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Volume 15, Issue 1 — January 1985

Dialogue

The 99th Congress: A Look at the Year Ahead

by Bud Ward

Superfund. Superfund. Superfund. There is more to the world of environmental legislation than just reauthorization of Superfund, the Comprehensive Environmental Response, Compensation, and Liability Act.

Keep telling yourself that. You may need to once the 99th Congress convenes late this month and its authorizing committees get down to the work of considering reauthorizations of the torrent of environmental legislation carried over from last year.

In reality, reauthorization of Superfund is just one of the several key environmental and pollution control issues that will face the new Congress. In addition to Superfund, the Clean Water Act, the Safe Drinking Water Act, the Toxic Substances Control Act, the Federal Insecticide, Fungicide, and Rodenticide Act, and the always-present Clean Air Act are pending reauthorization. Of the major Environmental Protection Agency (EPA) regulatory statutes, only the Resource Conservation and Recovery Act (RCRA) is "safe," not facing consideration in 1985, it having been reauthorized last year for fiscal years 1985 through 1988. Add to the EPA regulatory programs the resources and conservation programs administered at the federal level by the Department of the Interior, and the 99th Congress' environmental workload grows even larger.

Delisting Hazardous Wastes Under RCRA: A Response to Compton and Patterson

by Steven Silverman

In their article Delisting Hazardous Wastes—Do the RCRA Amendments Spell Relief?1 Ms. Compton and Mr. Patterson discuss the Environmental Protection Agency's (EPA's) rules for delisting hazardous wastes under the Resource Conservation and Recovery Act (RCRA),2 the Agency's implementation of these rules, and the recent statutory amendments dealing with delistings. Working at EPA, my biases naturally differ from those of the authors. Acknowledging these biases, I nevertheless believe that their article contains a number of mischaracterizations about the Agency's rules and actions. I also think that they have misread parts of the new statute. In some cases the misreadings are serious. I would like to describe briefly EPA's delisting rules and actions to date, summarize my view of the 1984 RCRA amendments on delisting, and give my views on future Agency actions in this area—responding to Ms. Compton and Mr. Patterson along the way when appropriate. My views are necessarily my own, and are not statements of EPA policy.