SECTION: Vol. 26 ; No. 4 ; Pg. 488; ISSN: 0095-3997

LENGTH: 11963 words

HEADLINE: Managerial leadership in divided times: William Ruckelshaus and the paradoxes
of independence.

BYLINE: Dobel, J. Patrick

BODY:
   U.S. Congress. (1983b). House, Subcommittee on Energy and Commerce, hearings on E.P.A.'s
Air Pollution Control Programs, 98th Cong., 1st Sess. November 7.

U.S. Congress. (1984a). House, Committee on Science and Technology, hearings on E.P.A.'s
Office of Research and Development, 98th Cong., 2d Sess. March 14.

U.S. Congress. (1984b). House, Committee on Energy and Commerce, Superfund Reauthorization
bearings on H.R. 4813 and H.R. 4915, Bills to Provide for the Clean up of Hazardous Waste
Disposal Sites, 98th Cong., 2d Sess. February 28, March 8, 15.

Divided government has dominated American national politics for a generation. The Presidency and
one or both houses of Congress have been held by different parties in 20 of the last 24 years. Given
the decline of party loyalty and the prevalence of split ticket voting, the pattern will continue to be an
ongiong possibility in national politics. Although debate rages as to its consequences, I believe
divided government can cause significant problems for managerial leadership in federal agencies
(Chubb & Peterson, 1989; Mayhew, 1990; Thurber, 1991). The party divisions are amplified by
ideological differences and aggravated by the three-way tensions among a politicized presidency,
career agencies, and a decentralized and assertive Congress. For an agency administrator, the
divisions in government generate levels of conflict that undermine the most important sources of
managerial power. Managerial success and innovation in American politics generally depend on either
strong executive support or strong interest-group and congressional support (Behn, 1991; Doig &
Hargrove, 1987; Gortner, Mahler, & Nicholson, 1987; Heclo, 1977). The scrutiny and conflict at
the agency level generated by divided government, however, ensure that most efforts to use these
sources of support create powerful counterpressures that undercut these two sources of support.
This state of affairs places very high demands on the political skills of managers (Williams, 1991).

The debates over the effects of divided government concentrate on aggregate levels of analysis
measuring whether policy outputs, such as laws or hearings, have been affected by divided
government.(1) I believe that fine-grained case studies will demonstrate a much greater impact on
administrators than the aggregate analysis suggests. This article will help fill that gap by studying
William Ruckelshaus's agency leadership during this period. I will focus on how he adapts to the
problems posed by divided government for a manager. In particular, I will examine his stance of
institutional and personal independence as a strategy to cope with these constraints.

Ruckelshaus served as the first administrator of the Environmental Protection Agency (EPA) from
1971-1973. A decade later, after the scandals of Anne Gorsuch Burford's term, he also directed
EPA from 1983-1984. Ruckelshaus is widely regarded as a free administrator. During his first term,
he solidified and expanded EPA's budget and congressional support, established a clear mission and
culture for the agency, and laid the foundations for public support that helped EPA weather the
environmental backlash of the late 1970s. In his second term, he rebuilt the shattered morale,
personnel, and budget of the agency, including recasting the agency's own internal culture and
reestablishing EPA's credibility in the public arena. He accomplished these under the constraints of
divided government. His case illuminates both the durability of these divisions and conflicts in
American national government that affected both his terms and how their repercussions add to the
complexity of managerial leadership. It also illustrates the consistency and evolution of his own
commitment to independence as a leadership style.

The article will first examine the divisions as they affect leadership in agencies. Second, it will discuss
the elements of Ruckelshaus's strategy and how they addressed the divisions. Finally, it will evaluate
the paradoxical strengths and weaknesses of this strategy as a way to lead in divided times.

DIVIDED TIMES AND ADMINISTRATIVE LIFE

Managerial leadership requires public officials to address the public context to attain goals, and
dealing with the environment usually imposes the greatest demands on a manager's skills. The
environment of many federal administrators has been dominated by the conflicts generated by divided
government. The divisions do not, however, have the same impact across government. In agencies
supported by a strong consensus or where considerable resources enable distributive politics to
overcome differences, significant administrative leadership can take place. In arenas where
government provides services with stable clientele, managers can gain considerable leeway. Where
the political environment is not highly organized or has become very decentralized, leaders can gain
substantial discretion. In areas with relatively low profiles or very limited publics or underdeveloped
political opposition, ample room exists for managerial leadership (Lynn, 1984, 1987; May, 1991;
Wilson, 1989).

These divisions have their most profound impact in highly visible areas such as regulatory policy
where all actors see the stakes as high, all sides are organized, media interest is high, and ideological
differences divide the various interest groups. Agencies like the Occupational Health and Safety
Administration or Federal Trade Commission fall under this rubric. Environmental politics exemplifies
the most extreme results of all these divisions, and I will use it as an exemplar of these problems.(2)

The political context of a public manager at the federal level is dominated by several divisions in
national politics. First, the presidency has largely been controlled by moderate to conservative
Republicans, whereas the legislatures have been controlled by moderate to liberal Democrats. Even
under the Carter presidency, the presidency remained moderate to conservative, and during the
Republican control of the Senate (1982-1988), the environmental committees remained firmly
proenviron-ment (Cohen, 1992). Second, the president and the executive office of the president
(EOP) became increasingly politicized and saw themselves locked in conflict with the bureaucracy
when they initiated changes. This politicized presidential establishment tried to control the agencies
through oversight by the Office of Management and Budget (OMB), the creation of special task
forces, and ideological screening of appointees.(3) Third, the major adversaries that regulated
business and the environmental movement remained staunchly distrustful of each other and polarized
in their rhetoric and assessments. The divided government abetted this rhetorical escalation and
encouraged each side to end run the other by appealing to their allies in the executive office or in the
Congress (Kraft, 1990; Oleszek, 1991). Lastly, given the intensive ideological screening of
appointees by administrations, many administrative appointees were often hostile to or ill at ease with
the laws and agencies they were charged to oversee (Goldenberg, 1984; Newland, 1984; Williams,
1991; Wilson, 1989, pp. 260-262).

These conflicts and constraints play out in a number of ways that affect administrators as
demonstrated by their effects on Ruckelshaus, and I will use examples from both agency terms to
illustrate these issues. Although, on the surface, Ruckelshaus's relations with the Nixon adminstration
appear more benign, the nature of the divisions and conflicts in the two terms remained largely the
same. Nixon's concern with the environment was almost exclusively political and designed to co-opt
the issue from Democrats. His indifference soon turned into hostility as the costs of environmental
legislation became obvious. He vetoed the Clean Water Act in 1972 over Ruckelshaus's strong
objections, opposed a number of Ruckelshaus's own intiatives, and encouraged the OMB to oversee
the EPA with intense scrutiny (Quarles, 1976). The conflicts came to a head at the start of Nixon's
second term when he planned to implement his plan to gain ideological control of the federal
agencies. The Reagan administration amplified and built on these strategies and connected them with
an avowed commitment to cut back on environmental regulation by using the budgetary and
appointive strategies that Nixon used (Lash, Gilman, & Sheridan, 1984; Nathan, 1983; Rosenbaum,
1991).

These divisions generated conflicts that affected administrators in Ruckelshaus's position in vital ways.
First, based on a self-conscious mistrust of the executive, Congress wrote very specific legislation
that imposed precise targets, deadlines, and "hammers" that required the enforcement of a law when
the deadline is not met. This approach attempted to escape the problem of captured agencies by
limiting the ability of administrators to benefit the groups they were supposed to regulate. The
emphasis on deadlines and specific standards also sought to force the development of technology
(Marcus, 1980; Kennedy School of Government, 1976b). All these innovations narrowed
administrative discretion.(4) As Ruckelshaus put it, "they might as well get robots to do the job"
(Ruckelshaus, personal communication, August 16, 1989). Democratic Congresses passed the major
environmental legislation under Republican presidents, and the legislators expected administrations to
balk at enforcement. In the area of clean water, the $ 36 billion dollar waste plant construction
program distributed benefits that buttressed clean water with a strong political consensus across
parties, but no other areas of environmental policy had such benefits to offset the conflict in the areas
such as clean air, toxic chemicals, waste disposal, or other newer arenas.(5)

Second, the conflict between EOP and the agencies lead to incessant battles with OMB (Hart,
1987). In Ruckelshaus's two tenures, he constantly had to fight the budget office's delays and
attempts to control the content of regulations. Early in his first term, Nixon's budget office attempted
to assert final approval for all EPA regulations, and he fired an official who tried to promote the
policy in EPA (Quarles, 1976, pp. 62-76). As a condition of his reappointment at the start of
Nixon's second term, Ruckelshaus demanded final control over regulations to thwart OMB efforts to
control them.(6) Building on the Carter administration's requirement that EPA issue a cost-benefit
statement on each proposed regulation, the Reagan administration required that agencies prove that
the benefits outweighed the costs for proposed regulations.(7) Ruckelshaus acknowledged that
"Most of the control of administration's administrative power ... is lodged in O.M.B.... The tension
between O.M.B. and EPA is not unique to this administration" (Kennedy School of Government,
1985, p. 16). In the Reagan administration, however, OMB under David Stockman drove the
budget cuts at EPA below a level even Anne Gorsuch Burford could tolerate. When Ruckelshaus
returned, the agency had experienced budget cuts totaling 29% over 3 years. He was able to restore
the budget to roughly the 1980 level, establish a new upward trend in budgets, and garner the largest
percentage increase for EPA of any non-defense agency. Yet Stockman fought every budget
proposal and initiative, even cutting his last budget increase request by 50%.(8) Ruckelshaus admits
he could "never reach an agreement with Stockman on the OMB relationship" (Ruckelshaus,
personal communication, August 16, 1989).

Third, the adversaries seldom negotiated directly but resorted to litigation. More than 80% of all
environmental regulations end in court (Kraft, 1990; Wilson, 1989, p. 284). Environmental groups
used court injunctions as their major weapon to move EPA to action given the specificity of the laws.
Many major actions of the EPA, such as the banning of lead or EDB or issuing standards on
radionuclides, responded to court orders (Bryner, 1987; Melnick, 1983). Additionally, industry
modified many of the stringent and unbending aspects of law by gaining equity decisions at the local
level that required EPA to account for economic considerations in orders as well as using the
unregulated access to OMB to influence regulations they opposed (Lash et at., 1984; Melnick,
1983; Rosenbaum, 1991).

Lastly, especially in the Reagan administration, appointed individuals were often drawn from
ideological cadres who disagreed with the policies they were charged with implementing. William
Baxter, Assistant Attorney General for Antitrust, exemplified it with his announcement that "if his own
personal conviction is different from what he thinks the law is, he will not bring actions" (U.S.
Congress, 1984d, p. 208). This obdurate attitude made Congress wary of any initiatives and
encouraged more hostile and sporadic oversight of agencies (Thurber, 1991).

Within this turbulent environment, a managerial leader has several legitimate goals that he or she can
justifiably pursue. These include: (a) create and protect an institution's capacity to perform its legally
mandated goals with competence and efficiency, (b) articulate a mission for the agency and instill
personnel with the mission, (c) build an agency culture that internalizes the mission and values of
competent performance, and (d) build coalitions to support the agency and its core functions.(9) This
range of goals in a complex environment places a premium on the judgments of managers. No
algorithms dictate the right solution. To succeed in any of these areas, managers must gain sufficient
power to implement their plans.

The conflicts generated by these divisions undercut the two most important sources of power for
managerial initiative: strong executive support or strong legislative and interest network support
(Behn, 1991; Doig & Hargrove, 1988; Gortner et al., 1987; Heclo, 1977). First, executive support
for Ruckelshaus remained sporadic and limited. In Ruckelshaus's two tenures, the major motive for
his appointment was political. Nixon wanted to get in front of the environmental issue for the 1972
election. Reagan wanted the EPA mess cleaned up prior to the 1984 election. Neither president
seriously supported strong environmental positions. On the other hand, any serious initiatives
supported by the executive usually floundered on legislative and interest-group opposition. Second,
the polarized and partisan environment obsessed the EOP with preventing managers from "going
native" and aligning with agencies, building independent congressional support, or working with
external allies. Presidential staff in both administrations jealously punished any independent operators
who seemed to be building external alliances to support policy initiatives.(10)

The divisions place significant limits on traditional managerial stances such as classical technocrat,
instructed delegate, bargainer, discretionary experimenter, and entrepreneur.(11) The classical
technocrat cannot survive in this world. Regulatory legislation with its clear guidelines might invite this
approach, each "technical" decision carries too much economic and ideological freight. This polarized
environment demands skill and leadership to defend agency decisions and marshall analytic
arguments to anticipate and defend the chosen decision to multiple audiences (Lynn, 1987). At the
other end of the spectrum, to act as an instructed delegate zealously pursuing a mandate from the
president generates intense political controversy in a polarized environment. Managers, such as Anne
Gorsuch Burford at EPA or James Watt at the Department of the Interior, who acted in this manner,
brought on themselves hostile oversight, media scrutiny, and litigation.(12) Their efforts imposed
significant costs on the administrations and discouraged executive support in many areas.

Discretionary experimenters gain a considerable delegation of power and discretion to shape vague
goals in limited areas. This delegation reflects the norm for most managers. Any initiatives, however,
are now fraught with high cost. The executive guards power very jealously in high-profile areas,
whereas the legislature, when alerted, will impose oversight and high costs, as will vigilant interest
groups. In a relatively low-profile area, without well articulated groups, this strategy might succeed.
Success might also occur in areas with low saliency, limited publics, or a dominant clientele (Lynn,
1984; May, 1991).

Ruckelshaus, himself, is often portrayed as a bargainer, mediator, or holder caught between two
inexorable forces with different agendas (Heymann, 1987, p. 74; Marcus, 1980, pp. 23-29). This
position often leads the manager to lose control of the agenda unless he or she can build a consensus
middle on policy. In an ideologically charged and polarized environment, efforts to mediate often
went nowhere. Ruckelshaus, however, used the bargainer and mediator strategy but in a creative
way. He sought more of an arbitrator's stance with an independent and respected voice, not just that
of a passive mediator. He managed, over intense opposition, to remain the administration's lead
initiator on environmental matters, a position usurped by the budget office in the rest of the Nixon,
Ford, and Reagan administrations (Vig & Kraft, 1990).

Finally, the role of an entrepreneur became very precarious in these times. In the strong sense of
formulating their own policy goals, marshalling power to implement them and convincing
policymakers to support them, the conditions of entrepreneurship are very rare in divided
government. In arenas with polarization, organized and antagonistic constituencies, and few benefits
to distribute, entrepreneurship will be blunted and costly. Ruckelshaus did not pursue this approach
except in a weaker sense of melding agencies around a mission and building competence and
long-term but diffuse political support (Doig & Hargrove, 1988, pp. 7-18). Ruckelshaus forged unity
and a mission. He could, however, never build support for his policy initiatives.

Managers in these situations must compensate for the limits on executive or network support in
divided times. To lead, Ruckelshaus's approach had to address polarized constituencies, skirt
watchful executive eyes, engage Congress directly without alienating the administration, and build the
core functions of the agency without having major benefits to distribute in most areas while imposing
significant costs.

RUCKELSHAUS'S STRATEGY OF INDEPENDENCE

Facing these constraints, Ruckelshaus pursued two consistent goals in both terms. First, he wanted to
establish agency credibility and achieve the mandated goals. He was deeply committed to the rule of
law and pledged in both his nominating hearings, "We will enforce the laws of this country" and "We
will be firm and will be fair" (U.S. Congress, 1983a, p. 191; U.S. Congress, 1970, pp. 2, 6, esp.
32-35). In both hearings, he faced considerable skepticism about the willingness of the administration
to enforce the laws and made enforcement a central goal from predilection and to blunt the
skepticism.(13) Second, Ruckelshaus desired to change the legal and policy agenda in environmental
affairs to get more flexibility for the EPA administrator, encourage alternative dispute resolutions, and
move to an incentive-based approach in many areas. Throughout both terms but especially in the
second, he doubted the wisdom of strict deadlines, self-enforcing requirements, and laws that
mandated action only on the basis of health considerations. In concert with Douglas Costle and
Russell Train, his predecessor and successor at EPA, he pleaded "give us more flexibility. Let us
have the ability to deal with these kinds of problems." He argued that the "lack of flexibility causes
distortion" in decisions with irrational and unjustifiable outcomes that only undermine the legitimacy of
environmental goals (U.S. Congress, 1983a, pp. 213-223, 261-262).(14) What he feared "most is
that we will end up setting unrealistic and unreliable goals." These will create a "credibility gap . . .
that would cause the whole environmental movement to lose legitimacy" (National Journal, January
15, 1972, pp. 85-87).

Ruckleshaus self-consciously linked the goals (Ruckelshaus, personal communication, August 16,
1989). In his mind, establishing a credible and independent agency record could overcome the
mistrust that poisoned legislative-executive interaction. He also believed an alternative consensus
could be forged on environmental issues. In his second term, he believed that the regulated
community largely agreed with the goals of environmentalism but differed on the means and tradeoffs.
EPA was ideally suited to forge this consensus, if it could establish an independent voice on issues.

Ruckelshaus believed independence possessed two aspects. At a minimum, it entailed avoiding being
captured by any one political actor.(15) Ruckelshaus never permitted himself or the agency to be
seen as the agent of the presidential office, Congress, environmentalists, or business. "We couldn't
afford even the appearance of being soft" (Kennedy School of Government, 1974, pp. 11-12). He
worried constantly about "insulating the agency from undue industry access and influence" (Kennedy
School of Government, 1974, p. 13). Very early in his first term, he responded to White House
attempts to influence policy on behalf of business by threatening to resign "if environmental decisions
are overruled because of political decisions."(16) In both terms, he worked hard to prevent
unwarranted access by any groups and fought attempts by OMB to smuggle in industry positions by
their analysis. This stance became even more important in his second term because he had publicly
gone on record while vice president at Weyerhaeuser as opposing the deadline-based approach of
environmental legislation. Almost all major environmental groups opposed his second term (U.S.
Congress, 1983a, pp. 1-145).

Second, Ruckelshaus's notion of independence extended beyond the negative. He sought credible
legitimacy for the agency that would be grounded in widespread public support distinct from any
interest groups. This would make EPA a source of independent competence and information that
could transcend the polarization of the debate and garner the respect of both sides. The agency could
define the terms of debate and develop proposals that would reflect a respected independent voice.
He consciously built his approach on four priorities: personnel, enforcement, information and rhetoric,
and fair access.

PERSONNEL

The lynchpin of his entire strategy of building independence and credibility began for Ruckelshaus
with his appointments. The possibility of any serious influence on the agency depended on getting his
own people into place. He knew he could only earn respect for the agency and some independence
of operation with competent performance (Ruckelshaus, personal communication, August 16, 1989).
If nothing else, good management kept the agency out of trouble and earned leeway in internal
matters (Heymann, 1987, pp. 47-49). In both terms, he expended immense political capital to gain
and protect his top appointees. During the first term, he fought fiercely to get the individuals he
wanted and to avoid unwanted political proteges. This approach incurred political animosity in both
the administration and the legislature and limited his ability to work with the legislature later. He
willingly appointed competent Democrats and alienated some members of the environmental
community by insisting on getting good managers rather than engineers (Quarles, 1976, pp. 32-39).
At the start of President Nixon's second term, when Nixon planned to implement his plan to gain
control of the agencies, Nixon demanded the resignation of all his senior officials, including
Ruckelshaus and his EPA team. When Nixon finally reappointed him, a furious Ruckelshaus balked.
At a meeting with Nixon, Ruckelshaus made it a condition of his reappointment that he retain his
senior staff as well as getting clarification of his final authority over OMB (Quarles, 1976, pp.
117-119).

When Ruckleshaus accepted President Reagan's offer to head the agency in 1983, the only condition
he set was a free hand in appointing his senior people. Control over appointments was significant
accomplishment given the EOP demand to screen and control appointees. Of Burford's top
appointments, 20 resigned or were fired, and Ruckelshaus got 13 top administrators confirmed in 6
weeks. It was the first time EPA had a full administrative complement since 1981 (Ruckelshaus,
personal communication, August 16, 1989). Whereas only two of Burford's top management team
had any environmental experience, Ruckelshaus's entire team was made up of respected individuals
with experience in the area (Davis, 1983; Lash et at., 1984). He immediately ended the infamous "hit
list" tactics of Burford and promoted one person on the list, sending a clear message of independence
and respect (National Journal, September 15, 1984, p. 1740). In both terms, he worked hard to
influence the naming of a qualified and experienced individual to succeed him: in the first term, Russell
Train, in the second, Lee Thomas. The Thomas appointment carried special importance because he
carried on the momentum of Ruckelshaus's management reforms and maintained credibility within the
regulated community.

In his second term, Ruckelshaus inherited an agency on the verge of implosion. Due to relentless
budget cuts, incessant reorganizations, and massive layoffs and transfers, employment had declined
by 20% from its 1981 level. By some reports, attrition ran at the rate of 2.7% a month during 1982
(Gottron, 1988; Lash et al., 1984). Ruckelshaus stemmed the hemorrhage of personnel, devoted
special efforts to retain and hire qualified scientists in the agency, and traveled across the country to
meet with EPA employees to restore morale and mission. He restored employment levels by 1986
and reestablished an upward trend in hiring personnel.(17) Fighting to control appointees and protect
staff stands as the most important element of Ruckelshaus's strategy for which he expended
considerable political capital and incurred major costs. The people appointed signal the level of
independence of outside control. This independence reinforced their responsiveness to Ruckelshaus's
own attempts to control operational initiatives and limit the incursions of OMB and outside influences
on the agency. They also determined the competence level (Wilson, 1989, pp. 212-215). This
involved considerable initial political cost, limited coalition-making possibilities later, and created
tensions with both Congress and EOP. The alternative, however, of losing control of appointees can
generate loss of internal control and external credibility and guarantee conflict and paralysis within the
agency.(18)

ENFORCEMENT

The second leg of Ruckelshaus's strategy depended on using law as a credible source to legitimize
agency actions. Fidelity to law became an alternative source of legitimacy, even when opposed to the
"mandate" of his president or the demands of Congress or coalitions.(19) He established this by
emphasizing enforcement. Enforcement proved the quickest route to find capacity but also to initiate
action to build the agency's reputation. At the beginning, he used enforcement action, persuasion, and
media pressure to attack obvious water and air pollution, and this focus became a way to unite the
disparate agencies he collected when EPA was formed around the mission of pollution
abatement.(20) These enforcement efforts built the public image of the agency, energized staff, and
gave the agency an advocacy cast that remained its core for 15 years. Enforcement forged a social
myth for the agency imbedded deep in the public mind, which became the basis for support when it
was attacked.(21) Ruckelshaus remained sensitive from the beginning that he was riding the crest of a
popular wave and needed to get maximum movement and institutional support before the wave
crested. He correctly sensed that congressional support was not as strong as public opinion and that
the Nixon administration would rein in the agency when given a chance. On the other hand, given the
politics of his administration and his commitment to independence, he could not build strong external
coalition support. He believed that public support alone, as it ebbed and flowed, would leave the
agency periodically vulnerable. Over the long run, the public support for EPA meant uneven support
for positive agency initiatives but a latent support to protect it from attacks.(22) Upon returning to
office under Reagan, he faced an enforcement staff that had been reorganized six times in less then 2
years and was decimated in morale (Gottron, 1988, pp. 112-114; Lash et al., 1984). He
reconsolidated the staff and reinvigorated enforcement by actively pushing his own people and the
states to initiate actions. Enforcement actions rose by 50% when he arrived and continued to rise to
record levels by 1986.(23) Enforcement also rebuilt EPA's image with Congress and the media.
Congress was assured that his enforcement staff had been "chewed out" and that positive and
"vigorous enforcement" on rules would follow.(24) This, combined with his recruitment of respected
professionals, effectively ended the implosion of the agency. The administration's and EPA's poll
ratings on protecting the environment rose from the lowest point in March of 1983, in the midst of the
controversy over Burford, by 5 points after Ruckelshaus took over. By the time he left office, the
levels of public opinion about the environmental protection had been restored to 1981 levels (Harris
Report, March 24, 1983, October 15, 1983, May 24, 1984).

Ruckelshaus designed the enforcement process strategically. He believed it was crucial not to set the
environment against growth, given the wide but thin public support. John Quarles, his first chief
enforcement officer in the Nixon administration, designed a plan to target the largest firms who
accounted for the grossest pollution and to leave the more numerous but lesser polluters to the states
(National Journal, October 7, 1971, pp. 2048-2053; January 15, 1972, pp. 85-94). In his second
term, he focused enforcement efforts where he thought it would do the most good - to support and
invigorate state efforts. He championed risk assessment techniques to target pollutants with the
greatest dangers (National Journal, October 7, 1971, pp. 2048-2053; May 26, 1984, p. 1034; June
6, 1984; February 9, 1985, pp. 314-316; Quarles, 1976, p. 117).

No amount of enforcement could satisfy various environmental groups. Ruckelshaus periodically
found himself forced to act on injunctions brought by these groups (Melnick, 1983). Relations
became increasingly strained in his second term as he felt a conflict between what he regarded as
credible science and the demands of the law. Ruckelshaus, like his predecessors, refused to ban
pollutants with high economic value and very little health risk, despite the law requiring him to take
account only health costs. In the case of toxics where he believed the law to be incoherent and
unenforceable, he challenged Congress directly to change the law or force him to act. Because
Congress itself remained riven along its own divisions, no significant action was taken and the
gridlock on toxics continued. These actions generated an ongoing tension between him and
environmental groups and the Senate, but he gained considerable support in the House and the EOP.
So his own enforcement efforts had mixed results in gaining the credibility he wished. They also
further revealed the tensions of independence because balanced decisions angered potential allies
demanding complete victories. His aggressive enforcement alienated the White House, but his
disagreement on toxics alienated the environmentalists.

Ruckelshaus's strong enforcement performed several vital functions for the agency. First, it made
serious negotiations possible. Only when industry realized that enforcement would occur was the
framework for voluntary negotiations set in place.(25) Second, it induced industry compliance by
promising regularity and predictability. Industry perceived Ruckelshaus as a "tough honest cop"
(Kennedy School of Government, 1976a, pp. 2-4). Third, EPA enforcement supported and
emboldened state agencies. Many state enforcement programs lagged due to lack of resources or
local pressures to avoid the economic penalties of pollution enforcement. The possibility of EPA
intervention gave state agencies some independent leverage to move on polluters.(26)

INFORMATION AND RHETORIC

From the beginning, Ruckelshaus believed that communication, education, and information were the
keys to building a consensus on environmental issues and establishing credibility for the EPA. He
knew that the agency could not tolerate poor information or analysis. He rushed the early standards
to build credibility for the agency, but he believed to the "bottom of my bones that good information
should drive these decisions" and was driven to base EPA decisions on good science (Kennedy
School of Government, 1974, pp. 11-12; Ruckelshaus, personal communication, August 16, 1989).
In his first term, he put the science advisory committees in place and began to build economic
analysis capabilities (National Journal, October 9, 1971, pp. 39-44). In his second term, he rebuilt
the credibility of the agency by depoliticizing the Science Advisory Boards (U.S. Congress, 1984a,
pp. 3-5). He also established the office of planning and management to create a strong analytic staff
to deal with OMB and "catch the silly ones" before they arrived. This helped EPA protect the
substantive content of many regulations (Bryner, 1987; Ruckelshaus, personal communication,
August 16, 1989). This did not end OMB's special scrutiny, harassment, or delay, but it enabled
EPA to play their game more successfully. Although OMB scrutiny bothered Ruckelshaus and
infuriated Congress, he always defended the cost-benefit discussions as a legitimate way to think
through all the consequences of a decision, even as he insisted on his own final decision power.(27)
He also tried, but with limited success, to regularize the data assessments across environmental media
by getting uniform criteria and standards. He demanded multimedia documents be produced to end
the problem of narrow assessments shifting pollutants from one medium to another (National Journal,
March 23, 1985, pp. 643-646; U.S. Congress, 1983b, p. 34ff; U.S. Congress, 1984a, pp. 15, 29).

Most controversially, Ruckelshaus had concluded during his time out of politics that the language of
risk assessment provided the best way to think through the dilemmas of managing many toxins. In the
major effort, he sought to change the culture and rhetoric of the EPA during his second term by
making risk assessment central to its decisions. Ruckelshaus believed this change would create a
better decision culture in EPA and offset the overly restrictive legislation. He pursued it vigorously.
He attended meetings and demanded that officials justify proposed courses of action in these terms.
This sent a clear message through the agency and helped change its decision culture (Phillip Angell,
personal communication, November 13, 1989). By 1987, a major EPA report stated that "the
fundamental mission of the Environmental Protection Agency is to reduce risk," and that risk
assessment had become the "primary language of analysis and management" (Andrews, 1990). He
and Thomas, his successor, saw risk assessment as a "powerful management tool," and it also
enabled the EPA to redefine the analytic battle with OMB by shifting to issues of health and risk
rather than pure economics. This gave EPA a comparative advantage in langauge and expertise in
their competition with OMB (Rosenbaum, 1992). His efforts inspired conflict with environmentalists
and generated criticism from Congress because the EPA considered factors beyond health in its
decisions. This shift also changed the cast of the agency from a more directive advocate, to one
seeking to balance competing risks in many areas. But Ruckelshaus firmly believed it provided a way
to identify and map out the dangers, risks, and costs of an action as well as to identify the level of
uncertainty. These methods highlighted the problem of unreasonable costs for marginal gains that
bothered him deeply.(28)

Ruckelshaus's focus on risk assessment and a search for getting adequate information can lead to
procrastination. In the congressional hearings on acid rain, he faced bitter criticism about his failure to
get administration support and the ineffectuality of the information strategy. As Congress member
Keane from New Jersey claimed in exasperation, "If all we do is more research, we're going to end
up with the best documented environmental disaster in history" (U.S. Congress, 1984a, p. 17). No
environmental policy is built on total certainty, and to demand too much certainty guarantees that no
action will occur. Ruckelshaus faced increasing criticism in his second term that the information-based
strategy resulted in paralysis.(29)

After his first term, Ruckelshaus played an active public role in trying to reshape the dialogue over
pollution control through public forums and speeches. During his second term, stymied in efforts to
change law, he conceived of his larger role as one of changing the public agenda. He wanted to
change the terms of public discussion and bring his vision into full public debate. As part of a broader
plan, he actively courted environmental groups and urged them to accept risk assessment as a
legitimate framework for decision. In public and private, he promoted incentive-based strategies as a
legitimate way to address pollution and encouraged environmental groups to embrace them. When
faced with a defeat, as in his acid rain initiative, he kept the issue alive with a strategy that promoted
gathering more information and building the case for action. In public speeches, he reached out to all
sides asking them to rethink environmental protection as a set of public health issues. He saw much of
this activity as long term and aimed at changing the terms of debate and discourse (Ruckelshaus,
personal communication, August 16, 1989).

In an effort to force the agenda into a broader context, Ruckelshaus chose a test case with the
Asarco copper smelter in Tacoma, Washington, to open a larger debate. Ruckelshaus traveled out to
Tacoma to have hearings on the level of tolerable arsenic emissions from the plant. The EPA used not
only traditional hearings but workshops to get public involvement and to communicate the risk issues
involved. This approach caused immense confusion and evoked intense controversy because it
seemed to foist a jobs versus poison decision on Tacoma residents - exactly the type of decision that
EPA was designed to avoid. Ruckelshaus admitted he underestimated the difficulty getting people "to
educate themselves" but remained adamant that he wished to initiate "the beginnings of a tradition of
public deliberation about hard issues" (Reich, 1990, pp. 162-170, 172).

The emphasis on structuring and gathering information to justify decisions and working to change the
terms of discourse formed the third leg of Ruckelshaus's strategy. Good information and risk
assessment could enable EPA to define the terms of the debate over environmental issues. They
could become "proxy advocates" on issues with a broader overview and gain a comparative
advantage with bureaucratic adversaries (Gormley, 1983, pp. 152-177). Although this caused
consternation among some environmentalists, it solidified support in the regulatory business
community because it factored in other cost and uncertainty issues into decisions. His approach
helped convince a number of environmental groups to adopt the same language. Ruckelshaus
ultimately saw information gathering and public heath rhetoric as central to the democratic process of
educating citizens to the real tradeoffs of environmental decisions. His efforts helped modify the
policy stream and lay the groundwork for changes and bipartisan coalitions that he could not achieve
given the polarization of his time.

FAIR ACCESS

The last leg of Ruckleshaus's strategy provided the positive side of not being captured by any group.
He demanded fair process and openness in the agency. In both terms, he actively sought out
interested groups. He honestly discussed issues and was amenable to persuasion. Time and again,
when faced with a complex decision, he held public hearings on issues ranging from banning lead, to
extending the auto emission deadlines, to banning DDT. In his first major decision under Nixon,
Ruckelshaus proved that he was open minded and persuadable. The information presented in his first
major hearings on whether to grant automobile manufacturers an extension on the deadline for
catalytic converters actually changed his mind. He issued a decision denying their request
(Congressional Quarterly Almanac, 1973, p. 294). This persuadability gave greater credence to the
procedures designed to assure fair access and maximized EPA's ability to get all the information. His
insistence on fair and open access helped enhance EPA's status as an arbiter between business and
environmentalists.

Upon first returning after Anne Gorsuch Burford resigned, Ruckelshaus issued a "fishbowl"
memorandum instructing all senior officials to publicize their calenders and make themselves available
to all constituencies and the press. He issued guidelines requiring EPA officials to treat all people
decently and to avoid "excessive rigidity or absence of common sense." As he had in his first term, he
actively discouraged any unauthorized ouside contact with parties in EPA decisions. The perception
that EPA under Burford had permitted undue access to business had to be eliminated. He knew that
only living in a fishbowl could ensure against the perception of undue influence and regain trust for the
agency (personal interview with Phillip Angell, November 13, 1989; U.S. Congress, 1983a, p. 200;
Vig & Kraft, 1984, Epilogue).

As the final leg of Ruckelshaus's strategy, access helped build procedural legitimacy for the agency. It
also gained him some tolerance from the embattled environmentalists who at least knew he would
listen and take them seriously, if not agree with them (Dobel, 1992, pp. 250-252). In the second
term, he allied it with his emphasis on building consensus and education to experiment with an
expanded form of public participation. Both the information and access aspects emphasized
procedural issues and complemented his focus on personnel and enforcement.

THE PARADOX OF INDEPENDENCE

Ruckelshaus is justly noted for his success in building political stature, high morale and purpose, and
competence and legitimacy for the agency. Control over his own appointments coupled with an
ability to engage OMB garnered the agency considerable control over daily operations and the ability
to issue regulations. He had little success, however, in his second set of goals - changing
environmental legislation and increasing administrative discretion. He could not persuade Congress to
connect these two aspects of his goals. In hearing after hearing, Ruckelshaus asked Congress to
grant this discretion. He always heard the same reply, best summarized by Representative Eckart
(D-Ohio), "If I were absolutely certain that you were going to be sitting there next year, making a
good faith effort," Congress would consider it. He could not transfer his personal credibility to the
agency. (U.S. Congress, 1984b, p. 757; U.S. Congress, 1984c, pp. 12-13; National Journal,
December 9, 1972, p. 1881).

Paradoxically, the stance of independence did not permit him to build the type of partisan political
support necessary to change the broader policy agenda or law. Although he was accessible to
environmentalists, he could never align fully with them, both out of personal conviction and from the
desire to avoid being "captured." This severely curtailed his ability to call on them to apply pressure.
Likewise, he had to be extremely careful with industry. His Republican antecedents and experience at
Weyerhaeuser made him doubly vulnerable to charges of collusion.

Neither could Ruckleshaus ally with any coalition in Congress, given the antipathy of the partisans.
With limited tenures both times, he was not able to cultivate long-term relations with key members of
Congress. In neither term could he break the hold of congressional staff on major senators. Although
he had open, cordial, and trusting relations with many senators, he could not persuade them to
change their positions. As with the executive, his insistence on recruiting his own staff limited his
ability to build rapport with Congress by hiring congressional proteges.

Ruckelshaus's independence limited executive support for his initiatives. Although his activism,
openness, and enforcement protected both administrations on environmental issues, it irked the inner
circles of Presidents Nixon and Reagan where environment was not regarded as a serious issue.
Even as he ceaselessly fought the tendency of the press and Congress to portray him as a "white hat"
against the President's "black hat" staff (National Journal, October 9, 1972, pp. 2039-2043;
September 1, 1984, p. 1607; Ruckelshaus, personal communication, August 16, 1989), he was
distrusted because he entered as an independent agent to serve a political purpose. The presidential
staff remained wary of his initiatives. Ruckelshaus's insistence on getting his own people also earned
him the enmity of the inner circles (Quarles, 1976). Simultaneously, his evenhanded openness to
environmental groups and his resistance to industry and political efforts to influence EPA further
isolated him as someone who was not a team player.

Given his own strategy, Ruckelshaus never leveraged the administration's need for him into any
positive support for policy initiatives. In his return to Reagan's administration, he only asked for
freedom with personnel and never sought commitments on budget or policy. This lack of leverage,
even inside the administration, undermined his policy forays and made him vulnerable to OMB
pressure (J. D. Hair, personal communication, November 13, 1989).

All the limits of the independence and problems of divided government are revealed in Ruckleshaus's
inability to establish a modest acid rain reduction program. Given his stance of independence, he
could only succeed with initiatives backed by a strong consensus. When President Reagan mentioned
solving the acid rain problem as a priority in his speech introducing him, Ruckelshaus began to consult
and acquire information on the extent of acid rain (Kennedy School of Government, 1986). The
Reagan administration had opposed all congressional acid rain initiatives, arguing that insufficient
information existed to justify massive outlays of money. This lethargy was reinforced by the regional
politics of the problem that pitted New England and northeastern states against the industrial
Midwest, where most of the SO.sub.2 was generated. The Appalachian states and miners opposed
any plan that might discourage the buying of high-sulfur coal produced in their region. This regional
gridlock nullified any efforts of Congress to build a program. Congress looked to Ruckelshaus to
exercise the leadership necessary to get beyond the dilemma.

Ruckelshaus became convinced of the seriousness of the problem after the National Academy of
Science and the White House Office of Science and Technology Policy advisory committees both
issued calls for action despite the limited information available. The panels were especially concerned
with the effect on the quality of soil in the affected states and their long-term agricultural and
ecological viability. Persuaded by their findings, he announced his own public support for action
(National Journal, June 6, 1984, p. 1258; U.S. Congress, 1984a, p. 16; National Journal, July 30,
1983, pp. 1590-1591).

Ruckelshaus believed action was needed and wanted to give the president a viable political option to
get ahead of the issue before the elections. He saw the issue as predominantly a political problem and
set out to devise a compromise acceptable to enough people to break the gridlock. He developed a
plan to create a controlled reduction of 3 to 4 million tons of SO.sub.2 that largely traveled to the
New England lake areas. He saw this as a way to test the basic hypothesis and address the most
politically potent issue of dying lakes. It also cost less than the other alternatives. Given his strategy,
he remained acutely sensitive to the political dimensions of the problem and to the need for a crafted
consensus. Painfully aware that it satisfied no one, he believed it was the only plan that had any
political feasibility (U.S. Congress, 1984a, pp. 11-13).

At an ad hoc interagency group, Ruchelshaus presented his plan. David Stockman of OMB
ambushed the plan by using numbers and graphics that emphasized that the cost per pound of fish
saved could run up to $ 66,160, a figure that Stockman leaked to the Wall Street Journal. Stockman
convinced the skeptical inner circle that any administration proposal would open the political arena to
bargaining and larger and more costly programs (personal interview with Phillip Angell, November
13, 1989). This meeting made it clear to Ruckelshaus that he had little executive support.
Ruckelshaus did not wish to put Reagan in the position of rejecting his proposal, so he exercised no
leverage with inside or outside groups. Instead, he proposed increasing the research expenditures to
fill holes in the knowledge base (Kennedy School of Government, 1986). Ruckelshaus saw this as a
way to keep the issue and its legitimacy alive, while building the information base necessary to "tip"
people over.(30) Congress could not develop its own plan, given the complicated politics, and
members bitterly criticized Ruckelshaus for his own failure to influence the administration. In the long
run, however, these efforts to keep the issue alive, as well as his courting of environmental groups
and his efforts to change their orientation to risk assessment and incentives, contributed to the
long-term resolution of the issues when George Bush became president.

CONCLUSION

The fissures of divided government impose significant political and institutional constraints on public
management, which cannot be understood without careful study of cases. The normal preconditions
of successful initiative, meaning strong executive support or strong congressional and issue network
support, become mutually exclusive in this environment. The polarized political environment with
Congress and the administration at odds and the administration overseeing agencies with a politicized
OMB subverted many traditional managerial stances. Consequently, divided government places very
high demands on the political skills of successful managers.

Ruckelshaus responded to this gridlock with his stance of institutional independence. He devoted his
energies and resources to ensuring that no major actor controlled or captured him or the agency. He
sought public credibility and an independent voice for the agency. This strategy depended on (a) a
strong emphasis on competent professionals to lead the agency, (b) strong, consistent but rational
enforcement efforts, (c) a public and institutional commitment to good information and definition of
the terms of debate, and (d) open and fair access to all parties.

Any case study raises the question of whether it illuminates a unique situation with no broader
applicability. I believe that the environmental area serves as a proxy for a number of policy areas and
agencies. Ruckelshaus's strategy is worthy of study because it addresses constraints that public
managers will continue to confront at many levels, and it models the political skills needed to address
them. Although this discussion focuses on the high-profile agencies in polarized divided environments,
the strategy of independence has the potential to be even more effective in other political
environments where agencies have single clienteles or face less organized environments and are not
as subject to media and interest-group cross pressures.

Although each aspect of Ruckelshaus's strategy possessed strengths and weaknesses, the strategy
succeeded by a number of the criteria of managerial leadership suggested in this essay. It enabled him
to (a) build capacity and competence, (b) articulate a mission that gave an identity to the disparate
parts of the agency, (c) establish a strong culture that internalizes the mission, (d) motivate staff, and
(e) succeed in anchoring the agency in widespread political support. His initial efforts helped forge a
social myth for the agency that supported the agency during the environmental backlashes of the
mid-1970s and early 1980s. His second term reinvigorated the agency, restored its budget and
personnel levels and morale, and helped solidify a new culture.

Paradoxically, the independence that enabled Ruckelshaus's success profoundly limited him in other
areas. In both terms, he failed to influence the content of environmental legislation or gain real
discretion for the agency. He regularly failed to control or influence the agenda on substantive issues,
law, or discretion. Courts often usurped his substantive decisions. Neither could he build a strong
coalition to support his initiatives, nor could he change the dominant interpretation of issues. The
long-term strength for the agency came from the political costliness of trying to assault the
environmental bureaucracy once it was in place.

Ruckelshaus's approach lead him to focus his political resources on gaining internal control over the
agency and enforcement. In this, he gained far more substantive freedom to act for the agency then it
had before. Externally, however, his strategy required consensus to be successful in changing the
agenda. He could not use partisan resources or interest groups or strong administrative pressure to
lead initiatives because this would violate his stance of independence. In the environmental area, the
mistrust and polarization remained too great to build a consensus. The conditions to alter the agenda
were not in place because neither public opinion nor a strong middle coalition embraced his vision.
Ruckelshaus perceived many of his actions to be aimed at a broader public education and as
contributing to longer term change in the policy agenda. Many of these "failed" efforts contributed to
his long-term efforts to change the terms of debate, build the credibility of EPA, and legitimize
incentives and risk assessment to some environmental groups. They helped lay the basis for a new
consensus when President Bush announced his support for new initiatives in 1991.(31) Institutional
independence, as a strategy, helped Ruckelshaus carve out a strong position for the agency, given
constraints of divided government. The strategy reinvigorates many aspects of an older tradition of
public service. It has much to recommend itself for managers in high-profile agencies in complex
polarized environments and wider applicability in other areas. His insistence on fighting for his own
appointees as well as the importance of consistent enforcement and open access are especially
important. None of these can be gained without cost. None of them will make sure, long-term allies,
but they can help create a credible position from which to influence long-term changes in the policy
stream. The paradoxes of independence suggest that in divided times, serious control over internal
agency may be more attainable than an ability to achieve short-term significant changes in the policy
agenda.

NOTES

1. Mayhew (1990) provides the most well-known assessment. In contrast, see Cohen (1992) and
Kraft (1984). For a typical example, see Dewar (1992).

2. Hargrove and Gildewell (1990) provide a similar typology of where managerial initiatives beyond
"coping" are possible.

3. Nathan (1983), Schick (1984), Hart (1987), and Foreman (1991), all discuss methods of political
control with special emphasis on budgets and appointees. Vig and Kraft (1984) examine these
themes in the environmental area.

4. National Journal, November 17, 1984, quotes Representative James Florio as describing the main
thrust of House legislation as to "limit their discretion and give them guidance." Florio and others
believed that enforcement of the laws "was not going to happen with the existing philosophy here in
Washington." He concludes that "the laws have to be self-enforcing so we're building in mechanisms
that some refer to as hammers." Mayhew (1990) has argued that the divided government has had
little effect on law making measured by quantity of law. Any reading, however, of legislative histories
reveals a clearly announced distrust of and aggressive preference for detailed outcomes as evidence
by Florio's comments. See Kennedy School of Government (1976b). For another example, see
Cohen (1992, pp. 174-176).

5. Rosenbaum (1991). More recently, superfund has not provided a politically reliable source of
funding to protect other aspects of the EPA.

6. Quarles (1976, pp. 117-118, 125-161) describes a number of cases where OMB became the
central actor in not just refining but delaying proposed regulations.

7. Bryner (1987, pp. 41-64, 91-118) describes the techniques used by OMB in cost benefit
requirements to impose some accountability on the agencies. DeMuth and Ginsburg (1987) provide a
defense of the OMB techniques.

8. Lash et at. (1984); Peterson (1984); Rosenbaum (1991, pp. 97-101); Vig (1984). Ruckelshaus
succeeded in getting the largest budget increase for any nondefense agency in the 1985 budget but
still only got half of what he sought. He restored the budget to its gross 1980 level and reestablished
an upward trend that even OMB could not stop. The EPA, however, had still lost considerable real
budget due to inflation.

9. The importance of context and the range of legitimate goals are discussed in Behn (1991), Doig
and Hargrove (1988), Lynn (1987), Heymann (1987), Hargrove and Gildewell (1990).

10. Nathan (1983) and Hart (1987) explain the logic behind this insistence on loyalty and
accountability.

11. Nakamura and Smallwood (1980, pp. 112-133- provide this typology of traditional roles a
managerial leader can assume.

12. Foreman (1991) and Heymann (1987) discuss the costs and limits of a pure "mandate-" or
instructed-delegate approach toward public management. Lynn (1984) provides several interesting
case studies demonstrating the limits of a pure instructed-delegate approach.

13. Kennedy School of Government (1974, 1985) make clear the priority Ruckelshaus gave to
pursuing credible agency action.

14. This is a consistent theme in all Ruckelshaus's dealings with Congress and the press. For
example, see U.S. Congress (1984a, p. 19ff) and U.S. Congress (1984b, p. 726ff.).

15. On the notion of "captured" agencies see Lowi (1979) and McConnell (1966).

16. Quarles (1976, pp. 62-74) describes Ruckelshaus's battles in this area to preserve the
independence of the agency.

17. Lash et al. (1984), Ruckelshaus (personal communication, August 16, 1989), Vig and Kraft
(1990) make clear that even as Ruckelshaus restored employment levels and reestablished an
upward trend, EPA was handed new assignments that could not be met because of the cuts.
Additionally, the EPA never restored the very deep cuts in the science areas.

18. Bell (1988) provides a sobering study of the costs of not controlling the appointees to the agency
that you must head.

19. Heymann (1987, p. 74, passim) discusses the different strategies one can use to gain managerial
legitimacy, such as referring to mandates from superiors, interpreting law, being a neutral mediator, or
establishing independent professional competence.

20. Kennedy School of Government (1974, pp. 3-11; 1976, pp. 2-6) describe how he and Quarles
instituted the enforcement strategy. Ruckelshaus chose this mission because he believed it to be
feasible and balanced and provided a coherence across other divisions. If they succeeded there, he
believed other responsibilities would come to the agency.

21. Hargrove and Gildewell (1990) discuss the importance of the social myth of an agency.

22. Marcus (1980, pp. 86-98, 125-130) and Quarles (1976, pp. 196-247). Rosenbaum (1984, pp.
23-30) discusses how environmentalism had been enshrined in public opinion as a "passive
consensus." For a disucssion of environmental values as "consensual values," see Dunlap (1989).

23. Wood (1988) shows that enforcement efforts jumped 50% when Ruckelshaus returned - 16%
higher than the average under even the Carter administration. He also analyzes the collapse of
enforcement efforts by 1982. His explanations for these actions differ considerably from this analysis
because he does not examine leadership as an independent factor in agency action.

24. U.S. Congress (1984b, p. 754). When Representative Eckart of Ohio commented that a
"reliable journal" had reported that Ruckelshaus had "chewed out" his staff and expected vigorous
enforcement, he replied, "You certainly can, and so can I, or we will get some new ones."

25. Quarles (1976, p. 117) explains, "We still prefer voluntary compliance, but we now stand ready
to go to court if necessary. We have the policy willingness to do it, and we are developing the
technical capacity." He later adds, "No federal regulatory program could be successful if litigation
was required in even a sizable minority of cases ... government must command respect to obtain
voluntary compliance."

26. This is a constant theme for Ruckelshaus. As an example, see U.S. Congress (1970, pp. 6-7).

27. National Journal, November 17, 1984, pp. 2202-2205; Ruckelshaus believed many of EPA's
most significant victories were helped by cost benefit analysis (Personal interview with Phillip Angell,
November 13, 1989). Others take a less sanguine view of the OMB requirements and their effect on
regulations.

28. Ruckelshaus (1985) lays out his most rhetorically clear call to move toward risk assessment. He
advocates one decision to determine the health risks and a second political decision about risk
management. He proselytized for his approach in many of his congressional hearings and it has
aroused a storm of controversy. See responses in Issues in Science and Technology, (Summer 1985,
pp. 4-7). See National Journal, December 3, 1984, pp. 2529-2532 for a summary of the
controversy.

29. Ruckelshaus's effort to ensure what he saw as credible science and institutional capacity caused
tensions with Congress. He vigorously resisted getting more money than he thought he could
reasonably spend, or that put EPA ahead of the learning curve on an issue. See U.S. Congress
(1984b, pp. 84, 725, 739-741).

30. U.S. Congress (1984d, pp. 15-20, 40). Ruckelshaus defends his request for increased research
in these terms, "Yes I am now convinced that we know enough to go forward with a control
strategy"; he points out that others are not, and that "we need knowledge to drive a consensus."

31. Kingdon (1984) discusses the importance of policy windows and the methods of gaining access
to the ongoing agenda that sets the policies and defines the options that will be discussed. On
contributing to long-term changes, see March and Olsen, 1988.

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SIC: 9511 Air, water, & solid waste management

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