The Environmental Protection Agency is rapidly being destroyed as an effective institution in the federal government. Current and planned budget and personnel cuts, if continued will inevitably reduce the agency to a state of ineffectualness and demoralization from which it is unlikely to recover for at least 10 years, if ever. While some may greet this situation with enthusiasm, I am convinced that the business community, among others, has very little to gain and a great deal to lose.

I see EPA's mission as a critically important one. I am convinced that, in the long run, our free enterprise system can only prosper and grow within the context of adequately protected public health and environment. I am also convinced that responsible business leadership knows this and asks only that regulatory requirements be reasonable, cost-effective, have an adequate scientific basis, and be fairly and uniformly enforced.

Corrected for inflation since 1981, President Reagan's expected 1983 budget request for EPA will represent a reduction of approximately 45 percent. Administrator Ann Gorsuch has reportedly been working on 1984 numbers of $700 million, or a cut of 61 percent. EPA's research branch has been cut by two-thirds, far more than any other basic research program.

In the personnel area, the cuts are equally drastic. If she is allowed to carry out plans that have been circulating within the agency for some time, by this coming June--one year and four months after the Reagan administration took office--80 percent of EPA's headquarters staff will have quit, been fired, or demoted or downgraded.

It is hard to imagine any business manager consciously undertaking such a personnel policy unless its purpose was to destroy the enterprise. Predictably, the result at EPA has been and will continue to be demoralization and institutional paralysis. Attrition within the agency is running at an extraordinary 2.7 percent per month or 32 percent a year.

From an administration that quite rightly emphasizes the need for good management, what we are seeing at EPA is its very antithesis. Permits that businesses need do not get issued. Required rules and regulations do not get promulgated. Enforcement has ground practically to a halt. The most competent, technically proficient, professional staff have either already left or are looking for jobs. If one believes that effective environmental protection is essential it is tragic. If one is not necessarily an environmentalist but believes that our environmental programs need to be managed efficiently, scientifically and less burdensomely, the current situation is equally disastrous.

Ultimately, I believe, Gorsuch's plans will not succeed. Congress and the courts will effectively impede the ability of the administrator to bring about substantial change by administrative action alone. But they will provoke an upsurge in lawsuits and more decision-making by confrontation. While adversarial approaches to conflict resolution seem to be deeply ingrained in American society, there have been encouraging signs lately of growing appreciation of economic realities within the environmental community and a greater environmental sensitivity on the part of the business community. A return to the early days of polarization benefits no one.

Many of EPA's difficulties over the years can be traced to the fact that Congress loaded the agency with far more statutory responsibilities within a brief period of time than perhaps any agency could effectively perform. Surely, those problems can only be compounded by drastically reducing its resources while its responsiblities remain the same or grow. When EPA came into being in 1970, it took over the air pollution, water pollution, solid waste, pesticide, and radiation programs scattered around the federal government. Since then those programs have been broadened and improved and Congress has added major new responsibilities-- including the Toxic Substances Act, the Safe Drinking Water Act, the Noise Control Act, the hazardous waste control program, and Superfund. These are not hangovers from the concerns of prior generations. EPA has been on the frontier of today's concerns, and there is every indication in the polls that environmental protection remains high on the public agenda.

Environmental protection needs are not going to lessen if EPA becomes ineffectual. The kepone problems and the Love Canals will continue to crop up from time to time. Unless the public has reasonable confidence in the public institutions charged with responsibility for handling such problems, there is real danger of a backlash developing against business. The pendulum will swing once more and in even more violent oscillations. EPA will be forced to react and will do so without adequate staffing and with a reduced research base. Business needs greater stability and predictability of policy, and for that it needs a credible EPA. The tendency of our political system to ignore the need for reasonable continuity in institutions and policies is one of its most serious failings.

As one who served two Republican administrations from 1969 to 1977 and who voted for President Reagan, I must record my profound concern over what is happening at EPA today. The budget and personnel cuts go far beyond that of any other major agency in terms of their relation to workload, and, unless reversed, will destroy the agency as an effective institution for many years to come. Environmental protection statutes may remain in full force on the books, but the agency charged with their implementation will be a paper tiger.