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71-670: EPA most commonly refers to the United States Environmental Protection Agency . EPA may also refer to: United States Environmental Protection Agency The Environmental Protection Agency ( EPA ) is an independent agency of the United States government tasked with environmental protection matters. President Richard Nixon proposed the establishment of EPA on July 9, 1970; it began operation on December 2, 1970, after Nixon signed an executive order . The order establishing

142-622: A Colorado mine, and accidentally released over three million gallons of waste water into Cement Creek and the Animas River . In 2015, the International Agency for Research on Cancer (IARC), a branch of the World Health Organization , cited research linking glyphosate , an ingredient of the weed killer Roundup manufactured by the chemical company Monsanto , to non-Hodgkin's lymphoma . In March 2017,

213-591: A 15-year cut of 32%, or 789 million metric tons of carbon dioxide. In 2019 it was voided and replaced by the Affordable Clean Energy rule under the Trump administration, and in 2022 its constitutionality was ruled out by the Supreme Court. In August 2015, the 2015 Gold King Mine waste water spill occurred when EPA contractors examined the level of pollutants such as lead and arsenic in

284-499: A CATEX from NEPA requirements as these portions of I-69 utilize existing freeways that required little more than minor spot improvements and a change of highway signage. Additionally, a CATEX can be issued during an emergency when time does not permit the preparation of an EA or EIS. An example of the latter is when the Federal Highway Administration issued a CATEX to construct the replacement bridge in

355-502: A dramatic move to the right, President Ronald Reagan in 1981 appointed Anne Gorsuch as EPA administrator. Gorsuch based her administration of EPA on the New Federalism approach of downsizing federal agencies by delegating their functions and services to the individual states. She believed that EPA was over-regulating business and that the agency was too large and not cost-effective. During her 22 months as agency head, she cut

426-410: A good analysis. In addition, government officials do not want to reveal an environmental problem from within their own agency. Citizens often misunderstand the environmental assessment process. The public does not realize that the process is only meant to gather information relevant to the decision. Even if the statement predicts negative impacts of the project, decision makers can still proceed with

497-620: A joint House–Senate colloquium was convened by the chairmen of the Senate Committee on Interior and Insular Affairs, Senator Henry M. Jackson , and the House Committee on Science and Astronautics, Representative George P. Miller , to discuss the need for and means of implementing a national environmental policy. Congress enacted the National Environmental Policy Act of 1969 (NEPA) and the law

568-612: A national outcry and criminal charges against major steel companies. The US Justice Department in late 1970 began pollution control litigation in cooperation with the new EPA. Congress enacted the Federal Water Pollution Control Act Amendments of 1972, better known as the Clean Water Act (CWA). The CWA established a national framework for addressing water quality, including mandatory pollution control standards, to be implemented by

639-511: A public record, making it controversial and difficult to rescind. So they did not open it; rather, they called Johnson and asked him to take back the draft. Johnson rescinded the draft; in July 2008, he issued a new version which did not state that global warming was danger to public welfare. Burnett resigned in protest. In April 2008, the Union of Concerned Scientists said that more than half of

710-591: A second term. As a condition for accepting his appointment, Ruckleshaus obtained autonomy from the White House in appointing his senior management team. He then appointed experienced competent professionals to the top management positions, and worked to restore public confidence in the agency. Lee M. Thomas succeeded Ruckelshaus as administrator in 1985. In 1986 Congress passed the Emergency Planning and Community Right-to-Know Act , which authorized

781-757: A senior official at the Environmental Protection Agency had worked to quash a review of Roundup's main ingredient, glyphosate, that was to have been conducted by the United States Department of Health and Human Services ." The records show that Monsanto was able to prepare "a public relations assault" on the finding after they were alerted to the determination by Jess Rowland , the head of the EPA's cancer assessment review committee at that time, months in advance. Emails also showed that Rowland "had promised to beat back an effort by

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852-580: A total of fourteen states had joined the suit—the U.S. Court of Appeals for the District of Columbia ruled that the EPA regulations violated the Clean Air Act. In response, EPA announced plans to propose such standards to replace the vacated Clean Air Mercury Rule, and did so on March 16, 2011. In July 2005 there was a delay in the issuance of an EPA report showing that auto companies were using loopholes to produce less fuel-efficient cars. The report

923-578: Is to promote informed decision-making by federal agencies by making "detailed information concerning significant environmental impacts" available to both agency leaders and the public. The NEPA was the first piece of legislation that created a comprehensive method to assess potential and existing environmental risks at once. It also encourages communication and cooperation between all the actors involved in environmental decisions, including government officials, private businesses, and citizens. In particular, an EIS acts as an enforcement mechanism to ensure that

994-744: Is with no action taken by the lead agency. Analysis of the No Action Alternative is used to establish a baseline upon which to compare the proposed "Action" alternatives. Contrary to popular belief, the "No Action Alternative" doesn't necessarily mean that nothing will occur if that option is selected in the Record of Decision. For example, the "No Action Alternative" was selected for the I-69/Trans-Texas Corridor Tier-I Environmental Impact Statement. In that Record of Decision,

1065-524: The Council on Environmental Quality and Atomic Energy Commission . Upon its creation, EPA inherited 84 sites spread across 26 states, of which 42 sites were laboratories. The EPA consolidated these laboratories into 22 sites. In its first year, the EPA had a budget of $ 1.4 billion and 5,800 employees. At its start, the EPA was primarily a technical assistance agency that set goals and standards. Soon, new acts and amendments passed by Congress gave

1136-492: The federally recognized tribes . The agency also works with industries and all levels of government in a wide variety of voluntary pollution prevention programs and energy conservation efforts. The agency's budgeted employee level in 2023 is 16,204.1 full-time equivalent (FTE). More than half of EPA's employees are engineers, scientists, and environmental protection specialists; other employees include legal, public affairs, financial, and information technologists. Beginning in

1207-506: The 2009 through 2016 model years. Following notice of violations and potential criminal sanctions, Volkswagen later agreed to a legal settlement and paid billions of US dollars in criminal penalties, and was required to initiate a vehicle buyback program and modify the engines of the vehicles to reduce illegal air emissions. In August 2015, the EPA finalized the Clean Power Plan to regulate emissions from power plants, projecting

1278-501: The Department of Health and Human Services to conduct its own review." On February 17, 2017, President Donald Trump appointed Scott Pruitt as EPA administrator. The Democratic Party saw the appointment as a controversial move, as Pruitt had spent most of his career challenging environmental regulations and policies. He did not have previous experience in the environmental protection field and had received financial support from

1349-449: The EA determines whether an EIS is required. If the EA indicates that no significant impact is likely, then the agency can release a finding of no significant impact (FONSI) and carry on with the proposed action. Otherwise, the agency must then conduct a full-scale EIS. Most EAs result in a FONSI. A limited number of federal actions may avoid the EA and EIS requirements under NEPA if they meet

1420-575: The EPA was ratified by committee hearings in the House and Senate. The agency is led by its administrator , who is appointed by the president and approved by the Senate . The current administrator is Michael S. Regan . The EPA is not a Cabinet department, but the administrator is normally given cabinet rank . The EPA has its headquarters in Washington, D.C. There are regional offices for each of

1491-580: The EPA to gather data on toxic chemicals and share this information with the public. EPA also researched the implications of stratospheric ozone depletion. Under Administrator Thomas, EPA joined with several international organizations to perform a risk assessment of stratospheric ozone, which helped provide motivation for the Montreal Protocol, which was agreed to in August 1987. In 1988, during his first presidential campaign, George H. W. Bush

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1562-501: The EPA was working on its own standards, but the move has been widely considered an attempt to shield the auto industry from environmental regulation by setting lower standards at the federal level, which would then preempt state laws. California governor Arnold Schwarzenegger , along with governors from 13 other states, stated that the EPA's actions ignored federal law, and that existing California standards (adopted by many states in addition to California) were almost twice as effective as

1633-448: The EPA. The EPA's inspector general had determined that the EPA's regulation of mercury emissions did not follow the Clean Air Act, and that the regulations were influenced by top political appointees. The EPA had suppressed a study it commissioned by Harvard University which contradicted its position on mercury controls. The suit alleged that the EPA's rule exempting coal-fired power plants from "maximum available control technology"

1704-604: The Federal Water Quality Administration, which had previously been transferred from PHS to the Department of the Interior in 1966. A few functions from other agencies were also incorporated into EPA: the formerly independent Federal Radiation Council was merged into it; pesticides programs were transferred from the Department of the Interior, Food and Drug Administration , and Agricultural Research Service ; and some functions were transferred from

1775-537: The LEDPA. An EIS typically has four sections: While not required in the EIS, the following subjects may be included as part of the EIS or as separate documents based on agency policy. Every EIS is required to analyze a No Action Alternative , in addition to the range of alternatives presented for study. The No Action Alternative identifies the expected environmental impacts in the future if existing conditions were left as

1846-621: The Texas Department of Transportation opted not to proceed with building its portion of I-69 as one of the Trans-Texas Corridors to be built as a new-terrain route (the Trans-Texas Corridor concept was ultimately scrapped entirely), but instead decided to proceed with converting existing US and state routes to I-69 by upgrading those roads to interstate standards. The NEPA process is designed to involve

1917-479: The Tier I EIS would analyze the potential socio-environmental impacts along a general corridor, but would not identify the exact location of where the action would occur. A Tier I ROD would be issued approving the general area where the action would be implemented. Following the Tier I ROD, the approved Tier I area is further broken down into subareas, and a Tier II EIS is then prepared for each subarea, that identifies

1988-450: The Trump administration attempted to revoke a waiver issued to the state which allowed more stringent standards for auto and truck emissions than the federal standards. Environmental impact statement Preliminary versions of these documents are officially known as a draft environmental impact statement (DEIS) or draft environmental impact report (DEIR). The purpose of the NEPA

2059-542: The US population. The law required EPA to enforce the standards with the cooperation of state agencies. In October 1976, Congress passed the Toxic Substances Control Act (TSCA) which, like FIFRA, related to the manufacture, labeling and usage of commercial products rather than pollution. This act gave the EPA the authority to gather information on chemicals and require producers to test them, gave it

2130-724: The ability to regulate chemical production and use (with specific mention of PCBs ), and required the agency to create the National Inventory listing of chemicals. Congress also enacted the Resource Conservation and Recovery Act (RCRA) in 1976, significantly amending the Solid Waste Disposal Act of 1965 . It tasked the EPA with setting national goals for waste disposal, conserving energy and natural resources, reducing waste, and ensuring environmentally sound management of waste. Accordingly,

2201-565: The act encourages them to consider the environmental costs of a project and introduces new information into the decision-making process. The NEPA has increased the influence of environmental analysts and agencies in the federal government by increasing their involvement in the development process. Because an EIS requires expert skill and knowledge, agencies must hire environmental analysts. Unlike agencies who may have other priorities, analysts are often sympathetic to environmental issues. In addition, this feature introduces scientific procedures into

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2272-538: The action can proceed. Obtaining these permits typically requires the lead agency to implement the Least Environmentally Damaging Practicable Alternative (LEDPA) to comply with federal, state, and local environmental laws that are ancillary to NEPA. In some instances, the result of NEPA analysis leads to abandonment or cancellation of the proposed action, particularly when the "No Action" alternative ends up being

2343-422: The action is not specifically sponsored by a federal agency. These factors may include actions that receive federal funding, federal licensing or authorization, or that are subject to federal control. Not all federal actions require a full EIS. If the action may or may not cause a significant impact, the agency can first prepare a smaller, shorter document called an Environmental Assessment (EA). The finding of

2414-399: The agency developed regulations for solid and hazardous waste that were to be implemented in collaboration with states. President Jimmy Carter appointed Douglas M. Costle as EPA administrator in 1977. To manage the agency's expanding legal mandates and workload, by the end of 1979 the budget grew to $ 5.4 billion and the workforce size increased to 13,000. In 1980, following

2485-613: The agency in partnership with the states. Congress amended the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in 1972, requiring EPA to measure every pesticide's risks against its potential benefits. In 1973 President Nixon appointed Russell E. Train , to be the next EPA Administrator. In 1974 Congress passed the Safe Drinking Water Act , requiring EPA to develop mandatory federal standards for all public water systems , which serve 90% of

2556-565: The agency its regulatory authority. A major expansion of the Clean Air Act was approved in December 1970. EPA staff recall that in the early days there was "an enormous sense of purpose and excitement" and the expectation that "there was this agency which was going to do something about a problem that clearly was on the minds of a lot of people in this country," leading to tens of thousands of resumes from those eager to participate in

2627-638: The agency's Scientific Integrity Official, Francesca Grifo , from testifying at a House committee hearing. EPA offered to send a different representative in place of Grifo and accused the committee of "dictating to the agency who they believe was qualified to speak." The hearing was to discuss the importance of allowing federal scientists and other employees to speak freely when and to whom they want to about their research without having to worry about any political consequences. In September 2019 air pollution standards in California were once again under attack, as

2698-489: The agency's ten regions, as well as 27 laboratories around the country. The agency conducts environmental assessment , research, and education. It has the responsibility of maintaining and enforcing national standards under a variety of environmental laws , in consultation with state, tribal, and local governments. EPA enforcement powers include fines, sanctions , and other measures. It delegates some permitting, monitoring, and enforcement responsibility to U.S. states and

2769-699: The agency. Assistant Administrator Rita Lavelle was fired by Reagan in February 1983 because of her mismanagement of the Superfund program. Gorsuch had increasing confrontations with Congress over Superfund and other programs, including her refusal to submit subpoenaed documents. Gorsuch was cited for contempt of Congress and the White House directed EPA to submit the documents to Congress. Gorsuch and most of her senior staff resigned in March 1983. Reagan then appointed William Ruckelshaus as EPA Administrator for

2840-419: The budget of the EPA by 22%, reduced the number of cases filed against polluters, relaxed Clean Air Act regulations, and facilitated the spraying of restricted-use pesticides. She cut the total number of agency employees, and hired staff from the industries they were supposed to be regulating. Environmentalists contended that her policies were designed to placate polluters, and accused her of trying to dismantle

2911-459: The censorship of environmental reports . President Obama appointed Gina McCarthy as EPA administrator in 2013. In 2014, the EPA published its "Tier 3" standards for cars, trucks and other motor vehicles, which tightened air pollution emission requirements and lowered the sulfur content in gasoline. In 2015, the EPA discovered extensive violations by Volkswagen Group in its manufacture of Volkswagen and Audi diesel engine cars, for

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2982-403: The combination of pesticide programs from the United States Department of Agriculture and the United States Department of the Interior . After conducting hearings during that summer, the House and Senate approved the proposal. The EPA was created 90 days before it had to operate, and officially opened its doors on December 2, 1970. The agency's first administrator, William Ruckelshaus , took

3053-527: The cost and schedule for implementing the action under control. However, many activities require various federal permits to comply with other environmental legislation, such as the Clean Air Act , the Clean Water Act , Endangered Species Act and Section 4(f) of the Federal Highway Act to name a few. Similarly, many states and local jurisdictions have enacted environmental laws and ordinances, requiring additional state and local permits before

3124-498: The criteria for a categorical exclusion (CATEX). A CATEX is usually permitted when a course of action is identical or very similar to a past course of action and the impacts on the environment from the previous action can be assumed for the proposed action, or for building a structure within the footprint of an existing, larger facility or complex. For example, two recently completed sections of Interstate 69 in Kentucky were granted

3195-498: The discovery of many abandoned or mismanaged hazardous waste sites such as Love Canal , Congress passed the Comprehensive Environmental Response, Compensation, and Liability Act , nicknamed "Superfund." The new law authorized EPA to cast a wider net for parties responsible for sites contaminated by previous hazardous waste disposal and established a funding mechanism for assessment and cleanup. In

3266-529: The environment. Because of the intense level of detail required in analyzing the alternatives presented in an EIS or EA, such documents may take years or even decades to compile, and often compose of multiple volumes that can be thousands to tens of thousands of pages in length. To avoid potential conflicts in securing required permits and approvals after the ROD is issued, the lead agency will often coordinate with stakeholders at all levels, and resolve any conflicts to

3337-420: The environment. The "detailed statement" would ultimately be referred to as an environmental impact statement (EIS). On July 9, 1970, Nixon proposed an executive reorganization that consolidated many environmental responsibilities of the federal government under one agency, a new Environmental Protection Agency. This proposal included merging pollution control programs from a number of departments, such as

3408-620: The exact location of where the proposed action will take place. The preparation of Tier II EISs for each subarea proceeds at its own pace, independent from the other subareas within the Tier I area. For example, parts of the proposed Interstate 69 extension in Indiana and Texas , as well as portions of the Interstate 11 corridor in Nevada and Arizona are being studied through a two-tiered process By requiring agencies to complete an EIS,

3479-460: The federal government adheres to the goals and policies outlined in the NEPA. An EIS should be created in a timely manner as soon as the agency is planning development or is presented with a proposal for development. The statement should use an interdisciplinary approach so that it accurately assesses both the physical and social impacts of the proposed development. In many instances an action may be deemed subject to NEPA's EIS requirement even though

3550-548: The fossil fuel industry. In 2017, the Presidency of Donald Trump proposed a 31% cut to the EPA's budget to $ 5.7 billion from $ 8.1 billion and to eliminate a quarter of the agency jobs. However, this cut was not approved by Congress. Pruitt resigned from the position on July 5, 2018, citing "unrelenting attacks" due to ongoing ethics controversies. President Trump appointed Andrew R. Wheeler as EPA Administrator in 2019. On July 17, 2019, EPA management prohibited

3621-416: The greatest extent possible during the EIS process. Proceeding in this fashion helps avoid interagency conflicts and potential lawsuits after the lead agency reaches its decision. On exceptionally large projects, especially proposed highway , railroad , and utility corridors that cross long distances, the lead agency may use a two-tiered process prior to implementing the proposed action. In such cases,

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3692-621: The late 1950s and through the 1960s, Congress reacted to increasing public concern about the impact that human activity could have on the environment. Senator James E. Murray introduced a bill, the Resources and Conservation Act (RCA) of 1959, in the 86th Congress . The bill would have established a Council on Environmental Quality in the Executive Office of the President , declared a national environmental policy, and required

3763-511: The mighty effort to clean up America's environment. When EPA first began operation, members of the private sector felt strongly that the environmental protection movement was a passing fad. Ruckelshaus stated that he felt pressure to show a public which was deeply skeptical about government's effectiveness, that EPA could respond effectively to widespread concerns about pollution. The burning Cuyahoga River in Cleveland, Ohio, in 1969 led to

3834-504: The nearly 1,600 EPA staff scientists who responded online to a detailed questionnaire reported they had experienced incidents of political interference in their work. The survey included chemists, toxicologists, engineers, geologists and experts in other fields of science. About 40% of the scientists reported that the interference had been more prevalent in the last five years than in previous years. President Barack Obama appointed Lisa P. Jackson as EPA administrator in 2009. In 2010 it

3905-846: The number of waste sites that are remediated in a given year. (In 2021 Congress reauthorized an excise tax on chemical manufacturers. ) Major legislative updates during the Clinton Administration were the Food Quality Protection Act and the 1996 amendments to the Safe Drinking Water Act. President George W. Bush appointed Christine Todd Whitman as EPA administrator in 2001. Whitman was succeeded by Mike Leavitt in 2003 and Stephen L. Johnson in 2005. In March 2005 nine states (California, New York, New Jersey, New Hampshire, Massachusetts, Maine, Connecticut, New Mexico and Vermont) sued

3976-610: The oath of office on December 4, 1970. EPA's primary predecessor was the former Environmental Health Divisions of the U.S. Public Health Service (PHS), and its creation caused one of a series of reorganizations of PHS that occurred during 1966–1973. From PHS, EPA absorbed the entire National Air Pollution Control Administration, as well as the Environmental Control Administration's Bureau of Solid Waste Management, Bureau of Water Hygiene, and part of its Bureau of Radiological Health. It also absorbed

4047-567: The passage of the Superfund law in 1980, an excise tax had been levied on the chemical and petroleum industries, to support the cleanup trust fund. Congressional authorization of the tax was due to expire in 1995. Although Browner and the Clinton Administration supported continuation of the tax, Congress declined to reauthorize it. Subsequently, the Superfund program was supported only by annual appropriations, greatly reducing

4118-416: The political process. The differences that exist between science and politics limit the accuracy of an EIS. Although analysts are members of the scientific community, they are affected by the political atmosphere. Analysts do not have the luxury of an unlimited time for research. They are also affected by the different motives behind the research of the EIS and by different perspectives of what constitutes

4189-417: The preparation of an annual environmental report. The conservation movement was weak at the time and the bill did not pass Congress. The 1962 publication of Silent Spring , a best-selling book by Rachel Carson , alerted the public about the detrimental effects on animals and humans of the indiscriminate use of pesticide chemicals. In the years following, Congress discussed possible solutions. In 1968,

4260-419: The presiding judge in a litigation brought about by people who claim to have developed glyphosate-related non-Hodgkin's lymphoma opened Monsanto emails and other documents related to the case, including email exchanges between the company and federal regulators. According to The New York Times , the "records suggested that Monsanto had ghostwritten research that was later attributed to academics and indicated that

4331-442: The proposed federal standards. It was reported that Johnson ignored his own staff in making this decision. In 2007 it was reported that EPA research was suppressed by career managers. Supervisors at EPA's National Center for Environmental Assessment required several paragraphs to be deleted from a peer-reviewed journal article about EPA's integrated risk information system , which led two co-authors to have their names removed from

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4402-437: The public and gather the best available information in a single place so that decision makers can be fully informed when they make their choices. This is the process of EIS Environmental Impact Statement Often, the agencies responsible for preparing an EA or EIS do not compile the document directly, but outsource this work to private-sector consulting firms with expertise in the proposed action and its anticipated effects on

4473-419: The public welfare—a decision that would trigger the first national mandatory global-warming regulations. Associate Deputy Administrator Jason Burnett e-mailed the draft to the White House. White House aides—who had long resisted mandatory regulations as a way to address climate change—knew the gist of what Johnson's finding would be, Burnett said. They also knew that once they opened the attachment, it would become

4544-414: The publication, and the corresponding author, Ching-Hung Hsu, to leave EPA "because of the draconian restrictions placed on publishing". The 2007 report stated that EPA subjected employees who author scientific papers to prior restraint , even if those papers are written on personal time. In December 2007 EPA administrator Johnson approved a draft of a document that declared that climate change imperiled

4615-592: The wake of the I-35W Mississippi River Bridge Collapse . NEPA does not prohibit the federal government or its licensees/permittees from harming the environment, instead it requires that the prospective impacts be understood and disclosed in advance. The intent of NEPA is to help key decisionmakers and stakeholders balance the need to implement an action with its impacts on the surrounding human and natural environment, and provide opportunities for mitigating those impacts while keeping

4686-619: Was based on ideas that had been discussed in the 1959 and subsequent hearings. The Richard Nixon administration made the environment a policy priority in 1969-1971 and created two new agencies, the Council on Environmental Quality (CEQ) and EPA. Nixon signed NEPA into law on January 1, 1970. The law established the CEQ in the Executive Office of the President. NEPA required that a detailed statement of environmental impacts be prepared for all major federal actions significantly affecting

4757-500: Was illegal, and additionally charged that the EPA's system of cap-and-trade to lower average mercury levels would allow power plants to forego reducing mercury emissions, which they objected would lead to dangerous local hotspots of mercury contamination even if average levels declined. Several states also began to enact their own mercury emission regulations. Illinois's proposed rule would have reduced mercury emissions from power plants by an average of 90% by 2009. In 2008—by which point

4828-605: Was reflected in the 1990 amendments to the Clean Air Act and in new approaches by the agency, such as a greater emphasis on watershed -based approaches in Clean Water Act programs. In 1992 EPA and the Department of Energy launched the Energy Star program, a voluntary program that fosters energy efficiency. Carol Browner was appointed EPA administrator by President Bill Clinton and served from 1993 to 2001. Major projects during Browner's term included: Since

4899-493: Was reported that a $ 3 million mapping study on sea level rise was suppressed by EPA management during both the Bush and Obama administrations, and managers changed a key interagency report to reflect the removal of the maps. Between 2011 and 2012, some EPA employees reported difficulty in conducting and reporting the results of studies on hydraulic fracturing due to industry and governmental pressure, and were concerned about

4970-536: Was supposed to be released the day before a controversial energy bill was passed and would have provided backup for those opposed to it, but the EPA delayed its release at the last minute. EPA initiated its voluntary WaterSense program in 2006 to encourage water efficiency through the use of a special label on consumer products. In 2007 the state of California sued the EPA for its refusal to allow California and 16 other states to raise fuel economy standards for new cars. EPA Administrator Stephen Johnson claimed that

5041-544: Was vocal about environmental issues. Following his election victory, he appointed William K. Reilly , an environmentalist, as EPA Administrator in 1989. Under Reilly's leadership, the EPA implemented voluntary programs and initiated the development of a "cluster rule" for multimedia regulation of the pulp and paper industry. At the time, there was increasing awareness that some environmental issues were regional or localized in nature, and were more appropriately addressed with sub-national approaches and solutions. This understanding

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