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Why Are Our Regional Offices and Labs Located Where They Are? A Historical Perspective on Siting
by Dennis C. Williams, March 1993
In response to a query from Director of the Office of Administration John Chamberlin concerning the reason EPA facilities were located where they are across the United States, the following material was compiled and presented to him on March 23, 1993, by EPA Assistant Historian Dennis Williams.
EPA inherited two distinct regional systems from its predecessor agencies. The Federal Water Quality Administration used a nine region topographical system divided along river basins. The Environmental Health Service, an EPA component inherited from the Department of Health, Education and Welfare had adopted the ten Standard Federal Regions suggested by the Office of Management and Budget in 1969 (OMB Circular A-105). In order to facilitate easier operations with local and state governments as well as with other federal agencies using the OMB plan, EPA chose to adopt the standard federal regions. In response to cost analyses concerning relocation of Federal Water Quality Officials from their previous regional headquarters to standard federal cities, EPA officials considered establishing alternative regional cities in regions III, V, and X (Charlottesville v. Philadelphia; Cincinnati v. Chicago; and Portland v. Seattle). They finally selected the standard cities--Philadelphia, Chicago, and Seattle--on the grounds that quartering regional administration proximate to other agencies' regional headquarters would contribute to long term efficiency.
EPA Laboratory Facilities
At its birth, EPA inherited 183 buildings at 84 sites in 26 states. Forty-two sites consisted of laboratories. Many of these labs were ill-equipped and duplicated the efforts of labs inherited from other agencies. In response to this apparent waste, OMB reserved some $35 million in funds appropriated by Congress for EPA to build an environmental research center in Cincinnati, Ohio, until the agency completed a comprehensive study of its laboratory system and designed a systematic plan for laboratory operation and development.
In an effort to produce an efficient, but fruitful lab system, the first study of EPA lab facilities, completed in 1972, recommended pruning the 42 existing labs to 22 over five years. Like the organization of the agency, the organization of the laboratory system reflected the contrary principles of decentralization and consolidation that dominated the political thinking of the 1970s. The 1972 study suggested that the agency consolidate a number of inherited labs into three National Environmental Research Centers designed to bring the functions and expertise of previously disparate labs to bear on particular research topics:
Research Triangle Park, NC--health effects
Cincinnati, OH--engineering and control technology. Associated labs (Andrew W. Breidenbach Environmental Research Center):
Risk Reduction Engineering Laboratory
Environmental Monitoring Systems Laboratory
Las Vegas, NV--monitoring (added 1974; created from Bureau of Radiological Health facility in Las Vegas)
Each of these facilities was created by merging the personnel and functions of labs inherited from the Federal Water Quality Administration, the Bureau of Radiological Health, the National Air Pollution Control Administration, the Bureau of Water Hygiene, the Bureau of Solid Waste Management, and others together at sites that already possessed substantial laboratory facilities or that had been allocated funds for construction or expansion during the 1960s. Laboratory system planners hoped that consolidating and expanding these four EPA facilities along functional, cross-media lines would bring science and technology effectively to bear on the agencies' broad national mission.
In response to the decentralizing tendencies of President Richard Nixon's "New Federalism" and in recognition of distinct differences in ecology and priority among the regions, the agency attached a laboratory to each regional headquarters. The regional Environmental Service Division Laboratories were supposed to be located in the standard federal city. However, the availability and adequacy of inherited facilities sometimes overrode that ideal. EPA inherited most federal labs from the Federal Water Quality Administration. The following provides a brief discussion of regional labs and their origins.
Region I ESD Lab
EPA inherited a facility at Needham s, Massachusetts, a Boston suburb, from the Federal Water Quality Administration. The lab was housed in a former motel and reported to be overcrowded and unsafe for most of its operations. When the lease expired in 1974, the lab was relocated to new facilities in Lexington, Massachusetts--another of Boston's suburbs.
Environmental Research Lab, Narragansett, RI
EPA inherited a Federal Water Quality Lab and the Bureau of Water Hygiene's Northeast Water Hygiene Lab in 1970. The agency consolidated these labs to study pollution stress on marine ecosystems. The Environmental research Lab in Newport, Oregon, is administratively attached to this facility also.
Region II ESD Lab
For some time, EPA planners suggested establishing an adequate laboratory in New York City to service the regional headquarters. However, the agency had inherited very inadequate pesticide research facilities from USDA in New York City. The agency had inherited two other facilities within the region located on the University of Rochester Campus in Rochester, New York, and at the Raritan Arsenal in Edison, New Jersey, the location of a significant number of research and development laboratories. By 1974 the agency chose to locate the Region II ESD lab at existing EPA facilities in Edison, New Jersey.
Region III ESD Lab
Like Region II, Region III inherited several facilities from predecessor agencies. While initially attempting to locate its lab in Philadelphia, the agency finally decided on the industrial location of the Annapolis, Maryland lab it had inherited from the Federal Water Quality Administration. Not only was the lab functional, but its siting also offered room for expansion.
Region III Wheeling Office
Inherited from the Federal Water Quality Administration, the laboratory facility in Wheeling, West Virginia, is housed in the upper floor of a Methodist church. Initially, it was targeted for merger with a Philadelphia based regional lab. The facility was later deemed necessary for its water quality ad biological research capabilities, especially acid rain research, in the West Virginia coal, chemical, and steel region. In 1978, this lab reported the most acidic rainfall yet recorded.
Region III Analytical Chemistry Lab (OPPTS)
EPA inherited a number of labs associated with the USDA Pesticides program. It consolidated these separate lab functions into its present Analytical Chemistry Lab in 1971.
Environmental Photographic Interpretation Center, Warrenton, VA
This facility was originally a military photographic interpretation center that EPA acquired in the early 1970s to support aerial photographic analysis of pollution sites.
Region IV ESD Lab
EPA inherited the substantial Southeast Water Quality Lab in Athens, Georgia from the Federal Water Quality Administration and chose to base its regional laboratory there.
National Air and Radiation Environmental Lab, Montgomery, Al.
This lab was created from the Bureau of Radiation Health's Southeast Radiological Health's Southeast Radiological Health Lab that EPA inherited.
Environmental Research Lab, Gulf Breeze, FL
Inherited from the Bureau of Commercial Fisheries in 1970 and consolidated with other labs throughout the 1970s.
Environmental Chemistry Lab, Bay St. Louis, MS
EPA entered into a joint agreement with NASA in June 1971 to locate the lab functions of the inherited Lower Mississippi Field Station in Baton Rouge and the Pesticide Monitoring Lab and Federal Water Quality lab in Gulf Port, Louisiana. NASA needed to fill the space once its Saturn rocket testing program was completed in order not to lose the facility. EPA saw this as an opportunity to consolidate their inadequate labs in the region.
Region V ESD Lab
EPA inherited the Federal Water Quality Administration lab in Chicago. But the complexity of the ecological and pollution problems in the Great Lakes region led the agency to retain the following Federal Water Quality Labs in the region:
Great Lakes Research Station, Grosse Ile, Michigan
Environmental Research Lab, Duluth, MN
Fish toxicology Lab, Newton, OH
In 1973, the agency established the Monticello Ecological Research Station as a field office of the Duluth Environmental Research Lab. Adjacent to the Northern States Power Company's nuclear generating plant and the Mississippi River in Monticello, Minnesota, this office studied thermal water pollution between 1973 and 1977. In the wake of Love Canal and a ened national concern over toxic chemicals, the Monticello station turned its attention to controlled studies of toxicants such as acids, pesticides, and ammonia/nitrogen in riverine ecosystems.
The agency also inherited the National Air Pollution Control Administration's Ann Arbor, Michigan lab, which was under construction in 1970. It became the EPA's National Vehicle and Fuel Emissions Lab.
Region VI ESD Lab
EPA inherited the Federal Water Quality Administration Office in Houston. The site proved worthwhile for monitoring industrial pollution in the Houston Ship Channel. No doubt the lab assisted EPA enforcement officers building a case against Armco Steel in 1970-1971. This was one of EPA's first major industrial enforcement cases. The pollution level of the channel in the 1970s, which threatened Galveston Bay, demanded not only rigorous enforcement and monitoring. This situation simplified the decision to establish the Houston lab as the Region VI ESD lab.
Robert S. Kerr Water Research Lab
The Robert S. Kerr Water Research Lab was inherited from the Federal Water Quality Administration. Even though some studies have advocated closing the facility, political and local economic concerns have overridden efficiency arguments.
Region VII ESD Lab
EPA inherited a Federal Water Quality Administration lab located in Kansas City, Missouri. By 1972, that facility had been deemed unsuitable and the lab was moved across the river into Kansas City, Kansas.
Region VIII ESD Lab
EPA inherited two lab facilities in the Denver Federal Center in Lakewood, Colorado: one from the National Air Pollution Control Administration and one from the USDA Pesticides program. The lab facilities at the Denver Federal Center have been managed by various organizational components. Initially the NAPCA lab, the Pesticides lab, and a trailer serving as the regional lab were operated separately. Later the pesticides lab functions were absorbed and presently the National Enforcement Investigation Center and the Region VIII ESD lab are collocated at the site.
Initially EPA inherited a Federal Water Quality Administration Lab in Alameda, California, and a USDA Pesticides lab in San Francisco. Those two labs were merged to form the Region IX ESD lab. EPA also inherited the Southwest Radiological Health Lab facility from the Bureau of Radiological Health. It created NERC-LV from this facility to serve as a centralized laboratory for developing environmental monitoring systems.
Region X ESD Lab
EPA inherited a number of laboratory facilities in the Pacific Northwest. The concentration of laboratory facilities in Corvallis, Oregon, encouraged officials to consider locating EPA's regional office in Portland. When they ultimately decided to quarter regional officials in Seattle, which according to the regional lab ideal meant that a lab facility would have to be acquired in Seattle, the agency rented space from the Washington State Department of Ecology in the Seattle suburb of Redmond. This facility was too small to begin with, and by 1974, the agency had decided to expand the shellfish bioassay lab, which it inherited as a part of the Northwest Water Hygiene lab from the Bureau of Water Hygiene, in Manchester (Port Orchard), Washington, into a much larger facility that would also house the region's ESD lab.
EPA transformed its bequest at Corvallis, OR--the Federal Water Quality Administration's Pacific Northwest Water Lab and the USDA Pesticides program's plant biology facility--into a NERC dedicated to ecological research. Ocean ecology research, performed on the East Coast by the Environmental Research Lab in Narragansett, Rhode Island, is complemented on the West Coast by the Environmental Research Lab/Pacific Ecosystems housed at the Marine Science Laboratory in Newport, Oregon. While documents defining the relationship, if any, this lab had with one of EPA's predecessor agencies are not available, the 1972 Laboratory Plan shows this lab a part of EPA's established facilities.
In 1970, EPA leaders acted quickly to shape the agency's inherited laboratory facilities into a practical, functional system, in order to meet the demands of its mission. The agency consolidated many of these laboratory functions, but the location of most of its present laboratories has deviated little from the location of its predecessor labs. There are a variety of reasons for this.
First, the agency has been impeded by the conflicting organizational philosophies that shaped its initial organization and mission. Agency planners wanted the efficiency of a functional laboratory system (NERC system) and the flexibility and responsiveness of a decentralized system of independent, regional labs. Various studies have assessed the efficacy of EPA's lab system and arrived at different conclusions based on their initial assumptions concerning the agency's research needs. None of these studies has had a substantial impact on the shape of the laboratory system. The larger social and political questions that fuel the conflict between the centralization and decentralization paradigms have forced the agency to retain the initial structure.
Second, plans for consolidating regional labs into fewer but more efficient facilities have met with strong political objections from congressmen who desire to maintain the flow of federal funds to their states and districts. Agency planning documents take into account political roadblocks to proposals to move or phase out laboratories. Many of these same outside political forces that encouraged the establishment of predecessor laboratories no doubt pressured EPA to maintain a presence in those facilities--especially if EPA was the sole occupant of a facility. Many EPA laboratory consolidations were supported by other agencies who wanted to expand their laboratories into the space EPA occupied under joint agreements. When EPA was te sole federal occupant--such as in the Robert S. Kerr Water Research Lab in Ada, Oklahoma, or the Arctic Environmental Research Lab in college, Alaska-- political pressure was exerted to maintain a federal presence at those facilities. Throughout the 1970s, planners recommended closing the College and Ada sites, but the Arctic Environment lab was not closed until the early 1980s and the small staff at the Kerr lab continues its soil and water pollution research. Political concerns have played a powerful role in shaping the agency's inventory of laboratory facilities.
Third, EPA has found it easier to acquire space in existing federal facilities and secure funds for renovation and expansion than to plan and build entirely new facilities. The philosophy of "New Federalism" in both the Nixon and Reagan administrations and the government efficiency emphasis of the Carter administration supported either holding he line or reducing expenditures in non-military, government labs. In response to this political atmosphere, the agency found it easier to expand its previously assigned government-owned space or maintain itself in properties leased for less than the cost of building new facilities.
In such an environment, EPA was initially constrained to consolidate laboratories and expand key facilities to accommodate its research and monitoring missions. Matching facilities with functions permanently established the locations of many of the agency's laboratories. Since the early 1970s, some facilities have been closed and a few new ones have been opened, but the laboratory system remains a product of the practical solutions developed by agency officials in the early 1970s to the problem of how to best use the facilities it inherited in December 1970.