April 10, 2001

MEMORANDUM

     The quality of the science and analysis that underlie EPA regulations is vital to the credibility of EPA decisions and ultimately our effectiveness in protecting human health and the environment. Additionally, continued testing and adoption of new environmental protection methods must. be a central tenet in environmental problem solving: An improved regulatory process and a strong commitment to innovative solutions will ensure that the significant environmental improvements that we all want to achieve are cost-effective, fair and fully protective.

     Today, I am announcing several actions to strengthen EPA's regulatory process and to strategically target environmental innovation. I am requesting a 45 day review of EPA's regulatory development process to identify opportunities to strengthen the role of science, economics and policy analysis. I am establishing a Task Force to be chaired by Tom Gibson until a Deputy Administrator is confirmed, to review the current internal requirements for the rulemaking process and make recommendations to me on improvements. All Acting Assistant Administrators will be members of the Task Force, which will commence the week of April 16, 2001.

     To expedite final Agency clearance of rules in the near term, I have asked the Office of Policy, Economics and Innovation (OPEI) to coordinate the internal approval process for rules ready for review by the Office of Management and Budget (OMB). OPEI will schedule a meeting with each program to review the underlying basis for these rules and to determine whether additional analysis is necessary prior to submission to OMB. Also, to ensure that the Agency speaks with one voice on regulatory issues, I have asked OPEI to serve as the Agency liaison with OMB, in partnership with each program, on all matters dealing with regulatory policy. All meetings and discussions with OMB should include both OPEI and the media program responsible for the rule. It is vital that we are fully prepared for close scrutiny of rules -- and ready to answer tough questions about science, peer review, benefits, costs, and policy alternatives selected.

     Finally, to reaffirm and update EPA's innovation agenda, I am requesting the Innovation Action Council (composed of Deputy Assistant Administrators and Deputy Regional Administrators) formulate recommendations for updating our innovations strategy by July 1, 2001. I am interested in leveraging the experiences gained in voluntary and regulatory flexibility programs, and in targeting innovation on environmental priorities with particular emphasis on collaborating with states. I fully support the continued progress on Project XL, Performance Track and innovation projects with states until I can review the recommendations of this group and affirm a new innovations strategy.

     By taking these actions, EPA will produce better informed decisions and ensure that the Nation's environmental protection system produces the best outcomes at an acceptable cost. Appropriate scientific, economic and policy analyses must be planned at early stages in the regulatory development process so that senior Agency decision makers understand the benefits and costs of policy options from which to choose. Additionally, I believe that we can continue to apply new methods to protect the environment -- by building flexibility into regulations up front, through non-regulatory approaches where effective, creating strong partnerships with states and businesses, and with vigorous public outreach and involvement -- to meet far reaching environmental goals.

     I need your leadership, as well as support from your organizations, to make these actions successful. Over the next several months, I look forward to hearing your ideas about improvements to the regulatory decision process and innovation at EPA. Thank you for your help.

/s/ CTW

Christine Todd Whitman