The central question for this book is how government agencies can “reconcile the necessary use of coercion in regulatory programs with the need to retain popular support” (p. 1). The authors answer this question by examining changes in the Environmental Protection Agency's (EPA) “Superfund” program during the latter half of the 1990s. In the late 1980s and early 1990s, reforming Superfund was a salient political issue. Scholars and stakeholders alike considered Superfund a failed program, and during this period, more than a dozen bills were debated in Congress with the aim of significantly reducing its scope or eliminating the program altogether.

In response to these pressures, the EPA undertook two sets of far-reaching administrative changes that fundamentally changed the nature of Superfund. First, the agency changed how potentially responsible parties (PRPs) were treated under the law, particularly how cleanup costs were allocated among these parties. Second, it revised environmental standards for completed cleanups and replaced an emphasis on removing contaminants from hazardous waste sites with an emphasis on in-site treatment of these contaminants. According to Robert Nakamura and Thomas Church, in implementing these changes, the EPA had to overcome substantial obstacles stemming from organizational culture and legal doctrine, but the reforms themselves dissipated the energy for Superfund reform within Congress. The lessons from Taming Regulation, then, are about how significant policy change can be fostered and managed within regulatory agencies, subsequently avoiding having unwanted policy changes imposed from without.

This book has many strengths, among which is the clear, concise, and informative summary of changes in the Superfund program during the late 1990s. After studying the program for more than 15 years, no one is better equipped to provide such a summary than Nakamura and Church. In addition, the book does a very nice job of placing these changes within the broader context of regulatory reform. Unlike most recent literature on the topic, this discussion does not begin with an automatic dismissal of the value of government regulation. Instead, the authors offer a refreshing review of the empirical literature, concluding that traditional command-and-control regulation is not only sometimes necessary but often works. This leads them away from prescriptions for replacing the current regulatory apparatus to the more practical question of improving the existing system.

The careful reader will note that the strengths are ancillary to the main goals of the book: explaining how regulatory reform can be managed internally and drawing general lessons from this experience at the EPA. Unfortunately, the book is much less successful at meeting these goals. Specifically, the authors employ a questionable definition of “success” when evaluating Superfund reforms; offer a debatable explanation of the source of these reforms by misdiagnosing their source; and draw “lessons” for regulatory reform that are neither supported by the evidence nor come from a generalizable case study. One reason for these shortcomings might be the scarce attention actually paid to reform within the EPA: Only 30 of the 108 brief pages of text are devoted to describing Superfund reforms and explaining why they succeeded.

First, Nakamura and Church “regard EPA's effort to reform the administration of the Superfund program as a major implementation success” (p. 70). Viewed through a less sympathetic lens, these “successful” Superfund reforms consisted of providing immunity to some PRPs, reducing the fines paid by others, and rolling back environmental standards at Superfund sites. These regulatory retrenchments were perfectly consistent with the wishes of polluting firms and the new Republican majority in Congress. Many EPA stakeholders saw these reforms as “successful” only insofar as they staved off elimination of the program altogether. From this perspective, the story of “successful” reform is a story of political survival through appeasement, and in this light, administrators were hardly the “heroes” profiled in Malcolm Sparrow's The Regulatory Craft (2000) and cited approvingly by Nakamura and Church.

Second, the authors attribute the success of Superfund reforms to the endogenous factors of leadership, management, and attention to individual incentives within the EPA (Chapter 6). These factors allowed the agency to overcome the legal and cultural obstacles mentioned earlier. While these factors are not irrelevant to the success of Superfund reform, most evidence indicates that the sources of reform were exogenous. First, consider that if the EPA had not acted to reform Superfund, there was near certainty that the program would have been reformed for them, or eliminated altogether, by Congress. Second, none of the reforms were invented by the agency to deal with the congressional threat. In 1993 the Clinton administration put together a task force made up of EPA officials, congressional officials, and Superfund stakeholders in order to craft a set of reforms to be codified in the reauthorization of the legislation predicted to take place in 1994. A deal had been struck on these reforms, and while Republican members of Congress pulled out of the deal in advance of their sweeping victories in the 1994 elections, the point is that the impetus for these reforms was largely exogenous to the agency. The real story of leadership and management is not in how these reforms were implemented but in how the reforms were negotiated in the first place. Taming Regulation is silent on this issue.

When considering any general lessons that might be drawn from the Superfund reforms, it is worth considering just how unusual this case is. Superfund officials at the EPA, faced with the certain restructuring and possible elimination of their program, had at their disposal a set of off-the-shelf reforms that had been vetted by all major stakeholders and political principles during two years of intense negotiations. These same officials then employed these reforms to stave off program annihilation. Rather than serving as a source of general lessons about successful regulatory reform, this case exhibits a remarkable confluence of fortuitous circumstances that is unlikely to be repeated often. Moreover, the positive lessons from this case presented by Nakamura and Church have very little to do with the evidence presented in support of the case (pp. 105–7).

The authors puzzle over how EPA officials were able to surmount legal and cultural obstacles in implementing Superfund reforms “in an organizational, legal, and political environment that was heavily weighted against success” (p. 88). Many scholars might disagree with this assessment. All stakeholders were dissatisfied with Superfund, a set of Superfund reforms acceptable to all groups with veto authority was available, and Congress was ready to implement its own reforms if the EPA did not act. Indeed, it would have been far more remarkable if EPA officials had managed to botch the implementation of reform under these circumstances. Now that would be a story with lessons for public managers.