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Integrated pollution control, or IPC, can be defined for now as an approach to environmental regulation that "seeks particularly to link air, water, and waste programs. Its concern is institutional changes that reduce total risk to the environment from pollutants." 8 This sounds remarkably appealing, which perhaps explains IPC's recurring popularity. As we shall see, it enjoyed a brief celebrity about twenty years ago, and it is once again in vogue-especially within the U.S. Environmental Protection Agency (EPA).

Is the Agency's recent interest in IPC a good thing? We worry that it is not. First of all, IPC has an unpromising political history and weak theoretical foundations; its allure, in other words, is largely superficial. Second, and despite the foregoing, IPC is now being used by the EPA as the cornerstone for a major initiative on evaluating environmental risk. Indeed, judging from all appearances, risk management has become at least as important to the Agency as the integrated controls that the risk methodology was initially designed to advance. Yet the EPA's case for its approach to risk is as superficial as the appeal of IPC, and even more deeply troubling.


This article was first published in Environmental Law as Krier, James E. "On Integrated Pollution Control." M. Brownstein, co-author. Envtl. L. 22 (1992): 119-38. Copyright 1992. Reproduced with permission.