I am returning without my signature S. 2577, the ``Environmental Research, Development and Demonstration Act of 1983.''

It should be understood that my disapproval of this legislation will in no way interfere with the conduct of any of the research programs of the Environmental Protection Agency. Pursuant to the Department of Housing and Urban Development -- Independent Agencies Appropriations Act of 1983, which I signed into law on September 30, 1982, EPA will spend $220.8 million on its research activities in fiscal year 1983. The appropriations authorized for research in 1983 are 10 percent higher than in 1982, reflecting this Administration's commitment to putting environmental regulation on the soundest possible scientific footing.

While S. 2577 is unacceptable as a whole, I want to commend Congressman Cooper Evans of Iowa for contributing to this bill an amendment to authorize the Senior Environmental Assistance Program. Congressman Evans' amendment provides the authority for EPA to continue promoting meaningful employment opportunities for older Americans in Federal, State, and local agencies, as they accomplish important short-term environmental protection projects. The amendment is based on a highly successful demonstration project carried out by EPA in conjunction with the Administration on Aging and the Department of Labor. I believe the amendent would further this Administration's goals of providing productive, meaningful employment to older workers, and providing the benefits of a cleaner, safer environment to future generations.

Nevertheless, enactment of S. 2577 would represent a major step backward in achieving the goal of assuring that our vitally important environmental research programs reflect the best judgment of the scientific community, unhampered by partisan or interest group politics.

S. 2577 would mandate that the EPA Science Advisory Board membership include representatives from ``States, industry, labor, academia, consumers, and the general public.'' This requirement runs counter to the basic premise of modern scientific thought as an objective undertaking in which the views of special interests have no role. The purpose of the Science Advisory Board is to apply the universally accepted principles of scientific peer review to the research conclusions that will form the basis for EPA regulations, a function that must remain above interest group politics.

In addition, under the statutes governing actual promulgation of EPA rules, the Administrator is obligated to seek public comment from any and all interested parties and to weigh such comment in shaping final rules. That is the stage of the rulemaking process at which involvement of special interest viewpoints is appropriate, not the earlier stage of developing a sound scientific understanding of the research findings that may be relevant to a particular rulemaking or class of rules.

Environmental regulation involves scientific, political, social, and economic judgments. The laws mandating protection of our air, water, and land against harmful pollution reflect this necessity to balance a wide range of factors. But for the entire regulatory process to function effectively, it must have as its starting point an objectively developed review of the state of scientific knowledge. The Science Advisory Board is vital to the preparation of this objective scientific review; to require that the Board become a political entity, with representatives from various special interests, would completely undermine the use of scientific knowledge in EPA rulemaking.

The maintenance of a free, essentially self-governing scientific research community is one of the great strengths of our Nation. To undermine this tradition by requiring that the scientists appointed to the EPA Science Advisory Board wear the label of ``industry'' or ``labor'' or ``consumer'' is a modern-day version of Lysenkoism to which I must strongly object.

In addition to imposing these new requirements on the procedures for selecting the EPA Science Advisory Board, S. 2577 contains a number of other objectionable features. It authorizes spending that is $46.4 million above the previously enacted appropriation bill; it mandates an increase in the proportion of funds devoted to basic research from 15 percent to 20 percent, which will take funds away from high-priority research needed for the support of regulatory proceedings; it mandates a duplicative and wasteful effort to create another national environmental monitoring network; and it mandates a number of research activities that are inconsistent with the previously enacted appropriation.

For these reasons, I am returning S. 2577 without my signature.

Ronald Reagan

The White House,

October 22, 1982.