MICHAEL P. LAST: Some may think that the question, "environmental compliance: is the system working?" is intended to be theoretical. That is not the case. Our objective is to take a hard and honest look at our regulatory struccture and evaluate how it works and whether the way in which it works optimizes what the system as a whole is hoping to achieve.

JOHN A.S. McGLENNON: I have two or three suggestions that EPA should consider in order to develop a more formalized feedback system. One is to  incorporate an annual review process into some of our regulations. There would be no harm in convening an annual or biennial meeting of representatives of the regulated community to ask how well we are doing and how well the regulation is working.

The Atomic Safety and Licensing Board, which operates within the Nuclear Regulatory Commission,¹ recently imposed the most severe penalties in its 13-year history on the Virginia Electric and Power Company (VEPCO), following its finding that VEPCO officials were responsible for a series of material false statements to the Commission. The false statements, 12 in all, were made between 1968 and 1973 at various stages in VEPCO's application for licenses to construct a four-unit complex of nuclear power reactors at North Anna, in rural Louisa County, Virginia.

Californians are no strangers to freeway interchanges and their strategic importance to ambitious land developers.

Two U.S. Courts of Appeals have recently ruled¹ that §113 of the Clean Air Act² does not give the Environmental Protection Agency authority to require states, under pain of civil sanctions and penalties, to adopt or enforce particular transportation control measures as part of their implementation plans.

Obliged to enforce myriad laws that lack built-in incentives to compliance, buffeted by literally hundreds of conflicting lawsuits, whipsawed by a congressional combination of strict legislative deadlines and skimpy budgets, and straitjacketed by OMB overseers, the Environmental Protection Agency must be the most beleaguered administrative agency in American history.¹

The recent case of Sierra Club v. Department of Interior¹ may supply a legal basis for compelling the Department of Interior to curtail activities on lands peripheral to any National Park when such activities have an adverse effect on it. The case may even permit the National Park Service to force the Secretary of Interior to go to Congress for funds for such environmentally protective actions if the Office of Management and Budget fails to provide them.

The Environmental Protection Agency won a signigicant victory in its battle to require stack gas scrubbers as the primary strategy for the control of sulfur oxides under the Clean Air Act¹ with the recent Sixth Circuit decision in Big Rivers Electric Corp. v. EPA.² The court in Big Rivers held that a power company that burns high sulfur fuel must provide for permanent emission controls (i.e., scrubbers) or show that such controls are unavailable.

When in the aftermath of the 1973 energy crisis jobs began to disappear and prices to rise, it came to be widely believed that pocketbook issues would soon eclipse the public's recently-developed fervor for cleaning up the environment.¹ This view was shared, albeit covertly, by many environmental groups, which responded by reducing public visibility.

The Administrator of the Environmental Protection Agency has upheld on appeal¹ a subordinate's commitment to more vigorous protection of the marine environment from the adverse effects of ocean dumping. In a test case² involving the city of Philadelphia's dumping of sewage sludge, Mr. Train, adopting the recommendations of a Hearing Panel, affirmed imposition by the Regional Administrator for Region III, of a significant condition on the city's latest one-year interim dumping permit.