EPA, TVA and Pollution Control: A Comparative Analysis of Intragovernmental Policy Implementation

Of late the substance, organization, and context of federal policies have been altered. This study examines one manifestation of these developments: the burgeoning necessity of one federal agency having to hold another accountable to national policy goals. Its analytical focus is the Environmental Protection Agency's experience with the Tennessee Valley Authority during the former's implementation of the Clean Air Act and the Federal Water Pollution Control Act. Specifically examined are the EPA's efforts to apply SO₂ and thermal pollution control policies to the TVA power program during the 1970's. Using a comparative case study design, the divergent responses of TVA to the implementation efforts of EPA--relatively swift compliance with the thermal pollution policy and protracted noncompliance with SO₂ policy-- are compared and contrasted. The analysis is guided by two sets of research questions. One set seeks to assess the nature of the intragovernmental implementation process, as well as the implications of the EPA/TVA cases for emerging policy implementation theory. The second set of questions addresses the implications of intragovernmental policy implemenation for the administrative state. The study both supports the importance of, and suggests refinements to, several factors found to condition implementation in other contexts. Those refined include policy/mission proximity, complexity of joint action, dispositions of actors, and validity of causal theory. What is more, the cases suggest that federal agencies can be made distinctly vulnerable to public regulation; that intragovernmental policy implementation as a form of "bureaucratic oversight" is a promising supplement to traditional overhead democracy techniques; and that challenges raised by public agencies to implementation may not be as inappropriate and dysfunctional as commonly assumed.