be written.
What this is about
One rule decides which streams and wetlands the government controls. It has changed many times. The book says it should be scrapped and rewritten.
Recommendations on the agency's mission and structure, the role of states, its use of science and risk assessment, enforcement, tribal affairs and the water rules.
The chapter's detailed treatment of individual Clean Air Act provisions, pesticide registration, chemical review and waste cleanup, which contain many technical recommendations.
This chapter is unusually technical and a large share of its recommendations concern specific statutory provisions. What is indexed is the structural and policy layer rather than the provision-by-provision detail.
