Richard J. Lazarus, The Neglected Question of Congressional Oversight of EPA: "Quis Custodiet Ipsos Custodes" (Who Shall Watch the Watchers Themselves)?, Law and Contemporary Problems, Vol. 54, No. 4, Assessing the Environmental Protection Agency after Twenty Years: Law, Politics, and Economics (Autumn, 1991), pp. 205-239
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Richard J. Lazarus (1991) studied this question.