United States Science Advisory Board EPA-SAB-EC-97-007 Y
Environmental Washington DC September 1997
Protection Agency
oEPA AN SAB REPORT: REVIEW
OF ENVIRONMENTAL GOALS
FOR AMERICA
A REVIEW BY THE ENVIRONMENTAL
GOALS SUBCOMMITTEE OF THE
SCIENCE ADVISORY BOARD
U.S. Environmental Protection Agency
Region 5, Library (PL*12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
September 10, 1997
EPA-SAB-EC-97-007
Honorable Carol M. Browner
Administrator OFFICE OF THE ADMINISTRATOR
U.S. Environmental Protection Agency SC.ENCEADV.SORYBOARD
401 M Street, SW
Washington, DC 20460
RE: Science Advisory Board (SAB) Review of the "Environmental Goals for America:
With Milestones for 2005"
Dear Ms. Browner:
I am pleased to send you the Science Advisory Board's comments on the December
1996 draft of the "Environmental Goals for America: With Milestones for 2005" (EPA, 1996).
As you know this document was prepared as part of the Clinton Administration's regulatory
reinvention efforts, and to help satisfy a requirement of the 1993 Government Performance
and Results Act. The purpose of the document is to stimulate public discussion of what
Americans are seeking to accomplish in environmental protection and what they are willing
to pay for such protection.
The document was reviewed by a subcommittee of the Executive Committee during
two public teleconferences held April 17, and July 3, 1997. Overall, the document is well
written and instructive. In general, the subcommittee considers the draft Goals document to
be quite successful, and well-suited to its intended task. The milestones are reasonable
surrogates for the environmental improvements desired by society, and they are defined by
quantitative information that can be measured with reasonable accuracy (or at least
precision).
The subcommittee appreciates the "generality" of the presentation and compliments
the Agency for publicly identifying goals across the diverse sets of environmental legislation.
The subcommittee also believes the document should stimulate public discussion of what
Americans are seeking to accomplish in environmental protection and what they are willing
to pay for such protection. The idea of setting goals and measuring progress is good and
the Agency is to be commended for submitting the document for review before it is finalized.
While the SAB review comments are generally supportive of the Goals and
Milestones guidelines, numerous suggestions for improvement are offered on each. The
body of the attached report contains general comments about the Goals document. More
specific comments about each goal and milestone are placed in the appendix. The major
concern is that the goals and milestones may be overly ambitious with respect to the
availability of resources and technologies required to reach them, and because they call for
a level of Federal interagency, state, and stakeholder involvement and cooperation that is
well beyond what has previously occurred for environmental protection.
U.S. Environmental Protection Agency
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There is also concern that the goals and milestones identified in this document lack
sufficient specificity to be judged as to their attainability by the year 2005. The
subcommittee felt that EPA should more explicitly state that the goals rely on 'cooperation'
with non-Federal entities. For many of the milestones it is likely that most of what needs to
be done does not come under EPA's mandate. If the Goals document is truly a document
for the nation, and not just for the EPA, then the Federal government as a whole needs a
strategy for how to proceed to insure attainment of the milestones.
The structure of the draft Goals report, which is centered on the current program
office- or media-specific issues, presents difficulties in recognizing and addressing
cross-cutting issues. EPA may wish to consider a meta-structure for the report, with three
main sections within the Goals document: a) environmental goals relating to human health;
b) environmental goals relating to ecological health; and c) environmental goals relating to
quality of life issues.
Even though the Goals document contains a number of references to the need for
improved scientific understanding, the committee believes that it also needs a specific goal
to develop an improved set of institutions and mechanisms that will assure the nation will
develop the fundamental scientific understanding that it will need to make future
environmental decisions.
The committee applauds the inclusion of the goal on empowering people with
information and education and expanding their right to know. In elaborating the specifics of
this general goal, more attention needs to be given to the objective of improving public
understanding of the scientific bases of environmental decision making though education
and outreach.
In addition to the focus on reducing chemical pollution, the Goals document should
put more emphasis on the physical and biological stressors affecting the environment. The
SAB "Reducing Risk" report (SAB, 1990) and other comparative risk studies have indicated
the highest risks to ecological systems are from physical stressors such as habitat alteration
and hydrologic modifications. The Goals document should be consistent with this increased
recognition of the importance of non-chemical stressors in the environment.
We look forward to your response to these comments.
Sincerely,
Dr. Genevieve Matanoski, Chair
SAB Executive Committee
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NOTICE
This report has been written as a part of the activities of the Science Advisory
Board, a public advisory group providing extramural scientific information and advice to
the Administrator and other officials of the Environmental Protection Agency. The
Board is structured to provide balanced, expert assessment of scientific matters relating
to problems facing the Agency. This report has not been reviewed for approval by the
Agency and, therefore, the contents of this report do not necessarily represent the views
and policies of the Environmental Protection Agency, nor of other agencies in the
Executive Branch of the Federal government, nor does mention of trade names or
commercial products constitute a recommendation for use.
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ABSTRACT
A subcommittee of the Executive Committee reviewed the Agency's report
"Environmental Goals for America: With Milestones for 2005" through teleconferences
held April 17, and July 3, 1997. The charge was: a) do the proposed measures use the
most reliable national-level data currently available or likely to become available; b) are
there issues of science related to these goals and milestones that ought to be better
explained or of which EPA ought to be made aware?
The subcommittee considered the draft Goals document to be quite successful,
and well-suited to its intended task. However, it felt that some goals and milestones
lacked sufficient specificity to be judged as to their attainability by the year 2005. To
better address cross-cutting issues it recommended that EPA consider a meta-structure
for the report, with three main sections within the Goals document: i) environmental
goals relating to human health; ii) environmental goals relating to ecological health; and
iii) environmental goals relating to quality of life issues. The subcommittee applauded
the inclusion of the Goal on empowering people with information and education and
expanding their right to know, but felt that more attention needs to be given to the
objective of improving public understanding of the scientific bases of environmental
decision-making though education and outreach. In addition to the focus on reducing
chemical pollution, the subcommittee felt that the Goals document should put more
emphasis on the physical and biological stressors affecting the environment.
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U.S. ENVIRONMENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
ENVIRONMENTAL GOALS SUBCOMMITTEE
CHAIR
Dr. Genevieve M. Matanoski, The Johns Hopkins University, Baltimore, MD
MEMBERS
Dr. Stephen L. Brown, Risks of Radiation and Chemical Compounds, Oakland, CA
Dr. Richard J. Bull, Battelle Pacific Northwest Laboratories, Richland, WA
Dr. Virginia Dale, Oak Ridge National Laboratory, Oak Ridge, TN
Dr. Mark A. Harwell, University of Miami, Miami, FL
Dr. James H. Johnson, Jr., Howard University, Washington, DC
Dr. Carol A. Johnston, University of Minnesota, Duluth, MN
Dr. Paul J. Lioy, Environmental and Occupational Health Sciences Institute, Piscataway,
NJ
Dr. Morton Lippmann, New York University Medical Center, Tuxedo, NY
Dr. Joe L. Mauderly, Lovelace Respiratory Research Institute, Albuquerque, NM
Dr. Paulette Middleton, Science and Policy Associates, Inc., Boulder, CO
Dr. Maria T. Morandi, University of Texas, Houston, TX
Dr. M. Granger Morgan, Carnegie Mellon University, Pittsburgh, PA
Dr. Ishwar P. Murarka, Electric Power Research Institute, Palo Alto, CA
Dr. Barbara Petersen, Novigen Sciences Incorporated, Washington, DC
Dr. Emil A. Pfitzer, Research Institute for Fragrance Materials, Hackensack, NJ
Dr. James Price, Texas Natural Resource Conservation Commission, Austin, TX
Dr. Verne A. Ray, Pfizer, Inc., Groton, CT
Dr. James E. Watson, Jr., University of North Carolina, Chapel Hill, NC
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LIAISON FOR SCIENCE ADVISORY PANEL
Dr. Ernest E. McConnell, ToxPath, Inc., Raleigh, NC
DESIGNATED FEDERAL OFFICIAL
Dr. John R. Fowle III, Environmental Protection Agency, Science Advisory Board
(1400), U.S. Environmental Protection Agency, Washington, DC 20460
STAFF SECRETARY
Mrs. Priscilla Y. Tillery-Gadson, Environmental Protection Agency, Science Advisory
Board (1400), U.S. Environmental Protection Agency, Washington, DC 20460
IV
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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1
2. INTRODUCTION 4
2.1 Background 4
2.2 Charge 5
3. GENERAL FINDINGS 6
3.2 Clarity of Science 7
3.3 EPA's Role 7
3.4 Organization 7
3.5 Approach 8
3.6 Ranking Goals and Setting Priorities 9
3.7 Research 10
4. CONCLUSIONS AND RECOMMENDATIONS 11
APPENDIX A. FINDINGS ON LONG RANGE GOALS & MILESTONES
A-1
A.1 Goal 1- Clean Air A-1
A.1.1 Milestone 1 A-2
A.1.2 Milestone 2 A-3
A.1.3 Milestone 3 A-3
A. 1.4 Milestone 4 A-4
A.1.5 Milestone 5 A-4
A.1.6 Milestone 6 A-4
A.2 Goal 2 - Clean Waters A-5
A.2.1 Milestone 1 . A-5
A.2.2 Milestone 2 A-6
A.2.3 Milestone 3 A-7
A.2.4 Milestone 4 A-7
A.2.5 Milestone 5 A-7
A.2.6 Milestone 6 A-7
A.2.7 Milestone 7 A-8
A.3 Goal 3 - Healthy Terrestrial Ecosystems A-9
A.3.1 Milestone 1 A-10
A.3.2 Milestone 2 A-11
A.3.3 Milestone 3 A-11
A.4 Goal 4 - Safe Drinking Water A-13
A.4.1 Milestone 1 A-14
A.4.2 Milestone 2 A-14
A.4.3 Milestone 3 A-14
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A.4.4 Milestone 4 A-15
A.5 Goal 5 - Safe Food A-15
A.5.1 Milestone 1 A-15
A.5.2 Milestone 2 A-16
A.5.3 Milestone 3 A-17
A.6 Goal 6 - Safe Homes, Schools and Workplaces A-18
A.6.1 Milestone 1 A-18
A.6.2 Milestone 2 A-20
A.6.3 Milestone 3 A-20
A.6.4 Milestone 4 A-21
A.6.5 Milestone 5 A-21
A.6.6 Milestone 6 A-21
A.6.7 Milestone 7 A-22
A.7 Goal 7 - Toxic-Free Communities A-22
A.7.1 Milestone 1 A-23
A.7.2 Milestone 2 A-23
A.7.3 Milestone 3 A-23
A.7.4 Milestone 4 A-24
A.7.5 Milestone 5 A-24
A.8 Goal 8 - Preventing Accidental Releases A-24
A.8.1 Milestone 1 A-25
A.8.2 Milestone 2 A-25
A.9 Goal 9 - Safe Waste Management A-25
A.9.1 Milestone 1 A-26
A.9.2 Milestone 2 A-26
A.9.3 Milestone 3 A-26
A.9.4 Milestone 4 A-26
A.9.5 Milestone 5 A-26
A. 10 Goal 10 - Restoration of Contaminated Sites A-27
A.10.1 Milestone 1 A-28
A.10.2 Milestone 2 A-28
A.10.3 Milestone 3 A-28
A. 10.4 Milestone 4 A-29
A.10.5 Milestone 5 A-29
A.10.6 Milestone 6 A-29
A.10.7 Milestone 7 A-29
A.11 Goal 11- Reducing Global and Transboundary Environmental Risks . A-30
A.11.1 Milestone 1 A-30
A.11.2 Milestone 2 A-30
A. 11.3 Milestone 3 A-31
A. 11.4 Milestone 4 A-31
A.11.5 Milestone 5 A-31
A.11.6 Milestone 6 A-31
A.11.7 Milestone 7 A-32
A.11.8 Milestone 8 A-32
vi
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A.11.9 Milestone 9 A-32
A.11.10 Milestone 10 A-32
A.11.11 Milestone 11 A-33
A. 12 Goal 12 - Empowering People with Information and Education and
Expanding Their Right to know A-33
A.12.1 Milestone 1 A-34
A.12.2 Milestone 2 A-34
A.12.3 Milestone 3 A-35
A.12.4 Milestone 4 ,. A-35
VII
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1. EXECUTIVE SUMMARY
The Environmental Goals Subcommittee of the Executive Committee of the
Science Advisory Board, hereafter referred to as the Committee, was established to
review a draft of the report "Environmental Goals for America: With Milestones for the
Year 2005" (EPA, 1996). EPA asked the Committee to conduct a broad brushstroke
review of "Environmental Goals for America: With Milestones for 2005". Given that the
goals are policy based, and that the Agency took a broad brush stroke approach
developing the goals, the Committee focused on the use of science, in general, to
inform the goal-setting process. The Committee's broad, general comments about the
Goals document are presented in the body of this report. More specific comments
about each goal and milestone are placed in the appendix.
The charge to the Committee was:
a) Do the proposed measures use the most reliable national-level data
currently available or likely to become available? Are there better
measures available to gauge progress towards the goals? One place
where we would particularly like your help is on the milestones and
measures for the Healthy Terrestrial Ecosystems goal.
b) Are there issues of science related to these goals and milestones that
ought to be better explained or of which EPA ought to be made aware?
Overall, the Committee found the document to be well written and instructive. In
general, the Committee considers the draft Goals document to be quite successful, and,
all things considered, well-suited to its intended task. The milestones are reasonable
surrogates for the real environmental improvements that are truly desired by society,
and they are defined by quantitative information that can be measured with reasonable
accuracy (or at least precision).
The Committee appreciates the "generality" of the presentation and compliments
the Agency for publicly identifying goals across the diverse sets of environmental
legislation. The Committee believes the document should stimulate public discussion of
what Americans are seeking to accomplish in environmental protection and what they
are willing to pay for such protection. The idea of setting goals and measuring progress
is good and the Agency is to be commended for submitting the document for review
before it is finalized.
There is a general concern that the goals and milestones may be overly
ambitious with respect to the availability of resources and technologies required to
reach them, and uecause thty call .or a level of Federal interagency, state, and
stakeholder involvement and cooperation that is well beyond what has previously
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occurred for environmental protection. Nonetheless, it would be hard to claim that any
one of the goals in the document is unworthy.
There is also concern that the goals and milestones identified in this document
lack sufficient specificity to be judged as to their attainability by the year 2005. In
addition, there are no intermediate-level options presented, and there is no sense of
what steps the Agency will take (e.g., budget) to maintain progress on each of the
milestones. How are priorities to be set across milestones if it becomes apparent that
all will not be achieved given the resources available for implementation?
It should be made more explicit that the goals stated rely on 'cooperation' with
non-Federal entities. For many of the milestones it is likely that most of what needs to
be done does not come under EPA's mandate. If the Goals document is truly a
document for the nation, and not just for the EPA, then the Federal government as a
whole needs a strategy for how to proceed to insure attainment of the milestones.
The structure of the draft Goals report, which is centered on the current program
office- or media-specific issues, presents difficulties in recognizing and addressing
cross-cutting issues. EPA may wish to consider a meta-structure for the report, with
three main sections within the Goals document: a) environmental goals relating to
human health; b) environmental goals relating to ecological health; and c)
environmental goals relating to quality of life issues. For example, the ecological
section would have as its primary focus the preservation, restoration, and sustainability
of a diverse set of ecological systems, including various types of terrestrial, wetland,
freshwater, estuarine, and marine ecosystems.
Solid scientific understanding is a prerequisite to sound decision making. While
the Goals document contains a number of references to the need for improved scientific
understanding, the committee believes that it also needs a specific goal to develop an
improved set of institutions and mechanisms that will assure the nation will develop the
fundamental scientific understanding that it will need to make future environmental
decisions.
The committee applauds the inclusion of the goal on empowering people with
information and education and expanding their right to know. In elaborating the
specifics of this general goal, more attention needs to be given to the objective of
improving public understanding of the scientific bases of environmental decision making
though education and outreach.
A major hope for the Goals document is the promise of an improved capability to
characterize environmental risks, understand how most effectively to allocate resources
across risk-reduction measures, and how to anticipate risks of the future. Establishment
of effective databases through existing or new monitoring, greatly improved integration
of diverse sources of information, and scientific analyses of the data would provide
time-trends and measures of success of the environmental milestones and goals.
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In addition to the focus on reducing chemical pollution, the Goals document
should put more emphasis on the physical and biological stressors affecting the
environment. The SAB "Reducing Risk" report (SAB, 1990) and other comparative risk
studies have indicated the highest risks to ecological systems are from physical
stressors such as habitat alteration and hydrologic modifications. The Goals document
should be consistent with this increased recognition of the importance of non-chemical
stressors in the environment. Many wetlands and other freshwater systems have been
affected by or are at greater risk from these stressors than by exposures to chemical
pollution.
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2. INTRODUCTION
The Environmental Goals for America is the Environmental Protection Agency's
(EPA) first attempt to propose long-range national environmental goals to improve the
personal health of people living in the United States, the national economy and
environment, and the quality of life. EPA believes the goals are achievable with current
laws and policies, and the Agency would like to use them to improve the public
understanding and discussion of environmental problems, policies, and programs. The
Agency also hopes that the goals will be useful as a starting point for planning and
accountability, both at EPA and in the Agency's work with the states and with local
communities.
In its request that the Science Advisory Board review a draft of the "Goals"
document, the Agency asked the Board to keep "in mind (a) the purposes for which the
document is intended, ... the fact that it does not create any new requirements, and (b)
the fact that this document is necessarily summary in nature and is not intended to
explain scientific issues in depth...". In this spirit, the Committee has conducted a
general review. The focus of the Committee's comments is not on the policy-related
aspects of the goals and milestones, but on how science can best be used to inform the
goal-setting process. These broad, general comments about the document are
presented in the body of the report, while more specific comments about each goal and
milestone are placed in the appendix.
2.1 Background
As part of the Clinton Administration's regulatory reinvention efforts, and to help
satisfy a requirement of the 1993 Government Performance and Results Act of 1993,
the EPA has drafted environmental goals to stimulate public discussion of what
Americans are seeking to accomplish in environmental protection and what they are
willing to pay for such protection. The intent of the goals document is to help the nation
answer such important questions as:
a) What tangible results should our national environmental programs aim to
deliver?
b) What investments should be made by Federal, state, tribal, and local
governments, industry, and others to achieve the nation's environmental
goals?
c) How can regulatory reinvention, flexibility, and innovation be encouraged
in working towards the goals?
d) What environmental progress are we really making?
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EPA has been developing these goals over the past four years. They cover
nearly all the major environmental issues and build on the Agency's 1987 Unfinished
Business: A Comparative Assessment of Environmental Problems (EPA, 1987) and the
SAB's 1990 report Reducing Risk: Setting Priorities and Strategies for Environmental
Protection (SAB, 1990). The Goals document lays out 12 goals, and, for each goal the
report:
a) Summarizes what has been done to meet the goal and what is left
undone;
b) Identifies what party(ies) is responsible to meet the challenge;
c) Proposes milestones or environmental indicators that can be used to track
progress towards meeting the goal; and
d) Describes a strategy to obtain the goal.
The Committee is commenting on the December 1996 draft of the
"Environmental Goals for America: With Milestones for 2005" (EPA, 1996) as part of a
government (Federal, state, and local) review. EPA has stated that it will use these
comments to shape the document further before sending it out for public review.
2.2 Charge
EPA asked the Committee to conduct a broad brushstroke review of
"Environmental Goals for America: With Milestones for 2005". Because the Goals
document is a policy document, and does not contain an in-depth explanation of the
relevant scientific issues, the Board was asked to focus on the use of science to inform
goal-setting.
The charge to the Committee was:
a) Do the proposed measures use the most reliable national-level data
currently available or likely to become available? Are there better
measures available to gauge progress towards the goals? One place
where we would particularly like your help is on the milestones and
measures for the Healthy Terrestrial Ecosystems goal.
b) Are there issues of science related to these goals and milestones that
ought to be better explained or of which EPA ought to be made aware?
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3. GENERAL FINDINGS
Overall the document is well written and instructive. The Committee appreciates
the "generality" of the presentation noting that the goals are appropriately based on
policy, not on a scientific evaluation of the environmental hazards the country is facing,
but this point should be made more explicit.
The Committee compliments the Agency for publicly identifying goals across the
diverse sets of environmental legislation, and for developing and producing such a
comprehensive and impressive set of goals and milestones. The idea of setting goals
and measuring progress is good and the Agency is to be commended for submitting the
document for review before it is finalized.
There is a general concern, however, that the goals and milestones may be
overly ambitious with respect to the availability of resources and technologies required
to reach them, and may call for a level of Federal interagency, state, and stakeholder
involvement and cooperation that is well beyond what has previously happened with
respect to environmental protection. Nonetheless, it would be hard to claim that any
one of the goals in the document is unworthy, even though the goals share, as with
many such undertakings, a loftiness that may be impossible to attain in a world that
ascribes absolute meaning to words such as "safe."
3.1 Objectives vs. Milestones
Milestones are generally regarded as a series of checkpoints by which progress
towards a goal can be measured. Having only one date for measurement does not
constitute a series. Thus, the milestones might better be called objectives for 2005.
The document would be more valuable if it defined a trajectory of intermediate
milestones by which progress could be assessed.
Another comment that bears on the ability of the goals to accomplish the
scientifically-based objectives of the Goals document is that there are no intermediate-
level options presented. Further, there is no sense of what steps the Agency will take
(e.g., budget allocations) to maintain progress on each of the milestones. What
happens if a milestone is not met? How are priorities to be set across milestones if it
becomes apparent that all will not be achieved given the resources available for
implementation? For example, what happens if it is clear that the milestone of a net
increase of 100,000 acres of wetlands by the year 2005 cannot be met unless
considerably more funding is made available for acquisitions of private lands or for
restoration activities? How would allocation of additional resources to meet this goal
impinge on the ability to achieve other goals?
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3.2 Clarity of Science
In some cases comparisons have been made to early time periods, for instance
the 1980s, as the baseline. While the Committee recognizes that often these are the
only data available, it would be helpful if the Agency stated that fact. Use of old data as
a comparison may be perceived as a device which allows the Agency to be well on the
way to achieving the goals at the time they are set. In such cases, the extended time
periods, as great as decades, could witness major environmental changes.
Where measures of effectiveness and achievement are presented, care needs to
be taken to define them clearly. For instance, in Goal 6, Milestone 5, the measure of
success is the increased use of biopesticides. However, without parallel measures of
health outcomes, especially monitoring of the incidence of infectious diseases and
allergies, the goal and milestone do not provide assurance that we will achieve better
environmental results or quality of life. When tracking progress and measuring success,
care should be taken to include measures of outcome or of processes that have been
shown to achieve the desired result.
3.3 EPA's Role
The role of EPA compared to that of other Federal and nonfederal entities needs
to be put into context with respect to the overall process needed to achieve these goals,
and it should be made more explicit that the goals rely on cooperation with non-Federal
entities.
If the Goals document is truly a document for the nation, and not just for the EPA,
then the Federal government as a whole needs a strategy for how to proceed. The next
iteration of the Goals document should identify the coordination needed with other
Federal, and perhaps state and local entities. The document could then specify the
Agency's goals versus the nation's goals. It might be important for the EPA to add a
goal which indicated the need for the Agency to act to coordinate environmental efforts
across agencies. For example, for habitat-related milestones, there are at least two
approaches: prevent further degradation of terrestrial ecosystems for the ecosystems
left, and restore damaged ones. The goals are a mix of the two, but most of what needs
to be done does not come under EPA's mandate, so there is a real question about how
realistic they are.
Similarly, the document relies on voluntary actions by Americans. This also
leaves uncertainty in how goals and milestones would be achieved. However, the
Committee does note and support the Agency's intent to inspire voluntary actions.
3.4 Organization
The draft Goals report is structured around program office- or media-specific
issues, but this presents difficulties in recognizing and addressing cross-cutting issues.
7
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One possible reorganization would be to develop a meta-structure, with three main
sections within the Goals document: a) environmental goals relating to human health; b)
environmental goals relating to ecological health; and c) environmental goals relating to
quality of life issues. For example, the ecological section would have as its primary
focus the preservation, restoration, and sustainability of a diverse set of ecological
systems, including various types of terrestrial, wetland, freshwater, estuarine, and
marine ecosystems.
With respect to ecological health, the current draft only contains a sustainability
goal for "healthy terrestrial ecosystems". However, the sustainability of aquatic and
marine ecological systems are just as important. Under the proposed structure, rather
than focusing on "clean waters", the focus, ecologically, would be on healthy aquatic
and marine ecological systems, and the separate issues of clean drinking water would
be addressed under the section'relating to human health goals. Such a reorganization
might result in some redundancy, but this could be mitigated by showing a matrix of
goals cutting across human health, ecological, and quality of life milestones. One major
advantage of this structure would be the identification of missing pieces; again the
example is the sustainability of ecological systems other than just terrestrial systems.
3.5 Approach
The document reflects EPA's desire to communicate effectively with the
American public on an easy-to-relate basis, through a set of challenges and a report
card. In general, the milestones are reasonable surrogates for the real environmental
improvements that are truly desired by society, and they are defined by quantitative
information that can be measured with reasonable accuracy (or at least precision).
However, there is also concern that some of the milestones identified in this document
lack sufficient specificity to be judged as to their attainability by the year 2005.
The milestones presented contain two types of measures, process (how are you
going to do something) and outcome (how does what you did impact the health of
humans or ecosystems). Process measures are here meant to include all those
measures that represent administrative or policy implementation activities, such as the
number of permits issued, the number of sites cleaned up, or the number of states given
regulatory authority. These are distinct from outcome measures, which report exposure
to and/or effects in the at-risk human or ecological systems. Examples of outcome
measures include blood lead levels (human exposure outcome), incidence rates of lung
cancer (health effects outcome), pH levels in acid-sensitive lakes (ecological exposure
outcome), and the number of hectares of wetlands restored (ecological effects
outcome).
These two types of performance measures are intertwined in the document.
The Committee acknowledges that both are appropriate and necessary. For example,
sometimes the process measures are all that can be monitored until sufficient time has
passed for effects to have occurred; in other cases, effects measures are inappropriate
8
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because of signal-to-noise issues; and in still other cases, effects measures are a
preferred way to demonstrate the actual efficacy of the environmental decision. Thus,
while outcome measures may be preferable to determine that the controls are
producing the anticipated outcome, monitoring of the control process may be the only
practical way of assuring the continued effectiveness of controls.
The key issue to note is the continuing need to measure what one really wants to
achieve - improved health and ecological outcomes. Thus, EPA is often forced to use
processes or intermediate or surrogate outcomes as success measures. However, the
direct outcome measures of exposure reduction or reduction in health/ecological
outcomes, if available, are preferable to the indirect process ones. The Committee
recommends that the Goals document include a discussion of these types of
performance measures and identify each measure proposed for each milestone as
being in one category or the other.
The document would also be strengthened if it more clearly recognized that
environmental protection is but one of our goals, and placed greater emphasis on
restoration of polluted environments.
3.6 Ranking Goals and Setting Priorities
Although the Goals Document explicitly states that it does not attempt to rank the
goals and milestones in order of importance, it leaves open the question of how
priorities for advancing toward the goals will be set. Some discussion of the criteria that
might be used would be desirable.
The Science Advisory Board's 1990 report Reducing Risk (SAB, 1990) provides
advice to the EPA and other Federal agencies about the use of science to help set
priorities. Thus, the Committee recommends that the Agency use the methodologies
and other recommendations from this report as a central component of the process to
set priorities across milestones and goals. Additional insights have also been provided
by the Congressionally mandated review of the costs and benefits of the Clean Air Act,
1970-1990, and the review offered on it by the Advisory Council on Clean Air Act
Compliance (SAB, 1997).
Furthermore, the SAB's Integrated Risk Project (IRP) will be finished this fall.
When it becomes available the Agency should find certain recommendations useful for
the Goals project. Perhaps the IRP's Risk Reduction Options Subcommittee (RROS)
methodology and recommendations could be of use in thinking about setting priorities.
Moreover, when the IRP report becomes available, the Agency should consider adding
milestones to the Goals document that reflect the high and medium categories of
environmental risks as characterized by the IRP's Ecological Risk Subcommittee (ERS).
Some of the higher risk stressors are explicitly listed in the Goals document with
milestones, but several are not. In the meantime, the Reducing Risk Report provides
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guidance on the more important ecological risks that should be addressed by Agency
goals.
3.7 Research Needs to Meet Goals
Reaching the stated environment goals and meeting the milestone objectives will
require the full employment of known technologies and the efforts of all governmental
agencies, industries, academia and the public-at-large. But in many cases it will also
require major research investments, both to improve existing technologies, as well as to
develop new approaches to old problems.
While the goals are theoretically achievable, as well as highly desirable, the
scientific bases and data to reach these goals in full, and to evaluate significant
progress towards the goals, are considered insufficient. Each goal, and each milestone
within the goals, requires research for a better understanding about the effects of
environmental stressors on human health and the environment.
Examples of critical needs include an improved basis for identifying appropriate
measures of human health, ecological health, and quality-of-life so that we can better
evaluate progress towards meeting environmental goals. Another example is an
improved capability to characterize environmental exposures and risks, understand how
most effectively to allocate resources across risk-reduction measures, and how to
anticipate risks of the future. Also, effective databases are needed to provide the
time-trends of the endpoints that relate to the environmental milestones and goals.
Thus, while it is clear that the purpose of the Goals document is not to lay out a
research agenda, a scientific understanding goal is necessary to ensure that scientific
information and data are sufficient to sustain an approach and validate progress.
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4. CONCLUSIONS AND RECOMMENDATIONS
The 12 Goals together cover most major issues related to human health and the
environment. Overall, the Committee found the document to be well written and
instructive. The "generality" of the presentation is appropriate and by publicly identifying
goals across the diverse sets of environmental legislation, the Agency should stimulate
public discussion of what Americans are seeking to accomplish in environmental
protection and what they are willing to pay for such protection.
There is a general concern that the goals and milestones may be overly
ambitious with respect to the availability of resources and technologies required to
reach them, and because they call for a level of Federal interagency, state, and
stakeholder involvement and cooperation that is well beyond what has previously
occurred for environmental protection. Nonetheless, it would be hard to claim that any
one of the goals in the document is unworthy.
There is also concern that the goals and milestones identified in this document
lack sufficient specificity to be judged as to their attainability by the year 2005. In
.addition, there are no intermediate-level options presented, and there is no sense of
what steps the Agency will take (e.g., budget) to maintain progress on each of the
milestones. How are priorities to be set across milestones if it becomes apparent that
all will not be achieved given the resources available for implementation?
The Committee notes several key overarching themes that EPA developed in the
document and suggests that they be more consistently applied:
a) Link individual goals and their associated strategies to each other to
reinforce the multiple benefits of many proposed actions.
b) Promote pollution prevention as the major path to long-term sustainability.
c) Develop monetary and non-monetary incentives for individuals and groups
in the public and private sectors to pursue waste reduction/pollution
prevention activities.
d) Design and implement communication strategies that bring information on
individual goals and on the relationships among goals, as well as the
interrelationships among key strategies, to the public and decision
makers.
e) Set up and implement a process for tracking indicators that help determine
progress toward the goals and for tracking the emergence of new factors
that could affect that progress.
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f) Reassess the progress to the goals individually and as a whole frequently,
and modify specific strategies as needed.
The Committee recommends establishing a broad science goal. Sound science,
especially when communicated effectively, leads to wiser decision-making. Reaching
the stated environment goals and meeting the milestone objectives will require the full
employment of known technologies and the efforts of all governmental agencies,
industries, academia and the public-at-large. But in many cases it will also require
major research investments, both to improve existing technologies, as well as to
develop new approaches to old problems. While the goals are theoretically achievable
as well as highly desirable, the scientific bases and data to reach these goals in full and
to evaluate significant progress towards the goals are considered insufficient. Thus,
each goal, and each milestone within the goals, requires research for a better
understanding about the effects of environmental stressors on human health and the
environment.
The Committee commends the Agency on the goal to empower people with
information and education and expanding their right to know. However, in elaborating
the specifics of this general goal, more attention needs to be given to the objective of
improving public understanding of the scientific bases of environmental decision-making
though education and outreach. Thus, the committee believes that the Goals document
also needs a specific goal for environmental education to develop an improved set of
institutions and mechanisms that will assure that the nation will improve its fundamental
scientific understanding that it will need to make future environmental decisions.
The "Reducing Risk" report and other comparative risk studies have indicated the
highest risks to ecological systems are from physical stressors such as habitat alteration
and hydrologic modifications. The Goals document should be consistent with this
increased recognition of the importance of non-chemical stressors in the environment.
Many wetlands and other freshwater systems have been affected by or are at greater
risk from these stressors than by exposures to chemical pollution.
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References
EPA. 1987. Unfinished Business: A Comparative Assessment of Environmental
Problems. U.S. Environmental Protection Agency, Washington, D.C.
EPA. 1996. Environmental Goals for America: With Milestones for 2005. Draft for Full
Government Review. U.S. Environmental Protection Agency, Washington, D.C.
SAB. 1990. Reducing Risk: Setting Priorities and Strategies for Environmental
Protection. EPA-SAB-EC-90-021. U.S. Environmental Protection Agency,
Science Advisory Board, Washington, D.C. September, 1990.
SAB. 1997. Closure Letter on Clean Air Act (CAA) Section 812 Retrospective Study.
EPA-SAB-COUNCIL-LTR-97-008. U.S. Environmental Protection Agency,
Science Advisory Board, Washington, D.C. July, 1997.
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APPENDIX A. FINDINGS ON LONG RANGE GOALS & MILESTONES
In this Appendix, the goals and milestones are listed and then followed by the
Subcommittee's comments on each.
A.1 GoaM-Clean Air
Every American city and community will be free of air pollutants at levels
that cause significant risk of cancer or respiratory and other health
problems. The air will be clearer in many areas, and life in damaged forests
and polluted waters will rebound as acid rain, ozone, and hazardous air
pollutants are reduced
The language in the first paragraph of the "Challenge" section of the discussion
of this goal needs modification to ensure that the reader will not interpret the impacts
noted as being substantially larger than the best estimates indicate they are.
On p. 11, under the subheading "Carbon monoxide" delete "heart damage" and
insert "worsens exercise-induced angina".
On p. 11, under subheading "Nitrogen dioxide" delete the statement "Causes
lung tissue damage and increases in respiratory illness and also". At current ambient
concentrations in the U.S. the statement is misleading (EPA, 1995).
On p. 12, line 3, it is not clear what is meant by the "residual harmful effects" of
these pollutants. Does this mean cumulative effects that are not important with any
given occurrence, but that may become important in a cumulative manner over time?
p. 12, line 4: The statement that "there is typically no minimum level we can call
safe" is confusing. It appears that EPA is trying to distinguish toxic air pollutants from
the criteria pollutants on this basis. There are two problems with this approach. First,
we are increasingly faced with difficulty in calling any level of exposure to criteria
pollutants "safe" as we identify responses closer and closer to background levels.
Second, the difficulty in calling levels of many toxic air pollutants "safe" is more an
outcome of our approach to the risk assessment of carcinogens than it is an outcome of
our knowledge of the pollutant. The definition of "safety" is a policy call. For many of
these materials, a linear, no threshold risk model is assumed, making it impossible to
declare a "safe" level of exposure. In such a case, the concern over safety is not based
on knowledge of the actual effects of the pollutant, but rather with the mathematics of
the risk assessment. Overall, it doesn't seem useful to appear to draw a contrast
between criteria pollutants and toxic air pollutants using this statement.
On p. 12, line 4 and throughout the document replace "unhealthy" with
"unhealthful". The distinction is that "healthy" and "unhealthy" are more appropriately
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used to describe a living organism (or an institution); "healthful" and "unhealthful" are
more appropriately used to describe something that affects health.
In paragraph 3, line 2, regarding "air toxics", the term is in wide use in air
pollution jargon, but "toxics" is not properly a noun. Replace this with "toxic air
pollutants" here and throughout the document.
p. 12, inset box: The approach of emissions trading needs to be better described.
Unless one already knows what this means, and how it works (which certainly excludes
most members of the public), one cannot understand the text.
A.1.1 Milestone 1
By 2005, the number of cities where air quality does not meet national
standards will be reduced more than 96 percent from 1995 levels, thereby
making the air safer to breathe for an additional 85 million Americans in
164 metropolitan areas.
In the wording of the milestone replace "will" with "is required to". It is unlikely
that this much progress will be made on urban ozone by 2005.
Under "Past Trends", line 3. "Particulates" like "toxics" is not properly a noun.
Replace it with "particles". Rewrite the last sentence to read: "The air in the six
remaining areas is required to improve significantly by 2005 and to meet the standards
by 2010."
p. 14: The issue of changing standards needs to be dealt with more thoroughly.
A goal of reducing the number of noncompliant "cities" (presumably statistical areas)
96% from the 1995 level is stated, but it is not clear if that is still the goal after the ozone
and PM standards change. These standards for the two National Ambient Air Quality
Standards (NAAQS) pollutants, and the others that will follow, will have a big impact on
compliance. A clearer statement is needed.
P. 14, "tracking results": The results are to be tracked as the number of areas out
of compliance. While that's one reasonable metric, it isn't a very strong one. It would
be better to track the number of people living in areas out of compliance, since the
different areas have orders of magnitude differences in population. Moreover, it would
be interesting to track the annual (or other relevant measure of) pollutant levels as
percentages of the standard. Much progress might justifiably be identified in reducing
pollution from present levels, even though the reductions were not sufficiently great to
allow the standard to be reached. In other words, more progress might be made in
protecting human health by reducing ozone, etc. in Los Angeles, with a huge
population, but not reducing it enough to meet the standard, than by meeting the
standard in a dozen smaller population areas.
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Air Milestone 1 (p. 14) and 2 (p. 15) involve too much precision for a goal to be
achieved in 9 years. "More than 96%" and "will fall 68%" should read "More than 95%"
and "will fall by close to 70 %".
Because of the many uncertainties in the proposed ozone strategies (N(VHC
combined, etc.), about which PM to control, EPA should be recommending effective
research as a prerequisite to achieving the goal.
A. 1.2 Milestone 2
By 2005, emissions of unhealthy smog-causing volatile organic
compounds will fall 68 percent per mile per car, compared to 1990 levels.
Change the wording of the milestone itself by replacing "unhealthy" with
"unhealthful" and inserting "for new cars" after "compounds".
Rewrite to make the statements apply to new car emissions. Under "Past
Trends" on line 1 insert "new" after "average". Under "Tracking Results" on line 3 insert
"new" after "average" and on line 4 insert "new" after "typical".
Mobile source emission models under predict VOC emissions from in-use fleets
in most areas of the country where appropriate studies have been conducted (e.g., the
Los Angeles basin, the Lake Michigan area, Houston) (Croes, 1996; Korc et al., 1995).
EPA doesn't have the "police power" necessary to gather a representative sample of
"super emitters" for dynamometer testing to model emissions. With this limitation, the
best that can be done is to tell the major success story about reductions in new car
VOC emissions.
A.1.3 Milestone 3
By 2005, increases in miles driven by U.S. vehicles will not interfere with
attainment or maintenance of air or water quality standards, nor will
increases in driving interfere with fulfillment of the U.S. commitment to
reduce greenhouse gas emissions.
The first part of the milestone cannot be measured reliably by any currently
available data, but the CO2 emissions can be calculated from total motor fuel sales.
This writeup fails to mention recent backsliding from the previously planned fleet fuel
economy standards or the trend of increased purchases of light trucks (sports utility
vehicles) with higher fuel use.
In discussing this milestone, no attention is given to development of alternate
fuels or alternate means of transportation. Moreover, here and elsewhere, there is no
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mention of the contributions of the DOE programs to develop cleaner heavy-duty
engines, alternate fuels, etc.
A.1.4 Milestone 4
By 2005, all 174 categories of major industrial facilities will meet toxic air
emission standards.
Under "Past Trends" insert "directly through national requirements established
under the Clean Air Act" after "controlled" on line 3.
The big successes seem to be missed (including reductions in toxic volatile
organic compound emissions that have resulted from ozone control programs and major
voluntary reductions made by industry, in part, because of the SARA Title III Annual
Toxic Release Inventory). These should be included in the "Tracking Results" portion of
this milestone.
Figure M.4. Insert "Must" before "meet" in the title and insert "requirements" after
"have" in the legend. Replace "in" with "by" before "2005" in the legend.
A.1.5 Milestone 5
By 2005, sulfur dioxide emissions, a primary cause of acid rain, will be
reduced by nearly 10 million tons from 1980 levels.
In the last line of the second paragraph, insert "cost" after "most" and add a note
about the originally projected cost per ton of sulfur dioxide reduced (about $1,500 per
ton) and the current market price for S02 reduction credits (roughly $150 per ton) (GAO,
1994). The economic success of the program is remarkable and is worth noting.
Under "Past Trends" line 3, replace "called for a" with "require".
If possible add an estimate of the timing and amount of NOX reductions.
A.1.6 Milestone 6
By 2005, annual average visibility in the eastern United States will improve
10 to 30 percent from 1995 levels.
The technical basis for this prediction is not clear. Is it the S02 and NOX
reductions required by Title IV of the 1990 Clean Air Act Amendments. The milestone is
reliably measured.
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A.2 Goal 2 - Clean Waters
All of America's rivers, lakes, and coastal waters will support healthy
communities of fish, plants, and other aquatic life and uses such as
fishing, swimming, and drinking water supply for people. Wetlands will be
protected and rehabilitated to provide wildlife habitat, reduce floods, and
improve water quality. Ground waters will be cleaner for drinking and
other beneficial uses.
The goal is for all of America's freshwater systems to support healthy
communities. This seems unrealistic, as many freshwater systems have been
converted to uses that simply are incompatible with this goal. Moreover, in the
ecosystem management concept, the decision is made explicitly about what ecological
systems have to be "sacrificed" in order to support the needs of society. For example,
waterways in urban areas that are heavily utilized for transportation and other societal
uses will not recover to support "healthy communities offish, plants, and other aquatic
life and uses, such as fishing, swimming, and drinking water supply for people." That is
not to say there should not be a goal to make all possible freshwater ecosystems as
healthy as possible, but meeting this level of ecological condition for all systems is not
possible, so it should not be listed as the goal.
The goals statement also seems to concentrate on reducing pollution, but many
wetlands and other freshwater systems have been affected by or are at greater risk
from habitat alteration and hydrologic modifications, rather than by pollution. Also, there
was little mention of the need to protect coastal waters extending beyond the near-
shore estuaries.
A.2.1 Milestone 1
By 2005, there will be an annual net increase of at least 100,000 acres of
wetlands, thereby supporting valuable aquatic life, improving water quality,
and moderating the effects of health- and property-damaging floods and
drought.
This is certainly a worthy goal and ecologically defensible because of the
important contribution of wetlands to ecological and societal systems, but it is unclear
how this can be accomplished.
The statement on page 26, 4th line from the bottom is incorrect. It should be
reworded to read "The USFWS Status and Trends of Wetlands report is updated every
10 years (Dahl 1990; Dahl and Johnson 1991)." The USFWS National Wetlands
Inventory is a nationwide mapping effort, distinct from these Status and Trends reports,
that was initiated in the late 1970s and has not yet been completed for the entire U.S.
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The milestone proposed for wetlands does not recognize that (1) an increase of
100,000 wetland acres/year will do little to compensate for the 117 million acres of
wetlands that have been lost over the past 200 years, and is a much smaller rate than
that called for by the NRC (see below), and (2) does not address degradation in quality
of the remaining wetlands and the functions they provide.
Recommendations pertaining to restoration of surface waters were quoted from
the NRC's "Restoration of Aquatic Ecosystems" (box on pg. 28), but the same report's
recommendation with regard to wetlands was not quoted. It calls for an increase in
wetland restoration that is 2 orders-of-magnitude higher than that proposed by EPA:
"The committee recommends that inland and coastal wetlands be restored at a rate that
offsets any further loss of wetlands and contributes to an overall gain of 10 million
wetland acres by the year 2010..." (Restoration of Aquatic Ecosystems, p. 12).
In order to achieve this targeted net increase, EPA states it will not examine its
own regulatory programs related to wetlands permit issuance under section 404 of the
Clean Water Act, but rather will depend upon under funded landowner subsidy
programs implemented by the United States Department of Agriculture (USDA) (e.g.,
Wetlands Reserve Program, Conservation Reserve Program). Given that these subsidy
programs have already been in place, it seems naive to expect a reversal in the
continued trends of wetland loss.
Because many wetlands are irretrievably lost, there needs to be a mechanism to
identify those wetlands most likely to be recoverable. Issues of private versus public
ownership are central here, meaning there must be a recognition of the investment
required for acquisition of property as well as for restoration activities.
The discussion about expanding wetlands should mention other long-term
ecological and health concerns. .
A.2.2 Milestone 2
By 2005, 80 percent of the nation's surface waters will support healthy
aquatic communities.
The milestone is good, as is the supporting discussion. However, the Agency
probably has more information available establishing a baseline than is presented. A
greater effort is needed to bring this information together. Part of the success in
achieving the goal will be continued Federal leadership in working with states to identify
waters that do not meet their stated uses and developing state plans to achieve the
water quality or sustainability goals.
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A.2.3 Milestone 3
By 2005, 90 to 98 percent of the nation's fish and shellfish harvest areas
will provide food safe for people and wildlife to eat.
This is a good milestone and the discussion is good too, but there is concern that
it may be too ambitious. Many of the contaminants responsible for unsafe fish and
shellfish are persistent, cycling the globe, and are already banned or heavily regulated,
so improvements in the burdens from these chemicals will be more difficult, and more
time may be needed for natural sequestering to occur and render these contaminants
non-bioavailable.
A.2.4 Milestone 4
By 2005, 95 percent of the nation's surface waters will be safe for
recreation.
The metric for this milestone is ambiguous, because while there are two types of
recreational uses of water defined, only one overall compliance figure is proposed. As
written, it would be possible to meet the milestone by making 95% of the surface waters
safe for secondary contact, but none safe for primary contact.
A.2.5 Milestone 5
By 2005, the number of Americans served by community and rural water
wells containing high concentrations of nitrate in ground water will be
reduced.
This milestone would be strengthened if EPA described the plan for how it will
deal with this issue, which falls under the auspices of both the Clean Water Act and the
Safe Drinking Water Act. The two major options available to reduce the number of
people exposed are to: reduce the nitrate releases identified, and to disallow the use of
water containing high nitrate for human consumptive purposes. Improving a data base
will not help reduce the number of Americans served high nitrate waters.
A.2.6 Milestone 6
By 2005, the annual rate of soil erosion from croplands will be reduced 20
percent from 1992 levels to a total of 948 million tons per year.
Both the milestone and the supporting discussion are good.
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A.2.7 Milestone 7
By 2005, total annual pollutant discharges from key point sources that
threaten public health and aquatic ecosystems will be reduced by 3 billion
pounds.
This milestone is problematic ecologically. Using pounds to measure the
ecological importance of pollutants does not make scientific sense. However, the
milestone would make sense if it were in terms of the percentage reduction of key
pollutants planned.
Using pounds in terms of reducing "toxics loading" to receiving waters also does
not clearly translate to protection of human health. Exposure to bioaccumulative
chemicals is largely indirect, through consumption of fish, not water from the affected
stream. Chemicals that impact drinking water safety are those which are not deposited
in sediments or bioaccumulated in fish. The major focus of the Clean Water Act is the
protection of aquatic ecosystems. This results in an appropriate concern with
bioaccumulative chemicals, e.g. non-polar organics and metals, that in some respects
protects human health, but its importance in protecting the uses of water for drinking
purposes is probably overstated.
This milestone is not consistent with statements in the previous clean water
milestones or the state-of-knowledge concerning pollutants, because it lists the priorities
for pollution reduction by point sources, such as industry, sewer treatment, and
combined sewers, while ignoring earlier statements about the importance of non-point
source contributions to surface water pollution. These non-point sources now rival or
exceed point source loads to surface waters, and this is where the greatest effort will
need to be placed to lessen loading of stressors to surface waters.
Greater emphasis should be placed on potable reuse of wastewater which a
number of communities in the U.S. are considering as a drinking water source because
of population pressures and the resulting shortages of high quality water sources.
Indirect reuse is considered preferable, with some separation in time and space
between the Advanced Wastewater Treatment (AWT) output and the intake to the
drinking water treatment plant. Sometimes this time and space is provided by
groundwater injection wells. Exposures to polar compounds introduced into wastewaters
or produced by wastewater treated and then discharged into a reservoir or stream are
well characterized. A strategy needs to be developed to track these chemical inputs
that are of potential health concern, perhaps as a potential expansion of the Industrial
Pretreatment Program.
On the bottom of page 34, it is unlikely that chlorine, per se, is a water pollutant.
The more probable chlorine containing contaminant is hypochlorous acid, hypochlorite
or chloramine. The discussion in the Goals document needs to be refined.
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Strategy - The discussion of the Strategy for the Clean Waters goal is well done,
but why settle for having only 65% of sewage treatment plants that need secondary
treatment in place by 2005? This is an area where we ought to do more, and the goal
here should be more stringent. However, it is difficult to determine how the Agency will
ensure that secondary treatment is in place in the sewage treatment plants that
currently do not have such levels of treatment unless EPA has sufficient clout to make it
so. Is there legislative authority or other requirements for compliance? If so, please cite
in bullets 1, 3, 4, 5.
The reference to "biological integrity" of types of water should refer to the
biological integrity of types of surface water ecosystems.
A.3 Goal 3 - Healthy Terrestrial Ecosystems
America will safeguard its ecosystems to promote the health and diversity
of natural and human communities and to sustain America's
environmental, social, and economic potential.
The goal here is to promote the health and diversity of natural and human
communities and to sustain America's environmental, social and economic potential.
This is an important goal that explicitly recognizes the critical need for sustainability.
The main comment is that precisely the same goal should be established for freshwater
ecosystems and estuarine/coastal ecosystems, not just terrestrial ecosystems.
The description of the goal is well done, but the discussion of stressors needs
revision. Natural stressors are identified, such as fire, pest outbreaks, and floods but in
fact, these natural stressors often become anthropogenic when humans change the
frequency, distribution, or intensity of natural events. For example, natural ecosystems
are adapted to the natural fire regime, but humans often change the frequency or
intensity of fires, which thus become due to anthropogenic stress. Even the effects from
storms, such as hurricanes, can be significantly affected by humans, such as when
habitat alterations result in the loss of large areas of particular ecosystem types,
resulting in diminished capacity to recover for the remaining systems of that class.
The discussion mentions an optimal balance between supporting diverse
populations and maintaining sustainable uses on a time frame of decades to centuries,
but longer time frames and inter-generational societal values are also important to the
concept of sustainability. The reference to the National Biological Survey should be
updated to its latest name (i.e., Biological Resources Division of the U.S. Geological
Survey).
The Clean Air Act should be added to the list of statutes included in the
Responsibilities section (p.42) and should be added to the discussion in the first two
paragraphs in that section.
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The first paragraph under the "Challenge" section for this Goal needs to include
other human values, such as aesthetic and religious benefits that people gain from the
ecosystems, as well as recreational benefits.
Second paragraph - (1) Outbreaks of pest species needs to be mentioned
instead of just "pest species." (2) The statement assumes "ecosystem recovery" occurs
in all cases. However, some systems are disturbance adapted. That is, the loss of the
disturbance (its characteristic frequency and/or intensity) would compromise or cause
the loss of that ecosystem (e.g., riparian systems are adapted to floods). (3) Human
disturbances won't necessarily cause an inability of a system to recover. There might
be a shift in dominance of particular successional types (e.g., more early successional
than late successional communities).
P. 42, under section on Responsibilities, first paragraph - This section needs to
mention lands owned by the Department of Defense, since about 80% of the rare
species in the United States occur on these lands (Goodman, 1996; Boice, 1997). Also,
it seems that Bureau of Land Management, Tribal, and other agency lands should be
mentioned in this section. If some Federal ownerships posing problems are identified,
then most or all of them that cause problems should be. These statutes could be listed
in a table like is done on P. 142.
Last paragraph - Protecting "ecosystems and wildlife" is redundant; just say
"ecosystems" or "ecosystems and their wildlife components." Also, what are the
economic incentives directed toward? Please note that tradeoffs are mentioned under
the first milestone and should be discussed earlier in the chapter and in the entire report
as well.
Third paragraph - "Integrity" is an odd word to use here. Also, replace "support"
with "provide long-term support of in the third line.
A.3.1 Milestone 1
By 2005, the loss of ecosystem types considered critically endangered,
endangered, or threatened will be eliminated.
This is a worthy milestone, but focusing only on those ecosystems that are on the
critical list may mean ignoring better opportunities for sustainability that less critically
endangered ecosystems may offer. The key should be to focus on ecosystem
management ("community-based protection"). The driver should be whatever
ecosystems in the region being managed require improvement in their condition to
achieve sustainability, rather than only those in critical condition; otherwise, excessive
resources may be invested with lower probability of success and less overall
improvement of ecological condition. So this milestone should become a more
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landscape-oriented goal, focusing on sustaining the spatial distribution of ecosystems of
specified levels of ecological condition.
Figure 1 - The regional boundaries are not'clear.
p. 45, Lines 2-3 - These statements imply that there is a difference between old
growth forests and virgin eastern deciduous forests. Since virgin eastern deciduous
forests are old growth forests, reference to them can be deleted in this sentence. Also,
in the discussion of tracking, the Department of Defense needs to be included.
A.3.2 Milestone 2
By 2005, the populations of endangered, threatened, rare, and declining
species of native terrestrial animals and plants will be stabilized or
increased.
This is indeed a critical first step in sustaining ecological systems, but if the focus
is merely on endangered species rather than on the habitats and ecosystem attributes
needed to protect those species, the approach is headed for failure. Thus, this ,
milestone needs to be more consistent with milestone 1.
P. 46, first paragraph - Please add a discussion on plants. Currently, the
paragraph only mentions wildlife; yet, plants are 54% of the federally listed and
endangered species by taxonomic groups (Figure 2). The dictionary definition of
"wildlife" includes plants, but throughout this document EPA does not include plants in
the definition.
Third paragraph - Eliminate the first sentence altogether, because there are
cases where the statement is clearly not true. For example, the red cockaded
woodpecker has 25+ species depending upon it, and the elimination of this threatened
species would have dramatic effects upon the biodiversity of the long leaf pine forests
(Dennis, 1971).
Figure 3 - The title says by region, but the data are by state.
A.3.3 Milestone 3
By 2005, ecosystem conditions and functions will be restored to ultimately
provide adequate amounts of habitat with the necessary size, mixture, and
quality to sustain native animals and plants in all regions.
This is a worthy milestone, but doing it for all systems seems unrealistic. Also,
this milestone confuses landscape issues (e.g., the distribution of ecosystems) with the
condition of ecosystems. It is better to focus on the structure and function of
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ecosystems with more of a within-ecosystem perspective. For example, other
ecological values are important beyond what is mentioned in the first paragraph (e.g.,
aesthetics, recreation, religious values). The first paragraph is too narrow and here, as
well as elsewhere, only wildlife are discussed. Also, while a few agencies are
mentioned, the Department of Defense is not, yet about 80% of the rare species occur
on DOD lands (Goodman, 1996; Boice, 1997). This is a big omission.
Strategy — The references should add the Interagency Ecosystem Management
Team report. There is a sideline box on costs, but a comparable sidebar on benefits is
also needed. Finally, while there is a statement that money is more effectively spent if
habitats are protected before the species are driven to extinction, the discussion just
focuses on user fees; there are many other valuation factors than just user fees that
should be discussed here.
P. 49 - The first statement is not necessarily true. What does representative
mean? What are the sizes and distributions of these ecosystems? Are metapopulation
dynamics being considered? The second sentence might also be contested. There are
likely to be tradeoffs in improving the quality, function, and values of ecosystems. The
values of ecosystems need to be defined. Most people think of values as being human-
related, rather than system-related. There are cases where these attributes might
change, but some people would say that the human community had suffered.
Second paragraph - The first sentence is confusing. Is it referring to landscape
properties? M3 focuses on ecosystems. Also, it is not clear why vegetation restoration
and land management are both mentioned, because restoration is a particular type of
land management.
Past Trends - First paragraph - Fragmentation is mentioned as a category here.
Can EPA provide references for the percent declines in the tropical migrants?
Tracking Results - Line 3 - "Ecosystems functions, area, and quality" are strange
combinations; what is the definition of quality? What about Department of Defense
activities?
P. 51 - Include in references the 1995 report by the Interagency Ecosystems
Management Task Forest (Christiansen et al., 1996).
Improve scientific understanding, monitoring data, and analytical tools - This
paragraph only makes recommendations for improving monetary and data management
systems. Yet, there also exists a need for improved analysis tools that focus on
ecosystems and landscape properties and that integrate across socioeconomic and
ecological sectors. These tools could allow tradeoffs between decision making options
and let one see the implications of the various options.
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P. 51 - Improved Land Use Decisions - Second sentence - Add evaluation of
the long-term environmental impacts of land use decisions to this discussion. Also
include not just economic forces, but also socioeconomic and political forces that drive
land use decisions.
Regarding "Public-Private Funding for Habitat and Wildlife Conservation", does
the reference to "a large outdoor industry" refer to one single company or the host of
industries? This section seems to just target "wildlife" yet, it is important to think about
habitat for wildlife and other considerations. A broader focus is needed here - what
about other recreational, aesthetic, and religious values?
Overall, confusion surrounds the mix between Figure M1 and Figure M3. M1
seems to refer to the loss of ecosystem types only. This approach means that if a few
museum specimen examples of a type are maintained, then the metric for retaining the
ecosystems types would still be valid. It seems that M3 is trying to pick up some of
these valuable characteristics of ecosystems; yet, it fails because it only uses the word
"ecosystem". The concept of landscapes needs to come into play. M3 also refers to the
term "ecosystem conditions and functions". The traditional words used by ecologists
are "ecosystem structure and functions."
What is referred to in terms of "conditions" here. Figure M1 should refer to a
discussion of the preservation of the appropriate landscape distribution of ecosystem
types, and some of the words under M3 that refer to the area and distribution should be
moved to this section. Then, M3 could just refer to the structure and functions of
ecosystems and be more within an ecosystem perspective. It is the area of ecosystem
types and the spatial distributions across the landscape as well as their "integrity" that
must be considered in M1. This would be a more natural fallout into the traditional
hierarchy that is used: M1 would refer to landscapes, M2 would refer to populations,
and M3 would refer to ecosystems. Therefore, a reordering of these goals by either
going from the smallest to the largest or vice versa, might be more appropriate. It would
make more sense, however, to start with the landscape that is given - M1, M2, then M3,
in order of presentation.
A.4 Goal 4 - Safe Drinking Water
Every American public water system will provide water that is consistently
safe to drink.
Three of the four milestones deal with source water protection which comes
under the purview of the Clean Water Act as well as the Safe Drinking Water Act
(SDWA). It would be useful if reference were made to the provisions of both as well as
to how EPA plans to coordinate its efforts across these provisions.
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In addition, intensive efforts are underway at EPA, and other Federal agencies,
to understand and control the risks posed by microbes and disinfection by products in
drinking water. The Goals document would be strengthened if greater emphasis were
placed on the outcomes of these efforts. This could be accomplished through a
separate milestone or in the discussion for this Goal.
A. 4.1 Milestone 1
By 2005, the population served by community water systems in violation of
health-based requirements will be reduced from 19 to 5 percent.
This milestone is laudable, but it should be noted that the increase in "violations"
for 1992, noted on figure M.1, were created by the filtration rules that went into effect
just then. Because the 1996 Safe Drinking Water Act amendments provide for the use
of loans through the State Revolving Fund (SRF) to help communities comply with new
regulations, a more objective and useful measure might be to determine how and to
what extent the SRF accelerated the process of compliance with the new regulations.
A.4.2 Milestone 2
By 2005, every person served by a public water system that draws from an
inadequately protected river, lake, or reservoir will receive drinking water
that is adequately filtered.
This milestone provides a different metric than does milestone 1, but it strives for
essentially the same endpoint, protection of public health through adequate treatment of
drinking water. Thus, milestones 1 and 2 could be combined.
A.4.3 Milestone 3
By 2005, 90 percent of the nation's river and stream miles and lake and
reservoir acres designated as drinking water supplies will provide water
that is safe to use after conventional treatment.
Caution should be taken to avoid the implying that conventional treatment will
provide water that is "safe". For instance, chlorine disinfection does not render
cryptosporidium noninfectious. This milestone would read better if the phrase "in a
relative risk context" were inserted after "safe".
It should also be noted that three Public Health principles guide efforts to insure
drinking water safety: protect the watershed; treat the water; maintain the distribution
system. This milestone focuses on the first principle, to protect the watershed. While
EPA plays an important role in water safety, the Agency doesn't have the authority nor
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resources to do much about watershed protection. Thus, greater emphasis should be
placed on working with other Federal, state and local agencies to reach this milestone.
A.4.4 Milestone 4
By 2005, 60 percent of the population served by community water systems
will receive their water from systems with source water protection
programs in place.
This milestone also focuses on the watershed protection principle. It is a
laudable milestone, especially the call for applying the four elements of a groundwater
protection program to the protection of surface water supplies. Emphasis should be
placed on developing criteria to guide the development of effective source water
protection plans and to evaluate the extent to which they are implemented and succeed.
A.5 Goal 5 - Safe Food
Long-Range Goal: The foods Americans consume will continue to be safe
for all people to eat
Because all the milestones for safe food require manufacturers to commit
additional resources, a strong argument could be made that none will succeed without a
timely and efficient regulatory response from both EPA and FDA. Mention should be
made of the plans for such coordination.
In this section more attention needs to be paid to exposure. Without it, there is
no dose, and without dose there is no potential effect. One of EPA's goals should be
effective exposure reduction.
A. 5.1 Milestone 1
Through 2005, the frequency of illegal pesticide residues in food will
remain at or below the current low level.
The thrust of this milestone is to continue to monitor "illegal" pesticide residues in
food in an effort to have them remain at or below current levels. This is a straight-
forward goal that is adequately addressed in the document. However, the EPA should
seek significant input from the FDA and the USDA. This is noted in the text, but a
stronger statement concerning the need for close coordination might be appropriate.
EPA has several key activities that will be essential to achieving this milestone
and which should be included in it:
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a) Implementation of the Food Quality Protection Act (FQPA) without loss of
tolerances on minor crops because farmers are already very short on
suitable compounds for many pests and because most fruits/vegetables
are considered minor crops
b) Timely registration of new compounds to provide tools to combat
resistance
c) Approval of import tolerances for crops that are imported from countries
with different pest pressures than the U.S.
d) Timely evaluations/approvals of emergency use requests (Section 18)
The graph does not suggest great promise that the goal will be met, and with the
advent of North American Free Trade Agreement (NAFTA) and the General Agreement
on Tariffs and Trade (GATT), we need to express a determination for vigilance in
checking all foreign produced foods. Further, why is the concern focused only on
pesticides? Shouldn't we be just as concerned with the presence of heavy metals in
foreign-grown and processed foods?
A.5.2 Milestone 2
By 2005, there will be a significant reduction in the use of the food
production pesticides that have the highest potential to cause cancer.
This milestone provides an ideal opportunity to interact with the private sector,
and once definitions are clarified, the ability to track results should be straightforward
and reasonable. However, it will be hard to defend in a public forum because it is hard
to distinguish between a probable human carcinogen, a possible human carcinogen and
a substance in the inadequate data/uncertain category. People will see that over 50%
of the pesticides in use have the "potential to cause cancer," and this will be
unacceptable. A "significant reduction" by 2005 is little comfort. Are pesticides really
that bad? Are we talking about significant animal findings that have relevance under
food-use conditions? This section needs extensive revision with updated cancer rating
guidelines and with a meaningful definition of "cancer-causing potential."
From a public health perspective, the issue of safe pesticide use is not solely
limited to their application on food. In fact, such uses may contribute only in small part
to the exposures. The concern is pesticides that accumulate (metals also) during food
preparation (unclean tables), because of food consumption practices, lack of vigilance
in home cleaning and maintenance, and because of cultural differences. It is exposure
to, not just the presence of, pesticides in foods that is of concern. Graph M.3 is too
idealistic.
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Figures M.2a and M.2b would be easier to understand if the pie chart segments
were also identified as B,C,D and E, respectively. It would also help to have a box
insert that briefly gave the criteria for labeling a chemical as a "B" or a "C".
The text should say that a target for 2005 has yet to be established.
This milestone is really a subset of Milestone 3. If risks are below the EPA
definition of "de minimis" (i.e., <1 x 10"6 increased lifetime risk), then there is minimal
potential for causing cancer under the prescribed use patterns and no public health
reason to reduce use. This milestone should be combined with Milestone 3 and
restated as achieving the statutory standard of "reasonable certainty of no harm".
A.5.3 Milestone 3
By 2005, all pesticide residues in food will meet the statutory standard of
"reasonable certainty of no harm."
The Milestone is fine. Tracking results should be accomplished using
FDA/California/USDA monitoring data where those data are available rather than relying
on worst-case field trial data.
This milestone, while simple in title (reasonable certainty of no harm), will require
a myriad of special considerations to implement. These are necessitated by the
requirements of the FQPA. Implementing this "new" legislation will require innovative
thoughts and procedures. It may not be as simple as the "goals" might suggest; it will
assuredly be an evolutionary process. The complexity of this issue needs to be made
more apparent in the document. The plan to reduce estimated exposures that are
greater than 75% of the RfD sounds like a new standard. Is that appropriate or legal? It
might be better to use the 75% value as a flag for closer monitoring to be sure that the
RfD does not become exceeded in time. The EPA may wish to have the scientific
rationale reviewed before including it in this Goals document.
That the percentage of U.S. crop acreage under integrated pest management
(IPM) will go up to 90% is a laudable goal, but it is completely outside of EPA's control.
IPM decisions are made by farmers. A more appropriate goal would be that EPA will
complete timely reviews of submissions for registration and for compounds that are
used in IPM so that farmers will not be prevented from using IPM by a lack of suitable
pesticides. This is a major problem at the present time. EPA could give priority to
submissions for these applications and-could also develop other incentives for
registrants to have pesticides that fill a gap in the IPM arsenal. Another possible activity
would be to identify pest/crop combinations that need additional pesticides to make IPM
approaches more successful.
With respect to increasing the use of safer pesticides, if all compounds reach the
goals established in Milestone 3, "reasonable certainty of no harm", then there is no
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reason to have an additional goal of 75% of safer (reduced risk) pesticides. If this goal
is retained, care must be taken to define reduced risk in a meaningful manner (e.g.,
taking into consideration exposure as well as toxic potential, not just application rates).
Furthermore, if IPM is a critical criterion, then efficacy also ought be considered.
The term "safe" needs to be defined in the context of the statement that by the
year 2005, all "inert" ingredients in registered pesticides will be safe. The process that
EPA will follow to achieve this worthy goal also needs to be defined.
The objective to have better application technology practices has great potential
to reduce exposures to pesticides and to improve efficiency. It should be given greater
emphasis in this document, and registrants should be given greater incentives.for
conducting research on this need and perhaps consideration should be given to
expedited reviews of data.
Communication - The concept of "reasonable certainty of no harm" can be
communicated to the public in an acceptable way. It is a critical concept for the public
who must understand the difference between "reasonable certainty" and "absolute
safety." The public will be accepting of the presence of pesticide residues in their food
under these conditions.
This milestone should be ideal for opportunities to interact with the private sector
about planning and budgeting. Accountability could be improved if the reporting of RfD
exceedances would include the magnitude of exceedance. Emphasis could be placed
on reducing the most severe exceedances, and not just the number of exceedances.
The document could be strengthened by more discussion of the "unknowns" that will
require investigation/consideration with the development of "biologically engineered"
pesticides.
A.6 Goal 6 - Safe Homes, Schools and Workplaces
All Americans will live, learn, and work in safe and healthy environments.
Many of the environmental factors affecting the safety and health of all
Americans are beyond direct influence by EPA, including firearms, drugs, domestic
violence, infectious disease, most allergens, and non-pesticide impacts of diet. EPA's
mission is to ensure that non-occupational exposures to physical and chemical agents
in the environment will not result in unsafe or unhealthy conditions.
A.6.1 Milestone 1
By 2005, the number of young children with high levels of lead in their
blood will be reduced by more than 50 percent compared to the late 1980s.
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This milestone is reasonable considering past trends and on-going programs
directed at reducing or eliminating lead-containing paint from residences, which is
generally accepted as the major primary source of exposure to lead, particularly for
children living in poor urban areas. Importantly, EPA has recognized that African-
American children are a population subgroup at increased risk from exposure as a
result of a combination of economic, social, and demographic factors and, therefore,
should be specifically targeted. The confluence of these same societal factors, however,
exists for other groups, including Hispanic children, Indians, rural poor Caucasians .
While the National Health and Nutritional Evaluation Survey II (NHANES II) only
considered Whites and African-Americans as ethnic-origin categories for the purpose of
selecting a representative sample of the national population, NHANES III included also
Hispanics. Therefore, it is important that these data be considered as soon as they are
available to determine if Hispanics (and/or other ethnic groups) should also be more
specifically targeted.
Besides NHANES data (which obviously has the advantage of being based on a
representative sample of the U.S. population), other sources of information on blood
lead levels in children are available, mainly through state and city health departments
which monitor individuals, particularly children, frequently with federal funding through
programs such as those mentioned on page 88 of the draft document. While these data
are not representative of nation-wide blood lead concentrations, they are the result of
efforts targeted at the sectors of the population most likely to be at increased risk from
exposure and, therefore, would be very useful in conjunction with the NHANES
information to both measure progress towards attaining the milestone and also
determine if it indeed has been realized by the targeted date.
It is important to recognize that a statistically-based, representative sample of the
population may not necessarily capture individuals belonging to very small groups who
are at high risk from exposure because of the specific and unique characteristics of the
group (the term "special populations" is sometimes used for these groups). As leaded-
paint abatement programs increasingly succeed at reducing paint as a source for
exposure to lead, other sources may become more important and should be
considered. The difficulty with local or state blood-Pb data (as with other environmental
data), is its limited availability due to non-standardized methods of record-keeping and
reporting. An effort should be made, perhaps through agencies such as the Department
of Housing and Urban Development (HUD) and the Public Health Service Centers for
Disease Control (CDC), towards standardization, so this information can be put to use.
The children's age targeted by EPA in the Goals document (i.e., 1 to 5 years)
and in the Healthy People 2000 report (i.e. 6 months to 5 years) differ. This difference
should be addressed in the milestone, because it could impact achievement of the
stated goal. By six months, many children start or are already crawling and can be
exposed through mouthing of objects in their environment that they can easily reach. At
a minimum, the document should indicate EPA's basis for the difference on target ages.
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A.6.2 Milestone 2
By 2005, 27 million homes will have been voluntarily tested for radon,
corrective action will have been taken in 1 million homes, and 1.5 million
new homes will have been built with radon-resistant features, resulting in a
25 percent reduction from 1985 levels in the number of Americans exposed
to elevated radon in their homes.
The data sources presented for this milestone contain uncertainty, but they are
the best available.
Figure M.2: Zero values cannot be shown on a log scale. As drawn, the 1985
values can be construed as 100,000. A break in the vertical axis with a true zero below
the break point would be more accurate.
The statement that radon is "the second leading cause of lung cancer" may be
misleading. Many scientists debate the magnitude of the health consequences of
environmental levels of radon, and some argue that they are not dangerous at all.
While the estimate of 500 lung cancer deaths avoided per year is properly
qualified, it is not placed in context. The baseline (14,000 per year) should also be
mentioned. That would allow the reader to understand better whether the goal is
ambitious or not.
A.6.3 Milestone 3
By 2005, children's exposure to environmental tobacco smoke will
decrease through voluntary actions in the home. The proportion of
households in which children 6 and younger are regularly exposed to
smoking will be reduced to 15 percent from over 39 percent in 1986.
This milestone is fine. It can lead to the possibility of reducing acute morbidity or
mortality through empowerment of the general public, but two questions arise. First,
what is EPA's mandated responsibility for indoor air? Second, if there is none, what is
EPA going to do to promote public awareness?
EPA should tie this closely to its efforts to effectively reduce exposure to
particulate matter.
Under "Past Trends" first paragraph, Environmental Tobacco Smoke (ETS),
mention the new Food and Drug Administration rules which will move toward the HHS
targets.
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A.6.4 Milestone 4
By 2005, the number of workers suffering adverse health effects caused by
acute poisoning from pesticides will be reduced significantly from 1992
levels.
This milestone is communicated well. However, the reliance on measures of
success based on data available from the American Association of Poison Control
Centers for case reports on agricultural workers may be insufficient. Given their
responsibility for workers, EPA should refer to the National Institute of Occupational
Safety and Health (NIOSH) and the Department of Agriculture for help with this
milestone. Reference should also be made to the National Institute of Environmental
Health Sciences (NIEHS) which supports academic Center programs (at the University
of Iowa, the University of California at Davis, and Oregon State University) that focus on
such concerns. EPA needs to harness these resources to make progress on this
milestone. Data from these organizations are likely to be more specific than are data
from poison control centers. One concern with poison control centers is that the
number of cases reported by them includes accidental exposure at home. Since
milestone 4 refers directly to workers, EPA should make it clear that the data collected
will be screened to include only work-related cases.
A.6.5 Milestone 5
By 2005, the use of safe agricultural biopesticides will double from 1995
levels.
To the extent that the biopesticides are perceived by the public as more "natural",
there should be excellent acceptance of this milestone and it should be ideal for
opportunities to interact with the private sector. The ability to track results should be
straightforward and reasonable.
However, it is not clear from the evidence presented, or even in concept, that
overall risks to agricultural workers are reduced by replacing some of the chemical
pesticides with biological pesticides. This goal needs a much better justification than
that provided on page 85.
A.6.6 Milestone 6
By 2005, the number of existing industrial high-production-volume
chemicals shown to be used safely in the workplace will nearly triple.
This is a noble goal, but it will be difficult to attain.
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Some in the public may read the milestone as 'of the 3000 to 4000 existing
industrial high-production-volume chemicals, EPA will try to have 1/2 to 2/3 of them
evaluated for safe use by 2005.' Phrased this way, it is not a good goal. The phrase
"shown to be used safely" will imply to the public that the others are likely not being
used safely. To the extent that the real milestone is the preparation of an extensive
document on what is known about the toxicity of these chemicals, then the goal is
probably realistic, and certainly the private sector should be able to contribute markedly
to this. However, how can tallying the evaluations of existing chemicals, as described
here, show that there is safe use? Such an analysis requires extensive input from
OSHA and NIOSH about actual exposures and problems. This milestone needs to
better explain what EPA actually plans to do in its evaluation of industrial high-
production-volume chemicals.
A.6.7 Milestone 7
By 2005, worker protection will be promoted for as many as 10,000 new
chemicals.
The claim that EPA will review 10,000 new chemicals and "establish exposure
limits for all new chemicals that might present an unreasonable risk to workers" isn't
credible. Setting occupational exposure limits is a demanding and time-consuming task
that taxes the talents of highly-skilled and broadly-experienced scientists. EPA staff
resources and/or contract budgets are unlikely to be adequate to meet this goal in any
responsible and useful manner. EPA ought to be cautious about setting a goal whose
implementation would largely be the responsibility of the Occupational Safety and
Health Administration (OSHA).
The National Research Council Report on Toxicity Testing (NRC, 1984)
described the data base on the 70,000 chemicals in commerce. Milestone 7 refers to
10,000 new chemicals being added to a base of 70,000 chemicals between now and
2005. Weren't there new chemicals added between 1984 and now? Are there plans for
reviewing them?
A.7 Goal 7 - Toxic-Free Communities
By relying on pollution prevention, reuse, and recycling in the way we
produce and consume materials, all Americans will live in communities free
of toxic impacts.
Pollution prevention, reuse and recycling certainly offer the most opportunity and
promise for achieving a toxic-free environment. While much progress has been made,
there are more possibilities for achieving even higher reductions in discarding, and
avoiding generation of wastes containing toxic chemicals. This goal provides the
incentives and enticement for everyone to participate in realizing a "toxic-free"
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environment for all Americans. However, the Committee notes that there is no such
thing as a "toxic-free" environment. The Committee also notes that reuse and recycling
do not necessarily reduce exposures to toxic substances.
A.7.1 Milestone 1
By 2005, industrial facilities will reduce by 25 percent (from 1992 levels) the
quantities of the toxic chemicals in waste streams that are released,
disposed of, treated, or combusted for energy recovery. Half of this
reduction will be achieved through pollution prevention practices.
This milestone is set with 1992 as the baseline. Available information on page 97
of the Goals report shows that while there was approximately 6% decrease in toxic
chemical releases between 1992 and 1993, as indicated by TRI data, there has been
very little or no further reduction shown in the TRI data between 1994 and 1995. In
1994, new toxic chemicals were added to the TRI list. In 1997, new industries became
subjected to the TRI reporting system, making it most likely that the reportable
quantities of toxics will increase in the years 1998 and beyond even though there may
have been reductions in the release of that subset of chemicals previously reported.
Pollution prevention can and will help reduce the reportable quantities. However,
manufacturing processes may also have to be modified to achieve the desired
reductions. It is quite likely that in some situations (e.g. coal burning power plants),
opportunities for reducing ash production can only be achieved if there are low-ash
coals available to burn in the utility boilers. Therefore, the 25% reduction may be an
overly lofty milestone to achieve by 2005.
A.7.2 Milestone 2
By 2005, more than 99 percent of new chemicals approved since 1995 will
have been used safely and will not require additional controls.
Both the milestone and the supporting discussions are clear.
A.7.3 Milestone 3
By 2005, the number of existing high-production-volume chemicals shown
to be used safely will nearly triple.
This milestone seems to repeat Milestone 6.6. Further, its relevance to
community exposures seems obscure under this goal, because high-production-volume
chemicals should not, as such, be directly accessible to the general public.
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A.7.4 Milestone 4
By 2005, municipal solid waste will be recovered for recycling or
composting at a rate of 35 percent. Municipal solid waste generation will
be reduced to the 1990 level of 4.3 pounds per person per day, with the
amount of waste combusted or landfilled decreasing to 2.8 pounds per
person per day.
Reducing per capita generation of municipal solid waste to 4.3 pounds per
person per day from 4.4 pounds per person per day in 1994 is not a very challenging
milestone. However, increasing recycling or composting to decrease to 2.8 pounds per
day the amount needing disposal or combustion is an ambitious undertaking. Municipal
solid waste production remains a major source of waste in our society. For clarity, the
first sentence of the milestone should be changed to "By 2005, 35% of municipal solid
waste will be recovered for recycling or composting."
A.7.5 Milestone 5
By 2005, the presence of the most persistent, bioaccumulative, and toxic
constituents in hazardous waste will be reduced by 50 percent from 1991
levels.
This milestone is critical to achieving the toxics-free environmental goal. EPA is
in the process of defining the details for tracking results, providing an opportunity for an
advisory group like the Science Advisory Board to provide scientific advice in finalizing
the list of the most persistent, bioaccumulative and toxic constituents in hazardous
wastes that would be tracked. However, it should be noted that reducing the amount of
each constituent by 50% will not necessarily render the waste nonhazardous.
A.8 Goal 8 - Preventing Accidental Releases
Accidental releases of substances that endanger our communities and the
natural environment will be reduced to as near zero as possible. Those
which do occur will cause only negligible harm to people, animals, and
plants.
The context of the wording in the goal may inadvertently exclude aquatic
organisms such as fish and may also exclude birds. It should be reworded to
specifically include humans, terrestrial and aquatic organisms.
The Strategy section under this goal speaks of "radiological substances" rather
than "radioactive" ones. The latter term is probably better to use consistently.
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A.8.1 Milestone 1
By 2005, there will be 25 percent fewer accidental releases of oil,
chemicals, and radioactive substances than in 1993.
The Committee supports the intent of this milestone, but recommends that EPA
heed the commentary on page D-11 of the draft Goals document, recommending that
the milestone be restated in terms of total quantity of release or at least in releases over
some threshold of size. EPA could go a step further and suggest that the volumes of
releases be weighted by toxicity before calculating the reduction. Otherwise, credit can
be taken for reductions in small releases of low-toxicity materials with little real benefit to
the environment.
Furthermore, although the milestone includes radioactive substances, there is no
suggestion of any intent to measure the number or activity of such releases or any clue
about how or where such data would be obtained With respect to radioactive
substances, unless this milestone can be better explained or at least related to another
federal target (e.g., of the Nuclear Regulatory Commission), the reference to radioactive
substances should be removed. If it is retained, the text should explain whether the 25%
reduction applies individually to oil, hazardous substances, and radioactive substances,
or to all releases combined (whether or not volume and toxicity are considered).
A.8.2 Milestone 2
By 2005, there will be a 50 percent increase over 1993 levels in the number
of industrial facilities in high-risk areas that have either eliminated
hazardous substance inventories or reduced them to minimum levels.
Clarification would help better define the milestone and how it will be tracked.
Clarification is also needed as to whether this Milestone is intended to include facilities
with inventories of radioactive substances (e.g., nuclear power plants and nuclear
medicine facilities)?
A.9 Goal 9 - Safe Waste Management
Wastes produced by every person, business, and unit of government in
America will be stored, treated, and disposed of in ways that prevent harm
to people and other living things.
This goal complements the toxics-free communities goal as well as the
restoration of contaminated sites goal. By emphasizing the value of proper storage,
treatment and disposal of wastes, we will have reduced the need for remediation of
contaminated sites in the future. By recycling, reusing and reducing generation of
wastes, we will have reduced potential for releases to the environment.
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A.9.1 Milestone 1
By 2005, chlorinated dioxin/furan emissions from waste-burning facilities
will be reduced 98 percent from 1994 levels.
This milestone and supporting discussions are good, reflecting the high priority
placed on reducing chlorinated dioxin/furan emissions. However, a 98% reduction may
be overly ambitious. The Agency should verify its estimates since the December 1996
draft document indicated that the figures were approximate and would be finalized later.
A.9.2 Milestone 2
By 2005, emissions of mercury and other harmful pollutants from waste-
burning facilities will be reduced by at least 80 percent from 1994 levels.
The milestone refers to 1994 and an 80% reduction, yet the accompanying
description refers to 1993 and a 90% reduction. These should be made the same for
consistency. Further, it should be noted that waste-burning facilities may be a small
contributor to environmental mercury exposures.
A.9.3 Milestone 3
By 2005, the annual number of confirmed releases from underground
storage tanks will be 80 percent lower than in 1994.
This milestone is well-defined and is consistent with the mature underground
storage tanks regulatory programs at the federal and state levels.
A.9.4 Milestone 4
By 2005, wellhead protection areas and vulnerable ground waters will no
longer receive industrial wastewater discharges from septic systems.
Both the milestone and the supporting discussions are clear.
A.9.5 Milestone 5
By 2005, 10 percent of the amount of spent nuclear fuel, high-level waste,
and transuranic radioactive waste currently stored across the nation will be
disposed of in accordance with EPA disposal standards.
This milestone is extremely modest, and will be achieved if 25% of transuranic
(TRU) waste gets into the Waste Isolation Pilot Project (WIPP), an accomplishment that
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EPA already projects will occur. It also fails to explain whether disposing of 25% by
volume of the TRU waste would eliminate 10% of the risk from all covered wastes.
The DOE report referenced for this milestone provides appropriate data, but
there is probably a more recent edition than the 1992 reference cited.
It may be outside the charge, but the "box" on page 116 on "Low- and High-
level Radioactive Waste" needs to be reviewed, particularly the statement that low-level
wastes are not by-product materials.
This milestone apparently does not apply to low-level mixed waste or to Naturally
Occurring Radioactive Materials (NORM), such as petroleum production pipe scale or
coal ash. NORM waste could well be more of a real environmental problem than the
covered wastes or the wastes at contaminated sites discussed in Goal 10. Continuing
intergovernmental problems in the regulation of the disposal of mixed wastes are also
important to solve. The brief mention of EPA's continuing interest in NORM and low
level wastes at the end of the Strategy section is not sufficient.
A.10 Goal 10 - Restoration of Contaminated Sites
Places in America currently contaminated by hazardous or radioactive
materials will not endanger public health and the natural environment and
will be restored to uses desired by surrounding communities.
This section is very idealistic. Part of the reason for success is that some of the
sites have finally been cleaned after regulatory and legal delays. The Agency should be
pleased with this forward movement. However, many sites require complex remediation
planning, exposure evaluations and land use options. In some cases, national security
or other interests prevent sites from being restored to uses desired by surrounding
communities (e.g., DOE plutonium waste disposal sites may be maintained because
there is no way to treat the wastes and no other place to place them). Flexibility is
needed to obtain creative solutions on clean-up objectives and land use. This will
address prioritization for contaminant removal or "in situ" capsulation or treatment and
to solve the additional problems caused by the persistence of some radioactive wastes.
The first paragraph of "the challenge" states that radioactive wastes are "highly
toxic" and can persist in the environment for "thousands of years." The use of the term
"highly toxic" is meaningless without a statement regarding compared to what and
conditioned on its complement of radionuclides and their concentrations. A safer
statement would be something like "can increase cancer risks for exposed persons."
The persistence of radionuclides is highly variable, but they can persist for billions of
years. The metals in hazardous wastes are infinitely persistent. The intent of this whole
sentence should be revisited and the sentence revised.
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Although the studies cited in "The Challenge" on page 126 do not concern
radioactive substances, the strength and causality of the associations reported seem
questionable. They paint a picture of a severe national problem that does not conform
with previous SAB ratings of Superfund sites among environmental issues. While the
SAB could be wrong, the Agency needs to be sure about the message it is trying to
convey with these bullets and the following text.
A. 10.1 Milestone 1
By 2005, long-term health threats will be eliminated and cleanup will be
completed at 95 percent of the 1,212 non-federal facility contaminated sites
on the 1995 Superfund National Priorities List.
This is a good milestone, and it provides an ideal opportunity to interact with the
private sector. The ability to track results should be straightforward and reasonable.
A.10.2 Milestone 2
By 2005, immediate health threats will be eliminated and long-term cleanup
will be underway at 85 percent of the estimated 3,200 Superfund sites (NPL
and non-NPL) expected to require cleanup.
This milestone is more difficult to understand than the one before. Will the
public understand "immediate health threats," or are there alternative words that will
give the same message? As with the previous milestone, this milestone should be ideal
for opportunities to interact with the private sector, and the ability to track results should
be straightforward and reasonable.
A.10.3 Milestone 3
By 2005, at least 10 percent of contaminated federal lands currently on the
National Priorities List will be cleaned up.
This milestone mentions radioactive wastes but does not provide sufficient detail.
As with other milestones, this one appears not to include any judgment about the
magnitude of threat posed by various sites, so cleaning up a site with minimal threat can
be counted to be just as much a success as cleaning up a major threat. Note that the
graph is shown in terms of number of sites, not percent, which causes initial confusion
between the 16 sites and the 10% cleanup target. As with Milestone 5 of Goal 9, the
target seems modest in comparison with the 95% target for non-Federal Superfund
Sites in Milestone 1. Why should it be easier to accomplish cleanups at those sites not
clearly the responsibility of the Federal Government?
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A. 10.4 Milestone 4
By 2005, stabilization to prevent the spread of contamination will be under
way or final cleanup completed at 100 percent of operating industrial waste
facilities where people have been exposed to contamination. Seventy-five
percent of all facilities estimated to require cleanup will be stabilized or
cleaned up.
The word "cleaned-up" in the milestone may be subject to different
interpretations. It may be more appropriate to use "will be remediated to achieve the
risk reductions necessary to reuse the sites".
A.10.5 Milestone 5
By 2005, cleanups will be completed at 200,000 leaking underground
storage tank sites—double the 1994 figure.
The milestone and supporting discussions are clear.
A.10.6 Milestone 6
By 2005, radioactivity will be cleaned up or contained at 6 percent of sites
contaminated by radioactivity.
The use of the EPA, DOE and NRC data bases presented seems appropriate for
this milestone.
Once again, the target seems modest in comparison to other targets where the
cost/benefit equation may be similar or less favorable. The cited problem regarding
limited places to store radioactive wastes is true but is not primarily a technical one and
could be resolved with an aggressive program to resolve the sociopolitical roadblocks.
Is the assertion about few cleanup technologies true? Physical removal is always an
option. The fact that it may not be cost-effective is not the same as it not being
available. Shifting the blame to DOE, DOD, and NRC for schedule problems in the
Strategy section does not seem consistent with the idea that the document presents
national goals, not just EPA ones.
A.10.7 Milestone 7
By 2005, point sources of contamination will be controlled in 10 percent of
the watersheds where sediment contamination has currently been
determined to be widespread.
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Protecting and restoring sediments in rivers and lakes are essential elements of
maintaining a healthy aquatic ecosystem. EPA's efforts to modestly control point
sources is a very good beginning.
A.11 Goal 11- Reducing Global and Transboundary Environmental Risks
The United States and other nations will eliminate significant risks to
human health and ecosystems arising from climate change, stratospheric
ozone depletion, and other environmental problems of concern at the
transboundary and global level.
This goal is to eliminate significant risks to human health and ecosystems from
climate change, stratospheric ozone depletion, and other global and transboundary
environmental problems. This seems to be an unrealistic goal, because eliminating
these risks is impossible globally given population growth and economic development in
other parts of the world, even if the developed countries meet the goal. Perhaps
reducing these risks to some specified level would be better.
In the discussion of transboundary pollution on page 161, the work of the
Commission on Environmental Cooperation, and the International Joint Commission of
U.S. and Canada, should be noted. These groups have traditionally addressed many of
the major issues considered in this document from the perspective of developing
strategies and plans for the entire North American Continent.
A.11.1 Milestone 1
By 2005 and beyond, U.S. greenhouse gas emissions will be reduced to
levels consistent with international commitments agreed upon under the
Framework Convention on Climate Change, building on initial efforts under
the Climate Change Action Plan.
This is a worthy milestone and the discussion is fine. However, the description of
data sources to be used for this milestone are quite general and they should be more
specifically identified.
A.11.2 Milestone 2
By 2005, ozone concentrations in the stratosphere will have stopped
declining and will have slowly begun the process of recovery.
This is a worthy milestone and the discussion is fine.
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A. 11.3 Milestone 3
By 2005, atmospheric concentrations of the ozone-depleting substances
CFC-11 and CFC-12 will peak at no more than 332.4 and 572.3 parts per
trillion, respectively.
This is a worthy milestone and the discussion is fine.
A.11.4 Milestone 4
Through 2005, with the exception of HCFCs and very limited "essential
uses," there will be no U.S. production of ozone-depleting substances.
The milestone and supporting discussions are clear.
A.11.5 Milestone 5
By 2005, cooperative efforts between the U.S. and other countries will
restrict the net loss of coral ecosystems to no more than 20 percent of the
world's current reef area.
This discussion states that without ecosystem management 40% of coral reef
areas will be lost by 2005, compared with 10% loss today. This number seems very
high. (It is only 8 years away.) So either this is an overestimate of the expected loss or
the milestone is set too low.
A.11.6 Milestone 6
By 2005, the United States and other countries will reduce the risks to
human health and the environment associated with aldrin, chlordane,
dieldrin, DDT, endrin, heptachlor, toxaphene, hexachlorobenzene, mirex,
PCBs, and chlorinated dioxins and furans.
The goal of this milestone, to reduce the global content of a list of several
chemicals currently banned in the U.S., is reasonable and consistent with current
thinking. However, while a noble goal, there seems little possibility of international
success without incentive to developing countries, lest the U.S. be viewed as interfering
with their right to a prosperous and cheap economy.
This Milestone 6 (p. 151) about reducing global insecticide use should explicitly
mention preserving and improving public health.
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A. 11.7 Milestone 7
By 2005, global air emissions of mercury will be reduced, in part through a
50 percent reduction from 1990 levels in the United States.
There is no formal mechanism or a strategy in place yet to achieve the milestone.
However, the Committee notes the draft Agency Mercury report to Congress as a good
starting point to reach this milestone.
A. 11.8 Milestone 8
By 2005, with U.S. leadership and cooperation many nations will have
phased out the use of lead in gasoline, and worldwide use of lead in
gasoline will be below 1993 levels.
The milestone target is clear, and the uncertainty of its achievement is
recognized. However, a strategy or list of actions should be developed to resolve the
ambiguities.
A.11.9 Milestone 9
By 2005, all seven nonattainment areas along the United States/ Mexico
border area will have met ambient air quality health standards for
particulate matter, sulfur dioxide, carbon monoxide, and ozone during the
preceding 4 years.
This milestone is well presented and raises a good point. For air pollution, in
general, San Diego is not a border community, but for ozone, for example, transport of
pollutants may occasionally have an effect on U.S. air quality.
The obvious deficiencies here are that nothing is said about a) how standards
differ between the US and Mexico (if they do), b) how to achieve the reductions, or c)
whether or not there are any agreements in place between the US and Mexico.
A.11.10 Milestone 10
By 2005, the United States and Canada will reduce sulfur dioxide and
nitrogen oxide emissions that cause acid rain. U.S. sulfur dioxide
emissions will be reduced by nearly 10 million tons and nitrogen oxide
emissions by more than 2 million tons from 1980 levels.
This is a worthy milestone and the discussion is one of the best in exposition.
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A.11.11 Milestone 11
By 2005, existing sources of high-level radioactivity in northwest Russia
with the potential for near-term release into the arctic environment will be
reduced by 25 percent.
This milestone is much more specific in geographic scope than the other
milestones. The text alludes to the vulnerability of Alaska to the release of the
northwestern Russia radionuclides, but does not state what the impacts might be, other
than the perception of radionuclide contamination in sea foods. Although perceptions
are important, and could affect Alaska economically and psychologically, this discussion
needs to be improved to justify placing this milestone at the same level of prominence
as reducing the level of greenhouse gas production. The Committee does not agree
with the comment on page D-14 of the draft Goals document that it should be dropped
as outside EPA's jurisdiction.
A.12 Goal 12 - Empowering People with Information and Education and
Expanding Their Right to know
Americans will be empowered to make informed environmental decisions
and participate in setting local and national priorities.
Strategy - The discussion here is well done
Two premises are listed on page 165;" right to know" and "help citizens make
informed decisions". The second should be broken into two parts so as to yield three
premises. Citizens need to be able to make informed decisions for themselves and for
their communities. They also need to become informed participants in public discourse
about environmental matters at both a local/regional and a national level. Being an
informed participant in public discourse is not quite the same thing as making a
decision. Often it is not clear what should be done, and the decision emerges only after
extended discourse among informed discussants who have different perspectives. This
enabling of discourse which underlies the democratic process deserves to be made
explicit.
The discussion in the second paragraph on page 165 notes the tradeoffs that
arise in environmental decision making when, for example, a decision related to
emissions control in one medium (e.g. air) has impacts on emissions in another medium
(e.g. water). However, the point is much broader and should be discussed in that
broader context. Environmental quality is only one of the desiderata for which our
society strives. There clearly are minimum levels which we simply insist upon as a
matter of right, but at some stage it becomes necessary to consider and balance a
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variety of different social objectives, of which environmental quality is just one. Helping
people to understand the need for such balancing, and the subtle and complex ways in
which our various social objectives are interrelated and affect each other, is a critical
element in the process of helping people to become informed participants in public
discourse.
Chapter 12 is focused, rather single-mindedly, upon getting the data out to
people. This is an important goal. However, making information intelligible and useful
is every bit as important as making it easily accessible. Thus, for example, the
usefulness of the environmental indicators discussed in Milestone 1 (p. 168) will depend
critically on how well the inputs are chosen, combined and explained to users. The
utility of the expanded TRI data that are discussed in Milestone 2 (p. 190) will depend
upon how easy it is to combine them (even qualitatively) with exposure and toxicity
information. The utility of the one-stop data source discussed under Milestone 4 (p.
171) would be increased considerably if clear, easily understood information on "data
pedigree" were included with the raw numbers to give the reader some idea of how
good or bad the numbers are and how they should and should not be used.
The discussion of education (p. 166 and 172) talks about helping people get to
the point that they can "analyze complex environmental issues". While one could
certainly argue that understanding is implicit in analysis, the document should talk
explicitly about helping people to understand complex environmental issues.
A.12.1 Milestone 1
By 2005, current, accurate, and easily accessible information on
environmental conditions will be available for at least 75 of the largest
metropolitan areas.
The choice of measures one adopts to report environmental conditions has
important consequences for what gets attention. If the objective is to move the nation
towards better and more cost-effective environmental control, the information that gets
reported for the 75 largest metropolitan areas needs to be selected so as to focus
attention on the most important environmental problems.
A. 12.2 Milestone 2
By 2005, the public's right to know what materials are released in their
communities will be more fully addressed by the collection and publication
of more comprehensive measures of the pollution sources.
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This milestone's objective of expanding the coverage of TRI is not sufficiently
ambitious. While retaining the current lower cutoffs, so that small players do not have to
report, TRI requirements would be extended to cover all industry so that a
comprehensive picture of emissions can be assembled, and used to systematically
perform such tasks as linking TRI to economic input/output analysis without there being
gaping holes across large sectors of industrial activity. If the objective is "know what
material is released" one has to include all major sources. Thus, the goal should not be
"more comprehensive measures" but "comprehensive measures".
A. 12.3 Milestone 3
By 2005, Americans will have improved environmental information about
the products and chemicals they use, including data on toxic effects such
as hormonal, reproductive, growth, and developmental risks.
This milestone talks of assessing environmental risks. While comparisons may
be an implicit part of assessment, the comparison of risks should be explicitly
mentioned in the context of this Milestone. Given the many risks we face, and the many
other social objectives we strive for, in addition to environmental quality, risk decision
making must involve a comparative process so that we do not misallocate individual and
societal resources by adopting too narrow a decision perspective.
A. 12.4 Milestone 4
By 2005, more information on environmental programs will be publicly
available, including one-stop access to and reporting of this information.
EPA will make 90 percent of its databases with raw environmental data and
100 percent of its major reports, policy statements, and Federal Register
notices available electronically.
In the discussion of this milestone, it would be appropriate to make some
reference to the need to coordinate with other Federal agencies.
A. 12.5 Milestone 5
By 2005, there will be substantial growth in the number and quality of
environmental education programs in schools, colleges, and communities.
This is a highly desirable objective, but is unlikely to be achieved without.
significant infusions of resources.
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A. 12.6 Milestone 6
By 2005, nations will be better able to share information on the transport of
pollutants and the movement of hazardous and toxic materials across
borders.
This too is a highly desirable objective. It would be strengthened if more
information about how the task will be accomplished were included.
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NRG. 1984. National Research Council Report Toxicity Testing: Strategies to
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