This memo from the President's Advisory Council on Executive Organization (PACEO), better known as the "Ash Council,” recommended that "key anti-pollution programs be merged into an Environmental Protection Administration, a new independent agency of the Executive Branch." This new agency would be the "principal instrument" for fulfilling the president’s pledge to "repair the damage already done, and to establish new criteria to guide us in the future."
The memo claimed that the "environmental crisis" was the result of "vastly increased per capita consumption, intensified by population growth, urbanization, and changing industrial processes." The rationale presented for an independent EPA was that: 1) There was a need to consider environmental protection in a unified way; 2) There should be a separate agency for setting key standards for other agencies so that the interests of those other agencies would not affect the standards. Consolidating these functions in a single agency would also have the benefit of simplifying intergovernmental and business relationships.
The Ash Council proposed that the key functions of the agency should be: scientific research, standard-setting, monitoring, and enforcement. It also proposed reorganizing the agency around those functions as opposed to organizing offices by the source, media, location, or effects of pollution. Doing the latter would mean not recognizing the interrelated aspects of pollution and environmental problems. The memo outlined why it rejected alternative organizational plans: A combined Department of Natural Resources and Environment would, the memo said, subject standard-setting to pressures of resource development. Putting the agency in any existing department would result in one department regulating others, which would not be ideal. Nor would creating a small, strictly standard-setting agency. This would leave monitoring and enforcement fragmented across departments.
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LINK TO THIS ARTICLEhttps://www.apeoplesepa.org/modules/federal-organization-for-environmental-protection
Ash Council (PACEO), "Federal Organization for Environmental Protection," [Memo], April 29, 1970