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Between the Devil and the Deep Blue Sea: Why NOAA Shouldn't Be Moved to the Interior Department

David Goldston

Posted January 15, 2012 in Reviving the World's Oceans, U.S. Law and Policy

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There may be no subject that sounds more arcane, dreary and trivial than governmental reorganization.  “Just rearranging the deck chairs on the Titanic” is one popular line of dismissal.  But in reality, how the government is organized can have enormous, tangible effects.

Clever leaders have long recognized that monkeying around with how the government is organized can be a way to slip through fundamental and durable changes that would be too controversial to approach head-on. 

To take one smallish example, House Republicans in the past tried to move the regulation of oil refineries from the Environmental Protection Agency (EPA) to the Department of Energy (DOE).  It just would make more sense, they argued – why have two different agencies that dealt with oil refineries, and the DOE knows more about energy anyway.  Of course, their actual goal was to weaken if not eviscerate the regulation of refineries.  EPA, which is charged with protecting the environment, inherently approaches issues differently than does DOE, which is designed to promote the energy industry.  Moving refinery regulation wasn’t about making a neater org chart; it was about tilting policy by trying to silence an agency that provided a viewpoint that could counter-balance DOE’s.  Happily, the proposal to reorganize EPA and DOE never got far, but it underscores the point that reorganization may sound dull and abstract, but the results can be quite consequential. 

I bring all this up because President Obama is now proposing to move the National Oceanic and Atmospheric Administration (NOAA), which is, among other things, the nation’s chief oceans agency, from the Department of Commerce into the Department of the Interior.  Like other reorganizations, this one would likely have major consequences, and none of them bodes well for oceans, science, government effectiveness or the environment .

This is especially unfortunate because this reorganization proposal isn’t even driven by a desire to change ocean policy for better or ill.  It’s collateral damage from an unrelated reorganization.  The President wants to reorganize the rest of the Commerce Department to make it into a central agency for economic and trade issues.  NOAA didn’t fit well into that plan, so it was jettisoned.  In casting about for a place for NOAA to land, the President reached back to an old idea of sticking it into Interior.  NOAA was just the remainder, as it were, when the Administration solved its Commerce division problem.  Some of the initial announcements about the President’s plans didn’t even mention NOAA.  The Administration was left to come up with after-the-fact rationales like repeating the already discredited claim that salmon are regulated separately depending on whether they’re in fresh or salt water.  

This is important because a reorganization discussion built around a question like, “What can be done to improve NOAA?” or “How could we develop a more effective oceans policy?” would likely have arrived at a very different answer.  Indeed, commissions that have looked at oceans policy in recent years never recommended this.

So what would be so bad about moving NOAA into Interior?  Well, it’s a lot like the EPA/DOE example.  NOAA brings an independent perspective to key issues that is likely to be muted or lost in Interior.  NOAA is primarily a scientific and environmental organization.  Interior, historically, is primarily an agency focused on extracting raw materials, and that’s even truer when it comes to its water and oceans portfolios.  Interior builds and manages dams; NOAA worries about what happens when fish reach them.  Interior leases the ocean to drill for oil; NOAA worries about what that might do to ocean species and ecology (and the industries that depend on them). 

The government needs both viewpoints; if Interior and NOAA get combined into a single agency, that balance will likely be lost.  If NOAA and Interior disagree now, it’s a dispute between two cabinet departments that has to get elevated to the White House to get worked out by third parties.  If NOAA is a division of Interior, the Interior Secretary can just shut NOAA up.  And since Interior secretaries in virtually all Administrations tend to be from the inter-mountain West, and have tended to be most interested in exploiting natural resources, one can hardly assume that NOAA, with its coastal environmental concerns, will get a sympathetic hearing as the newcomer in Interior.

The situation when the government is making a decision that involves Interior and NOAA is a little like what happens when a doctor tells you to have surgery.  No matter how much you respect your doctor, you’ll want a second opinion, especially if your doctor is known to favor a type of surgery.  And you don’t seek that second opinion from someone in the same practice. 

One can see the inherent differences between NOAA and Interior even in some of the disputes and scandals in the Bush Administration.  Interior had the most egregious scientific scandal – a high level official telling scientists to change their findings – that came to light because of allegations by outside groups and led to an Inspector General investigation and admonishment by the courts.  NOAA, fundamentally a science agency, faced some allegations of trying to muzzle scientists (but none of trying to change scientific results); no specific, clear incident was ever uncovered; and the agency head spoke out against scientific interference.               

Interior and NOAA have different histories, different “cultural DNA,” different kind of functions, approaches and staffs; and different kinds of leaders.  Subsuming NOAA within the mammoth that is Interior can only mute the independent voice and strengths that NOAA can now bring to the table.  Any supposed synergies – which are not the reason this is being proposed anyway – would be far outweighed by the costs of losing NOAA’s independent voice and the balance it inherently brings to government decision-making.

Having NOAA as a separate agency also brings more of a federal focus and voice to ocean issues, which are critically important to health, the economy and the environment yet are all too easy to overlook.  NOAA will be less prominent as one small part of Interior than it is in Commerce, where it accounts for most of the Department’s budget.  Interior is fundamentally a lands agency, as its quaint name suggests.  One has to go back quite a ways in geological time to find an interior ocean in North America.

Now, proponents of the merger point to areas where Interior and NOAA functions intersect or overlap.  And certainly Interior has science elements and deals with some related issues.  But such connection is not in and of itself a reason to combine agencies.  NOAA and Interior already work with each other – it’s not as if this merger is needed to get the two of them to talk.  The question is whether government policymaking and operations would be stronger or weaker after NOAA is subsumed in another agency.  It’s hard to make the case for increased strength, and notably few are even trying.

Also, there are key parts of NOAA that have little if any overlap with Interior, most notably the National Weather Service, which is the biggest part of NOAA.  Interior is certainly a user of weather service information, but so are you and I, and Interior would be unlikely to improve the massive NOAA program to procure satellites.  (Satellite procurement, by the way, offers an object lesson in how reorganizations that look good on paper often don’t work.  NOAA, NASA and the Air Force satellite programs were yoked together in the Clinton Administration because it just seemed logical, and the result has been massive cost overruns and organizational dysfunction that is taking years to untangle.)

And proponents of the move often sometimes argue that NOAA never fit into Commerce anyway.  This misses the point in two ways.  First, it doesn’t matter if it “made sense” for NOAA to have been put in Commerce 40 years ago or even whether being in Commerce creates some headaches for NOAA.  It’s there now, and the question is whether a move is worth the cost and distraction it would cause.  Besides, it turns out that NOAA has been able to play a relatively high profile and independent role from its Commerce perch, and that would be eroded by a move to Interior. 

Second, any organizational scheme can be said not to make sense from some angle.  Life is complex; any way to categorize it will have loose ends and arbitrary aspects.  NOAA’s responsibilities relate to those of lots of agencies besides Interior – EPA, the National Science Foundation and NASA, to name a few.   That’s not a reason to upend the current, workable arrangement and force a shotgun marriage with another agency.

And there’s one final reason to fear the President’s proposal – it requires Congressional action.  Who knows what riders, limitations and insults the House Republicans will try to tack on to a bill to okay a Presidential proposal to shove NOAA over to Interior.  Plus, changing around Hill jurisdictions as a result of the reorganization could cause additional headaches for NOAA.  If NOAA’s budget is reviewed with the rest of Interior’s, it would end up competing for funding against other environmental agencies instead of other science agencies, and also come up against more hostile overseers. 

(A final note:  the current arrangement of House spending subcommittees was the work of arch-conservative Tom Delay, an operator who understood well the power of reorganization.  He stuck spending decisions for many of the environmental agencies together when he reworked House organization precisely to make it harder to fund them well.)

So, in short, there’s little if anything to be gained by moving NOAA to Interior and much to lose – all from a proposal that wasn’t motivated by anything involving NOAA to begin with.  The Administration wasn’t trying to screw up the National Weather Service, or to silence NOAA, or to weaken the federal focus on oceans, or to distort the already precarious balance that keeps environmental issues on the table when fisheries and ocean issues are being decided.  It just seems to have stumbled on to a way to do so.  This reorganization proposal would have made more sense coming from NOAA’s enemies.

Before NOAA is sent down to Davy Jones’s locker, there ought to be a debate about the very real policy consequences that could result from reorganization.   

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Comments

kenanJan 15 2012 01:33 PM

Does it make sense to leave NOAA in a reorganized Commerce Department? Does that altered context not still result in the distracting upheaval of moving the agency itself? Would you recommend either leaving the Commerce Department as it is, or sending NOAA to the EPA or another more suitable home?

Alan SillJan 15 2012 06:07 PM

The arguments presented here all boil down to organizational inertia. They do not form a rational basis for opposing the proposed move or consolidation and border on agency favoritism.

If the science programs conducted by NOAA have merit -- and we are willing here to argue strongly that they do -- then they will continue to have merit in a new agency home, whether it is Interior or NASA. There is no real value in arguing that there is any potential for good programs to lose funding or their organizational footing during a move, if sufficient science- oriented oversight and care is taken before, during and after the transition.

In research and in pursuit of important forefront work of any type, there are often difficult choices to be taken. Rather than whine about them or try to avoid them, I believe that this is such a case and it would be better for NRDC and the science agency folks involved to roll up your sleeves and get started working to achieve the best possible outcome after the move by assuming that one is going to take place, rather than trying to avoid it.

Scott Jan 15 2012 06:46 PM

Actually I think the NOAA in the Interior Dep. makes sense. What doesn't make sense is the Dep. of the Interior being more concerned with resource extraction than with protecting and conserving our natural resources.

If they are moving things around, how about making the Interior Dep. the Department of the Environment and shift the entire agency more towards conservation and protection. Move the NOAA into it and the Forest Service (from Agriculture) and maybe even the EPA.

With an environmental focus and all those agencies in the same tent, there would likely be a lot of redundancies that could be trimmed out.

AnneJan 15 2012 10:24 PM

Why the assumption that Republicans don't have the country's and the citizenry's best interests at heart and the automatic presumption that Democrats do? I seriously question both.

John DJan 16 2012 08:11 PM

Interesting discussion, but I would have liked to have heard what you think would happen. It is easy for one to sit on a perch and say 'no', a very republican thing to do recently. I'd like to hear where you think it should go? Perhaps extract out the NWS from NOAA and put that in DHS? Then the fisheries and other aspects to EPA? Maybe NOAA shouldn't be kept whole.

I do see some of your points, but I also don't see where else it should land than Interior.

MaddnessJan 17 2012 02:19 PM

Do I have this right? You think that the Department of Commerce has less of a profit motive in managing fisheries, weather forecasting, climate and atmospheric issues than the Department of Interior does?

You say that the Department of the Interior has a long history of favoring extractive uses, but you don't talk about the Department of Commerce's long history of natural resource stewardship. Could that be because it doesn't have one?

Right now the Department of the Interior houses the Fish and Wildlife Service, the National Park Service, and the Geological Survey. The last of those does pretty much all the scientific research relating to wildlife on the federal level, except for research on marine fish.

So are you saying that those three organizations should be moved to the Dept. of Commerce too, just for their own safety?

Skeeter EJan 17 2012 03:13 PM

Make NOAA a Federal independent agency - like NASA, NSF, EPA, and dozens of others.

All federal organizations don't need to be part of a Cabinet-level department to function effectively.

StevenJan 17 2012 06:50 PM

My cross-post from another:

Sheesh...NOAA is not just a coastal/oceanic/atmospheric natural resources agency that deals with matters involving the "interior" of the USA. It's responsibilities are much broader and global in scale and complexity, and include many competing national objectives that NOAA, its National Ocean Service and Office of Ocean and Coastal Resources Management, other federal agencies and many state coastal management partners must implement in a manner that achieves those competing objectives while also avoiding conflicts between them. Commerce also administers other and excels in science and technology programs that neither exist in nor would be appropriate in other agencies such as Interior, or EPA. It would, however, make sense to move the administration of Clean Water Act and related regulatory programs out of the Corps of Engineers (Corps) in the Department of Defense and move those programs either to Interior or EPA. Having four decades of experience in science and management in government at all levels, and being a supporter of President Obama, I do not support moving NOAA functions to Interior, or EPA. It's a big mistake, made perhaps by people who are simply unaware of all of NOAA's and Commerce's roles. As has been suggested by others, perhaps some other reorganization involving relevant responsibilities of NOAA, Interior, EPA, and the Corps makes more sense.

I agree with "Skeeter E" - make NOAA an independent agency, along the lines of NASA. And while at it, perhaps better coordinate our "inner' and "outer" space programs and give our ocean "innerspace" programs a little more attention...

Roy T. MeyersJan 21 2012 11:02 AM

To begin, the "final note" about the current arrangement of the subcommittees of House Appropriations is incorrect in several respects. First, DeLay's reorganization was designed to protect NASA (especially its operations in Houston) from cuts made necessary by growing health care spending for veterans. Second, when the Democrats took back the House in 2007, they further reorganized the subcommittee jurisdictions. For a good history, see the CRS report available at: http://opencrs.com/document/RL31572/2011-03-08/

Unfortunately, the rest of this blog entry is even worse than that error. If this is the best quality political and organizational analysis that NRDC can present, that is a real shame.

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