RESEARCH, DEVELOPMENT, AND
TECHNICAL SERVICES AT EPA:
A NEW BEGINNING
REPORT TO THE
ADMINISTRATOR
JULY 1994
Agency-Wide Steering Committee
U.S. Environmental Protection Agency
-------
-------
EXECUTIVE SUMMARY
The mission of the Environmental Protection Agency (EPA), and its unique
role, is the joint protection of environmental quality and human health. Effective
environmental policies depend on sound science. Therefore, science must be the
fundamental basis for decisions at EPA.
To insure that its science program is of the highest quality, EPA has
completed a comprehensive review of all of EPA's research and technical support
laboratories (Office of Research and Development [ORD] research laboratories,
Program Office laboratories that meet regulatory development and technical
support needs, and Regional Environmental Services Division [ESD] laboratories
which provide technical services and support). This review, in combination with
past studies of the science and laboratories at EPA, the National Performance
Review (NPR), and the ORD Streamlining findings, points out the need to define
EPA's role in environmental research more clearly, and to change the way in which
EPA carries out research and implements its science and technology functions.
To implement the Administrator's directive and respond to a Senate and
House mandate for a comprehensive assessment of its laboratory structure, the
Agency engaged the MITRE Corporation to conduct an independent study
developing a baseline description of all EPA laboratories, gathering data, and
assessing options for enhanced quality, efficiency and effectiveness of laboratory
operations to respond to current and future roles and missions. EPA also asked the
National Academy of Public Administration (NAPA) and the Agency's Science
Advisory Board (SAB) to review this Study. The NAPA effort included an
assessment of organizational capacity and science issues in addition to its critique
of the MITRE Study. NAPA concluded that mission and management issues
outweighed organizational issues, and needed to be resolved first. The SAB review
focused primarily on ORD's capability and recommended an improved management
framework and laboratory structure to promote research at EPA.
This report reflects the conclusions of an Agency-wide policy level Steering
Committee on major research and science/technology management issues
confronting EPA. The major findings and recommendations fall into seven areas:
Research leadership and focus;
Management and administrative streamlining;
Partnership with the academic science community;
Peer review;
Science and scientific careers;
Organizational structure; and
Regional and Program laboratories.
-------
The following discussion highlights the major components of the Steering
Committee's reasoning and recommendations on each issue.
Research Leadership and Focus
EPA research, development, and technical services will continue to promote
risk assessment/risk management as the principle that drives priority setting. As a
primary element in its unique role of joint protection of environmental quality and
human health, EPA will advance research that will have the greatest impact on
reducing the uncertainty in risk assessments and facilitating risk management.
To gain a better understanding of today's environmental problems and
anticipate those of tomorrow, ORD should establish a goal of directing 50% of its
resources to support long-term research. This new focus on long-term research
would help EPA better understand complex, multi-media environmental problems,
and would help the Agency focus its scarce environmental protection dollars. The
remaining 50% of ORD's resources would be used to provide vigorous support for
the more applied research and implementation requirements of the regulatory
Programs, and Regions.
Recognizing the importance of science and technology in the overall Agency
mission, the Administrator should designate a senior level policy-maker to serve as
the focal point for the strategic planning and implementation of the Agency's
research, development and technical services (RDTS) as an integral part of the
Agency's Strategic Plan. An important first step in this activity would be the
development of a new Agency-wide RDTS planning process that integrates the
needs and capabilities of ORD, the Program Offices and Regions.
The RDTS strategy will be a single effort to consolidate the needs and
capabilities of the Agency and its laboratories. It will provide the basis for redesign
of the research planning process to focus on an achievable set of strategic goals.
EPA's research planning process would involve the Program Offices, the Regions,
the broad scientific community, and the Federal research community.
Management and Administrative Streamlining
The Steering Committee recognized that the Agency has, over the years,
increased its dependence on contractors to complete the scientific/technical work
expected of it. As a result of the contracting, EPA scientists are overburdened
with administrative tasks. The fiscal year 1995 budget request to Congress
includes a proposal for conversion of extramural resources to the intramural
category to hire EPA employees to replace contractor personnel. These new FTE
should be used to strengthen the scientific/technical capabilities of the laboratories,
-------
minimize Federal/contractor mixed work forces, and eliminate any potential
personal service relationships across the Agency.
ORD should decentralize research laboratory management and administration
to the extent possible, and enhance and empower laboratory and science managers
in the field. ORD should establish a goal of reducing the number of supervisory
and administrative positions by 50%, and directing the resources made available by
this streamlining to participate in the scientific/technical work of the laboratories.
EPA should use this opportunity to increase the accountability of all of its
laboratories to the overall research, science and technology mission of the Agency.
Partnership with the Academic Science Community
EPA will become a partner with the Nation's environmental research
community to carry out the environmental research mandate of the Agency
cooperatively. EPA would provide $100 million annually for competitive,
peer-reviewed, investigator-initiated grants to the academic and not-for-profit
scientific community. EPA would expand the graduate fellowship program to train
a cadre of new scientists for EPA and the Nation by making graduate fellowships
available to students nationwide through a competitive process. These actions
would make it easier for EPA and the academic community to build partnerships
across a broad front of environmental science and technology and work more
closely with other Federal scientific agencies to ensure coherent and integrated
research programs.
Peer Review
EPA will significantly increase involvement of the scientific community in its
research through an enhanced peer review process. This process will focus on:
• On-site review of research laboratories and extramural programs,
following an approach similar to that used by the National Institutes of
Health (NIH);
• Uniform level of external peer review of research products and
publications;
• Peer reviewed, internal, investigator-initiated competitive research
program to fund innovative ideas and to improve intramural science
quality; and '
• Appropriate peer review of Program and Regional scientific and
technical work products.
in
-------
Research and assessments in Program Offices, and Regions, as well as
Program Office laboratories and Regional Environmental Services laboratories, will
be held to the same high standards and high expectations as the ORD programs for
streamlining, peer review, and coordinated research planning.
Science and Scientific Careers
In addition to establishing a process for internal research grants for EPA
scientists, EPA will provide better resources for professional development that
helps scientists stay current in their fields, and will provide improved career
opportunities across the Agency for scientists through the implementation of
multiple career tracks.
Organizational Structure
The Steering Committee accepts the organizational concept for ORD of
National laboratories proposed by the Carnegie Commission on Science,
Technology, and Government report "Environmental Research and Development -
Strengthening the Federal Infrastructure," December 1992. Building on the
Carnegie Commission recommendations, a variation has been proposed by ORD
that would more closely address the risk assessment/risk management paradigm
that is fundamental to the Agency's mission. ORD would reorganize its National
research laboratories according to the following alignment:
• Health and Environmental Effects;
• Exposure;
• Environmental Assessment; and
• Risk Management.
To achieve greater effectiveness in ORD, EPA will adopt the overall strategy
advocated by both the NAPA and SAB reviews. This calls for accepting and
implementing the management recommendations under the new National
Laboratory structure on a phased basis over the next two years. The Steering
Committee accepted the SAB and NAPA recommendation to focus on functional,
not physical, consolidation in the near term. Once these new structures are fully
operational, EPA will periodically seek external examination of the ORD laboratory
and science and technology functions. This will include: where the long-term
Research Plan requires expertise not adequately represented in the laboratories;
where in-house centers of research excellence have emerged from the competitive
process; means for refocusing activities in facilities to better meet environmental
IV
-------
research needs; and whether over the long-term there is any merit to consolidation
of operations.
Moreover, EPA will use the budget process to seek modern facilities for all
of its laboratories through improvements to existing facilities and/or the
construction of new facilities and will participate actively in the government-wide
review of National laboratories under the auspices of the National Science and
Technology Council to assure that EPA's laboratories complement those of other
Agencies.
Regional and Program Laboratories
The Steering Committee recognizes the importance of maintaining the
Program laboratories. With their clear mission and customer focus, they provide
vital technical support to assist in the regulatory development and enforcement in
the mission areas of their parent Program Offices. During the Steering
Committee's June 7-8, 1994, Retreat, two Program Offices with laboratories
(OAR and OPPTS) were charged with conducting fast-track evaluations of issues
and developing recommendations for the Steering Committee's consideration.
The Office of Radiation and Indoor Air conducted a review of the merits of
consolidation of its laboratories and appropriate ORD laboratory activities into its
laboratories. Their recommendations were presented to the Steering Committee
on July 11,1994, where they received general support and were referred to an
Implementation Subcommittee for additional evaluation and action. OAR
recommendations included:
• Administrative and physical consolidation of the resources and
functions of the ORD Environmental Monitoring Systems Laboratory,
Radiation Science Division in Las Vegas, NV into the Office of
Radiation and Indoor Air (ORIA) Laboratory in Las Vegas, NV;
• Maintaining the status quo at the ORIA National Air and Radiation
Environmental Laboratory in Montgomery, AL; and
• Use of the ongoing ORIA streamlining and organizational assessment
to evaluate additional administrative and physical consolidations of
radiation laboratories over the next two years.
The Office of Pollution Prevention and Toxic Substances {OPPTS), Office of
Pesticide Programs, conducted a preliminary evaluation and determined that more
time would be required to evaluate the merits of combining the functions or
physically consolidating the two laboratories currently in Bay St. Louis, MS, and
Beltsville, MD. A report on these further analyses is expected November 1, 1994.
v
-------
OPPTS intends to proceed with the movement of its Beltsville, MD laboratory to a
new site at Fort Meade, MD where they will co-locate with the Region 3
laboratory. This project is well into the design phase and construction monies for
the OPPTS laboratory are included in the Agency's
FY 1995 budget request.
The Regional Environmental Services laboratories provide scientific and
technical support to the Regional Administrators. The Steering Committee
determined that these laboratories are important to maintain and endorsed the
current decentralized model. Individual Regional laboratories should be encouraged
to become "centers of excellence" with respect to emerging analytical
instrumentation and methods.
At the Steering Committee retreat, a Subcommittee was charged with
developing recommendations on a series of issues relating to the Environmental
Services Divisions and their laboratories including their Headquarters advocacy,
budget mechanisms, centers of excellence, and participation in the Agency's
research planning process. Their recommendations were presented to the Steering
Committee on July 11, 1994, where they received general support and were
referred to an Implementation Subcommittee for additional evaluation and action.
The ESD Subcommittee recommendations included:
• Recognition of the need for a National ESD Central Advocate from a
neutral office to maintain the alignment between scientific and
technical services of the ESDs and their clients;
• Continuation of OROS/LR as this National ESD Central Advocate with
modifications to enhance OROS/LR management and budget systems;
• Creation of a balanced ESD budget for greater resource stability for
the ESDs;
• Establishment of a Program Element under the Central Advocate's
budget authority to carry the ESD resources for its current core
resources. The remaining resources which constitute ESD's base
would be established as line items in their respective Program Offices'
budgets. Increased capability and capacity would be subject to the
existing negotiation process;
• Coordination between the Central Advocate and Regional
Administrators to ensure integration of ESD scientific and technical
services into the Agency's RDTS strategic plan;
VI
-------
• Development of an integrated process to track current and forecast
future science and technical service requirements; and
• Resolution of specific issues of organizational location of the National
ESD Centra! Advocate and development of the National ESD budget to
be addressed during the Implementation phase of this Study.
Move to Action
The Laboratory Study Steering Committee has concluded that the
recommendations in this Report, when implemented, will provide EPA with better
science, better decisions, and better environmental protection. The actions will
also reinforce EPA as the premier research organization addressing issues involving
the joint protection of environmental quality and human health.
The Steering Committee found that management, organizational, and
communication problems create much of the uncertainty about responsibilities for
supporting the RDTS needs of the Agency. The problems were viewed as needing
radical solutions to allow a well-qualified and dedicated work force to achieve the
scientific and technical excellence needed to support the Agency mission.
The changes contemplated by these proposals are intended to strengthen
the scientific and technological base of the Agency and should result in new and
expanded opportunities for professional development of EPA employees.
Throughout, care will be taken to minimize adverse impacts on individual careers
and disruption of the Agency science program.
Overall coordination and oversight of these initiatives will be provided by an
expanded Agency-wide Steering Committee; the current Steering Committee will
be expanded to include additional members from the affected organizations
including the laboratories and the Unions. Six Implementation Subcommittees,
listed below, will be created under the expanded Steering Committee to develop an
implementation master plan by November 1, 1994. The master plan will receive
full review and ratification by the expanded Steering Committee. A formal tracking
process will be established to permit Agency-wide monitoring of implementation
actions.
The Implementation Subcommittees will be lead by managers from ORD,
OARM, the Program Offices, and the Regions. The Subcommittees will be staffed
by managers, non-supervisory staff, and Union representatives. The process for
staffing the Subcommittees is currently being developed but will be certain to
encourage broad and active involvement of EPA staff, including Union
representatives. The current listing of Implementation Subcommittees follows:
VII
-------
Research Leadership and Focus Subcommittee
ORD Organizational Structure Subcommittee
Regional/Program Office Laboratories Subcommittee
Cross-Cutting Management and Administrative Subcommittee
Science Quality Subcommittee
Science and Scientific Career Subcommittee
Implementation of the broad range of proposals discussed in this report will
require a concerted effort over the next several months. In some instances
significant action will be completed in the near term, but most often
implementation can be expected to require several years.
VIII
-------
RESEARCH, DEVELOPMENT AND
TECHNICAL SERVICES AT EPA:
A NEW BEGINNING
REPORT TO THE ADMINISTRATOR
TABLE OF CONTENTS
1.
2.
3.
4.
5.
6.
Executive Summary
Table of Contents
Appendices
Introduction
Science Missions at EPA
Management Issues
Laboratory Organization '
Implementation Actions
List of Steering Committee Members
i
ix
X
1
3
6
16
34
37
IX
-------
APPENDICES
A. Carnegie Commission Recommendation for EPA Office of Research
and Development
B. "Recommendations for National Center for Environmental
Assessments," William H. Farland, June 22, 1994; "Additional
Working Group Recommendations Concerning Proposed National
Center for Environmental Assessments," William H. Farland,
July 6, 1994.
C. "Report to the Laboratory Steering Committee from the Ecological
Laboratory Committee," Tudor T. Davies, June 30, 1994.
D. "Report on Consolidation of the Exposure and Risk Management
Laboratories," Alfred W. Lindsey, July 8, 1994; "Special Analysis of
Proposed Restructure of ORD Environmental Exposure and Risk
Management Laboratories," July 6, 1994.
E. "EPA Laboratory Study: Recommendation for EPA Radiation
Laboratory Consolidation," Mary D. Nichols, July 6, 1994.
F. "EPA Laboratory Study: ESD Evaluation - Cross-Agency
Subcommittee Final Report," Joe D. Winkle, June 21, 1994.
x
-------
INTRODUCTION
To implement the Administrator's directive and the Senate and House
Appropriations Committees' mandate to complete a comprehensive assessment of
EPA's laboratory structure as a basis for the development of an optimal laboratory
organization, the Agency engaged the MITRE Corporation to conduct an
independent study. The Study was directed by an Agency-wide Steering
Committee comprised of senior policy officials and Regional Administrators with
oversight by the Deputy Administrator.
The MITRE Study provided a baseline description of all EPA laboratories and
assessed options for enhancing the quality, effectiveness, and efficiency of
laboratory operations to respond to current and future roles and missions. This
Study addressed the current configuration and focus of scientific and technical
support functions within EPA and provided the data for the evaluation of major
options for functional, organizational, and physical realignment.
EPA also asked the National Academy of Public Administration (NAPA) and
the Agency's independent Science Advisory Board (SAB) to review this Study.
The NAPA effort included an assessment of organizational capacity and science
issues in addition to its review, evaluation, and critique of the MITRE Study.
NAPA's review provided EPA with its best judgement for the most effective means
of enhancing the capabilities of EPA's science and technology organization. NAPA
indicated that mission and management issues outweighed organizational issues,
and believed that the mission and management issues needed to be resolved first.
The SAB assessment focused primarily on ORD's capability and recommended an
improved management framework and laboratory structure to promote scientific
research at EPA.
EPA complemented these efforts with broad internal, Agency-wide
participation in the review and analyses of the MITRE Study findings and
organizational options. This included: 1) a team of Laboratory Directors and senior
staff support from the Office of Research and Development; 2) a team of
Environmental Services Division Directors and senior staff support from the Office
of Regional Operations and State/Local Relations; 3) senior staff involvement from
the Office of Administration and Resource Management; 4) senior staff
involvement from the Program Offices having laboratories; and 5) participation
from Agency Union representatives.
The Steering Committee convened a retreat on June 7 and 8, 1994, to
discuss the full range of information that had been developed through the
Laboratory Study and related analyses. The objective was to decide which
actions should be recommended to the Administrator to strengthen science
-------
management within the Agency. The Steering Committee organized its discussion
Into four areas:
• Science mission clarification;
• Management problems and issues;
• Organizational issues; and
• Implementation strategies.
The Steering Committee met a number of times after the
June 7 and 8, 1994, retreat to review the draft report, integrate the results of
additional special analyses, and complete its recommendations to the
Administrator. In late June, a draft of the Steering Committee report was
distributed to staff across the Agency; meetings were held at the laboratories and
Headquarters to present the draft to the staff and receive their comments. The
meetings were chaired by members of the Steering Committee to provide these
senior policy officials the benefit of direct input from the individuals most affected
by the effort. In general, the comments received on the draft report indicated that
staff did not believe that physical consolidation was needed for the proposed
functional consolidation to be effective in focusing and directing the work of ORD,
the Program laboratories, and Environmental Services Divisions. Many useful
comments were received and are reflected in the final report. In some cases, the
comments were more relevant to the Implementation Subcommittees that will be
created to complete the analyses and planning needed to perform the actions
required by the recommendations. These comments have been referred to the
Implementation Subcommittees for their use in the coming months.
Based on its deliberations and the input received in response to the draft
report, the Steering Committee is making its recommendations to. the
Administrator. This report reflects the full range of significant, immediate
management and organization actions the Steering Committee deemed necessary
to allow EPA to meet its science and technology responsibilities in the coming
decades.
-------
SCIENCE MISSIONS AT EPA
A clear point of agreement of the various assessments of the current EPA
laboratory structure has been that EPA must establish a clear statement of its
science and technology not only to guide its research, development, and technical
services but also as a precondition to any major change in management or
organizational structure. The Steering Committee agreed with these assessments
and focused its attention on the following issues as a matter of first priority:
• EPA needs a clear statement of its overall role for science and
technology and subsequent redefinition of the specific missions of the
ORD laboratories;
• The clear mission elements and customer-focus of the ESD and
Program laboratories result in high customer satisfaction and should
be preserved;
« The roles of long-term research, program support, and technical
services need to be clarified as implemented across the three
categories of Agency laboratories; and
o
Discussion
The principal customers for the different mission elements need to be
clearly identified and science support must be tailored to meet their
requirements.
A. Mission:
The EPA Laboratory Study Steer-ing Committee agreed that the Agency must
provide scientific and technical leadership, expertise, and support if it is to be
effective in accomplishing its mission of protecting environmental quality and
human health. EPA's science role is unique within the overall Federal
environmental science effort because it focuses on the intersection of ecological
and health concerns and therefore, the joint protection of environmental quality
and human health. While EPA controls less than ten percent of the Federal science
budget for research and development in the environmental sciences, it is the only
Federal Agency with mission capabilities across the full range of science disciplines
and activities that are required for effective decision-making related to
environmental protection. Therefore, a key role for EPA is to serve as a catalyst
and leverage the science efforts of other Federal programs, the academic
community, and industry to ensure that the necessary level and scope of
-------
information and technologies are available to enable EPA to meet its broad mission
on behalf of the general public.
The Steering Committee concluded that four important principles are
paramount to EPA with respect to its role in science and technology:
• Continued strong commitment to the highest standards of quality,
including heavy reliance upon peer review;
a
• The development and nurturing of career scientists and engineers;
• Leadership in the establishment of the National environmental science
agenda; and
• Building partnerships in science and engineering with academia, the
private sector, and Federal environmental programs as well as States,
local governments, and Tribes.
J3.. Mission Categories:
It was recognized that there are three critical categories of EPA's science
mission: 1) research and development; 2) scientific and technical information
integration; and 3) technical support and services. For purposes of this report,
these topics will be referred to as "research, development, and technical services"
(RDTS). Long-term research is focused on anticipating future environmental
problems and on filling significant gaps in knowledge relevant to Agency decision-
making. Program support research and development involves the expansion and
use of existing knowledge to solve defined problems or provide specific analyses,
methods, and technologies to support regulatory development and implementation.
Scientific and technical information integration provides the interpretation,
extrapolation and synthesis of environmental data to evaluate the significance and
extent of environmental problems to assess risks to humans and ecosystems, and
to predict the effectiveness of mitigation strategies. Technical support and
services address specific immediate Agency needs for advice and environmental
information.
£.. Laboratory Missions/Customers:
The science mission of EPA is supported primarily through the activities of
the ORD research laboratories, Program Office support laboratories, and the
Environmental Services Divisions (ESDs) of the ten Regional Offices. Agreement
was reached that the specific mission of the ORD laboratories is to lead the
production and integration of technical knowledge and basic understanding to
generate scientifically sound advice and facilitate the formulation of effective
-------
policies and regulations for present and future environmental protection. The
primary customers for ORD research, development, and technical services are EPA
policy leaders, regulatory Program Offices, Regional Offices, the regulated
community, and the technology applications and assessment community. To
conduct its mission effectively, ORD relies upon strong partnerships with the
academic community, science and technology programs in other Federal Agencies,
and the private sector.
The Steering Committee affirmed that the mission of the Program Office
laboratories is to provide technical support to assist in regulatory development and
enforcement on the mission areas of their parent Program Offices. Aside from
their primary customers, the parent regulatory programs, their customers also
include the policy leadership of EPA and the Regional Offices.
The mission of the ESDs is to provide inspections, investigations, laboratory
services, and quality assurance management to the Region and States to produce
physical, chemical, and biological data used for environmental and enforcement
decision-making. The ESDs' primary customers are the policy leadership of EPA;
State, local, and Tribal officials; the Regional Offices; and the regulated
community.
Important stakeholders in the outcome of EPA science are the Congress, the
public, national environmental interest groups, the national and international
scientific communities, the national and international environmental community,
State and Tribal co-regulators, and the regulated community.
-------
MANAGEMENT ISSUES
The MITRE report and the evaluations conducted by NAPA and the SAB all
indicated that there are important issues in the management of RDTS across the
Agency. It was felt that many of the management issues were more important
than many of the structural and organizational issues and that the management
issues needed to be addressed first. The discussion of management issues at the
Steering Committee Retreat was driven by the comments and recommendations
found in the MITRE, NAPA and SAB reports. The issue summaries are divided into
four categories. Roles and relationships deals with internal Agency communication
and integration efforts and relations with the external science/technology
community. The science quality and peer review discussion addresses the internal
and external review of projects from planning through project completion. The
presentation on the use of the Federal work force and extramural resources
summarizes the management issues associated with using the wide range of
Federal and extramural staff for common projects and activities. The human
resources discussion presents approaches to maximizing the abilities and
productivity of the Agency's technical and scientific staff.
Roles/Relationships
Issues:
There is a lack of shared expectations among ORD, the Regions, and
Programs concerning their respective roles in the science and
technology functions of the Agency.
There is a need for improved understanding of client needs among
ORD, the Regions, and Programs and improved input of Regional and
Program needs into the ORD research planning and implementation
processes.
Science/technology needs are not sufficiently integrated into the
Agency budget preparation and strategic planning process.
There is insufficient joint (ORD/Programs/Regions) decision-making on
science priorities.
There is a need for improved understanding and agreement on the
relative roles and budgets to be devoted to long-term research and
short-term research/technical support.
-------
The extramural scientific and technical community feels that there is
inadequate competition for research funds and that the Agency relies
on too few sources for extramural scientific and technical support.
Discussion:
The Steering Committee recognized that many of the above roles and
relationships issues deal primarily with communication and fragmentation of
planning and management systems. Historically the science and technology needs
of the Agency have not been handled in an integrated manner. ORD has planned
its work in consultation with the Programs and Regions but has not always met
their needs. The Programs and Regions have generally planned and implemented
their internal scientific and technical work without consultation with ORD. There
has also been a lack of clarity of the missions of the various organizations; there
has been no process established to ensure that the various scientific and technical
activities conducted across the Agency are complementary without unnecessary
duplication or overlap.
The current ORD issue planning process aggregates research needs into 41
issues, each dealing with a specific research topic (e.g., global climate change,
drinking water contaminants, criteria air pollutants). An Issue Planner, a senior
ORD official at either Headquarters or a research laboratory, is assigned
responsibility for working within ORD, and with interested Program Office and
Regional managers, to develop research needs and plan the research for the next
three to five years. The participants in the planning process identify and rank
needs and allocate the research and development funds to the laboratory
responsible for the work. The planned projects are then merged with the other
work of the laboratory. Program Offices plan their laboratory's work during their
annual work planning process; Program Office plans are not systematically shared
with ORD or the Regions. Regional laboratories focus on technical services and
support and conduct little research. The ORD issue planning process is intended to
incorporate Regional needs, but is not always successful; the Regional needs often
have very short response-times that cannot be accommodated by the multi-year
research planning structure.
To respond to the concerns about communication of needs and integration
of planning of RDTS, the Steering Committee recommends that a new Agency-
wide planning process be established. This new process would ensure that the
RDTS needs and capabilities of the Agency are identified, combined and dealt with
in a consistent manner. The new system would include the RDTS work of the
Programs and Regions in an integrated planning process to ensure Agency
managers that the full spectrum of needs would be identified, that all needs would
be evaluated, and that a single organization would be responsible for a defined
-------
task. This process would also clarify responsibilities and minimize overlap or
redundancies in work.
The Steering Committee also decided that a senior level policy-maker should
be designated to lead the development of a Cross-Agency RDTS multi-year
strategic plan. This plan would integrate all of the RDTS needs and efforts
required by the Agency's Strategic Plan (e.g., R&D, scientific analyses and
assessments, technology evaluations, and technical services and support) and
provide an integrated presentation with the strategic goals, customers, priorities
and major products identified. The Science Policy Council would be utilized to
facilitate this Cross-Agency planning and ensure that Regional and Program Office
needs and activities are incorporated. After review by the Science Advisory Board,
this RDTS plan would be presented to the Senior Leadership Council for
concurrence and then integrated in the Agency planning and budgeting system.
The Steering Committee expects that this effort would result in an optimum
allocation of the resources to the priority environmental problems, a clear
understanding both inside and outside the Agency of the RDTS strategy and a
basis for assigning accountability to Agency laboratories for RDTS products and for
customer satisfaction. :
Within the research program, the Steering Committee noted the previous
failures of the Agency to recognize the importance of long-term R&D and the
significant, beneficial role that the extramural science community can bring to the
Agency. In the past, the long-term research program has been subject to frequent
and substantial funding changes that have limited its ability to deliver a science
base for the Agency Programs. Where long-term research has been maintained,
the external research community has felt that there has not always been open
competition for the work. Sharp criticism has also come from the Congress and
the Office of Science and Technology Policy on this issue.
In response, since sound science is an Agency guiding principle, the Steering
Committee recommended that a clear commitment to long-term research would be
made. An initial numerical goal of 50% of the ORD's resources would be
established to provide stability and increased visibility for the long-term research
program. An Implementation Subcommittee will review the present use of R&D
resources and will make recommendations regarding future goals and the transition
process to implement these goals.
The competitive, extramural investigator-initiated research program would be
expanded from the current $20M to $100M per year. Topics for this research
would be developed as an integral part of the Cross-Agency RDTS plan.
Laboratory intramural, research would also be designated in the RDTS plan,
utilizing in-house expertise and following an in-house peer review system similar to
that utilized at the National Institutes of Health (NIH), which uses committees
8
-------
chartered under the Federal Advisory Committee Act (FACA). Finally, as part of
this 50% goal, an internal competitive grants program will be established to allow
EPA scientists with bright, innovative ideas to compete through an investigator-
initiated peer-reviewed process for funding; joint proposals with academia and
other Federal agencies would be encouraged.
Recommendations:
• Develop an EPA-wide planning process to incorporate the RDTS needs
and activities of ORD, the Program Offices and the Regions and to
ensure that all RDTS needs are identified and that work in response to
the needs is carried out efficiently;
• Designate one of the senior level policy-makers to lead the
development of the strategic plan for scientific and technical activities
across the Agency. The plan would be coordinated with the Agency's
strategic planning, reviewed by the Science Policy Council and
Science Advisory Board, and submitted to the Senior Leadership
Council for approval;
• Establish an initial numeric goal for long-term research of 50% of
ORD's total resources and review current research resource
allocations to determine how best to approach that goal;
« Expand the competitive, extramural, investigator-initiated research
program from $20M to $100M a year and establish an appropriate
process for defining the scope of the research and evaluating the
proposals;
• Establish a peer reviewed, internal, investigator-initiated competitive
research program to fund innovative ideas and to improve intramural
science quality; and
• Conduct on-site reviews of ongoing and planned research within ORD
and Program laboratories, following an approach similar to that used
by NIH, including use of committees chartered under FACA.
Science Quality and Peer Review
Issues:
There is a need for strong quality assurance processes associated with
the development of Agency scientific and technical products.
-------
• The Agency-wide peer review process needs to be strengthened.
Discussion:
The Steering Committee felt strongly that the Agency must have high quality
science to support its actions and decisions. To this end, the Committee has
affirmed the importance of the Agency-wide quality assurance program.
In some instances, the quality of Agency science is questioned because the
activities have not been subjected to peer review by an independent, extramural
panel. The Steering Committee supported the use of a peer review process
covering all intra- and extramural scientific/technical work to ensure that the work
meets the standards required of competitive efforts in the academic sector. The
Agency has established a framework for peer review of scientific/technical
activities across the Agency. Organizations are currently developing standard
operating procedures for their peer review programs.
ORD will refine its peer review programs for both the intramural and
extramural scientific and technical programs. Intramural, competitive research
proposals would be subjected to the same rigorous peer reviews as the extramural,
competitive research proposals. In this way, the intramural researchers would
improve the planning and documentation of their research thereby proving that
their efforts are competitive with research in the extramural community.
Increasing restrictions on the use of FACA committees may seriously impair
the Agency's ability to involve the extramural research community in the peer
review process.
Recommendations:
• Expand implementation of the Agency-wide quality assurance
program. Increase senior management attention to existing planning,
implementation and assessment programs to improve quality and
documentation of scientific/technical products;
• For in-house research, utilize a peer review process under the FACA
similar to that used by NIH for its intramural research program; and
• Establish an integrated peer review program from planning through
project completion. ORD, the Program Offices, and Regions should
develop peer review procedures that are appropriate to their scientific
and technical products.
10
-------
Use of Federal Work Force and Extramural Resources
Issues:
ORD relies extensively on contractors for scientific and technical
activities. There are continued concerns about work teams with both
Federal and contractor employees (personal services relationships).
EPA scientists are overburdened with administrative tasks.
There is too much layering/redundancy in management structures.
Discussion:
The Steering Committee recognized that the Agency has, over the years,
increased its dependence on contractors to complete the scientific/technical work
expected of it. The fiscal year 1995 budget request to Congress includes a
proposal for conversion of extramural resources to the intramural category to hire
EPA employees to replace contractor personnel. The Steering Committee felt that
a top priority for the use of the new FTE from the contractor conversion would be
to replace contractor employees and minimize the mixed work force and eliminate
personal services relationships across the Agency laboratories.
It was clear that the limitation on the availability of Federal FTE will
continue. The Steering Committee strongly felt that the Agency must maximize
the effective use of FTE and use contractors for the more routine tasks that do not
require the use of Federal employees. Each laboratory should evaluate its tasks
and responsibilities and assure that all activities that can reasonably be
accomplished by contractors are contracted; examples of these tasks are providing
building security and maintenance. Additional analyses should be conducted to
determine specific areas of scientific and technical support that require specialized
expertise that is needed infrequently, but urgently, that would best be provided by
contractors instead of maintaining the capability on-staff; this will free the FTE to
be used for more needed scientific support.
The Steering Committee emphasized that the analysis of contracting should
also evaluate the workload of the various facilities and determine if any have a
majority of staff that are contractors; these facilities would be considered for
conversion to a Government Owned, Contractor Operated (GOCO) facility. The
freed-up Federal FTE would be redeployed to other Agency laboratories to
strengthen the science functions.
The Agency has a number of streamlining groups that are evaluating many
Agency administrative procedures for opportunities for management improvements
11
-------
to increase efficiency and effectiveness of the operations. In particular, the Office
of Administration and Resources Management (OARM) is leading a number of
Agency-wide groups that are analyzing the contracting process to streamline the
process and remove unnecessary steps and requirements. The Steering
Committee endorsed the OARM activities and noted that ORD should work with
OARM to assure that all OARM/ORD administrative concerns are either
incorporated in the OARM activities or that special OARM/ORD groups should be
chartered to deal with concerns that are common only to those two organizations.
Over the years, many of ORD's decision making and administrative oversight
functions have been centralized to Headquarters. The Steering Committee strongly
recommends that the authority and responsibility to initiate and direct the scientific
and technical programs of the Agency be delegated to the laboratory managers,
who should also be held accountable for the quality and timeliness of outputs.
This puts the primary leadership of the program where the work is done, and
makes communication and commitments more direct and efficient.
Audits by the Office of Inspector General (OIG) have noted many
shortcomings in the management and oversight of contracts and administrative
functions in the laboratories. The management structure of ORD will be redesigned
by an Implementation Subcommittee to assure consistent interpretation and
application of administrative policies and procedures across the new ORD
laboratories.
It was also noted that ORD has a substantial number of FTE in
Headquarters and in administrative positions in its laboratories. The Steering
Committee directed that there be a detailed analysis of the ORD Headquarters
staffing needs, including the organizational location of the Quality Assurance
Management Staff, which has Agency-wide responsibility for the QA program.
Regarding ORD Headquarters streamlining, to the extent that the training is
provided and the skills are transferrable, a substantial fraction of the supervisory
and administrative staff will be reassigned to scientific and technical activities.
Laboratory organizations will also evaluate their administrative functions to
streamline them to free staff for direct science-related activities. ORD has
established a target of reducing the administrative and supervisory staff by 50%.
Recommendations:
• Replace contractor employees with Federal employees to minimize
mixed work forces and eliminate personal service relationships in
research activities;
12
-------
Review contractor use in all laboratories;
Ensure that all contracted activities are appropriate;
Determine areas that require special procurement of services
(scarce talent, occasional need) and determine appropriate
approaches and controls; and
Evaluate proposal for GOCO operation of laboratories that are
now predominantly contractor staffed.
Endorse Agency-wide contractor conversion effort and streamlining
(administrative efficiencies) efforts;
Continue participation in OARM efforts to streamline Agency-wide
administrative functions. Establish OARM/ORD committees as
necessary to streamline OARM/ORD interactions;
Delegate appropriate authorities and responsibilities, with
accountability systems, to the managers at the laboratories.
Development of the new processes and control systems should be
done by an Implementation Subcommittee;
Set goal of 50% reduction of ORD supervisory/administrative
positions and reassign the FTE and resources to science-related
functions in ORD laboratories; and
Review the organizational placement of the Quality Assurance
Management Staff.
Human Resources
Issues:
Opportunities for advancement are limited in scientific/technical career
paths. The talents required for non-supervisory science management
are often not recognized.
The Agency cannot hire enough science/technical staff due to staffing
limitations.
There are insufficient opportunities for career development through
participation at meetings and seminars.
13
-------
Discussion;
The Steering Committee's extensive discussion on human resources raised a
number of important aspects regarding the need for the Agency's work force to
have the skills and tools needed to perform the mission. The Agency must have an
exceptionally well qualified work force to meet the scientific and technical needs of
the increasingly complex regulatory and policy environment. However, the
Steering Committee recognized a number of important limitations to the ability of
the Agency to attract and retain the highly qualified work force. Among the most
important is the historical limitation on promotion potential for non-supervisory
scientific and technical staff; higher grades were available to managers and
supervisors than to non-supervisory scientists and technical staff. The Committee
strongly endorses the Agency's ongoing efforts to establish multiple career track
programs for all organizations as a means of retaining the highly qualified
scientific/technical resources of the Agency.
There is intense pressure on all EPA staff to accomplish the day-to-day work
of the Agency and a perception has developed that no time during the work day is
available for scientific and technical staff to maintain competency in their fields of
expertise. The Steering Committee felt strongly that expanding personal
knowledge and experience and receiving formal training are critical to maintaining
the intellectual edge required to perform in the Agency and that these activities are
to be encouraged as part of the day-to-day responsibilities of the staff. This
recommendation was made with full awareness that the "output" of the
organization may be reduced temporarily, but that the quality will be better over
the long term. The formal Individual Development Plan component of the
performance management system should be used as the vehicle to implement this
recommendation.
In further support of the development of the Agency's human resources is a
discussion from the National Performance Review (NPR), " [l]n 1989, the National
Commission on the Public Service, headed by Paul Volcker, estimated that while
leading private firms spend 3 - 5% of their budgets on training, retraining, and
upgrading employee skills, the Federal government spends less that one percent."
The Agency Performance Review has accepted this NPR philosophy on expanding
training and development opportunities and is developing implementation plans to
incorporate it into the Agency's planhing and personnel management processes.
The Steering Committee endorses this action and believes that an additional step
should be taken. Benchmarks of the proportion of budget allocated to training and
development in academia and private research operations should be developed and
evaluated for application at EPA. In another effort, the Agency should explore
alternative ways to reduce costs to the Agency of employee development;
activities such as sponsoring symposia at EPA facilities and splitting costs of
14
-------
conference attendance with employees to increase the number of employees who
can participate should be considered.
The limitation on hiring Federal employees and the restrictions on temporary
employment have had a negative affect on scientific and technical staffing. In
research, the standard one-year decision on employment probation is far too short
to determine if the employee will be an important contributor to the research. The
National Institutes of Health has a "Staff Fellow" program, which permits term
appointments that allow the tenure decision to be made after seven years, and
therefore, allows the scientific capabilities and performance of the employee to be
better judged. The Steering Committee encourages exploration of innovative
approaches to increasing the number of scientific and technical employees without
increasing the FTE requirements; programs to increase the use of internships, pre-
and postdoctoral fellowships, and postdoctoral grants for mission-related work
should be considered. The current fellowship and traineeship programs receive
approximately $1.6M per year; the Steering Committee recommends that these
programs be expanded and augmented. This would make graduate fellowships
available to students nationwide through a competitive process.
Recommendations:
• Endorse multiple scientific/technical and management career track
activities for use across entire Agency.
• Exhort managers to recognize that expanding personal knowledge,
experience and training of subordinates are part of their job and
deserve time. Increase use and significance of Individual Development
Plans (IDPs).
• Support IMPR recommendation that 3% of the Agency personnel
budget go to employee development.
• Develop specific science and technology staff development goals
through benchmarking industry/academic practices.
• Investigate innovative approaches to hiring and training scientific and
technical personnel.
• Expand financial support for fellowship and traineeship programs.
15
-------
LABORATORY ORGANIZATION
This chapter of the report has three parts: the ORD laboratories, Program
Office laboratories, and ESD laboratories. Each part includes an issue, discussion,
and recommendations section.
ORD LABORATORIES
The Office of Research and Development (ORD) is comprised of a
Headquarters component and a geographically dispersed array of twelve
laboratories, three field stations, and four assessment centers. The science and
engineering focus and scope of responsibilities for the several laboratories have
been the object of almost twenty years of debate without satisfactory resolution.
Similarly, the respective roles of Headquarters offices and laboratories have varied
significantly over time resulting in similar lack of clarity and consistency.
In 1992, the Carnegie Commission on Science, Technology, and
Government published a report entitled "Environmental Research and Development
- Strengthening the Federal Infrastructure" that included recommendations for
restructuring the ORD laboratories into four National laboratories. That
recommendation and analysis provided a baseline for the MITRE option analysis
and subsequent EPA assessments and recommendations.
In examining organizational alternatives for ORD, the Steering Committee
considered the following goals:
• Enhance ORD effectiveness in achieving its clarified and unique
research mission;
• Distinguish ORD in the Federal research and development
infrastructure;
• Respond to recommendations of outside review groups;
• Promote orderly identification and delivery of research
products/services to key customers;
• Focus on research to reduce uncertainties in risk assessment and
facilitate risk management decisions; and
• Align research organizational structure to support designated research
functions.
16
-------
Issues:
There has been difficulty in clarifying the scope of ORD's research;
There has not been full agreement on strategic/applied planning
decisions to support ORD's customers;
Current laboratory structure and missions blur the boundaries among
laboratory outputs and environmental outcomes; and
Laboratory resources are fragmented among a number of
geographically dispersed operating sites, causing a sub-optimization of
scientific potential.
Discussion:
Historically, the Agency's responsibilities and needs for environmental
research have been so vast that priority setting and directing resources where their
value would be greatest, taking into account research being conducted elsewhere,
has been difficult. ORD's current discipline-based structure does not track well
with existing media/problem-based Programs and Regions or with science based on
risk assessment/risk management. Thus, any reorganization of ORD must provide
for enhanced interaction with Program Offices that are driven by legislative
mandates. Also, relationships with other Federal agencies, academia, and the
international science community must be strengthened to improve the Agency's
use of their, information. ,
Attempts to improve the strategic/applied planning decisions to support
ORD's customers have been procedural in nature, including use of research
committees and, recently, issue planning groups. Although issue planning has
resulted in coherent development and integration of major science issues, effective
participation of major customers in the overall process has been less than
satisfactory. These attempts did not provide a scientific rationale for allocating
(balancing) the use of intramural and extramural resources for both fundamental
and applied research outputs. The current discipline-based structure within ORD
tends to impair integration of the science products and ability to meet media-based
customer needs. Among Federal agencies, only EPA is established, as the broad-
based Federal environmental protection leader and its research focus should
become compatible with this Agency role.
The current ORD laboratory structure and vagueness of missions confuse the
distinctions among laboratories and their capabilities. Many laboratories have
shared parts of science operations better handled as a single operation. Many
participate in a range of science activities, but single organizational units are not
17
-------
accountable for systematic achievements leading to timely responses to regulatory
needs. The vagueness of missions and overlapping disciplines among laboratories
has led to confusion and frustration among customers on accountability for
deliverables.
Alternative Research Structures
The Carnegie Commission recommended restructuring the ORD laboratories
into four functionally oriented National laboratories: ecological systems;
environmental monitoring; environmental engineering; and health effects
(Appendix A). EPA's research objective of reducing uncertainty in risk analyses
that undergird environmental management decisions is not directly addressed by
the Carnegie recommendation. A second option was proposed at the
June 7 - 8, 1994, retreat of the Steering Committee to organize the laboratories
around risk assessment and risk management.
A majority of the Steering Committee believe that an alternative risk
assessment/risk management research laboratory structure for ORD will be more
effective and will allow EPA to meet the organizational goals previously identified.
The risk-based alternative to the Carnegie Commission option would create four
National laboratories aligned to match the risk-paradigm used in EPA decision-
making. This organization (Figure 1) creates National laboratories for health and
environmental effects, exposure, environmental assessment and risk management.
A key element in the National laboratory organizational scheme is the
decentralization of science program design and management from ORD
Headquarters to science leaders selected as National laboratory directors. The
fundamental rationale is to remove administrative "layering" and empower the
laboratory leadership to creatively design and implement research activities that are
scientifically sound, responsive to customer needs, and directly relevant to
reducing uncertainty in environmental risk assessments.
National Health and Environmental Effects Research Laboratory
Issue:
Protection of environmental quality and human health requires sufficient
scientific understanding of stressor/receptor interactions to know whether
estimated exposures or physical/biological disturbances will result in ecological
changes or adversely affect human health. Currently, our knowledge of effects for
many stressors is severely lacking, e.g., for endocrine disrupters and algae toxins.
18
-------
W
03
»••(
B5
i
a$
"O
fl .— -
("3 O1
P^ •
j|^ . 1
*|MM r*"H
2 & o
5* O I-"1"*11!
g LJ /-I
o w w
^ gj i
^ w> "^
(•M r/5 ^^<
|o
t0
^
P^
^•^
Et.
O
*«
O
O
••HBHHI^^^BH
^^^rBHaPrnfr^ffl
^ » '*-
2 ta J-
J5 *> *
^^^ *•< /^.
S3
. § 6f) *o3
III
Z ^; «
Q^
3 P= t S
1 1 . 1 §
UJ UJ (£ -1 UJ
i i i i m,
1
•4^
0>
_MMUim«l
13
I1U
811
o § S
fiS **^ ai
" 1 1! s
Z 55
«*«
i "°
§
0 I & I .
Q 0 0 K ^
O 5 O O QJ
< O < < co
i
1 2:
iMHBBBBBBOBBp «_ c/^ ^*_
XI
H
hi
S b
1— C/J ™
«J 4> »
g rt «
~ .2 « "•
•C ?;' ®
« fc| -a
0 ^J
<
r*S
fcl
lBH^BfBB^|p^|fl
«« t
al Health an
imental Effe
ch Laborato
S3 H «
1 1 8
tS S «
S "
W "
"3 u OJD
5 "G a?
•• O Uw
« 18 -<— > ^^
Q; a . w
Of >* 4s , < '• X • S
^ = S I „ S S
uj w to ^3 o ^ i— i
Oi S E K Q. ec
-------
Discussion:
The central mission of the National Health and Environmental Effects
Research Laboratory would be to conduct the array of life science research
experiments and studies across a wide spectrum of responses ranging from
subcellular alterations through effects on individual organisms to changes in
ecological landscapes. These experiments would reduce critical gaps in our
knowledge about the risks of chemical, physical, and biological stressors to
ecosystems and humans. This Laboratory would have lead responsibility for
ecological, place-based research.
A Subcommittee was chartered to review the missions and capabilities of
the current Office of Environmental Processes and Effects Research (OEPER)
laboratories and to make recommendations to the Steering Committee on the
placement of the organizations in this proposed structure. Their recommendations
were presented to the Steering Committee on July 11, 1994 (Appendix B), where
they received general support and were referred to an Implementation
Subcommittee for additional evaluation and action.
The National Health and Environmental Effects Research Laboratory would
be based in Research Triangle Part, NC, and would be composed of the Health
Effects Research Laboratory (HERL/RTP), Research Triangle Park, NC; the
Environmental Research Laboratory - Corvallis (ERL/COR), Corvallis, OR; the
Environmental Research Laboratory - Duluth (ERL-/DUL), Duluth, MN; the effects
research at the Environmental Research Laboratory - Gulf Breeze (ERL/GB), Gulf
Breeze, FL; the Environmental Research Laboratory - Narragansett (ERL/NARR),
Narragansett, Rl; the effects work at the Environmental Monitoring Systems
Laboratory - Las Vegas (EMSL/LV), Las Vegas, NV; the Large Lakes Research
Station (ERL/LLRS), Grosse Isle, Ml; and the Pacific Ecosystems Branch (ERL/PEB),
Newport, OR.
The specific scope of responsibilities, appropriate organizational structure,
and other key issues related to the establishment of a National Health and
Environmental Effects Research Laboratory will be addressed by an Implementation
Subcommittee.
National Environmental Exposure Research Laboratory
Issue:
The greatest uncertainties associated with risk assessment frequently result
from an inability to adequately characterize the full temporal and spatial
characteristics of a stressor, whether it involves exposure to toxic chemicals,
physical disturbances or biological introduction or depletions.
20
-------
Discussion:
The principal purpose of the National Exposure Research Laboratory would
be to carry out the environmental process, measurement, monitoring, and activity
pattern research needed to reduce uncertainty in risk assessments. The Laboratory
would:
• Develop an understanding of environmental processes necessary to
characterize both the movement and fate of chemical stressors and
the patterns of disturbance created by physical or biological stressors;
• Develop measurement and monitoring techniques for quantifying
chemical, physical, and biological stressors and their interaction with
receptors;
• Conduct monitoring programs to characterize and quantify exposures
of humans, other biological species, communities and ecosystems to
environmental contaminants through all pathways and evaluate status
and trends in the conditions of ecosystems;
• Provide fate and transport data, process level descriptions, and
exposure analyses for toxic chemicals in air, soil, water, and
subsurface;
• Develop predictive models for multi-media, multi-pathway analysis of
transport and fate, ambient levels and exposure; and
• Develop appropriate quality assurance/quality control methods for all
environmental measurements.
The report noted in the previous section (Appendix B) also, addressed the
Exposure laboratories. The Steering Committee accepted the report's
recommendations for structuring the Laboratory. The National Exposure Research
Laboratory, based in Research Triangle Park, NC, would be composed of the
Atmospheric Research and Exposure Assessment Laboratory (AREAL/RTP),
Research Triangle Park, NC; the Environmental Monitoring Systems Laboratory -
Cincinnati (EMSL/C1N), Cincinnati, OH; the exposure research functions of the
Environmental Monitoring Systems Laboratory - Las Vegas, (EMSL/LV), Las Vegas,
NV; the Environmental Photographic Interpretation Center (EPIC), Vint Hill Station,
Warrenton, VA (functions and personnel would be transferred to EMSL-LV); the
Environmental Research Laboratory - Athens (ERL/ATH), Athens, GA; and the
Robert S. Kerr Environmental Research Laboratory (ERL/ADA), Ada, OK.
21
-------
The specific scope of responsibilities, appropriate organizational structure,
and other key issues related to the establishment of a National Environmental
Exposure Research Laboratory will be addressed by an Implementation
Subcommittee.
National Center for Environmental Assessment
Issue:
Long-term research alone cannot provide the Agency with an adequate
science base for strategically fulfilling its future mission responsibility. The
research results must be interpreted, integrated and synthesized into policy
relevant environmental assessments.
Discussion:
The primary purpose of the National Center for Environmental Assessment
(NCEA) is to produce risk assessments based upon the research that is completed
by the rest of the ORD laboratories. Another major purpose of the Laboratory is to
produce risk assessment guidelines to insure consistency and state-of-the-art
quality in the preparation of risk assessments by the Agency and the public. The
Center sponsors and carries out research to improve risk assessment methods for
both ecological and human health effects. The Center will also provide predictive
ecological risk assessment methods for chemical and land-use related stressors,
and provide predictive watershed, regional and Earth systems models that integrate
the global climate and biosphere.
A committee was chartered to review the mission and alternative structures
for the Center. The committee's reports are contained in Appendix C. The report
was presented to the Steering Committee, and was referred to an Implementation
Subcommittee; with the clear statement that the Center would be headquartered in
Washington, DC, so that the Center's major clients, the Administrator and other
senior Agency policy-makers, would have the benefit of close working and
consulting relationships.
The National Center for Environmental Assessment would be headquartered
in Washington, DC, and would be composed of the Human Health Assessment
Group (HHAG/DC), Washington, DC; the Exposure Assessment Group (EAG/DC),
Washington, DC; the Environmental Criteria and Assessment Office (ECAO/RTP),
Research Triangle Park. NC; and the EnvironmentalCriteria and Assessment Office
(ECAO/CIN), Cincinnati, OH.
22
-------
The specific scope of responsibilities, appropriate organizational structure,
and other key issues related to the establishment of a National Center for
Environmental Assessment will be addressed by an Implementation Subcommittee.
National Risk Management Research Laboratory
Issue:
The long-term credibility and effectiveness of EPA depends upon the
Agency's ability to assess risks, and also to identify cost-effective actions,
policies, and/or regulations to manage risks. Risk management research is required
to make available risk management options in the areas of pollution prevention,
treatment and remediation technologies, and/or new management practices for
managing risks.
Discussion:
The purpose of the National Risk Management Research Laboratory is to
conduct proof-of-concept and pilot scale studies of production technologies for
industrial and consumer products to prevent environmental releases of pollutants;
to develop and/or evaluate new treatment technologies and new restoration and
remediation technologies; to carry out studies to modify management practices in
industrial, commercial and governmental enterprises as a means of mitigating
environmental stressors; and to conduct research, demonstration, and evaluation
to promote the development and commercial use of innovative risk reduction
technologies in the U.S. and abroad.
Two Subcommittees were chartered to review the functional and physical
consolidation options for the Risk Management and Exposure laboratories. The
reports are contained in Appendix D. The recommendations, including cost
estimates, were presented to the Steering Committee. After lengthy discussion,
the reports were accepted, with the recognition that additional analysis would be
conducted on other options by an Implementation Subcommittee.
This Laboratory would be based in Cincinnati, OH. and would include: the
Risk Reduction Engineering Laboratory (RREL/CIN), Cincinnati, OH; the Air and
Energy Engineering Research Laboratory (AEERL/RTP), Research Triangle Park, NC;
the Edison, NJ, RREL Releases Control Branch (RREL/RCB), and the bioremediation
component of the Environmental Research Laboratory - Gulf Breeze (ERL/GB), Gulf
Breeze, FL.
The specific scope of responsibilities, appropriate organizational structure,
and other key issues related to the establishment of a National Risk Management
Research Laboratory will be addressed by an Implementation Subcommittee.
23
-------
It has not been possible to explore fully how all the scientific activity at all
the ORD laboratories will align with the National laboratories. Moreover, it has
been suggested that some facilities or activities might be more appropriately
aligned with Program or Regional laboratories. In those cases, a more detailed
analysis of the options is planned by November 1, 1994.
Benefits/Limitations of the Risk-Based National Laboratories
Benefits:
• Aligns laboratory missions with EPA's unique research responsibilities
of reducing uncertainty associated with risk assessments, with
research priorities directly related to needs of the environmental
management decision process;
• Focuses missions to provide a clear framework for determining the
appropriate composition of the scientific workforce and supports
development of required critical mass of key scientific and engineering
disciplines;
• Permits organization of ORD research on a multi-media, multi-stressor
basis involving human and ecological risks;
• Enables the Agency to better identify where cooperation and joint
activities with other Federal agencies, industry, and academia can
yield significant gains;
• Moves laboratory leadership to field and creates necessary condition
to empower laboratory directors and Federal scientific teams;
• Creates opportunities to build new working relationships between
ORD and its clients; and
• Creates the opportunity for greater scientific career development in
the staff.
Potential Limitations:
• Science leadership and innovation by National laboratories must be
guided by a strengthened research planning and decision process that
includes effective participation of Program and Regional Offices in
establishing needs, priorities and accountability; and
24
-------
• Processes must be established that support laboratory-based science
leaders allowing them to interact effectively in national and
international policy and science forums.
This functional reorganization of ORD's research activities will not only
facilitate risk assessments in general, but also will allow better place-based
assessments. When the need arises for place-based studies or assessments,
teams made up of individuals with the appropriate expertise will be constructed
from the various National laboratories to conduct the work themselves and work
with Regional laboratories or field personnel to carry out the studies and
assessments.
There was significant discussion within the Steering Committee regarding
the need for major physical consolidation to accompany the functional
consolidation proposed here. A number of options for physical consolidation were
identified; analyses of these options are included in the Appendices to this report.
These analyses demonstrate that some Agency employees believe that combining
laboratories at a single location will improve teamwork and raise productivity. On
the other hand it is clear that, at least over the near term, consolidation will be
costly, will disrupt ongoing research and will damage employee morale. Balancing
these considerations, it was decided that the important science and management
improvements described in this report should be implemented and given time to be
integrated into planning and budgeting operations before any decision on physical
consolidation and relocation of staff would occur.
The Steering Committee accepted the SAB and NAPA recommendation to
focus on functional, not physical, consolidation in the near term. Once these new
structures are fully operational, EPA should periodically seek external examination
of the ORD laboratory and science/technology functions. This would include:
where the long-term Research Plan requires expertise not adequately represented in
the laboratories; where in-house centers of research excellence have emerged from
the competitive process; means for refocusing activities in facilities to better meet
environmental research needs; and whether over the long-term there is any merit
to consolidation of operations.
Recommendations:
• Adopt a modified version of the Carnegie Commission proposal for
ORD laboratory organization that is based on a risk assessment/risk
management paradigm.
• Establish Implementation Subcommittees to develop the specific
mission statements and structures for the proposed National
laboratories.
25
-------
Take advantage of opportunities for administrative consolidation at
Research Triangle Park, NC and Cincinnati, OH.
Periodically seek external review of its implementation of the
recommendations in this report, including implementation of the
management changes, RDTS strategy, and functional reorganization.
While no physical consolidation is recommended in the near future, as
part of a periodic review, the benefits and costs of physical
consolidation would be assessed.
26
-------
PROGRAM LABORATORIES
The Steering Committee recognized the importance of maintaining Program
laboratories. With their clear missions and customer focus, they provide vital
technical support to assist in the regulatory development and enforcement in the
mission areas of their parent Program Offices.
Issues:
• Missions and customers of Program laboratories;
• Relationship between ORD and Program laboratory activities; and
• Current or potential overlaps and duplications of laboratory activities.
Discussion:
The clarity of both mission and customer focus for Program laboratories was
identified in both the MITRE and the NAPA reports and affirmed by the Steering
Committee. The distinction between "overlap of capability" and "duplication of
effort" of laboratory activities was noted, with the former acceptable and
justifiable in most circumstances, and the latter to be avoided. In addition, the
advantages of laboratory co-location as opposed to physical consolidation were
discussed as a means to achieve a "critical mass" of Agency staff at a given
location without diminishing effectiveness. The need to address both existing
duplication of effort in Agency laboratories as well as the potential for such
duplication in the overall Agency laboratory organizational redesign was
recognized. The Steering Committee acknowledged the need for increased
engagement of the Program Offices and their laboratories in the Agency's RDTS
planning program.
Recommendations:
• Maintain the current structural configuration of Program laboratories.
• Develop and implement a mechanism for the strategic planning of
Program laboratory technical issues, and link it to the enhanced
. strategic research and development planning and accountability
process recommended elsewhere in this report.
• Where duplication of effort exists between ORD and Program
laboratories, the Program laboratory should continue the activity as
needed with sufficient resources. ORD should redirect its energies
toward other high priority objectives.
27
-------
Explore improved development and communication of analytical
methods across the Agency and eliminate inconsistencies in methods.
Develop a planning process to prevent future duplication of Agency
laboratory activities as the new ORD organizational structure is
designed and implemented.
The Steering Committee charged the Program Offices with
laboratories (OAR and OPPTS) to conduct a fast-track evaluation of
consolidation and functional overlap issues for the Steering
Committee's consideration. The criteria to be used in the evaluations
were whether any such consolidations would increase efficiency and
effectiveness while providing greater scientific quality.
Following the charge of the Steering Committee, The Office of
Radiation and Indoor Air conducted a review of the merits of
consolidation of its laboratories and appropriate duplicate ORD
laboratory activities into the Program laboratories. Their
recommendations were presented to the Steering Committee on
July 11,1994, (Attachment E) where they received general support
and were referred to an Implementation Subcommittee for additional
evaluation and action. OAR recommendations included:
• Administrative and physical consolidation of the resources and
functions of the ORD Environmental Monitoring Systems
Laboratory Radiation Science Division in Las Vegas into the
Office of Radiation and Indoor Air (ORIA) Laboratory in Las
Vegas;
• Maintenance of status quo at the ORIA National Air and
Radiation Environmental Laboratory in Montgomery, AL; and
• Use of the ongoing ORIA streamlining and organizational
assessment to evaluate additional administrative and physical
consolidations of radiation laboratories over the next two years.
Again, following the charge of the Steering Committee, the Office of
Pollution Prevention and Toxic Substances (OPPTS), Office of
Pesticide Programs conducted some preliminary evaluations and
determined that more time would be required to thoroughly evaluate
the merits of combining the functions or physically consolidating their
two laboratories currently in Bay St. Louis, MS, and Beltsville, MD. A
report on these further analyses is expected November 1, 1994.
OPPTS intends to proceed with the movement of its Beltsville, MD
28
-------
laboratory to a new site at Fort Meade, MD, where they will co-locate
with the Region 3 laboratory. This project is well into the design
phase and construction monies for the OPPTS laboratory are included
in the Agency's FY 1995 budget request.
Program Offices and their laboratories should fully engage with ORD
and the Regions through the RDTS planning process to define Agency-
wide research needs and capabilities.
29
-------
ENVIRONMENTAL SERVICES DIVISIONS
Environmental Services Divisions are located in the Regions and support a
full range of customers, the Regional Administrators, Program divisions, State/local
and Tribal governments, and the regulated community. Their multi-media functions
include environmental monitoring, analytical services, quality assurance, field
investigations, technical transfer/services, applied methods development/validation,
and environmental data handling. ESDs draw on the research and development
work of ORD and the Program Offices in their implementation activities.
Issues:
Need to strengthen current Headquarters advocacy for ESDs;
Lack of dedicated resources (FTE/Dollars) for ESD services in budget
planning process;
Perpetual resource instability due to changing priorities;
Lack of dedicated Building and Facilities (B&F) and Repair and
Improvement resources;
Lack of integrated Cross-Program system for analytical methods
development to meet statutory requirements;
Lack of validation of methods before issuance of regulations; and
Instability of ESD support to States/regulated community.
Discussion;
The Steering Committee worked to achieve an understanding of the issues
surrounding the Regional Environmental Services Divisions and their analytical
laboratories. It was noted that ESDs are organizations that have strong customer
alignment and a high degree of efficiency and effectiveness in providing a
responsive service for the Regions. The Steering Committee did not propose any
reorganization of the Regional laboratories but advocated management actions and
the designation of an individual .with a key dotted-line relationship to the ORD and
the Program Offices. Currently the Associate Administrator for Regional
Operations and State/Local Relations (AA/OROS/LR) represents the Environmental
Services Divisions in budget negotiations. Since OROS/LR is in the Office of the
Administrator, budget caps are applied that may make expansion of the ESD
program element needed for creation of the ESD base problematic. A
30
-------
Subcommittee was asked to review alternative Assistant Administrator-ships as
possible advocates for the ESDs.
Discussions about funding mechanisms for the ESDs ranged from the current
system to consideration of full engagement of ESDs in the Agency's annual budget
planning decisions. Designation of core resources for the ESDs was considered.
Concerns were raised that Program Offices might feel they had met their full
funding responsibilities for the ESD activities by creating the ESD core. The net
effect might be the overall loss of programmatic support for the ESDs. The Deputy
Administrator asked how the ESDs might achieve greater efficiency and
effectiveness through participation in national planning and networking. The role
of potential centers of excellence in the Regional laboratories was discussed in the
terms of maintaining full service, place-based laboratories in all ten Regions while
investing in costly state-of-the-art specialization in certain laboratories.
ESDs are presented technical issues associated with the implementation of
the Agency's regulations. To get basic needs for development of analytical
methods and proficiency testing materials, ESDs must rely on personal
relationships, ad hoc committees and informal connections. A formal mechanism
is needed for the ESDs to access the tools they require to implement the
regulations. A partnership between ORD, the Program Offices and ESDs in the
development of the Agency's regulations and funding must be assured for
provision of these basic tools.
Recommendations '.
The EPA Laboratory Study Steering Committee:
• Endorsed the current decentralized model for the provision of a full
range of routine analytical services to the Regions. Regional
laboratories are a critical element of the Environmental Services
Divisions which provide integrated laboratory, field, and quality
assurance functions to the Regions. The current design is best
prepared to meet the scientific and technical needs of the Regions and
their customers as it directly:
• • Provides scientific/technical advice to the Regional
Administrators;
«• Supports Regional Program divisions; and
• • Provides technical services and oversight functions for States,
local governments and tribes.
31
-------
Recognized the need to review the optimal Headquarters senior
management advocate for the Environmental Services Divisions to
ensure the most effective representation of their interests in the
Agency's planning and budgeting processes.
Called for the evaluation of opportunities for development of centers
of excellence in selected Regional laboratories. These centers would
be an adjunct to the routine core functions of the Regional
laboratories. They would provide analytical services requiring highly
specialized, state-of-the-art instrumentation, facilities or personnel
which would not be cost effective to duplicate across ten laboratories.
Strongly endorsed establishment of a core set of resources for the
ESDs.
Recommended that the ESDs and their laboratories fully engage with
ORD and the Programs through the RDTS planning process to define
Agency-wide research needs and capabilities. Planning and oversight
of an Agency-wide program to develop and validate methods for
environmental measurement would receive high priority.
Charged a Cross-Agency Subcommittee, by June 23, 1994, to
evaluate:
Options for the organizational location of a central Headquarters
advocate and their national planning functions and budget
formulation for ESDs;
Creation of a dedicated resource (FTE/dollars) base for ESDs;
Available budget mechanisms (program element, line item) and
location for ESDs including B&F and capital equipment;
Coordination options to the Agency budget planning process
and strategic planning; and
Functional and organizational alignment of ESDs with program
offices and ORD in performance of the Agency's scientific and
technical mission.
Following the charge of the Steering Committee, a Cross-Agency
Subcommittee considered issues related to the ESDs. Their recommendations
were presented to the Steering Committee on July 6, 1994, (Attachment F) where
they received general support and were referred to an Implementation
32
-------
Subcommittee for additional evaluation and action. The Subcommittee
recommendations included:
• The National BSD Central Advocate, from a neutral office perspective,
assure and maintain the alignment between scientific and technical
services of ESDs and their clients;
• OROS/LR should continue as the National ESD Central Advocate with
enhanced management and budget support to the ESDs;
• A balanced ESD budget be created to provide greater resource
stability for ESDs while maintaining flexibility to respond to Program
requirements;
• A National budget for ESDs be established in a program element (PE)
under the Central Advocate's budget responsibilities. This PE would
be the sum of the core resources currently across the ESDs. The
remaining elements of the existing ESD base would be established as
line items in the budgets of their respective Program Offices.
Increased capabilities and capacities would continue to be established
through the existing negotiation process;
• The National ESD Central Advocate, in coordination with the Regional
Administrators, would ensure integration of ESD scientific and
technical services into the Agency's RDTS strategic plan;
• To maintain their strong client focus, the ESDs should develop an
integrated process to evaluate its current and forecast its future
science and technical service requirements.
• Specific issues surrounding the organizational location of the National
ESD Central Advocate and the development of a National ESD budget
will have to be developed in the Implementation Phase of this Study.
33
-------
IMPLEMENTATION ACTIONS
Overview
Implementation of the broad range of proposals discussed in this report will
require a concerted effort over the next several months. In some instances
significant action will be completed in the near term, but most often
implementation can be expected to require several years.
The changes contemplated by these proposals are intended to strengthen
the scientific and technological base of the Agency and should result in new and
expanded opportunities for professional development of EPA employees.
Throughout, care will be taken to minimize adverse impacts on individual careers
and disruption of the Agency science program.
Implementation Coordination
Overall coordination and oversight of these initiatives will be provided by an
expanded Cross-Agency Steering Committee; the current Steering Committee will
be expanded to include additional members from the affected organizations
including the laboratories and the Unions. Six implementation Subcommittees,
listed below, will be created under the Steering Committee to develop an
implementation master plan by November 1, 1994. The master plan will receive
full review and ratification by the expanded Steering Committee. A formal tracking
process will be established to permit Agency-wide monitoring of implementation
actions.
The Implementation Subcommittees will be lead by managers from ORD,
OARM, the Program Offices, and the Regions. The Subcommittees will be staffed
by managers, non-supervisory staff and Union representatives; the process for
staffing the Subcommittees is currently being developed. The current listing of
Implementation Subcommittees follows:
1. Research Leadership and Focus Subcommittee
Issues:
• Risk-based Research Priorities and Accountability.
• Three-year Implementation Plan.
• Long-term Strategic Environmental Research Funding Plan.
• Mission Overlap of EPA Laboratories.
34
-------
2. ORD Organizational Structure Subcommittee
Issues:
• New ORD National Laboratories, including facilities.
• Management & Financial Structures for the new National Laboratories.
• ORD Headquarters Function & Structure.
• Administrative Consolidation Options.
3. Regional/Program Office Laboratories Subcommittee
Issues:
• OAR Action Plan.
« OECA Action Plan.
• OPPTS Action Plan.
• OSWER Action Plan.
• OW Action Plan.
« Regionai/ESD Action Plan.
• Administrative Consolidation Options.
4. Cross-Cutting Management and Administrative Subcommittee
Issues:
« Management & Financial Structures for the new National Laboratories.
• Contractor Utilization.
« Management Controls.
35
-------
5. Science Quality Subcommittee
Issues:
• Quality Assurance program implementation.
• Peer Review program implementation, including Federal Advisory Committee
Act negotiations.
6. Science and Scientific Career Subcommittee
Issues:
• Personnel Development.
• Workforce Planning.
• Fellowship Program.
-------
LABORATORY STUDY
AGENCY-WIDE STEERING COMMITTEE MEMBERS
Ex Officio, Robert M. Sussman, Deputy Administrator
Co-Chair, Jonathan Z. Cannon, Assistant Administrator, Office of Administration
and Resources Management
Co-Chair, Gary J. Foley, Acting Assistant Administrator, Office of Research and
Development
Co-Chair, Shelley Metzenbaum, Associate Administrator for Regional Operations
and State/Local Relations
Frank M. Covington, Director, National Enforcement Investigative Centers
Tudor T. Davies, Acting Deputy Assistant Administrator, Office of Water
James Dryer, President, NFFE Local 801, Cincinnati, OH
Gerald A. Emison, Deputy Regional Administrator, Region 10
Jeanne Fox, Regional Administrator, Region 2
Lynn Goldman, Assistant Administrator, Office of Prevention, Pesticides and Toxic
Substances
i
Ann Goode, Acting Deputy Assistant Administrator, Office of Air and Radiation
Dennis Grams, Regional Administrator, Region 7
John Hankinson, Regional Administrator, Region 4
Victor J. Kimm, Deputy Assistant Administrator, Office of Prevention, Pesticides
and Toxic Substances
Henry L. Longest, II, Director, Office of Emergency and Remedial Response, Office
of Solid Waste and Emergency Response
Sylvia K. Lowrance, Associate Deputy Administrator, Office of the Administrator
John C. Martin, Inspector General
William F. Raub, Science Advisor to the Administrator
37
-------
Barbara White, EPA Region 1, President, AFGE National Council of EPA Locals
Joe D. Winkle, Deputy Regional Administrator, Region 6
38
-------
APPENDIX A
-------
•
«^
Q.
HI
O^"™
z
u- £
ZZ S
O Q.
Q "J
•Mp ^^V
s Q
< IQ
1 1 ^ o 3?
1 Q O "^
i \ T Hi IT!
II «"• fcfcl *•*••
uj a: o
ID. z a:
<• o 55
^**, _i UJ
CO CO
CO UJ
11 KMHI _
li *~ f^
! /^ V"'
Oil!
Lu
ot
If 3"*
i
O
•
o c
t: s
00
<*••
to o
L. 0
.£2 o
.E Q
£^^^
T5
< s
^•s
HM f^
£1 Q
s s
W/ft
Mt
C0 «o
o J2
^ 3
C 0)^
•g K g
aj -73 °-
g£
i^
O 2
t-
'c
OJ C
{£ CO
^^
o
a> E
O CO
1?"* %"
*- O)
0 o
a.
c
o
If
uj a»
u
£
o
•*^
IE °^
0
5 «
O 5 T»
S||
0 « S
g <2 Q
O =
UJ
•a
c
O) * *
c w S
|| 2
? *0 rf
Office o
Monitoring
Quality
_ j=
+3 O
"5 5 £r
5 S I
- a> IS
'•J5 ® Jj
2 UJ
S 0
<^ <4W
2 o
0 J3
u to
LU -1
.2 S
CO ^^
z OT
15 S*
c 2
o> to
^ f^\
5.i
1 i
'•S OS
to c
S UJ
15
c 2
CD C
r-
-------
APPENDIX B
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JJN 2 2 1994 •
MEMORANDUM
OFFICE OF
RESEARCH AND DEVELOPMENT
SUBJECT: Recommendations for National Center for Environmental
Assessments
FROM:
TO:
William H. Farland, Ph.D.
Director
Office of Health and Environmental
Assessment (8601)
Gary J. Foley
Acting Assistant Administrator
for Research and Development (8101)
As part of the Laboratory Study Steering Committee meeting
held in Annapolis, MD on June 7-8, 1994, several recommendations
for the Administrator were developed which will have significant
implications for ORD. Two of these recommendations, the
reorganization of ORD along the lines of the NAS Risk Assessment
paradigm, and the prioritization of ORD's research to reduce
uncertainty in risk assessment, have broad ramifications for the
risk assessment function both within and outside of ORD. To
begin to discuss and plan for change, you requested that I
convene and chair an interoffice working group to look into
several issues concerning the planned National Center for
Environmental Assessment (NCEA, variously spoken of at the
Annapolis meeting as the National Assessments Laboratory,
National Risk Assessment Research Laboratory, or the National
Risk Assessment Center).
The working group viewed the establishment of the National
Center very favorably. It would clearly establish an
identifiable risk assessment focal point for those outside ORD.
It would provide "one stop shopping" for risk assessment research
and information for Program and Regional Offices, and would
establish a responsibility center for risk assessment issues from
Congress, other Agencies, and the scientific community. Within
ORD, the Center provides the focus for the anticipated risk-based
research, and should take a central role in planning research to
reduce uncertainty in the Agency's risk assessments. The Center
would also strengthen the quality of the Agency's risk-based
decisions by providing consistent risk assessment approaches for
broad Agency use, and by putting new methods and the latest risk
information in the hands of the Agency risk assessors across the
country.
Printed on Recycled Paper
-------
In addition to discussing the value added by such a Center,
the_working group has also discussed several key management
decisions that must be made, and issues of consolidation of
functions, operations, physical consolidation and relocation, and
functional relationships once the new Center is established.
These issues are spelled out in greater detail in the attached
report.
In summary, the working group recommendations are as
follows:
1. That the charter for the Center reflect the need to include
some research into "value" analysis. Although this is outside
the scope of the NAS risk assessment paradigm, it is a necessary
starting and interpretive point for ecological assessments (to be
able to deal with a multitude of potential risks in the context
of their perceived values to society).
2. The working group anticipates that NCEA would have a
leadership role in the Agency's National and Global scale
assessments, including serving as a focal point for intra-agency
and interagency teams to get the assessments done. The working
group recommends that senior Agency management (Senior Leadership
Council?) agree on the process by which the lead role for
National or other large scale assessments is assigned, whether to
the Center or to Program or Regional Offices.
3. The working group recommends that Science Policy Council
discuss and agree on what role of the Center will play as a
quality check on important Agency assessments, especially those
done in offices where the research, assessment, and risk
management functions are in the same line organization.
4. Although there is much risk-related training available in
various parts of the Agency, there is a recognized need for more
and better risk assessment training, since having a well-trained
and scientifically current cadre of Agency risk assessors is a
key to the Agency's risk assessment credibility. The NCEA could
play a pivotal role in risk assessment training for the Agency.
A work group (the Agency's Risk Training Committee?) should be
tasked to study how the new Center should interact with these
diverse training activities, and whether significantly more
resource emphasis needs to be given to this topic.
5. The working group views ORD's current Office of Health and
Environmental Assessment as the primary building block of the new
NCEA, with some additional functions being added from within ORD.
Among other responsibilities, the NCEA should become the focus
for Agency risk assessment guidelines, cross-office risk
assessments, and dealing with other Agencies, OSTP, and Congress
on risk-related scientific issues.
-------
6. The NCEA should establish relationships with "customers" such
as the Program Offices and Regional Offices that are customized
to the customer's needs, ranging from consultation and advice to
more hands-on development of risk assessments as the customers'
needs warrant. The NCEA should also be viewed as a client or
customer for research in model development, data collection,
toxicology, etc. that is performed elsewhere in ORD.
7. Because of the location of the NCEA's major customers is
predominately in Washington, the headquarters of the NCEA should
be located in or very near Washington, DC. Separating the NCEA
from the EPA Headquarters building would help establish an
identity as a National Center.
8. There was strong support for ORD's assessors having an
organizational home in the NCEA, but for certain assessments
(e.g., area-based ecological assessments) having the individual
assessors on-site in the field to have close contact with those
who develop the data.
Attachment
-------
-------
ISSUES AMD RECOMMENDATIONS
NATIONAL CENTER FOR ENVIRONMENTAL ASSESSMENTS WORKING GROUP
On May 31, 1994, a Congressionally requested, EPA-commissioned
report called Assessment of the Scientific and Technical
Laboratories and Facilities of the U.S. Environmental Protection
Agency was completed by Mitre Corporation. In this so-called
"Mitre Report" were a number of options for changes in the way
EPA's laboratories (both within ORD and outside of ORD) are
organized and managed. To respond to the Mitre Report, the
Administrator requested recommendations be developed by a high-
level committee made up of representatives from the AA-ships,
Regions, and Offices having a stake in EPAfs laboratories. This
committee, called the Laboratory Study steering Committee (LSSC),
met in Annapolis, MD, on June 7-8, 1994, to develop these
recommendations.
During the course of the Annapolis meeting, the Committee agreed
to recommend that ORD be reorganized around a modification of one
of the options discussed in the Mitre Report. This so-called
"Carnegie Commission" option, named for the 1993 commission which
suggested it, would have ORD reorganized into a small number of
National Laboratories. In the Annapolis meeting, it was agreed
that four National Laboratories would be established, organized
around the 1983 National Academy of Science risk assessment
paradigm: Effects, Exposure, Risk Characterization, and Risk
Remediation. It was further agreed to recommend that the
research done by ORD be focused on helping the Agency make better
decisions by reducing the uncertainties in the Agency's risk
assessments.
During the Annapolis meeting, the LSSC established several short-
term working groups to study the issues and make recommendations
for resolving issues surrounding the new proposed National
Laboratories, tentatively called the National Effects Laboratory,
the National Exposure Laboratory, the National Center for
Environmental Assessments, and the National Risk Reduction
Research Laboratory, respectively. This is the report from the
working group assigned to study issues related to the proposed
National Center for Environmental Assessments. The working
group, headed by Dr. William H. Farland, was given a charge to
develop, by June 22, 1994, options, pros and cons, and
recommendations specifically concerning five questions (listed as
#1-5, below). The Working Group, as a start, outlined and
discussed several additional, more fundamental issues which must
be resolved, namely:
A. What is the scope of the assessments envisioned for this
Center; are they strictly risk assessments, or more?
-------
B. For the assessments done by the Center, what is the scale of
the assessment, or the criteria or process by which the
assessments are chosen?
C. What should the role of the Center be in acting as a quality
check on assessments done elsewhere in the Agency?
D. What should the Center's role be in risk assessment training?
The issues the working group was charged by the LSSC with
resolving were:
•1. In considering consolidation of the risk assessment function
within EPA into a National Center for Environmental Assessments
(NCEA), what functional units are among the universe to be
considered?
2. What would be the nature of the consolidation?
3. What physical consolidation would take place?
4. Where would the Center Headquarters be located?
5. What would be the functional relationships between this
laboratory and the others, and with the outside organizations?
The working group viewed the establishment of the National Center
very favorably. It would clearly establish an identifiable risk
assessment focal point for those outside ORD. It would provide
"one stop shopping" for risk assessment research and information
for Program and Regional Offices, and would establish a
responsibility center for risk assessment issues from Congress,
other Agencies, and the scientific community. Within ORD, the
Center provides the focus for the anticipated risk-based
research, and should take a central role in planning research to
reduce uncertainty in the Agency's risk assessments. The Center
would also strengthen the quality of the Agency's risk-based
decisions by providing consistent risk assessment approaches for
broad Agency use, and by putting new methods and the latest risk
information in the hands of the Agency risk assessors across the
country.
In summary, the working group recommendations are as follows:
1. That the charter for the Center reflect the need to include
some research into "value" analysis. Although this is outside
the scope of the NAS risk assessment paradigm, it is a necessary
starting and interpretive point for ecological assessments (to be
able to deal with a multitude of potential risks in the context
of their perceived values to society).
2. The working group anticipates that NCEA would have a
-------
leadership role in the Agency's National and Global scale
assessments, including serving as a focal point for intra-agency
and interagency teams to get the assessments done. The working
group recommends that senior Agency management (Senior Leadership
Council?) agree on the process by which the lead role for
National or other large scale assessments is assigned, whether to
the Center or to Program or Regional Offices.
3. The working group recommends that Science Policy Council
discuss and agree on what role of the Center will play as a
quality check on important Agency assessments, especially those
done in offices where the research, assessment, and risk
management functions are in the same line organization.
4. Although there is much risk-related training available in
various parts of the Agency, there is a recognized need for more
and better risk assessment training, since having a well-trained
and scientifically current cadre of Agency risk assessors is a
key to the Agency's risk assessment credibility. The NCEA could
play a pivotal role in risk assessment training for the Agency.
A work group (the Agency's Risk Training Committee?) should be
tasked to study how the new Center should interact with these
diverse training activities, and whether significantly more
resource emphasis needs to be given to this topic.
5. The working group views ORD's current Office of Health and
Environmental Assessment as the primary building block of the new
NCEA, with some additional functions being added from within ORD.
Among other responsibilities, the NCEA should become the focus
for Agency risk assessment guidelines, cross-office risk
assessments, and dealing with other Agencies, OSTP, and Congress
on risk-related scientific issues.
6. The NCEA should establish relationships with "customers" such
as the Program Offices and Regional Offices that are customized
to the customer's needs, ranging from consultation and advice to
more hands-on development of risk assessments as the customers'
needs warrant. The NCEA should also be viewed as a client or
customer for research in model development, data collection,
toxicology, etc. that is performed elsewhere in ORD.
7. Because of the location of the NCEA's major customers is
predominately in Washington, the headquarters of the NCEA should
be located in or very near Washington, DC. Separating the NCEA
from the EPA Headquarters building would help establish ah
identity as a National Center.
8. There was strong support for ORD's assessors having an
organizational home in the NCEA, but for certain assessments
(e.g., area-based ecological assessments) having the individual
assessors on-site in the field to have close contact with those
who develop the data.
-------
ISSUES, DISCUSSION, and RECOMMENDATIONS
The interagency working group (membership listed in attachment)
was first convened on June 14, then again on June 20, with
members attending either in person in Washington or by
teleconference. The following is a list of the issues, a summary
of .the discussioli, and the sense of the working group in terms of
recommendations on each. The first four issues (A-D) deal with
fundamental decisions which better define the vision of a Center
for Assessments; these decisions need to be made early in the
life of the NCEA and need agreement or support from groups
outside of ORD. The final five issues (1-5), from the charge to
the working group, deal with some of the organizational questions
which have to be resolved.
KEY MANAGEMENT DECISIONS
A. Scope of the Assessments Done by the NCEA.
Issue: Should the NCEA focus solely on risk assessments, or will
it become a focal point for economic, social science, and other
types of assessments?
Discussion: Some group members suggested that the scope of the
NCEA be greater than risk assessment, per se, and that research
into economics and social scientific and behavioral aspects of
risk analysis be included in the scope of the charter, also. It
was noted that there doesn't seem to be a one-stop "home" that
Program Offices can go to for all the aspects of risk analysis.
Although it might start as a risk assessment organization, there
was discussion of the possibility of NCEA evolving into an
organization which could deal with economic and benefit
assessments. OPPE currently has extensive risk analysis
activities including economics, risk training, and risk
communication. Bringing such related activities together under
the NCEA would allow all of these activities to get the benefit
of the strong guidance, quality control, and model validation
aspects that have been evolving on the risk assessment side. It
would also provide a focal point for risk assessment and related
analytical research. On the other hand, economics research is
not very much like the kinds of research done in risk assessment,
and requires different disciplines.
After discussion, the sense of the group was that economics
research as a field was different enough from risk assessment to
warrant being done outside the Center. Nevertheless, there was
support for the need, especially in ecological assessments, for
the Center to go beyond the strict limits of the NAS risk
assessment paradigm. At least for ecological assessments, there
are chronically unanswered questions about how society values
-------
certain ecological resources, and the way society , chooses to
prioritize resources when choices must be made. These questions
affect the approach to the ecological assessments themselves,
since choices must be made by assessors about which among a
plethora of endpoints are important enough to merit attention,
and the use of assessment resources.
Recommendation: The working group recommends that the charter
for the National Center for Environmental Assessments include
"value analysis" research. The group recommends that economic
and benefits assessments not be a part of the responsibilities of
the Center at the start, but that this decision be reevaluated as
the Center matures within the next 3-5 years.
B. Seal* of NCSA's Assessments.
Issue: One of the duties of the NCEA will be to perform risk
assessments. By what criteria or process will the Agency decide
when an assessment should be done by the Center and when it
should be done elsewhere, either within or outside the Agency?
Discussion: There was a strong sense in the working group that
the new National Center for Environmental Assessments would
quickly become a focal point for risk assessment within the
Agency, and as such, would probably have to take on the
responsibility of multi-Agency coordination on issues such as
comparative risk and cumulative risk.
NCEA should also have a representational role outside the Agency,
where it should become the focal point for risk assessment
aspects of international activities such as harmonization.
The working group also discussed the possible roles the Center
could play within the Agency. In general, the group, saw large,
multimedia assessments with a National scope as falling under the
coordination of the Center, if not being done by the Center
outright. It was less clear how large assessments which may have
"a natural home," such as the stratospheric ozone work in OAR,
would relate to the Center. It was generally agreed that
routine, small-scale assessments currently being done in Program
Offices and Regions would not necessarily need to be done under
the Center, although the Center should maintain an advisory role
and could provide some assistance. The group agreed that the
Agency needs to agree on the process concerning how, when, and by
whom (Senior Leadership Council?) the Center would be assigned
multimedia assessments.
Recommendations: The working group recommends that senior Agency
management (Senior Leadership Council?) agree on criteria
concerning the scale of assessments which would naturally fall
under the Center's mission. These criteria should include the
process of how, when, and with whom the Center would agree to do
-------
large, multimedia assessments.
C. Role of NCEA as Quality Check.
Issue: Should the National Center for Environmental Assessments
provide a neutral quality check for assessments done within
offices where the risk assessment function and risk management
function are within the same line organization?
Discussion: It was noted that there are some Programs where the
laboratory research, assessment function, and management
decisions are all contained in the same line organization. This
has led in the past to the Agency being questioned, rightly or
wrongly, about the possibility of allowing management preferences
to influence the results of scientific assessments. There was
discussion of what the role of the Center would have in acting as
"checks and balances" for large assessments done in these
Programs.
The working group was divided on whether the NCEA should play
such a role. Many in the group, particularly those in Program
Offices, noted that they believed peer review would suffice,
while others felt strongly that the Agency should utilize the
Center as a neutral advisor to Agency top management as a "check
and balance." Although this issue was not resolved, the group
agreed that the Center's role in the quality check of other
Agency assessments needs to be clarified by the Agency.
Recommendation: The working group recommends that the Science
Policy Council resolve this policy issue before the NCEA is
established, to avoid later misunderstandings.
D. Role of NCEA in Risk Assessment Training.
Jssue: Should the lead for Agency risk assessment training be
housed within NCEA? This could result in establishing a Risk
Assessment curriculum for determining minimum training needed for
Agency risk assessors.
Discussion: Currently, there are many courses being given within
EPA in various aspects of risk assessment. Many of these are
quite successful, but few are routinely available to all the
Agency's assessors. Although there have been efforts to
catalogue these courses by the Risk Training Committee and the
EPA Institute, there is no mandate currently to put together a
cohesive curriculum out of these many courses, or to establish
certain minimum training requirements for Agency scientists who
perform risk assessments. There is some benefit to having the
lead role for such risk assessment training within ORD, since
state-of-the-art research and methods development are being done
there, much as research in academic institutions is linked to
University courses and curricula. This lead role would entail
-------
working with the EPA Institute and the groups around EPA to
define risk training needs, highlight courses already available
in a systematic way, and if necessary, to develop new courses
(with Agencywide involvement). Currently, risk assessment
training has not received high priority or visibility within the
Agency. If such a risk assessment curriculum and training
program, which could significantly upgrade the analytical skills
of EPA scientists, is to be one of the basic missions of NCEA, it
must receive the attention and support of Agency Management.
Ultimately, such a training program could lead to a certification
of risk assessors within the Agency. This certification program
could be established with the help and approval of the
appropriate professional societies (Society for Risk Analysis,
International Society for Exposure Analysis, Society of
Toxicology, etc.)
There is much that is appealing about NCEA taking the lead role
in risk assessment training. On the down side, this is a program
that would have to be developed on a much different scale than is
currently being done, so it would take resources and management
attention.
Recommendations: The working group recommends that a working
group (Risk Training Committee?) be tasked by Senior Management
to study how NCEA will interact with other Offices in the
Agency's risk assessment training. If the Center is to take an
active lead in the training aspects of risk assessment, the
working group should plan the details of this role as soon as
feasible.
KEY ORGANIZATIONAL ISSUES
The remaining issues were included in the original charge to the
working group.
1. Consolidation of Functions.
Issue: In considering consolidation of the risk assessment
function within EPA, what functional units are among the universe
to be considered? As a starting point, risk assessment
activities may be currently being done in at least the following
organizational units: OHEA/ORD, RAF/ORD, parts of AREAL, ERL-
Athens, the NHEXAS and EMAP programs in ORD, parts of OPP, OPPT,
OAQPS, Mobile Sources, ODW, OST/OW, ORP, osw, HSED/OEER, and
Regional risk assessments. Which of these (or others) should be
considered for potential consolidation? Only ORD labs? ORD labs
plus some others? All of the above?
Discussion: The group discussed the nature of the risk
assessments being done in the various organizations listed above,
and made several observationso
-------
First, the Program Offices currently have a rather wide range of
self-sufficiency in the risk assessments they perform. This
ranges from organizations like OPP which are highly self-
contained, where the assessors are part of the OPP line
organization and rely little on ORD, to organizations like OAQPS,
which rely heavily on ORD for parts of their risk assessments.
Second, the nature of the assessments themselves varied from
routine, repetitive assessments with an established standard
operating procedure (e.g., the PMN assessments done in OPPT), to
much more complicated, multi-office assessments which must break
new ground in methodology (e.g., the recent dioxin reassessment
being headed up by ORD).
Because of the wide ranging differences in both self-sufficiency
and nature of the assessments, it was suggested that the NCEA
should start, for the purposes of discussion, with a baseline
mission much like what OHEA does currently (viz., doing certain
risk assessments, providing guidelines for the Agency,
consultation, doing research to improve risk assessment methods,
and developing, facilitating consensus, and transferring risk
assessment information such as IRIS, RfDs, and criteria
documents, which are used both within and outside EPA). The
discussion then centered around adding to, or subtracting from,
this baseline mission.
It was the working group consensus that the NCEA would
appropriately have different relationships with different
customers, depending on the customers* needs. Since all Program
Offices and Regions are not equally self-sufficient in the risk
assessment area, the NCEA will have to be flexible. For example,
under the "OPP model," the Program Office would receive basic
guideline and consultation support, along with products of
research, but the Program Office would do the actual construction
of risk assessments to be used in their decisions. Under the
"OAQPS model," we would anticipate more routine, day-to-d.ay
aspects of risk assessments, .such as the effects and dose-
response assessments to be done by ORD. This flexibility would
also allow the flourishing of "joint ventures" between ORD and
customers, such as is taking place with the combustion strategy.
In that case, ORD is providing the scientific rationale and
assessment, which will ultimately be one of the bases for the
.strategy and policy decisions made by the Program Office.
It was suggested that the new NCEA lay out the functional
relationships clearly with each of the Offices, to start with a
baseline much like what is currently in place, and to look toward
possible incremental shifts between the National Center for
Environmental Assessments and units outside ORD as the
relationships solidify.
It was the sense of the working group that within ORD, the risk
8
-------
assessment function, per se, be shifted to the NCEA. This would
also make the NCEA the focal point for cross-cutting assessments
such as dioxin or lead. The group agreed that the risk
assessment part of ORD programs such as EMAP and NHEXAS belong
within the National Center for Environmental Assessments, and
when the assessment part of these programs are done, they should
be done under the NCEA. The NCEA should also be the place where
future development of ecological risk assessment takes place.
Given the multi-Agency focus and the need to deal extensively
with Program Offices and Regions, there was a suggestion that the
relationship to OSPRE be considered, including how research
planning for risk assessment-related research would be done, and
the relationship of NCEA to the Regional Scientist Program.
Although the working group saw a clear need for a research
planning role for risk assessment research within the Center, the
group felt that OSPRE's current role as coordinator of research
planning was wider in scope than would be necessary for the NCEA.
Since the Regional Scientist Program also includes more than risk
assessors, the group felt that this program should remain at a
higher ORD level than in NCEA or one of the other National Labs.
Nevertheless, the working group saw a real need for the NCEA to
develop strong•Regional ties. Although the existing Technical
Support Centers such as the Superfund center in ECAO-Cincinnati
would provide a start, the NCEA needs to work to establish a
Regional presence for advice and assistance. Regional
representatives to the working group expressed concern that the
role of the NCEA relative to Regional assessments be better
defined, lest there be confusion about who has responsibility to
make risk assessment/risk management calls. The working group
did not see the NCEA's role as in any way diminishing the
Regions' or Program Offices' responsibilities to make risk
management decisions. The NCEA is seen as an advisor on the
merits and weaknesses of the scientific credibility of the risk
assessments used, and the risk assessments are only one of
several factors which must enter into risk management decisions.
Under any research planning system used by ORD, the working group
saw a need for the NCEA to have a strong research planning
function, both to plan its own research and to put other risk
research needs into perspective.
The Risk Assessment Forum would logically fit either as an AA-
level staff office (as it is now), or as a part of the NCEA. The
working group briefly discussed the merits of. including the RAF
in either place, organizationally. As an ORD-level staff office,
the RAF can perhaps better project the idea of a cross-Agency
coordinating unit. However, there was some discussion that if
the NCEA moves out of the Headquarters building and becomes a
separate, visible presence outside of Headquarters, it may be
more beneficial for the RAF to be housed along with the Center.
-------
The working group sees merit in continuing the RAF as an AA-level
staff group for the time being, but suggests that this decision
be revisited if the NCEA is established outside of the
Headquarters building.
Recommendations: The working group recommends the initial core
organization of 'the National Center for Environmental Assessments
include the entire current OHEA, the assessment functions
associated with EMAP and NHEXAS, and certain functions currently
within OSPRE. The working group recommends that the
relationships between the NCEA and the other risk assessment
units within the Agency be clarified, starting with certain
ongoing projects (e.g., comparative risk, cumulative risk, the
scientific aspects of the combustion strategy) which can be used
to more clearly determine how the relationship will work. The
working group recommends that the Risk Assessment Forum continue
as an AA-level staff group, but that this decision be reevaluated
if the NCEA is established outside of the Headquarters building.
2. Operations.
Issue: What would be the nature of the consolidation? One
comprehensive line organization? A strong central line
organization made up of some of the above units, with methodology
and implementation oversight responsibilities over all the units?
What functions and people would be part of the central
organization? If not a line organization, would a matrix or
other "cooperative" organization (how managed?) be feasible?
Discussion: There was consensus that the NCEA should be a line
organization within ORD, but that it should also have influence
with outside-ORD risk assessment entities through the
establishment and implementation of guidelines, and that it
should have a major role in setting the research agenda.
The Guidelines role of the NCEA would roughly work as follows.
After a basic set of risk assessment guidelines are established,
departures from the Guidelines can be made by the Agency's
assessors on a case by case basis .if the departures pass peer
review. When these departures are used frequently, or when new
science evolves that can pass peer review muster, the NCEA would
issue interim guidance. Periodically, the guidelines would be
revised to incorporate interim guidance and other methodology
changes that can pass peer review. The risk assessors within the
Agency would be expected to comply with current guidelines or
justify departures from them. The NCEA would not have a
controlling role (i.e., review and sign off), but rather an
oversight role (i.e., advice and assistance). The NCEA would be
expected to advise programs on the scientific supportability of
aspects of the assessments, and would be expected to discuss
perceived weaknesses in the assessments with programs to assure
10
-------
these are acknowledged and dealt with appropriately at high level
decision meetings.
The ORD research agenda is envisioned as being largely driven by
work to reduce uncertainty in risk assessments, and the NCEA must
have a strong role in shaping research to reduce identified
weaknesses in the risk assessments done both by ORD and by
Program Offices or Regional Offices. The NCEA, in this role,
should avoid also become a communication bottleneck between the
bench researchers and the customer programs.
Recommendations: There was consensus that the NCEA should be a
line organization within ORD. The NCEA should also have influence
with outside-ORD risk assessment entities through the
establishment and implementation of guidelines, and should be
involved at least as advisors in potential major Agency actions
that are based on risk assessment. The NCEA should have a major
role in setting the research agenda for ORD. In addition, the
NCEA should be a customer or client for the other National Labs
in applying the results of their research to advance the quality
and substance of EPA's risk assessments.
3/4. Physical Consolidation/Relocation.
Issue: What physical consolidation would take place? Should
everyone in the National Center for Environmental Assessments be
located in one place? Should consolidated functions/units be
left geographically in place and managed centrally? Other plans?
Where would the Center Headquarters be located? WSM? Near
Washington (is a one-hour plane flight "near")? In "the field?"
Discussion: There was strong working group support that the
Center needs to be near its primary customers, and this was
generally viewed as the Program Offices and other Agency
decision-makers, other Agencies, OSTP, and Congress. Because
these customers are in Washington for the most part, and because
of the inter-Agency risk coordination aspects of the National
Center for Environmental Assessments, there was strong support
(consensus) that the Center Headquarters should be in the
Washington DC area. The National Center for Environmental
Assessments should be viewed as an operational Center that,
because of its mission, carries out its mission primarily in
Washington. As to the location of NCEA within the EPA
Headquarters building or somewhere closeby but separate, there
was a feeling that the NCEA as a separate unit would put it on
equal footing with the other National Laboratories, and be viewed
more favorablyf and as a more powerful statement of Agency
commitment, by those outside the Agency.
The pros and cons of physically consolidating the entire Center
into one place were discussed. Currently, OHEA is located in
Washington, Cincinnati, and RTP. There are obvious management
11
-------
efficiencies which could be gained by consolidation in one
physical location, since utilization of skills in team situations
would not be hampered by geographical distance. In general,
managing a geographically dispersed organization is unwieldy and
does not gain the benefit of day-to-day interactions among all
the staff. On the other hand, relocation is very costly, both in
dollars and in disruption. It was pointed out that modern
telecommunication technology may evolve to the point where it
would be just as easy and effective to talk to someone over a
videophone as to meet in person. The sense of the group was that
the NCEA needed to be close to the program offices, which means
Washington and to some extent, RTF (for OAQPS). the Cincinnati
location came about historically due to proximity to the water
research laboratories (WERL, HWERL, now RREL), but it is less
clear today that NCEA presence in Cincinnati is an absolute
requirement.
Although clear advantages and disadvantages exist when
considering consolidation, the working group was reluctant to
suggest moving laboratories. It was felt that this working group
did not have, the time to study the matter and that given the
importance of potential moves, a more cautious approach was
warranted which could consider all the aspects of the matter.
Even if the NCEA were consolidated in one location, it was clear
that the operation of the Center would require much teamwork with
other organizations, and perhaps some location of assessors in
field sites (see #5 below).
Recommendations: The working group recommends that the NCEA be
headquartered in the EPA Headquarters in Washington, DC, or
nearby, where it would be close to the Program Offices and the
other Federal Agencies with which it would have to deal. The
working group discussed pros and cons of physical relocation
under consolidation, but did not reach a concluding
recommendation.
5. Functional Relationships.
Issue: What would the functional relationship be between the
NCEA and the proposed National Exposure Laboratory and National
Effects Laboratory? Customer-Supplier? How about between the
NCEA and the proposed National Risk Reduction Laboratory? How
would research requests and results flow from requester (incl.
Program Offices) to researchers and back again?
Discussion: The working group felt it was important that the NCEA
have a major role in setting the research agenda for the other
ORD National Labs. This would probably take the form of a
leadership role in research planning, including a major voice in
defining and evaluating what "research to reduce uncertainty in
risk assessment" means, but would not preclude direct researcher-
12
-------
customer contact as the research is being done.
The working group also discussed, at some length, the
relationship between the field/bench researchers and the
assessors. Can or should they be the same people? More
specifically, what is the relationship between the NCEA and
field-based assessment projects such as geographically-based
ecological research and assessment? In these cases (the Pacific
Northwest assessment was used as one example), it would be
awkward for all the research, monitoring, etc. to be performed in
one locale, then the data transferred to another group across the
country for data interpretation and construction of the
assessment.
There was also agreement by the work group, however, that having
the same people do the data collection and the risk assessment
has not worked particularly well in the past. When researchers
whose primary job is to produce data are also tasked with doing
assessments, often this is viewed as an ancillary function for
which they get little credit, and perhaps worse. The working
group agrees that we need to have trained risk assessors focusing
on the assessment end of these projects. In the case of
geographically-based ecological assessments, the most effective
way to accomplish this would probably be to have NCEA-trained
assessors on site. There are a variety of ways to
organizationally accomplish this end.
Recommendations: EPA's effort to re-engineer its science program
[see Browner statement, currently in draft] will focus on
promoting research that will have the greatest impact on reducing
the uncertainty in risk assessment and facilitating risk
management. For that reason, the NCEA should have a major role in
setting the ORD research agenda, particularly that portion that
deals with reducing uncertainty in risk assessment, but also work
with the National Risk Reduction Laboratory in their planning of
the risk management research. The working group recommends NCEA
have a strong role in determining customers' risk assessment
needs and working with the National Labs to put together a
program to satisfy those needs. The NCEA should also act as a
facilitator and conduit for dialogue between researchers and
their counterparts in other offices.
There was strong support for ORD's risk assessors having an
organizational home in the NCEA, but for certain assessments,
such as place-based ecological assessments, having individual
assessors on-site in the field would be an advantage.
13
-------
ATTACHMENT
PARTICIPANTS IN NATIONAL ASSESSMENTS LABORATORY WORK GROUP
Name
Bill Farland, Chair
Elmer Akin
Tim Barry
Mike Callahan
Steve Cordle
Jim Dryer
Mike Firestone
Richard Hardesty
Beth Hassett-Sipple
Arnold Kuzmak
Rick Linthurst
Carl Mazza
Jay Messer
Jim Murphy
Dorothy Patton
Charles Plost
Peter Preuss
Hike Slimak
Jeanette Wiltse
Organ i z at ion
ORD/OHEA
Region 4
OPPE
ORD/OHEA
ORD/OEPER
NFFE (Cinci)
OPPTS
ORD/OHEA
OAR
OW
ORD/EMAP
OAR
ORD/OMMSQA
NFFE (HQ)
ORD/RAF
NFFE (HQ)
ORD/OSPRE
ORD/OEPER
ORD/OHEA
'14
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUL 6 1994
MEMORANDUM
SUBJECT:
FROM:
TO:
Additional Working Group
Recommendations Concerning Proposed National
Center for Environmental Assessments (NCEA)
OFFICE OF
RESEARCH AND DEVELOPMENT
William H, Farland, Ph.D.
Director
Office of Health and Environmental
Assessment (8601)
Gary J. Foley
Acting Assistant Administrator
for Research and Development
(8101)
In response to my memo of June 22, 1994, outlining the
recommendations of the working group on the proposed National
Center for Environmental Assessments (NCEA), you noted that the
working group did not make specific recommendations on the issue
of consolidation and relocation. You asked if the working group
would reconsider the issue and try,to reach more solid
recommendations in this area.
The working group met on June 30, 1994 to sjpecifically
discuss the issues of consolidation and relocation. As you might
imagine, these issues were considered very important by the
workgroup, with many aspects of the issues seriously discussed
and weighed.
Although there was not unanimity among working group
members, the sense of the group was that potential benefits of
consolidation were not great enough to outweigh the cost and
disruption of physical consolidation.
The views expressed by the working group members ran the
entire spectrum from strongly pro-consolidation to strongly
against consolidation. Most members saw merit in both the pros
and the cons of the issue, but in the final discussions, a
majority of the group felt that the disruptions that would result
from moving jobs from RTP and Cincinnati would be more costly
than the benefits derived.
Attached is a summary of the group's discussions, comments,
and recommendations.
Attachment
PHnM MIH Seycinett we en PMMT MM
MM TSK raefdM DMr
-------
-------
NATIONAL ASSESSMENTS LABORATORY WORKING GROUP
DISCUSSION AND RECOMMENDATIONS REGARDING PHYSICAL CONSOLIDATION
FOR NATIONAL CENTER FOR ENVIRONMENTAL ASSESSMENTS
The working group met on June 30, 1994, with several members
attending via teleconference and several members providing
comments in their absence.
Issue: The issue on the table was whether the proposed
National Center for Environmental Assessments (NCEA), presumably
to be headquartered in the DC area (as per June 22, 1994
recommendations), should physically consolidate. Such
consolidation would involve moving either or both Environmental
Criteria and Assessment Offices from their present locations (in
RTF and Cincinnati). This could conceivably be done by moving
both ECAOs to the Washington, DC, area, or by consolidating the
NCEA into two locations rather than the current three. The
question of the location of the ecological assessment capability
was raised but not extensively discussed.
Discussion: The working group began by discussing a list of
pros and cons for moving the ECAOs to Washington:
PROS: SOME REASONS WHY NCEA FIELD UNITS SHOULD BE PHYSICALLY
CONSOLIDATED
• A physically centralized structure is more easily
managed since operational communication is enhanced,
can be more streamlined in terms of management
duplication, and can react more effectively to quick-
turnaround assignments.
• There will be closer, more direct personal
communication and interactions among the NCEA
scientists, fostering exchange of ideas on risk
assessment methodology development, and easier
participation in joint assessment projects and
workgroups such as RfC/RfD, IRIS, etc.
• There will be better operational interactions with
Washington-based clients, including Program Offices,
ORD-HQ, other Federal Agencies, OSTP, Congress, etc.
This would allow more direct interaction with these
clients in planning, preparation of strategy,
Congressional testimony, etc.
• Travel costs for within-NCEA interactions would be
virtually eliminated, and travel costs associated with
-------
programmatic travel would be reduced. Travel costs for
Regional meetings would be about the same.
Some redundancies in staffing could be eliminated.
CONS: SOME REASONS NOT TO PHYSICALLY CONSOLIDATE NCEA
• Initial cost of consolidation will be high. In
addition to the cost of moving personnel per se, there
would be have to be new infrastructure built for
maintenance/repair, PC and LAN support, and the other
day-to-day operations of the current field units.
• There would be a disruption of service and
responsiveness of the organization which may run
anywhere from 6 months to 2 years. During the early
stages of this period, responsiveness would be severely
hurt, building slowly back to normal over time. In the
case of ECAO-RTP, this may mean that legally-sensitive
schedules for Air Quality Criteria Documents for Ozone
and Particulate Matter are delayed.
• There would be loss of staff for the units which were
being relocated. This would likely involve some
critical scientific staff (RTF estimate: "some;" Gin
estimate: 60%) and virtually all of the support staff.
• New space would have to be found for the consolidated
NCEA. The consolidated Washington location would be
50-100% larger than current staffing if one or both of
the ECAOs were moved to Washington.
• Both groups would lose the proximity to their current
University associates (Cinci: Universities of
Cincinnati, Dayton, Miami, Kentucky, Northern Kentucky;
RTP: UNC, Duke, NCSU), which provide intellectual
stimulation, library facilities, cooperative student
support, peer participation, and collaborative research
opportunities.
• ECAO-Cin would lose proximity to DOD, DOE, and
TriServices Health Labs at Dayton, diminishing
opportunities for interactions.
• ECAO-RTP would lose proximity and opportunity for
interaction/partnership with NC-based organizations
such as NIEHS, CIIT, NISS,
their extensive libraries.
SAS Institute, etc., and
ECAO-RTP would lose geographic proximity to a primary
Program Office customer, OAQPS. This would also
-------
separate OAQPS from the NAAQS docket files maintained
by ECAO-RTP.
ECAO-RTP would lose geographic proximity to HERL and
AREAL, which will most likely be located in RTP as part
of the new National Laboratories for Effects and
Exposure, respectively. This will hamper opportunities
to continue day-to-day interactions with these labs as
part of the assessments done in RTP. ECAO-RTP would
also lose easy access to the EPA National Computer
Center in RTP.
ECAO-Cin would lose proximity to the National Risk
Reduction Laboratory, which will most likely be located
in Cincinnati.
Travel costs for visiting OAQPS, a major customer, are
now minimal and would increase substantially.
Most of the working group members agreed that these were the
major pros and cons in dealing with potentially moving the ECAOs.
Noting that the ECAOs were originally set up to deal closely with
the Air Office (RTP) and the Water Office (Cin), these offices'
representatives were asked to comment.
OAQPS was a very vocal opponent of ECAO-RTP moving, noting
the disruption of criteria documents currently under development
might be legally "fatal" for them. The ORD/OMMSQA representative
added that they often have face-to-face meetings with the
scientists at ECAO, and when the National Labs are formed, the
National Exposure Laboratory (including the current OMMSQA/AREAL-
RTP) would be a "supplier" to NCEA.
Similar arguments were made for ECAO-Cin, including the
proximity to the proposed National Risk Reduction Laboratory.
The representative from the Office of Water noted that the
geographical location of the ECAO-Cin to the risk assessments
done in the Office of Water was less clear than for RTP, since
most of Water's risk assessments are done out of Washington.
The question was raised as to where the ecological
assessment facility would be located. This could be established
in one of the current OHEA centers (DC, RTP, Cin) or it could be
associated with one- of the major ecological effects laboratories.
Comments from one working group member, on the other hand,
noted that risk assessment is becoming an increasingly multi-
media and cross-disciplinary endeavor, and that because of this,
"it is a futile and expensive anachronism to have risk assessment
people in many locations."
-------
The other representatives took less polar stances,
moderately for or moderately against physical consolidation.
Perhaps typical of these reactions was the comment, "Our
experience with field units is that it's difficult to make them
feel part of the team, .and it's generally a management burden to
have field offices, but there are balancing benefits to having
them there. The answer may lie in what kinds of problems are
seen currently in the present organization. If ORD wanted to opt
for physical consolidation, I probably wouldn't oppose it, but my
recommendation would be not to move."
Many of the pros and cons discussed had direct
counterpoints. For example, in the area of cost savings, full
consolidation would save travel among the NCEA units themselves,
but would partly be offset by more travel to OAQPS. Physical
consolidation may allow some redundancies to be eliminated, but
that savings may be offset by higher locality pay. In the area
of working relationships and partnerships with Universities and
local institutions, these could be hampered or lost by moving the
ECAOs, but there would be opportunities for new relationships to
develop. Close ties with other co-located EPA units may exist
currently, but ECAO personnel are also often called to Washington
to help prepare and give testimony. Even the recommendation that
the needed face-to-face interactions among the NCEA units in the
field could be accomplished by desktop video has the counterpoint
that NCEA-to-Customer interactions could just as easily be
handled the same way.
The representative from the Risk Assessment Forum noted that
the RAF's charter often results in their need to draw a number of
people from various points "in the field" to serve on Technical
Panels and other groups. Currently, OHEA members are heavily
involved in the Forum's activities. This has led to a more
functionally complex situation than if all members were located
close together. It also has generated some comments from the
people in the Regions and Laboratories that they would like to
participate more fully, but are constrained by the distance
involved. Depending on the way assessments would be done in the
new NCEA, more interactive approaches to assessments
("groupthink") suggest that the people should be close together.
On the other hand, these projects have progressed in spite of the
distances.
In summary, the group discussed many aspects of potential
physical consolidation. The group was quite aware of the
potential disruptions of personal lives when moves occur. Most
of the arguments for and against a consolidation have direct
counterarguments.
Recommendations: The majority of the group did not feel the
arguments in favor of consolidation to outweigh the costs of such
a move, tfhe arguments against moving the ECAO-RTP were stronger
-------
than those against moving ECAO-Cin, primarily due to ECAO-RTP's
co-location with a major customer, OAQPS. The group recommends
that if a three-location (or four-location, depending on
resolution of the issue of locating an ecological assessment
capability) organization is maintained, a considerable upgrade in
communications would be necessary, including wide-area networks
and probably desktop video capabilities.
A minority position within the working group holds that the
advantages of being able to have direct interaction with an
interdisciplinary "critical mass" of risk assessors far outweighs
the cost of consolidation/ and benefits of leaving the groups
separated are more than compensated by the benefits of
consolidation.
-------
-------
APPENDIX C
-------
-------
I
a
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUM 3 0
WATER
MEMORANDUM
SUBJECT: Report to the Laboratory Steering Committee from the
Ecological Laboratory Committee
FROM: Tudor T. Davies, Chair
Ecological Laboratory Committee
TO: Gary Foley, Acting Assistant Administrator
Office of Research and Development
Based on your charge to me to provide recommendations on the
configuration of ORD laboratories I formed a committee and we
have completed the attached report. As a committee we were able
to reach a number of solid recommendations to be considered by
the Laboratory Steering Committee. ;
I look forward to presenting our findings to the Steering
Committee on July 6. If I can be of further assistance in the
meantime, please call me at 260-5400.
Attachment
oomaiM « IMK 50K racyctod NMT
-------
-------
June 30, 1994
RECOMMENDATIONS ON ORD LABORATORY RECONFIGURATION
UNDER THE RISK-BASED DESIGN CONCEPT:
Report of the Committee
Introduction
The Chairman of the Agency-wide Laboratory Steering Committee requested that a
committee be convened to formulate recommendations for the mission and linkages of the
OEPER laboratories to the new ORD laboratory configuration. Using the concepts of risk
assessment and management, and other concepts of the June 21, 1994 draft Report to the
Administrator entitled, "Research, Development and Technical Services at EPA: A New
Beginning," the committee charge had three components:
1. Make recommendations on the National laboratory linkages of existing EPA
laboratories, based upon the defined programmatic mission and the strengths of the
laboratory programs.
2. Make recommendations on focusing the mission of the laboratories to sustain
scientific excellence.
3. Make management recommendations on the future management and operations of the
laboratories in terms of physical consolidation, relocation, closing, or realignment of
laboratories. Define alternative methods of operation of the laboratories to reduce the
reliance on on-site contractors.
The laboratories that are considered under the charge are:
ERL - Corvallis
ERL - Narragansett
ERL - Ada
ERL - Duluth
ERL - Gulf Breeze
ERL - Athens
Grosse Isle, MI
Newport, OR
Laboratory Linkages
Based on laboratory descriptions and programmatic missions provided by OEPER
(Riordan memo, 4/15/92), the committee determined that two main linkages exist for these
laboratories: 1) National Health and Environmental Effects Laboratory and 2) National
Exposure Assessment Laboratory.
-------
Recommendation: Laboratories should be linked as follows:
NATIONAL HEALTH AND
ENVIRONMENTAL EFFECTS
LABORATORY
Narragansett
Corvallis (inch Newport)
Duluth (inch Grosse Isle)
Gulf Breeze
NATIONAL EXPOSURE
ASSESSMENT LABORATORY
Ada
Athens
Committee Agreements:
The Committee unanimously agreed with the linkages for Narragansett, Corvallis
(incl. Newport), Duluth (incl. Grosse Isle), and the Ada laboratory. There was some
discussion on the missions of Athens and Gulf Breeze.
Committee Discussion on Assignment of the Gulf Breeze Lab:
The Committee discussion on Gulf Breeze led to its placement in the National Effects
Lab. Most of the federal workforce expertise in Gulf Breeze is in ecological systems
and fish pathology. Most of the microbial degradation research is effects research;
the biotechnology portion of Gulf Breeze is more closely related to risk management
research.
Committee Decision on Gulf Breeze:
The general consensus of the Committee was to place Gulf Breeze in the National
Effects Laboratory, however, further work is necessary to relate the bioremediation
research to the activities of the National Center for Risk Management.
Committee Discussion on Assignment of the Athens Lab:
The historical mission of the Athens laboratory is in predictive environmental fate and
exposure and modeling of ecologic systems.
Two options evolved with respect to the Athens Laboratory:
1. Athens be assigned to the exposure center and the function of the exposure
assessment lab be changed to include environmental fate and ecosystem model
development.
-------
2. Athens seeks to be the sole research laboratory reporting to and providing
support to the National Center for Environmental Assessment (NGEA). (See
further discussion on NCEA below.)
National Center for Environmental Assessment
The unique and identifying character of EPA's ecological research program is that it
is done in the context of the risk assessment paradigm. Research on ecological effects
and exposure should be planned to answer questions that feed into specific risk
assessment and the development of risk assessment methods. Thus, it is obvious that
research on effects and exposure must be planned in conjunction with the risk
assessment component. The new ORD organization must therefore integrate the risk
assessment components.
The Reconfiguration Subcommittee asked for clarification from the Laboratory
Steering Committee on the function of the NCEA. The Steering Committee indicated
that the NCEA would identify research needs based on the results of assessment
activities carried out by ORD and Program and Regional Offices. Support for risk
assessment would consist of both data and tools developed in-house across the three
National Laboratories, as well as a targeted component of the investigator initiated
grants program. This work would include a wide range cf scientific disciplines that
would not be found in any one lab. NCEA would therefore manage the overall risk
assessment program, setting priorities and direction, but assign individual risk
assessment research projects to a particular laboratory or inter-laboratory team for
execution. In this manner, each lab would have a risk assessment component that
would take direction from NCEA.
. This structure serves a dual purpose. First, it allows the development of risk
assessment teams with required expertise without creating a large in-house staff at
NCEA. Second, it provides investigators with first hand experience in assessment
activities which serves to improve their perspective, enabling them to plan and justify
their research.
In summary, risk assessment is the central paradigm with four components:
1. Each laboratory has a core of researchers involved in risk assessment.
2. NCEA will be the focus of risk assessment but will involve the other centers
(health effects, exposure and risk management) in planning and execution as
appropriate to each issue.
3. Some risk assessment would be led by laboratories.
4. Individual labs would be components of a national program.
-------
Committee Decision on Athens: Athens should become part of the exposure assessment
center. A number of the Committee members request that the Steering Committee review
the concept that the NCEA needs a dedicated laboratory to conduct research on risk
assessment.
To clarify the discussion on integrated ecological risk characterization and modeling, the
Committee agreed to request that the mission statement of the NCEA (as described in the
6/21/94 draft report to the Administrator) include research in these areas:
1. Providing predictive ecological risk assessment methods for chemical and land-use
related stressors, and
2. Providing predictive watershed, regional, and Earth systems models that integrate the
global climate and biosphere.
The functional descriptions of the National Health and Environmental Effects Research
Laboratory and the National Exposure Research Laboratory (as described in the 6/21/94 draft
report to the Administrator) should include the following:
Research in support of the NCEA in these areas:
1. Providing predictive ecological risk assessment methods for chemical and land-
use related stressors, and
2. Providing predictive watershed, regional, and Earth systems models that
integrate the global climate and biosphere.
The mission statement of the National Exposure Research Laboratory (as described in the
6/21/94 draft report to the Administrator) should include research into:
Predictive Environmental Fate and Exposure
- Provide fate and transport data, process level descriptions, and exposure
analyses for toxic chemicals in soil, water, and subsurface.
4
-------
Focusing the Laboratory Mission to Sustain Scientific Excellence
Recommended Alignment of Mission and Reporting Relationships
LAB
SCIENTIFIC AND TECHNICAL PRIORITIES
LABORATORY
REPORTING
RELATIONSHIP
Athens
1. Predictive Environmental Fate and Exposure
2. Modeling Ecological Processes
Development of process-based models to describe the
response of aquatic and terrestrial ecological systems to
natural and man-made perturbations.
1. Exposure
2. Exposure
Ada
1. Subsurface Processes and Application
Understanding the physical, chemical and biological
processes that control mass and energy transport in the
subsurface to determine response to natural fluxes and
anthropogenic activities.
2. Ground Water Modeling
1. Exposure
2. Exposure
Gulf Breeze
1. South Atlantic, Gulf, and Caribbean Coastal Ecology
2. Environmental Microbiological Ecology -
1. Effects
2. Effects
Narragansett
1. Atlantic Coastal Ecology
2. Diagnostic Marine Ecotoxicology Research
Methodologies focus on environmental indicators and
identifiers of exposure and effects.
1. Effects
2. Effects
Duluth
1. Predictive Toxicology
Development of methods for assessing and predicting the
effects of pollutants and polluting activities on freshwater
2. Fresh Water/Mid Continent Ecology
Provides the scientific focus on the effects of land-use and
related disturbance on aquatic ecosystems for environmental
risk assessments, with emphasis on the Great lakes.
1. Effects
2. Effects
Corvalis
1. Regional/Landscape Ecology (Western U.S.)
Understanding the structure, functioning and resiliency of
landscape, regional and biome scale ecological systems.
2. Terrestrial Plant and Wildlife Ecology
Major issues include: response to stress, ecological
indicators, habitat modification, and ecological restoration
1. Effects
2. Effects
-------
Recommendation: The four laboratories with ecosystem focus should take on a geographic
coordinating role as follows (associate missions are in parenthesis):1
1. Corvallis - Western Ecological Center (terrestrial)
2. Duluth - Mid-Continent Ecological Center (ecotoxicology)
3. Narragansett - Atlantic/Eastern Ecological Center (marine toxicology)
4. Gulf Breeze - Gulf Ecological Center (ecotoxicology andl microbiology)
The Committee recognized that the most important organizational needs for the risk-based
paradigm is to achieve integration rather than additional functional specialization. We
recommend a geographic structure. However, each laboratory has a major specialization in a
particular area and the associate mission needs to be recognized and maintained.
Future Operation and Management of Laboratories
Recommendation: Physically integrate the Grosse Isle laboratory with Bay City facilities.
Under this relocation, Grosse Isle would retain its functional ties to Duluth yet have
physical ties to the supercomputer, the LAKE GUARDIAN, and other GLNPO
programs.
Recommendation: Integrate the Newport laboratory with the Corvallis laboratory.
Although there is concern among some Committee members that the Corvallis laboratory is
an "inherently governmental" function, the Steering Committee should investigate the
possibility of management of this laboratory as a government owned contract laboratory.
- Newport would integrate into the ecosystem mission of Corvallis
- Over time, transfer Newport's work on toxicology of contaminated sediments to
Narragansett
Recommendation: Over time, phase out the bioremediation and effects research currently
being performed by the Athens lab.
Current legislation in the 103"* Congress may require the establishment of an arid land ecological center. If this legislation
were to be passed, the mission of this new center would need to be defined.
-------
Recommendation: The coastal ecology work of the laboratory at Gulf Breeze should
integrate with the Gulf of Mexico Program and report to the effects laboratory.
Recommendation: Investigate the reporting relationship of the bioremediation research at
Gulf Breeze with the risk management center.
Recommendation: Reduce overall dependence on on-site technical support contractors.
- Investigate possibility of beginning a phase-out of on-site technical support contractors
at the laboratories.
-------
Appendix I (not yet completed)
To include short descriptions of the unique characteristics of each laboratory
Appendix IE; Committee Members
Tudor Davies, Chair
Gary Foley, Chair of the Steering Committee
Bill Raub, Science Advisor to the Administrator
Gil Veith, ORD/Duluth
Wil Davis, ORD/Gulf Breeze
Mimi Johnson, ORD/Narragansett
Sam Karickhoff, ORD/Athens
Mike Slimac, ORD/HQ
Ann Barton, OPPTS/HQ
Barbara White, AFGE/Region 1
8
-------
APPENDIX D
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
8 1994
MEMORANDUM
OFFICE OF
RESEARCH AND DEVELOPMENT
SUBJECT:
FROM:
TO:
Report on Consolidation of the Exposure and Risk
Management Laboratories
Alfred W. Lindsey, Director
Office of Environmental Engikeerlng
and Technology Demonstration (8301)
Gary J. Foley, Acting Assistant Administrator
for Research and Development (8101)
In response to your charge to me of July 1, I convened a
panel of Laboratory Directors and Union representatives to
consider the advantages and disadvantages of consolidation of the
Exposure and Risk Management laboratories. We used the report of
the Commission headed by Walter Kovalick as a jumping off point.
We considered benefits and negative impacts from mission,
facilities, personnel, programmatic, and cost.perspectives.
The report language is mine, there was virtually no time for
review, by committee members and incorporation of their comments
is, therefore, incomplete. Thus some may take issue with parts
of my portrayal. But X have tried to be faithful to the sense of
the discussions that we had.
cc: Steering Committee Members
Racyctod/Rccydabl*
EHmmlrrtUHay/Ctnoauittom
conutrm at ttttt 71* mercM fl
-------
-------
Recommendations
Rastructuring of ORD Environmental
Exposure and Risk Management Laboratories
Introduction
The Agency-wide Laboratory Steering Committee requested that
recommendations be developed on structuring the proposed
Environment Exposure and Risk Management 'megalaboratories with a
focus on whether and how to physically consolidate operations.
The recommendations are to be based on mission, cost, and
practicability.
Baclccnround
The Laboratory Steering Committee has proposed among other
things the potential consolidation of many of the environmental
exposure and risk management activities of the Office of Research
and Development, including possible physical consolidation as
follows:
» National Environmental Exposure Research Laboratory
(NEERL) at RTP
- Atmospheric Research and Exposure Assessment
Laboratory (AREAL/RTP)
- Environmental Monitoring Systems Laboratory (EMSL/LV)
- only the exposure functions
- Environmental Monitoring Systems Laboratory
(EMSL/CIN)
• National Risk Management .Research Laboratory (NRMRL) at
Cincinnati
- Risk Reduction Engineering Laboratory (RREL/CIN)
- Releases Control Branch of RREL now in Edison, NJ
(RCB/EDIS)
- Air and Energy Engineering Research Laboratory
(AEERL/RTP)
- Center for Environmental Research Information
(CERI/CIN)
A commission chaired by Walter Kovalick, Director of the
Technology Innovation Office of OSWER, produced a factual
analysis of the costs and impacts of the proposed restructuring
(see "Special Analysis of Proposed Restructuring of ORD
Environmental Exposure an Risk Management Laboratories'* dated
7/6/94). Using this report as a point of departure, the current
-------
charge is to provide further analysis, particularly of the more
subjective nonquantifiable findings of the "Kovalick Commission"
and to formulate recommendations.
Approach
To carry out this change, a one day retreat was organized
(6/6/94) involving the following:
Fred Lindsey - Director,OEETD, Chair
Wayne Marchant - Director, EMSL/LV
Tom Clark - Director, EMSL/CIN
Tim Oppelt - Director, RREL
Jim Dryer - representing NFFE, GIN
Jay Messer - Acting Director, AREAL
Frank Princiotta - Director, AEERL
Bob Davis - representing AFGE, RTF
It was felt that this group was in the best position to
judge the benefits and impacts of the proposal and to otherwise
review the findings of the Kovalick Commission,
The following summary:
- does not attempt to rehash the Kovalick Commission Report
except where this Committee has differences - there are very few
of these
- is the product of the Committee deliberations but the
report itself was written by the Chairman - there was not time
for extensive review and modification of the text
- does not represent a consensus in all areas - it was in
some cases not possible to arrive at one
- may, as a result of the above, meet with some disagreement
from committee members on specific points
- discusses consolidation effects on mission, facilities,
program and personal disruption, and costs
Benefits and Impact Based on Mission
There are benefits and negative impacts of physical
consolidation that are specific to the two organizations and a
number of others that.occur generically.
-------
Exposure Specific
- Consolidate current disparate efforts
Currently-exposure programs are spread across OEPER and
OMMSQA laboratories. Consolidation will provide critical
mass in one place facilitating coordination, cooperation,
planning, and' implementation. This is judged to be a major
benefit.
- EMSL Cincinnati units are a force fit
Only part of the current EMSL/CIN program relates to
exposure. Other parts are clearly effects related or in the
case of the microbiology work, portions could also fit into
risk management organization. This should be pursued as it
would relieve other negative impacts of consolidation {e.g.,
shortage of space in RT?, personal impacts/ skill mix
issues, etc.)
Risk Management Specific •
i
- Severing close OAQPS/AEERL ties
The close proximity of the two organizations affords an
uncommon level of cooperation - in fact: some programs, e.g.,
the Control Technology Center - an air pollution control
clearinghouse are jointly staffed. Joint .staffing would
have to cease and other coordination will be made more
difficult. While an important negative impact, many other
laboratories function acceptably vis a vis their program
office counterparts in a -non-collocated fashion.
•
- Permits will have to be reestablished
AEERL has extensive flexible RCRA and Clean Air Act (CAA)
permits for conducting large pilot scale combustion and
other research. Reestablishing these in Cincinnati will be
problematic. Previously, there was citizen opposition to a
hazardous waste incinerator at the site of the Cincinnati
T&E lab facility. Consequently, while the Cincinnati T&E
facility has a RCRA permit, it does not include
incineration. It is also possible that CAA permit with the
city which currently covers all activities at the
laboratory, may require substantially more rigorous cleanup
equipment at a possible cost of $5 million or more. These
are potential problems. It is also not clear what the
demand will be for incineration R&D in 1999 + „
-------
C. Generic
- Management efficiencies
A major benefit inherent in collocation is management
efficiencies. Program coordination is easier; there is less
potential for redundant work with everyone in one spot.
Managers have greater flexibility to create research teams
and move technicians and other support to new or critical
programs.
- Stature, competitive position, prestige
Establishing a central focal point for R&D in a given area
in one place brings added potential for heightened prestige
A central mega lab can arguably compete more effectively for
world class personnel and other resources. A centralized
assemblage of expertise will bring intellectual stimulation
through the heightened 'potential for peer collaboration.
These are major advantages of collocation.
- Cross media and multidisciplinary teams
Consolidation provides improved opportunity to form cross
media investigatory teams. The current media based,
fragmented structure discourages such teamwork. On the
negative side, forming multidisciplinary teams to focus on
media type problems will be made more difficult.
Multidisciplinary teams in indoor air and global warming
have been especially effective at RTF. In sum, the
consolidation is probably neutral from a team building
perspective.
- Convert Administrative positions to technical
When WERL and HWERL were consolidated into RREL on 1989, 60%
of the program operations (administrative) staff positions
were converted over time to badly needed technical
positions. Consolidation would facilitate this but most of
the same advantages could be implemented now in Cincinnati
and RTF under the current ORD structure. This
administrative consolidation should be pursued in any event.
- Destroy national air pollution lab
A reorganization in the early 1970s, brought together all of
the air-related laboratories in RTF in close proximity to
OAQPS. The purpose was to create a national center of
excellence in air pollution there. It has worked remarkably
well. Removing AEERL from this location offsets many of the
-------
advantages of collocating the risk management function in
Cincinnati.
T- Enhance multimedia R&D effectiveness
Increasingly, both exposure and risk management work are
multimedia in nature. This is less true in risk management
but still major new programs such as pollution prevention
and many of the outreach focused ETI programs (e.g.,
verification and U.S. TIES) are multimedia. These programs
will be substantially enabled and encouraged and can be
expected to be considerably more effective with
consolidation - a major benefit.
Facilities Impacts
The committee accepts the Xovalick Commission assumption
that any actual moves should occur in 1999 to coincide with
availability of the new RTF facility.
- Availability of Facilities in RTF
The committee understands that additional square footage
cannot be added to the proposed new building in RTF based on
current negotiated agreements. A net increase of 62 people
in RTF will result from the proposed plan. They cannot all
be accommodated. Options include moving additional
contractors offsite or finding space offsite for some
Exposure Lab units. This negates some of the benefits of
consolidation This issue needs substantial further
investigation.
- Swapping equipment and furniture
AEERL and EMSL/CIN could largely swap telecommunications
equipment and furniture saving about $1M - not covered in
the Kovalick Commission report.
- Pathogenic Suite
A new 4,000 + foot2 pathogenic laboratory will be needed in
RTF to enable EMSL/CIN programs dealing with microbiological
methods development. The pathogenic suite in Cincinnati
will continue to be used for Drinking Water microbiology
R&D.
- Edison NJ UST Test Facility
The underground storage tank research and test facility
would cost $2.6M to move to Cincinnati. If still needed in
1999, it can be operated, as it largely is now, as a GOCO
-------
facility. Therefore, it is not recommended that a new
facility be constructed in Cincinnati.
- Newtown Facility/ Cincinnati
Newtown would be closed under the proposal. This would
likely have happened in the near to mid term anyway as the
mission and resource base to sustain it has eroded.
- Full Containment Facility
The need for this facility to support EMSL/CIN work has
declined in recent years. The facility has seen increased
use for hazardous waste and superfund research. Thus, EMSL
does not require a comparable facility in RTF and in fact,
the Containment Facility will enable labs to be freed up. for
use by AEERL in Cincinnati.
- High Bay Space
High Bay space will be needed to house AEERL's equipment in
Cincinnati. Conceptually, this will be built at AWBERC just
to the north of the present building. The cost may be more
or less a wash compared to costs to build equivalent space
in the .new RTF facility. But there is question as to
whether money can be obtained, and the facility designed,
built, and permitted for a projected 1999 move.
Disruption
This is the overriding negative impact associated with
consolidation with collocation. Programs and personal and family
lives will be seriously disrupted in the mid term - 3-7 years.
There are, however, some positive benefits particularly in the
outyears.
A. Feople Related
- Personal and Family Disruption
A survey taken of AEERL employees showed a variety of
impacts that would ensue if these people are forced to move.
These include health (several are cancer patients), elderly
parents who have to be watched over, children in difficult
straits, and spouses with important professional or business
positions. These impacts are inevitable in organization
relocations but, at least in industry, there is normally an
enticement provided through promotions, substantial bonuses,
or payraises. These are perhaps not possible in the
government but should be pursued if they are possible.
-------
- Loss of Expertise
The Xovalick Commission report estimates that 30-30% of the
eligible employees will move. It also assumes that all
eligible employees will retire. This Committee disagrees
with the latter assumption, and believes, unanimously, that
if the relocation were to happen in the next 18 months,
about 40% of all professionals would relocate. This may
vary somewhat by lab depending on local employment
opportunities but 40% is thought to be a sound overall
prediction. The expertise loss will likely be distributed
across both new and experienced staff and across all
programs and will be significant if 60% chose to, not move.
- Dealing with attrition
By the 1999 move date, labs to be relocated will lose a
substantial number of people through normal attrition. The
Xovalick Commission assumed these would be rehired in the
new location only. The committee believes this approach to
be impractical. To minimize substantial programmatic
disruption, laboratories must be able to replace key
researchers in key programs up to perhaps one year before
the move. Hires, of course, would understand that they will
be moving. If this practice is followed, it is estimated
that 60% of the professional staff will be moved. Using
these assumptions, Table 1 of the Kovalick Commission report
is restructured as follows:
Table 1. Estimated Number of EPA Employees to be Relocated to
Consolidate the Exposure and Risk Reduction Laboratories (1999)
Total #
Employee
Sec/Admin
#Prof .
Employee
Est %
Range
to Hove
Est Range
# Emp to
Move
EMSL/CIN
118
28
90
40
or
60
36
or
54
EMSL/LV
42
7
35
40
or
60
14
or
21
EPIC
6
6
40
or
60
2
or
4
AEERL
104
30
74
40
or
60
30
or
44
EDISON
28
4
24
40
or
60
10
or
14
TOTAL
298
69
229
40
or
60
92
or
137
NOTE: 40% vs. 60% move estimate based on whether labs can
replace attrition prior to that move.
-------
8
- Contractor Conversion
Our analysis and that of the Kovalick Commission report
assumes contractor conversions would not occur in labs to be
relocated until after the move. If a different decision is
reached, this will increase the number moved.
- Professional opportunity
The megalab concept embodying a center of excellence should
be attractive particularly to younger professionals.
Enhanced intellectual, advancement, and recognition
opportunities should be available. This may encourage some
to move.
B. Program Related
Programmatically, there are severe short term problems
partially balanced by significant long term advantages.
- Loss of critical skills
The best researchers are those most in demand elsewhere and
are more likely to be able to leave to avoid a move. Loss •
of critical skills is expected to be a major problem. Given
the snails pace experienced by ORD in hiring the level of
people needed, the impact per person leaving may be as long
as 3 years.
- Restructuring skill mix
Partially offsetting the expected serious loss of critical
skills, is the opportunity to .restructure the laboratories
to face new challenges such as pollution prevention more
effectively - a significant advantage in the long run.
- Improving diversity
Likewise, rehiring provides an opportunity to improve our
diversity in both management and technical positions.
- Lost productivity
Significant loss in productivity will stem from the
following:
.• dismantling, moving, and rebuilding equipment
• inefficiency in conducting programs and overseeing the
work of others before and after the move
• research foregone and delayed
-------
The impacts will be most noticeable with regard to in-
wor&. "Productivity losses are also possible in work carried
out in local universities and extramurally due to less
effective oversight and direction and due to severing and
reestablishing relationships. The impacts will be most
noticeable in the year of the move and for a year on either
side. However, morale has already beer impacted and some
loss of productivity has already been experienced (estimate
5-10%) as people consider and diacuss this potential
- . disruptive event in their lives. This will continue until
the move.
"While productivity loss projections require subjective
judgements, tiie committee felt it useful to try in some way
to quantify the value of lost research or research less
efficiently conducted, subjective though it is, the
affected Lab Directors are the best able to make these
judgments. Expected lost research worth $31 million is
expected. This is about 15% of the projected budget for the
affected units over a 3-year period* Following are our
projections:
Table a. Estimated Value of Lost Research due to Relocation
AEEKL-BTP
(I)
Li-Hous*
Local Univ
Other
E7[tpimiiT»1
Total
AEERLta
Cine.
Li-Housc
LwolUniv
Other
Extaunuj*!
Tbtel
EMSL (o KTP
la-Houac
Lo
-------
10
Other
Extramural
Thtal
Edison to
Cine.
In-House
Local If niv
Other
Extramural
Tbt4
-
20
30
4.0
8,0
1.5
8.0
2.8
14.0
N/A —
-
-
10
10
—
10
1.0
4.0
S.O
0.5
1,0
U
Tbtill.oiC'Vfdue
0.2
1.0
1.0
S31M
W _ .
(?) Kgurca rounded
(3) Appmx. 16S of total budget
Costs
Making the following changes to the Kovalick Commission
tables yields a net implementation cost of about $67M
• AEERL and EMSL/CIN swap telecommunications equipment
and furniture - save $1M
• Do not move UST test tank - save $2.6M
• 60% of all professionals move - cost of moving is
$10.3M instead of $4M. Relocating new hires is $3.2M
instead of $5.3M
• Lost value of R£D - $31H
Table -b. 4 Year costs
consolidate labs - facility
Statue quo - facility
Wet facility cost
Personnel cost
Value of Lost R&D
Total Estimated Net
Implementation Cost
$79. 2M
57* OH
22, 2M
13 . 5M
31. OH
67. OH
-------
11
other Issues
- Other Exposure and ."Risk Management Laboratories
The Committee felt strongly that the exposure and risk
management activities of several OEPER laboratories should
be integrated into the consolidated laboratories. Unless
this is done, the intellectual basis for consolidation is
seriously impaired. To make sense from a mission point of
view, consolidation should be done completely. Xt is also
hard to 'defend the personal hardships on staff when some ara
affected and others with the same mission are not.
The Ecological Laboratory Committee headed by Tudor Davies
in their report dated 6/30/94 proposed that Athens and Ada
be designated as exposure labs. They also recognized that
the Gulf Breeze laboratory has some components
(bioremediation related specifically) which belong more
appropriately in the Risk Management megalab. . Similarly,
this committee observed that significant parts of Ada's work
deal with remediation and more logically belongs in risk
management than exposure,, These labs were not represented
on this 'committee and might see their consolidation in the
Exposure and Risk Management megalabs in a different light.
~ CERI
The proposed incorporation of the Center for Environmental
Research Information (CERI) was not focused on either by
this committee or the Kovalick Commission. However,
attached is a brief analysis from Gal Lawrence, the Director
of CERI. The Chairman observes that there is little to be
gained by consolidating CERI into the Risk Management
Laboratory. And, it is possible that the broader mission of
CERI to serve all of ORD could be subverted by the parochial
interests of the Risk Management Laboratory Director.
Savings through consolidating administrative functions can
be carried out without incorporation. ' .
- Las Vegas
It is not clear from the proposal put forward to this
committee or from Tudor Davies report, • what is to happen to
the rest of the Las Vegas lab. 139 to 146 positions are up
in the air and the morale is suffering.
- Travel
Travel will be somewhat less for Edison staff because
current frequent trips to Cincinnati will not be necessary.
AEERL travel will be greatly increased, however, due to the
need for frequent tripe to Durham to coordinate with OAQPS,
-------
12
their primary customer,
be cost neutral.
Effects on Exposure Lab travel will
- Chemists/Microbiologists
The committee observes that some chemists in AEERL (approx.
5) and some chemists and microbiologists in EMSL/CIN
(approx. 20) may beneficially be absorbed in the new
structure. This should be pursued since it lessens all
impacts, so long as these people fit within the needed akin
mix of the new structure.
- Use of information superhighway
Clearly some of the benefits of consolidation can be
achieved without physical relocation by making much greater
use of telecommunications and other electronic developments.
This field is developing so quickly that it is easy to
conceive in five years of desk top videoconferencing for
example* Many of the tools are available today. However,
there were mixed opinions among committee members on how
effective such devices will be in replacing the face-to-facs
communication, teaming, facility and personnel sharing
afforded by collocation.
- Edison Transfer to ERB
An option that should be considered is the possible transfer
of the Edison staff to OERRs Emergency Response Branch also
in Edison. ORD would have to transfer (or cease) some
programs also the ERB. The most logical program would be
the START (Superfund Technology Assistance Response Team)
program which provides expert .on site technical assistance
to Regional decisionmakers on difficult technology issues*
Advantages of this shift involve lower cost and less
personal impact on staff. Programmatic impacts involve
retreading a staff in Cincinnati that are now associated
with START while .finding people in Cincinnati to take over
other Edison responsibilities involving SITE, UST, and storm
and combined sewer overflows. Moving START from QRD will in
the longer term diminish the effectiveness of the program
because the Edison staff will become less familiar with the
results of ongoing research that can be factored into their
support recommendations.
Bottom Line
The foregoing analyses are largely subjective. As a result
trying to draw conclusions on the advisability of consolidating
the laboratories as proposed is also necessarily subjective. In
addition, comparing and balancing the benefits and negative
impacts, one with another, involves comparing advantages and
-------
13
disadvantages with unliXe characteristics, i.e., it is largely an
apples and oranges affair. Nevertheless, the committee members
fait it important to render a considered opinion baaed on their
considerable experience.
There was no raal consensus, though a Majority o
cowptittee members felt that in the proposal as presented
benefits and negative impacts nearly cancel each other
cd
O
1
to
4-1
4-1
O
•H
M O
d) C
t>*i *H
(H 1-1
Q 0,
1 1
2
u" g
Cfl U
T3 01
C 03
J s
• i
3 4
-p
-u n]
Htj .1^
^^* •*••*
-------
Regoanaendat i ons
In accordance with the foregoing discussion, if the
consolidation is pursued, the following are recommendedi
l - Explore consolidating the fate and transport modeling
and risk management functions of the Athens, Ada and Gulf
Breeze laboratories with the Exposure lab in RTP and Risk
Management lab in Cincinnati*
2 - Completion of actual relocation should be in 1999 to
coincide with availability of the new building in RTP and
additional High Bay space in Cincinnati.
3 - Based on agreements already struck/ see if additional
square footage can be added to the new facility in RTP to
accommodate 62 additional people, or whether they can be
otherwise accommodated.
4 - Utilize any incentives allowed to the maximum to offset
the negative impacts of relocating on employees and
families.
5 - Explore transferring the Edison Releases Control Board
to the OERR's Emergency Response Branch also in Edison along
with the START program.
6 - Explore potential for some professionals (e.g.,
miorobiologists and chemists) to transfer to the new
organizations without moving, consistent with needed skill
mix in new structure.
7 - Do not .incorporate CERI into the Risk Management
Laboratory.
8 - To ameliorate programmatic impacts allow replacement of
attrition to within one year of relocation.
9 - Do not implement contractor conversions in laboratory
units to be relocated until after the move.
10 - Do not reestablish the Full Containment Facility in
11 - close Newtown.
12 - Do not move the Underground Storage Tank Test Facility
from Edison - operate it as a GOCO*
13 - Increase travel budget for the Risk Management lab to
accommodate significant additional travel to Durham to
coordinate with OAQPS, AEERLs principal customer.
-------
15
14 - A pathogenic smite' far EMSL/CIN will have to be
replicatad in RTP. The Risk Reduction Lafc will continue to
•use the one in Cincinnati.
A.Lindsey/cnr/8301:260-2600/Jiily S,
-------
-------
Pros and Cons of Proposed Incorporation of CERI Into
National Risk Management Research Laboratory
The Center for Environmental Research Information (CERT) is the focal point for ORD technical
information products. CERI's technical information activities support all ORD organizational
units, including the Assistant Administrator's Office. CERI responsibilities include document
publication and technology transfer services. Specialists in science and engineering, technical
writing, editing, graphics, and desktop publishing support the management, production, quality
assurance, design, packaging, and publication of ORD's information products. CERI technical
staff work with all of EPA's program offices, laboratories, and regions, as well as state and local
governments, academia, and the private sector to produce technology transfer products useful
primarily to small communities and industries in solving their environmental problems.
Additionally, in response to recommendations in the Credible Science report, CERI is actively
engaged in a communications effort to disseminate information about many of ORD's
comprehensive, multimedia research programs and expertise, e.g., Preventing Waterborne
Disease; Bioremediation; Stratospheric Ozone Depletion; Protecting Freshwater Wetlands;
Cleaner Technologies and Cleaner Products. Products such as the ORD Locator, Program
Guide, Technical Assistance Directory, and Publications Announcement are made possible by the
broad scope of services provided by CERI.
CERI is able to act as an independent ORD agent in evaluating and developing an ORD-wide, cross-
laboratory technical information program due to its non-association with any specific ORD laboratory.
It follows, therefore, that those technical information products developed through CERI have non-
parochial attributes that broaden their utility to and ultimate acceptance by the end users of these
products. The following are some specific pros and cons with regard to the proposed incorporation of
CERI into a new National Risk Management Research Laboratory to be comprised also of the
existing RREL-Ci, RREL-Edison, and AEERL-RTP organizations:
Pros:
• That portion of CERI's technology transfer work that is conducted with ORD's non-
Cincinnati engineering laboratories would be made more efficient due solely to the physical
move of personnel
• Access to a larger base of PRO money might overcome existing travel constraints
Cons:
• A coordinated and integrated ORD-wide technical information program would cease to exist
• The perception, if not reality, will be that CERI is the technical information arm of NRMRL
only
• That portion of CERI's technology transfer work that is not engineering based will naturally
receive less emphasis from within an engineering-focused laboratory
• Technology transfer work in the non-engineering areas will not be recognized for its true
value since it was produced by an engineering organization
• Our ability to work with the Program Offices and Regional Offices will be reduced to
engineering areas only
-------
7/6/94
SPECIAL ANALYSIS OF PROPOSED RESTRUCTURING OF
ORD ENVIRONMENTAL EXPOSURE AND
RISK MANAGEMENT LABORATORIES
She EPA-wide laboratory Study Steering Committee proposed the
reorganization of the QRD laboratories into four national laboratories, This
analysis highlights the mission implications and clarifies the costs and benefits
of carrying out a part of that reorganization, including ispacts on personnel,
buildings and facilities, and equipment. It focuses on the creation of the
National Risk Management Research laboratory in Cincinnati, Ohio and the National
Environmental Exposure Research laboratory in RTF, North Carolina.
The elements of each of these two proposed laboratories are listed below:
National Environmental Exposure Research laboratory (NEERL) at RIP
Atmospheric Research and Exposure
nt laboratory (AREAL/RPT)
Environmental Monitoring Systems Laboratory (EMSL/LV) : exposure
functions moving from las Vegas, Nevada
- Environmental Monitoring Systems laboratory (EMSL/dN) ' moving from
Cincinnati, Ohio
National Risk Management Research Laboratory (NRMRL) , Cincinnati, Ohio
- Risk Reduction Engineering laboratory (RREL/CEN)
'- Releases Control Branch (RCB/EDIS) , a branch of RREL/dN
• - Air and Energy Engineering Research laboratory (AEERL/KEP)
- Center for Environmental Research Information (CERI/dN)
^Under the Steering Committee proposal, EMSL/dN would move from Cincinnati
to REP, the exposure functions of EMSI/LV would move from las Vegas to KEP,
AEERI/REP would move to Cincinnati, and RCEj/EDIS would move to Cincinnati. These
moves are shown in figure 1. Shifting of EPIC resources to las Vegas are not
covered in this analysis.
OUTLINE
This analysis includes a discussion of
related issues (using
criteria developed for the MITRE report) in evaluating the qualitative costs and
benefits of the consolidation, a review of the cost inpacts of the facilities and
equipment and personnel aspects of the change, a discussion of related personnel
issues, and a brief- outline of potential non-quantifiable personal and
programmatic impacts.
-------
MISSIOr-RErATED CONSIDERATIONS
To provide a-context for a more detailed evaluation of the quantifiable
impacts of the consolidation, the proposed consolidation into the two
laboratories was considered in light of selected MURE lab study evaluation
criteria. These criteria provide a backdrop against which to consider the less
quantifiable impacts.
it
Siirply moving staff will have little impact on individual or collective
credibility. In the short term, EPA technical stature and credibility are likely
to be negatively impacted if, as expected, experienced staff elect to retire
rather than relocate (see separate discussion of personnel impacts) , particularly
for AEERL components.
On the other hand, coramitment to world-class facilities for risk management
and/or exposure assessment, adequately staffed and funded, with clearly
delineated functions (e.g., pollution prevention, leveraging other public and
private sector risk management technology development efforts, multimedia
exposure modeling) could result in enhanced credibility. Such a comnitmant might
eliminate the short term loss of credibility by inducing experienced staff to
relocate to be part of a significant initiative.
Geographic Location
An argument can be made that having dispersed centers of activity improves
our ability to interact effectively with the research and academic ccmmunities.
AEERL and RGB/Edison identify significant long-standing relationships with major
academic institutions. Although it is possible to maintain relations at a
distance (the ADA lab maintains relationships with major institutions throughout
the US and Canada) , and new relationships can be formed with institutions in the
Cincinnati area for AEERL and in RTF for the exposure laboratory, the near term
result may be reduced effectiveness in academic interaction.
Customer Satisfaction
The Steering Committee report identifies increasing emphasis on other
public and private customers. To the extent that the emphasis is shifting to
non-EPA customers and support mechanisms such as investigator initiated research
and public/private partnerships, organizational adjustments wwould be needed.
Transfer of AEERL to Cincinnati would have a negative effect on OAQPS and HERL,
major current customers, as well as the synergy of ttieir relationships.
RGB/Edison reports that 85% of their Superfund technical assistance efforts under
the START program are devoted to Regions 1,2 and 3.
Use of Intramural Workforce
Consolidation of the components identified offers the potential for savings
in general administration and in contract administration. Time did not permit
an evaluation of the contracting postures of the various components or the
associated workload. Experience from the past merger of the water and waste
-------
4
functions at KREE/CTN support the potential for savings.
Consolidation" would offer greater flexibility to collocated laboratories
in use and movement of technicians and analytical support among research
projects, sharing of laboratory facilities and in the formation of research
teams.
tfcilti-media Approach
Perhaps the major impetus for the KREE/AEERL consolidation is to enhance
the Agency's ability to address multi-media issues, with some loss of
interdisciplinary capability. The value of a multi-media approach is only
realized at the later stages of technology development - i.e., well beyond proof
of process - when it becomes necessary to develop controls for ancillary emission
and effluent streams.
Most pollution control problems at the engineering level are limited in
their dimensionality (usually one). Multi-media factors only come into-play when
the particular situation has the potential for uncontrolled emissions to other
media or where decisions must be made about the disposition of captured
contaminants.
Thus the question becomes whether staff will be involved in initiating
research into promising technology areas or whether they will be more heavily
involved in the later stage efforts of private vendors and/or other federal
laboratories.' To the extent that the specialized skills of 'technology
evaluation' and 'certification' becomes a major focus as envisioned in several
bills before Congress, co-location provides opportunities for increased
interaction among intramural staff.
Possible EMSL consolidation is driven by inter-disciplinary considerations.
Exposure assessment modelling and cross-media receptor work should benefit from
co-locating interdisciplinary teams.
Facilities and Equipment
Consolidation of the EMSIs should allow maximum utilization of analytical
equipment such as GC/MSs.
Both RREL and AEERL have requirements for high bay space to conduct pilot-
scale technology development and evaluation projects. High bay space involves
a significant initial investment. There is limited opportunity to share these
resources in the near term, as bay space is likely to be occupied for an extended
period of time (6 new projects at the T&E facility are expected to be in place
for 2 to 2 1/2 years). Over a longer horizon, more opportunities for sharing
exist.
EACHZTIES AND EQUIPMENT COST IMPACTS
Fundamental to this analysis and to the consolidation decision is the time
frame for physical relocation. The absolute minimum estimate for a consolidation
is three years—no matter whether space is to be leased or built by GSA for EPA.
-------
This timeframe assumes best case scenarios for every aspect of the space
procurement. This analysis posits four years as the timeframe for analysis in
order to develop cost impact data. Based on a decision prior to 1996 budget
submission, a move in date of 1999 is assumed, which is the current move in date
for REP.
The cost impact for facilities and equipment to implement the proposed
consolidation of laboratories has been evaluated by comparing the costs for the
relocated facilities to the costs for the keeping each in its current location
and providing equivalent facilities as currently projected (i.e. planned
upgrades, relocations at existing locations). Each laboratory now has plans for
some improvements to remain at EPA standards for laboratories. It was assumed
that capabilities currently existing or planned would be accommodated in the new
alternative. No efficiency in space use derived from co-location was
incorporated.
AEERL is currently designed to be incorporated in the new consolidated RTF
facility, which is at the 35% design stage. The plan for that facility can be
incorporated in the AWBERC in Cincinnati with the addition of new high bay space
to the north of the existiiig building. The alternative scenario for AEERL would
leave it in its existing space with addition of space to provide equivalent
capabilities.
RGB/EDISON currently is in inadequate space and has a Master Plan that
calls for renovating a building on the existing campus for office space. These
needs can also be met in renovated space in the AWBERC in Cincinnati. The RGB
UST Test Facility would be Located at Center Hill. RGB relocation would also
, require modification of parking areas to accomodate storage of trailerized field
equipment.
EMSL/CIN currently does not meet EPA office space standards and requires
•renovation in many lab spaces. Those needs could be met in a new facility in
RIP, either in the proposed Consolidated KTP redesigned to accomodate EMSL
requirements or in other new leased facilities at RIP.
EMSL/LV has an expiring lease in las Vegas, and will need to move in any
case. EPA is in the process of developing the Program of Requirements (FOR).
The areas used to project required space in RTF were provided by the lab.
The current need for additional office space in Cincinnati for EMSL would
be replaced by the need for high bay laboratory space for AEERL in the
Consolidation alternative. Existing bench laboratory space at AWBERC would be
converted to office space and building ventilation systems modified accordingly.
Design for the consolidated RTP facility would need to have major revisions to
substitute the Monitoring labs and offices for AEERL. It is estimated that this
would entail a six month delay in current schedule. Since the Monitoring labs
require more space, particularly more bench labs than AEERL, the proposed RTF
facility will be larger than currently planned.
-------
In summary, fcxir alternative scenarios were evaluated for comparative costs:
• Status quo - Build
AEERL: Build Proposed Consolidated RTF facility
RCB/EDIS: Renovate space in Edison per current Master Plan
EMSI/CEN: Renovate AWBERC space and build additional office
space per current Master Plan
EMSL/LV: Lease new space in las Vegas as currently planned
• Status Quo - Lease
AEERL: Extend current lease at existing RTF facility and build
additional space as currently programmed for Consolidated
facility
REEL: Renovate space in Edison per current Master Plan
EMSL/CIN: Renovate AWBERC space and build additional office
space per current Master Plan
EMSL/LV: Lease new -space in Las Vegas as currently planned
• Consolidate - Build
- AEERL:Renovate AWBERC space and build new high bay space in
Cincinnati
- RCB/EDIS: Move to renovated office space in AWBERC
EMSL/CIN: Build space in Consolidated RTP facility
- EMSL/LV: Build space in Consolidated RTP facility
• Consolidate - lease
- AEERL: Renovate AWBERC space and build new high bay space at
AWBERC
- RCB/EDIS: Move to renovated office space in AWBERC
- EMSL/CIN: Lease space in RTP
- EMSL/LV: Lease space in RTP
Based on the costs detailed in Attachment A, the estimated implementation
costs of each alternative are as follows:
Bund
20 year
Net Present
Value*
Consolidate: $57 , 065 , 000
Status Quo: S47.884.OQO
Difference: $9,181,000
Personnel Relocation Costs -
See Discussion below:
4 Year
Budget Cost
$82,764,000
$56.981.000
$25,783,000
$9,300,000
Lease
20 year
Net Present
Value*
$100,435,000
$50.345.000
$50,090,000
Total
Net Implementation Cost:
$35,083,000
4 Year
Budget Cost
$37,391,000
$18.527.000
$18,864,000
$9,300,000
$32,164-, 000
* The Net Present Value is calculated over a 20 year period of analysis in
-------
order to reflect long term lease costs. The 4 Year Budget Cost represents
the budgetted costs for the first four years of the analysis period with no
escalation or discount.
The analysis does not include costs of consolidating any other exposure or
risk management groups to REP or Cincinnati.
PERSONNEL COST IMPACT
EMPLOYEES AFFECTED
Table 1 shows the estimated number of employees to be relocated from the
impacted OPD facilities. The following assumptions were made in estimating
the total number of EPA employees which would be relocated in this
consolidation:
1) the move would occur in 1999 based on estimated time required to
construct or lease required facilities;
2) clerical and administrative personnel would not be moved since their
functions would be required in the remaining laboratory;
3) those employees eligible for retirement would choose not to move;
4) hiring to backfill vacancies would be permitted during the transition
period for functions to be relocated, however, the hires would be at
the new location (there could be case-by-case exceptions, but in
general this would be the assumption); and
5) estimated between 30 and 80 % of the employees actually eligible to
relocate because of the transfer of their function would elect to
relocate for individual reasons (e.g., family, spouse employment, other
employment opportunities, etc.).
NOTE: Decisions by employees to relocate will be based on the options
presented to them and the Agency's Human Resource policy governing any
consolidations. This will impact the range of the assumption in item 5.
not consider any cost implications associated with future decisions on
contractor conversion.
Relocation costs may be impacted by geographical location, individual
circumstances, and actual items included in any relocation. An estimate of
$75 K/employee was used to determine the relocation expenses, this estimate
includes a house hunting trip, air transportation for employee and family,
transport and storage of household goods, temporary quarters, etc. The total
estimated relocation cost for employees could range between $3,075,000 and
$7,725,000 depending on how many elect to relocate. A decision was made to
estimate this cost at $4,000,000, based on the assumption that the lower end
of this estimate represents the likely scenario.
-------
8
Table 1. Estimated Number of EPA Errployees to be Relocated to Consolidate
the Exposure and Risk Reduction Laboratories (1999)
TOTAL #
EMPLOYEE
SEC/ADMN
#EK)F.
EMPLOYEE
# PROF
BMP.
RETIRE
# BMP.
ETiTGIBLE
TO KDVE
EST. %
RANGE TO
MOVE •
EST RANGE
# EMP TO
M3VE
EMSL/CI
118
28
• 90
42
48
30 to 80
15 to 38
EMSL/LV
42
7
35
17
18
30 to 80
6 to 14
EPIC
6
6
5
1
NA
1
AEERL
104
30
74
29
45
30 to 80
14 to 36
EDISON
28
4
24
7
17
30 to 80
5 to 14
TOTAL
298
69
229
1OO
129
41 to
103
NOTES:
1. Data generated from review of EPAYS data, workforce survey, and
consultation with designated laboratory representative.
2. EMSL/LV data only includes exposure related personnel, EPIC data
obtained from personal communication.
RELATED PERSONNEL ISSUES
If the total number of professional/technical employees remains
constant in the programs being consolidated opportunities for new hiring
would be present. EPA employees, especially those who decide not to
relocate, could compete for these positions and/or be reassigned to fulfill
the duties of these positions, possibly requiring some retraining. This
opportunity should not be overstated given the differences in skill mix of
the two laboratories. In addition, new hiring would provide the opportunity
to reconfigure or update the skills of the workforce to meet the needs for
the future, increase diversity, and help achieve the streamlining goals. On
the other hand hiring as many as 188 professionals to provide the necessary
scientific expertise in the impacted laboratories and programs may be
-------
difficult due to the limited number of available scientists, administrative
delays and highly competive hiring market.
Table 2 provides an estimate of the number of potential new hires at
the consolidated national exposure (RTF) and risk management (Cincinnati)
laboratories.
Table 2. Estimated Range of Professional/Technical Level Hiring
Opportunities as a Result of Consolidation
LOCATION
NEERL/RTP
NRML/CIN
EMSI/LV
TOTAL
POTENTIAL
HIRES
73 to 104
48 to 79
5
126 to 188
DISCUSSION
21 to 29 to fill EM3I/LV requirements and
75 to fill EMSL/Cin requirements
38 to 60 to fill AEERL requirements and 10
19 to fill Edison requirements
52 to
to
From the transfer of EPIC/Vint Hill
NOTE: Calculated as follows, Total # Professional Required - Estimated #
Employees to Move.
Hiring these professional/technical employees could potentially add
some additional relocation costs estimated at $35 K/person. These costs
could range from zero if all hiring is done locally to an estimated
$6,580,000 if all 188 new hires are eligible for relocation expenses. A
reasonable estimate for these additional expenses would be 80 % of the upper
number or approximately $5,300,000.
POTENTIAL PERSONNEL AND PROGRAM COSTS
While estimates can be made for the cost of obtaining the necessary
office and laboratory space, and for moving equipment and people to
consolidate these functions, there are several other intangible and indirect
costs. These costs are related to lost productivity, program disruption, and
disruption of professional relationships.
Obviously the potential loss of employment or requirement to move will
have the effect of producing stress and lowering morale of the workforce.
This in turn could reduce productivity over the course of the consolidation.
Lost productivity may vary over the projected four year implementation period
from 30% during the initial stages to 100% physical disruption for three to
six months during actual relocation. These productivity losses impact
programs funded at approximately $22.1 M intramural and $40.5 M extramural
•in FY 1993 (MITRE Report).
-------
10
Also, the potential loss of senior professionals with many years of
experience would have an impact on the program with an indirect and unknown
cost value. Consideration should be given to developing a retention
incentives program to encourage highly skilled employees to relocate.
Relocation would also disrupt ongoing professional collaboration with local
academic institutions and existing oversight of contractors servicing the
needs of EPA laboratories. Some of these could be phased out over time and
managed from the new location until new relationships develop.
-------
A *
IRL • Existing Condition:
AEERL currently occupies 55,463 NSF of leased space in several buildings at RTF.
The leases expire in 1998, and a process is underway to design and build a GSA owned
consolidated facility to house all of the EPA laboratory groups at RTF, including AEERL.
This facility is expected to be occupied in late 1999, depending on receiving funding from
Congress.
Existing Space:
Office:
Office Support:
Bench Lab:
High Bay Lab:
Lab Support:
Total:
21,610
12,605
19,713
7.838
61,766
NSF
Note: This total includes some space
away from the Environmental Research
Center not included in the Mitre Report
Space summary
Status Quo Build Cost:
Interim Lease Cost:
Construction Cost:
New Furniture:
Telecommunications
Existing Site Cleanup
Administrative Costs:
Space Total:
Move Equipment:
Equipment Total:
$4,244,572
$40,433,000
$712,000
$320,000
$570,000
$125,000
$44,804,174
$6,613,000
$6,613,000
Space Required:
Office:
Office Support:
Bench Lab:
High Bay Lab:
Lab Support:
22,350
0
19,512
32,647
Total: 74,509
Note: This is the current program for
the'AEERL portion of the consolidated
RTF facility
$l,061,143/year through 1999 (4 years)
Current AEERL budget for proposed facility
178 occupants @ $4,000/workstation
178 occupants @ $1,800
SHEMD estimate to clean lab and certify non-
contamination; $500,000 estimated for cleanup of
high bay area. Assumes no major site
contamination.
Estimated cost for HQ administration of move
only.
$6,000,000 estimated by AEERL for high bay
equipment; S5/GSF for 122,648 GSF for small
equipment
AEERL Status Quo - Build
TotalCost; $51.417.174
-------
AEERL
Status Quo Lease Cost:
Lease Cost:
• $3,183,429
$2,562,840
Renovation Cost: $2,773,150
Administrative Costs: $20.000
Space Total:
Move Equipment:
Equipment Total:
$8,539,419
$6,000,000
$6,000,000
AEERL Status Quo Lease
$14.539.419
$l,061,143/year through 1998 (3 years)
$2,562,840/year for 17 years for 73,224 NSF new
and renovated space @ $35/NSF
55,463 NSF existing @ $50/NSF
Estimated cost for HQ administration of renovation
only.
Cost for four year comparison of costs only. See the
economic analysis attached for net present value of
each alternative.
AEERL estimate to move high bay equipment
Cost for four year comparison of costs only. See
the economic analysis attached for net present
value of each alternative.
-------
AEERL
Consolidate - Build Cost:
Interim Lease Cost: _ $4,244,572
Construction Cost:
Office: $319,000
Renov. Lab: $1,951,200
New High Bay: $11,975,000
Site Costs: $500,000
RCRA Permit: $500,000
Air Permit: $200,000
New Furniture: $712,000
Telecommunications $320,000
Existing Site Cleanup $570,000
Administrative Costs: $125.000
Space Total: $21,416,772
Move Equipment: $9,350,240
Equipment Total:
AEERL to CIN
Total Cost:
$9,350,240
$30.767.012
$l,061,143/year through 1999 (4 years)
Renovate 6,380 NSF existing lab space to office space
@ $50/NSF (Reutilize current 18,328 NSF EMSL
office space)
Renovate 19,512 NSF existing EMSL bench labs to
AEERL use @ $100/NSF
Build new high bay lab space - 32,647 NSF
(37,064 GSF) @ $323/GSF per current budget
Estimate from AEERL
Estimate from AEERL; assumes least stringent
requirements
178 occupants @ $4,000/workstation
178 occupants @ $1,800
SHEMD estimate to clean lab and certify non-
contamination. $500,000 estimated for cleanup of high
bay area. Assumes no major contamination.
Estimated cost for HQ administration of move only.
Note: This cost is conditional on providing space for
EMSL elsewhere.
$8,737,000 estimated by AEERL to move high bay
equipment; $5/GSF for 122,648 GSF for small
equipment
In order to meet the needs of AEERL, new high bay space will need to be built adjacent
and attached to the existing AWBERC facility, probably to the north. The currently
planned office addition will not need to be built, nor additional structured parking.
AEERL
Consolidate • Lease: Same as Consolidate - Build
-------
RREL RGB • Edison
Existing Condition:
RREL RGB has 28 total personnel (EPA and Contractor) occupying approximately 8,500
NSF of office space in Edison, New Jersey. Although renovations are planned in current
Edison Master Plan, Laboratory staff indicate that current space is adequate. Costs have
been included for furniture and telecommunication upgrades only.
Status Quo Cost (No Lease Alternative):
New Furniture: $56,000
Telecommunications: $25.200
Space Total: $81,200
Personnel Total: $0
Equipment Total: $0
Total Status Quo Cost; $81,200
14 personnel @ $4,000/ workstation
14 personnel @ $1,800/ workstation
Consolidate - Build Cost (No lease alternative):
Renovate existing labs
to office space: $212,800
Duplicate UST facility $2,658,000
$112,000
$50,400
$20.000
New Furniture:
Telecommunications:
Administrative Cost:
Space Cost:
Equipment Total:
Total Move Cost;
$3,053,200
$0
$3.053.200
28 personnel @ 152 NSF/person = 4,256
NSF @ S50/NSF
Per Laboratory staff
28 personnel @ $4,000/ wrokstation
28 personnel @ $1,800/ workstation
Estimated cost for HQ administration of
move only.
-------
EMSL
Existing Condition: .
EMSL Cincinnati currently occupies 87,743 NSF in two EPA owned facilities in Cincinnati
and Newtown, Ohio. Current plans suggest that the Newtown facilities could be replaced
with smaller scale lab facilities in the AWBERC facility. There are currently 242 EMSL
occupants at the site, including EPA and contract employees, according to the Mitre Report.
EMSL Las Vegas occupies approximately 100,000 NSF in several leased buildings in Las
Vegas; the leases are due to expire in 1996. The process of developing a Program of
Requirements for a new leased facility for the lab is currently underway. For the purposes
of this analysis, it is assumed that 30 professionals will be located in RTF; 15,400 NSF was
identified by the Laboratory as required space.
Status Quo Cost • New Leased Facility for EMSL LV; Renovation Cost EMSL CIN:
(No separate alternatives for Build / Lease)
Interim Lease Cost - LV: $440,040
Long term Lease - LV: $1,064,000
Renovation Cost - CIN: $2,099,410
New Furniture - LV: $140,000
Telecommunications - LV $63,000
Existing Site Cleanup - LV $70,000
Administrative Costs: . $30.000
Space Total: $3,896,450
$146,680/year through 1998 (3 years) for 15,200 NSF
$l,064,000/year for 17 years to lease 15,200 NSF @
$70/NSF (based on 20 year analysis)
EMSL proportion of renovations to AWBERC
identified in FMSD Master Plan
30 occupants @ $4,000/workstation
30 occupants @ $1,800
SHEMD estimate to clean lab and certify non-
contamination. Assumes no major contamination.
Estimated cost for HQ administration of move only.
Cost for four year comparison of costs only. See the
economic analysis attached for net present value of
each alternative.
Move Equipment:
Equipment Total:
EMSL Status Quo
Total Costt
$0
$3.896.450
Cost for four year comparison of costs only. See the
economic analysis attached for net present value of
each alternative.
-------
EMSL CIN and EMSL LV
Consolidate - Build Cost:
Interim Lease Cost: $586,720
Construction Cost: $34,402,020
New Furniture:
Telecommunications
Existing Site Cleanup
$1,108,000
$498,600
$70,000
Administrative Costs: $150.000
Space Total:
Move Equipment:
Equipment Total:
$36,815,340
$1,212,280
$1,212,280
$146,680/year in LV through 1999 (4 years)
74,365 NSF for EMSL/Cin and 15,200 NSF
for EMSL/LV - 149,574 GSF @ $230/GSF
242 Cin and 35 LV occupants @
$4,000/workstation
277 occupants @ $1,800
SHEMD estimate to clean LV lab and
certify non-contamination. Assumes no
major contamination.
Estimated cost for HQ administration of
move only.
$5/GSF for 182,456 GSF; $300,000 for 10
pieces @ $30,000/piece
EMSL Move
Total Cost;
$38.027.620
-------
EMSL
Consolidate - Lease Cost:
Interim Lease Cost: $586,720
New Lease Cost:
New Furniture: $1,108,000
Telecommunications $498,600
Existing Site Cleanup $70,000
Administrative Costs: $150.000
Space Totals $2,413,320
Move Equipment: $1,212,280
Equipment Total: $1,212,280
$146,680/year in LV through 1999 (4 years)
$6,269,550/year for 16 years for 74,365 NSF
for EMSL/Cin and 15,200 NSF for
EMSL/LV @ $70/NSF (Current average
rental rate)
242 Cin and 30 LV occupants @
$4,000/workstation
272 occupants @ $1,800
SHEMD estimate to clean LV lab and
certify non-contamination. Assumes no
major contamination.
Estimated cost for HQ administration of
move only.
Cost for four year comparison of costs only.
See the economic analysis attached for net
present value of each alternative.
$5/GSF for 182,456 GSF; $300,000 for 10
pieces @ $30,000/piece
EMSL Move
Total Cost;
$3.625.600
-------
FILENAME: RTPCINC
DATE GENERATED: 05 JUL 1994
VERSION: PC V3.0
EXECUTIVE SUMMARY REPORT
PROJECT TITLE
DISCOUNT RATE
PERIOD OF ANALYSIS
START YEAR
BASE YEAR
PROJECT OBJECTIVE
RTP - Cincinnati
20 YEARS
1996
1996
Move AEERL/ RTP and RREL/EDS to Cincinnati, and
EMSL/CIN and EMSL/LV to RTP
PAGE!
ALTERNATIVES CONSIDERED FOR THIS ANALYSIS:
ASSUMPTIONS OF THE ANALYSIS:
A discount rate of 8% is used.
Inflation rates used are 2.3% for 1996 and 2.2% for subsequent years
per COE guidance.
Maintenance and Operations costs are assumed to be constant in any
alternative and are not included in the analysis.
Costs for new facilities are taken from EPAB data.
RESULTS AND RECOMMENDATIONS ($ in thousands):
ALTERNATIVE NAME NPV
EUAC
SIR
DPP
1 Status Quo - Build
2 Consolidate - Build
3 Status Quo Lease
4 Consolidate - Lease
$47,884
$57,065
$50,345
$100,435
$4,692
$5,592
$4,933
$9,842
0.83
0.61
-1.04
DISCUSSION:
NPV Net Present Value - The cumulative discounted amount that also
includes the discount value of the residual amount.
EUAC Equivalent Uniform Annual Cost - The amount of money which, if
paid in equal annual installments over the life of a project, would
pay for the project.
SIR Savings to Investment Ratio - Ratio of discounted future cost
savings to the discounted investment cost. An SIR of 1 indicates that
the present value of savings is equal to the present value of the
investment.
DPP Discounted Payback Period - Time required for the accumulated
present value of savings of a proposed alternative to equal the total
present value of its investment costs.
ACTION OFFICER:
ORGANIZATION :
-------
Consolidated Engineering and Monitoring Systems Laboratories
RTF and Cincinnati
AEERL RREL-Edsn
Existing Space (Net Square Feet):
Office Space 21,610 6,000
Lab Space:
Bench 12,605
Animal Care
Containment
High Bay 19,713
Other 7,838
Totals: 61,766 6,000
Proposed at RTF:
AEERL:
Office Space 22,350
Lab Space
Bench 19,512
Animal Care
Containment
High Bay 32,647
Other
Total: 74,509
Proposed at Cincinnati:
AEERL: RREL-Edsn
Office Space
Existing -Ren 15,970
Renovated lab 6,380 8,529
Lab Space
Bench 19,512
High Bay 32,647
Other
Total: 74,509 8,529
EMSL-Cinc. EMSL-Nwtn EMSL-^*** ^)
15,970 2,358 4,200
29,570 ! 4,976 * 9,000
12,190 *
7,500 *
7,859 4,567 * 2,000
75,842 11,901 15,200
Totals
Proposed for
EMSL-Cinc. EMSL-Nwtn EMSL-LV RTF:
34,352 ** 2,584 4,200 41,136
29,570 9,000 38,570
0
0
7,859 2,000 9,859
71,781 2,584 15,200 89,565 NSF
149,574 GSF
Total
Proposed for
Cincinnati:
i
15,970
14,909
19,512
32,647
0
83,038 NSF
138,673 GSF
Data from Mitre Report, FMSD and Laboratories
* Indicates facilities not replicated in new location
242 total occupants @ 152 NSF/person
related component of EMSL - LV proposed for relocation
-------
APPENDIX E
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
-6 694
OFFICE OF
AIR AND RADIATION
MEMORANDUM
SUBJECT:
FROM:
TO:
EPA Laboratory Study:
Laboratory Cpnsolidat
Mary D. Nichols
Assistant Administ
for Air and Radial
commendation for EPA Radiation
ion
EPA Laboratory Steering Committee Members
This is in response to your recommendation that we examine
the potential consolidation of the Agency's radiation
laboratories. After extensive review of the activities,
missions, customers, and geographic location of each facility, I
have several recommendations to present to you for consideration
which I believe best address the Agency's future needs regarding
program-related radiation laboratory functions. Attached are the
recommendations and a discussion of the rationale for them.
If you have any questions, both Ann Goode and I would be
pleased to speak with you about them.
Attachments
Pilnwd wm Soy/Canola Wt on pWtM
contain* « IMX 50% r*eyd*d «*r
-------
RECOMMENDATIONS FOR EPA RADIATION LABORATORY CONSOLIDATION
Background
The EPA Laboratory steering Committee provided the following
recommendation at its meeting on June 7 and 8, 1994:
Have the Radiation Program Office examine the potential
consolidation of its laboratories as well as the
consolidation of appropriate duplicated ORD laboratory
activities into the Program laboratories. The criteria to
be used in the evaluation are whether any such
consolidations would increase efficiency and effectiveness
while providing greater scientific quality.
The three radiation laboratories currently operated by the
Agency are the Office of Radiation and Indoor Air Laboratory in
Las Vegas/ Nevada (ORIA-LV), the ORD Environmental Monitoring
Systems Laboratory Radiation Sciences Division (RSD) in Las
Vegas, and the ORIA National Air and Radiation Environmental
Laboratory (NAREL) in Montgomery, Alabama. Descriptions of each
of the labs are attached.
Recommendations
In evaluating potential changes to the current arrangement
of these three radiation laboratories, both administrative and
physical consolidations have been considered. After an extensive
review of the activities, missions, customers, and geographic
location of each facility, the following recommendations are
presented:
o Consolidate RSD resources and functions into ORIA-LV both
physically and administratively, and retain this
consolidated laboratory in Las Vegas at this time.
o Retain the current operations at the NAREL.
o Use streamlining and the organizational assessment currently
underway by ORIA as opportunities to plan additional
administrative and physical consolidations of the radiation
laboratories' functions, to be implemented over the next two
years.
The rationale and discussion of the issues considered for
this recommendation are.provided below.
-------
Discussion
The current ORIA-LV functions are closely aligned with
program priorities and capitalize on the geographic proximity to
critical sites and western customers. With the physical and
administrative consolidation of ORIA-LV with RSD, RSD-based
resources can be used more efficiently and effectively by
eliminating duplication and redundancy in the new organizational
unit.
The mission and current functions of the RSD (formerly the
Nuclear Radiation Assessment Division) are primarily routine
monitoring and laboratory analysis of samples, with an emergency
preparedness capability, and have steadily evolved away from a
research orientation associated with device testing activities at
DOE's Nevada Test Site (NTS). RSD's technical support
activities, largely in the form of quality assurance, laboratory
audits and provision of measurement standards, have also been
reduced over time.
This recommendation is consistent with the Laboratory
Steering Committee, SAB, and NAPA views of the ORD mission, and
assigns to the appropriate program laboratory those activities
which are routine and provide technical or regulatory support,
but are not research oriented. In addition, consolidation of the
two Las Vegas radiation laboratories into one will result in a
more effective, streamlined unit that will be better able to
provide program and regional technical support in accomplishing
the Agency's radiation protection mission. Site investigations,
radioanalytical sample collection, data analyses, monitoring, and
field demonstration capabilities will be enhanced with the
combined resources of the two Las Vegas laboratories under the
direction of ORIA.
There are specific activities which are based in the Las
Vegas radiation laboratories and which should be maintained there
due to geographic considerations. These include:
o Emergency Response to Radiation Accidents and Incidents -
Since the Agency's ability to respond effectively and
quickly to accidents relies upon the response team's
geographic proximity to the accident site, the maintenance
of emergency response capability in both .the eastern and
western U.S. is critical. In addition, the primary western
U.S. DOE response team and capabilities are located in Las
Vegas. In the event of a major radiation accident, a DDE-
chartered plane with an EPA response team on board can leave
Las Vegas within 2 hours and fly directly to the accident
site.
o Radiation-related Monitoring Activities at the NTS - These
activities by EPA should be maintained in the Las Vegas area
to evaluate the extent of contamination at the NTS over
time.
-------
o Review and Oversight over the Waste Isolation Pilot Project
(WIPP) - The WIPP site, waste generators, and western-based
contractors that will be the initial shippers are located in
the western U.S. The Las Vegas facility is strategically
located to monitor and characterize the waste and generator
sites through collection and review of field information,
review of certification applications, and compliance.
Without an ORIA facility in Las Vegas, it would be necessary
to establish a field office in New Mexico to perform these
duties.
o Radon Chambers - The approximately 200 radon chamber walk-in
clients who are located in the western U.S. depend on the
chambers in Las Vegas for the proficiency certification
testing of their active radon measurement devices. Without
such capabilities, the western clients, who represent half
of all those certified by the Agency, would have to travel
to Montgomery, Alabama, for certification. Quality
assurance is also enhanced through the maintenance of
separate chambers.
o NIST Primary Standards Laboratory - This facility is located
at the NTS and has the only neutron source available to EPA,
instrumentation electronics, airflow capabilities, and low
background calibration wells.
Some activities being performed at both the consolidated Las
Vegas facility and the NAREL may continue to be similar (radon
chamber proficiency testing, emergency response, e.g.). However,
each laboratory activity will be carefully reviewed during the
ORIA organizational assessment to be conducted during the next
several months. During this process, opportunities for both
administrative and activity-specific consolidations will be
identified based on the criteria provided previously by the
Steering Committee.
-------
ATTACHMENT
EPA RADIATION LABORATORIES AMD FUNCTIONS
Office of Radiation and Indoor Air Laboratory - Las Veaas
ORIA-LV is -a program support: laboratory with direct
involvement in, and support to, ORIA HQ programs. The laboratory
operates several technical programs which support regulatory and
policy development as well as support to HQ and Regional program
implementation. ORIA-LV is centrally located near national and
regional radioactive waste repository sites, waste generators,
and western U.S. and Indian Nation customers. ORIA-LV programs
include:
o Review and oversight of DOE's Waste Isolation Pilot Project
(WIPP) at Carlsbad, New Mexico and WIPP waste generators;
o Technical support for the development of clean-up standards
for contaminated sites;
o Technical support for indoor air quality activities,
including field measurements, demonstrations, and
evaluations;
o Emergency response capabilities and the maintenance of
mobile laboratories which provide on-site technical services
to western locations; and
o Operation of three radon chambers for the Agency's western
U.S. clients of the radon measurement proficiency program.
ORD Environmental Monitoring Systems Laboratory's Radiation
Sciences Division - Las Veaas
RSD conducts several radiation programs in support of HQ and
regional customers, as well as programs for the Department of
Energy with reimbursable FTE*s provided by them. All these
activities are routine,, and provide technical or regulatory
support to their customers. RSD programs includes
o Quality assurance cross-check activities;
o On-site audits of radiological laboratories seeking Safe
Drinking Water Act certification;
o Calibration standards services to various customers,
including EPA's regional offices and states;
o Thermoluminescent dosimeter services to EPA staff for health
and safety monitoring;
-------
Off-site monitoring of the Nevada Test Site and other former
DOE weapons sites with reimbursable FTE's provided by DOE;
and
Emergency response and emergency preparedness functions to
DOE in support of the Federal Response Plan with
reimbursable FTE's provided by DOE.
ORIA NationalAir and Radiation Environmental Laboratory -
Montgomery
NAREL is an ORIA facility located in Montgomery, Alabama, in
a specially designed and newly-constructed building. It is a
technical support laboratory to ORIA, EPA Regions, and States.
It also provides support to the Superfund program, as well as the
Agency for Toxic Substances and Disease Registry with
reimbursable FTE's to EPA. NAREL programs include:
o Operation of the nationwide Environmental Radiation Ambient
Monitoring System to analyze various media for radioactivity
and to track releases from nuclear weapons tests and nuclear
accidents;
o Management of the Agency's Radon Measurement Proficiency
Program and operation of two radon chambers for eastern U.S.
clients;
o Emergency response capabilities and the maintenance of a
mobile radioanalytical laboratory for response to nuclear
• accidents;
o Electromagnetic radiation measurement activities, including
the use of a unique calibration laboratory and field study
capability;
o
o
Mixed waste analysis capability; and
Technical support for guidance documents in support of the
clean-up standards for contaminated sites.
-------
APPENDIX F
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6
1445 ROSS AVENUE. SUITE 1200
DALLAS. TX 75202-2733
ency
JUH I I '994
MEMORANDUM
SUBJECT: EPA Laboratory Study: ESD Evaluation - Cross-
Subcommittee Final Report
FROM: Joe D. winkle
Deputy Regional Administrator Region 6
TO: EPA Laboratory Steering Committee Members
on behalf of myself and my fellow co-chairs, Jeanne Fox
(Region 2) and Shelley Metzenbaum (OROS/LR), it is my pleasure to
inform you that the Cross-Agency Subcommittee (Subcommittee) has
successfully completed the additional evaluation of the
Environmental Services Divisions (ESDs) requested by the Deputy
Administrator and EPA Laboratory Study Steering Committee
(Steering Committee) at the Annapolis retreat. As you will
recall, after a lengthy discussion, Mr. Sussman suggested that
there were several issues that needed to be further evaluated
concerning future operations of the ESDs.
Attached is a copy of the report prepared by the
Subcommittee, including a summary of recommendations. The
Steering Committee as a whole will need to evaluate these
recommendations and develop a plan for implementation.
I would like to tJtJc« this opportunity to acknowledge the
intensive efforts of the Subcommittee members and their support
staffs. This evaluation was done in an extremely short period of
time, requiring a tremondous amount of coordination and
participation.
I am looking forward to discussing these recommendations
with you at our next mooting, if you have any questions, please
contact me at 214-655-2100.
Attachment
Printed on
-------
-------
RESEARCH, DEVELOPMENT AND
TECHNICAL SERVICES AT EPA:
A NEW BEGINNING
ESD EVALUATION REPORT
REPORT TO THE
EPA LABORATORY STUDY
STEERING COMMITTEE
JUNE, 1994
Cross-Agency Subcommittee
-------
ENVIRONMENTAL SERVICES DIVISIONS EVALUATION
CROSS-AGENCY SUBCOMMITTEE REPORT
I. EXECUTIVE SUMMARY
II. DESCRIPTION OF ENVIRONMENTAL SERVICES DIVISIONS (ESD)
A. Introduction
B. ESD Mission Statements
C. ESD Services
D. ESD Customers
III. SUMMARY OF EPA LAB STUDY FINDINGS*
A. Mitre Report
B. NAPA Report
C. SAB Report
D. Research. Development and Technical Services at EPA: A New
Beginning Report {Draft 6/13/94)
IV. CROSS-AGENCY SUBCOMMITTEE CHARGE
V. EVALUATION APPROACH
VI. EVALUATION ANALYSIS
A. ' Evaluation of Central Advocate(s) and Their National Planning
Function for ESDs
B. Evaluation of Dedicated Resources for Base
C. Evaluation of Budget Mechanism and Location
D. Evaluation of Alignment and Coordination Options between ESDr
Program Offices and ORD Activities and Exploration of Coordination
Options to the Agency Budget and Strategic Planning Processes
E. Exploration of Processes to Ensure that Future Planning includes
review of Organizational Alignment of ESDs with Agency's
Scientific/Technical Mission
VII. RECOMMENDATIONS
APPENDIX A ADVOCATE PRO/CON ANALYSIS CHARTS
-------
ENVIRONMENTAL SERVICES DIVISIONS EVALUATIQM
CROSS-AGEMCY SUBCOMMITTEE REPORT
i.
EXECUTIVE SUMMARY
The U.S. Environmental Protection (EPA), in an effort to assess the state of its
science and technology program, has conducted a comprehensive Laboratory
Study, whereby, ail its research and technical laboratories were reviewed. This
study was conducted by a contractor, Mitre, and their findings presented in a
comprehensive report.
The EPA Laboratory Study Steering Committee (Steering Committee) convened in
Annapolis, MD on June 7 and 8, 1994 to evaluate the results of the Mitre Study,
and to develop its own opinion and plan of action that addresses the Agency's
science and technology program.
The Steering. Committee endorsed a series of recommendations that covered issues
pertaining to the balance of long-term research and applied research, peer-review,
competition of research resources, streamlining and management improvements,
and reorganization options for laboratories in EPA's Office of Research and
Development (ORD), the program offices and the regional Environmental Services
Divisions (ESDs). .
After a lengthy discussion concerning the ESDs, the Deputy Administrator raised
several issues to the Steering Committee that required further evaluation. The
Steering Committee formed a CrossrAgency Subcommittee (Subcommittee) to
evaluate:
• A central advocate(s) and its national planning function for the ESDs;
• A dedicated resources (FTE/dolUirs) base;
• A budget mechanism (program element, line item) and location;
• Alignment and coordination options between ESDs, Program Offices and
ORD;
• Coordination options to the Agency budget and strategic planning processes;
and
• Processes to ensure that future planning includes a review of organisational
alignment of ESDs with the Agency's scientific/technical mission.
-------
Upon completion of series of analyses, the Subcommittee presents the following
recommendations:-
• The ESD Central Advocate should be charged with the primary responsibility
of the assurance and maintenance of customer alignment between scientific
and technical services of the ESDs and their customers. OROS/LR provides
the essential neutrality required in establishing and maintaining this customer
alignment across the Agency.
• OROS/LR should continue in its national advocacy role for the ESDs.
Modifications to enhance OROS/LR management and budget systems will be
necessary. If the enhancements outlined by the Subcommittee cannot be
achieved, supplemental analysis would need to be conducted to determine
an alternative advocate.
• By establishing a balanced ESD budget, EPA provides for the essential
organization stability and maintains flexibility to fulfill program requirements.
The balanced ESO budget fosters customer alignment.
• The Subcommittee does not propose any redistribution of the ESD scientific
and technical resources across the Agency.. The Subcommittee proposes
that a national budget for the ESDs be established in a single program
element placed within the central advocate's budget responsibilities. The
national budget will be the sum of the individual core requirements identified
for each Region. The remaining targeted ESD base should be established as
line items with the respective program office budget responsibilities.
Additional negotiations for increased capability and capacity would continue
to be conducted through the existing negotiation process.
• A new Agency-wide planning process for research, development and
technical services should be developed. The ESD Central Advocate, in
coordination with the Regional Administrators, is charged with the primary
responsibility for ensuring that ESD scientific and technical services are
integrated into the Agency's Strategic Plan.
• To effectively plan for the future, accurate and readily available information
concerning the ESD's scientific and technical services must be available.
EPA should develop an integrated process to evaluate its current, and
forecast its future, science and technical service requirements.
These recommendations are being forwarded to the full Steering Committee for
inclusion in their recommendations to the Administrator.
-------
II. DESCRIPTION OF THE ENVIRONMENTAL SERVICES DIVISIONS
A., Introduction
The regional Environmental Services Divisions (ESD) of the U.S. Environmental
Protection Agency (EPA) offer a full-range of technical services in support of
regional and national media-specific (air, water, pesticide, toxics, and hazardous
waste), and enforcement programs.
The Divisions are typically divided into three branches: the Surveillance and
Monitoring, the Regional Laboratory and the Quality Assurance Branches. These
branches provide complimenting services for the collection, analysis, and*
evaluation of quality data. They direct and coordinate surveillance and monitoring
activities within the Region, provide necessary analytical services, and ensure the
quality of data generated in support of all Agency mandated programs.
ESDs work with State, local and tribal governments on a day-to-day basis, not only
in an advisory role, but in a hands-on capacity, providing on-site assistance. ESDs'
multi-disciplinary technical staff provide technical assistance concerning laboratory
and field techniques, quality assurance and control, and when necessary, actual
analytical support to ensure their field investigations. ESDs have an essential role
in interpreting data, measuring trends, and establishing environmental profiles.
Through the leveraging of multi-discipline technical employees, ESDs are able to
provide services at a significant cost savings allowing for the Agency to retain in-
house expertise. Maintenance of in-house expertise is vital for effective and
efficient review of external parties performance, evaluation of proposed
technologies, evaluation of grant proposals and cost. Additionally, in-house
expertise is essential to proper case development for sensitive enforcement
actions.
-------
fi*
ESP Mission Statements
The ESDs have adopted the following mission statements1 in their strategic
planning effort.
• To maintain and enhance a technically scientifically skilled, dedicated and
diverse staff through the excellence of our recruitment, career development,
training, management and leadership. To incorporate the ESDs as equal
partners in the Agency's budget, management and decision-making
processes.
• To conduct quality inspections and investigations to achieve and maintain a
high level of compliance with environmental laws and regulations. To
participate in enforcement programs by providing comprehensive technical
support and analysis.
• To assess, from a multi-media/multi-program perspective and in partnership
with regional programs, the environmental problems in the region and their
relative risk. To identify information gaps to direct future data acquisition
activities.
• To use scientific information and environmental data to identify problems,
assess their relative risk and identify information gaps that exist for
identification of emerging problems.
• To provide fully equipped, field and laboratory support to produce physical,
chemical and biological data of known quality to be used for environmental
decision-making at ail levels of government.
\ ' -
• To provide scientific data of known quality to support Agency decision-
makers through partnerships with regional and national media program
offices, state, local and tribal governments, academia, the private sector and
public.
• To communicate ESDs' vision, mission, goals, priorities and expertise to its
customers and policy-makers.
National Strategic Plan for the Environmental Services Division. Aoril 1993.
6
-------
£j. ESP Services
The ESDs provide the following full range of complimenting services.
• Analytical Services - The ESDs operate regional laboratories that provide a
full cadre of analytical testing services for physical, chemical, microbiological
and biological parameters utilizing modern instrumentation and Agency-
approved methodologies. This capability provides essentiai geographically
data that is used for compliance monitoring of all media, including civil and
criminal enforcement, special health risk studies (ambient air toxic
monitoring) and special ecosystem studies (EMAP/REMAP), Several regional
laboratories have specialized unique services due to specific regional needs
(e.g. low level metals analysis, dioxin, protozoa).
• Environmental Data Handling and Assessment - Data management and
assessment are critical to ensure sound Agency decision-making.
Centralized data management allows for integrated data assessment. The
ESDs assist in managing national databases consisting of a full array of
environmental data. Examples of these include, STORET, AIRS and WBS.
These data are used to assist in establishing baselines, determining trends,
ensuring data quality and assisting in evaluating compliance to
environmental laws and regulations.
• Environmental Monitoring - oversight, technical assistance and data
evaluation are monitoring services provided by the ESDs. Examples of these
services are the ozone PAMS network, ambient air toxics monitoring,
participation in the national estuary program providing field and analytical
support, and interaction with the states for a wide range of statutory
programs (105, 106, 305t>, and 319).
• Reid Inspections and Investigations - The ESDs provide a wide array of
complimenting services in support of single and multi-media inspections and
investigations. This includes facility compliance inspections, compliance
sampling inspections, criminal and civil enforcement investigations,
emergency response support and oversight of state media programs and
contractors.
• Quality Assurance - Development and management of the regional Quality
Assurance (QA) program is performed by the ESDs which provides e
centralized approach to ensure that data used to make decisions ere of
acceptable and appropriate quality. This involves working closely with
regional staff, other Federal agencies, State, local and tribal governments
and the private sector providing assistance in the development of monitoring
-------
plans, grant and contract workpfans, methodology requirements and
standard operating procedures.
• Technical Services/Transfer - The ESDs provide technical assistance to
strengthen fheir partnerships with regional and national media program
offices, State, local and tribal governments, academia, the private sector and
public. Services offered include assistance related to laboratory techniques,
equipment/instrumentation, and quality control. In addition, training is
provided by the ESOs related to these issues.
Qj. ESP Customers
The ESDs provide services for a wide variety of customers that can be categorized
into primary and secondary customers both internal and external to the Agency.
Their primary internal customers include the Regional Administrators (RAs), Deputy
Regional Administrators (DRAs), Program Division Directors (regionally and
nationally), regional staff, criminal investigators, the Office of the Inspector General
(OIG) and the Office of Regional Counsel (ORC). Primary external customers are
state, local and tribal government agencies (such as environmental, health and
agricultural) and the regulated community.
Secondary, internal customers are the regional offices of External Affairs, the
National Environmental Services Officer (NESO) in the Office of Regional
Operations and State/Local Relations (OROS/LR), Headquarters Program Office
Assistant Administrators (AAs), the Office of Research and Development (ORD)
laboratories and the National Enforcement Investigation Center (NEIC). The public,
volunteer monitoring groups, other federal agencies, academia, contractors,
commercial environmental laboratories. Congress, environmental interest groups
and the media are considered secondary external ESD customers.
8
-------
III. SUMMARY OF EPA LABORATORY STUDY FINDINGS
Aj. Mitre Report
A baseline description of all EPA laboratories was provided in the Mitre report.
Mitre assessed options for enhancing the quality, effectiveness and efficiency of
laboratory operations to respond to current and future roles and missions.
These options included customer orientation, streamlining, the Carnegie
Commission, a distinct Environmental Services Organization and geographic
approaches, all with and without physical consolidation.
Mitre reported that EPA can improve the efficiency and effectiveness of its
operations through management changes. The changes would eliminate the
apparent duplications of facilities and equipment, and facilitate the disciplinary
strengths of the human resource base. These changes are:
• Consolidation of all of the Office of Prevention Pesticides and Toxic
Substance (OPPTS) laboratories and the two Office of Radiation and Indoor
Air laboratories;
• Realignment and consolidation of ORD laboratories in the manner of the
Carnegie Commission option; and
• Reduction of the number of laboratories within the regional offices through
consolidation to a few laboratories with national service focus.
Mitre recommended five management .improvements that in their opinion would
provide for positive changes:
• The establishment of quality assurance as a visible high-level function;
• The perfection of the issue-based planning process;
• The creation of customer orientation throughout the Agency with a clearly
focused and articulated mission statement;
• The improvement to the information management system to increase the
accessibility of managers to complete, consistent and accurate data; and
• The delegation authority to the lowest level of management consistent with
federal policies.
-------
.8. National Academy of Public Administration Report
The National Academy of Public Administration (NAPA) convened two panels of
experts to review the recommendations of the Mitre Report pertaining to
organizational capacity and science issues.
NAPA reported that the ESDs work was science and technology-based. The ESD
workload is clearly defined, and there appears to be a reasonable match between
workload and capacity for the ESDs. The ESDs receive direction mainly from the
program offices, but it is placed through and managed by the RAs allowing for
flexibility and appropriate accountability.
NAPA recognized the close relationship the ESDs have with the RAs. NAPA stated
that there are program support requirements placed in ORD that cannot be satisfied
by the ESDs or program office laboratories that then poses a serious challenge to
ORD in achieving these requirements and maintaining a longer-term strategic
research agenda.
NAPA supported the creation of an Environmental Services Organization. This
would create a single Headquarters official responsible for ESDs and program office
laboratories at a national level. This approach would enhance multi-media support
and research to future regulatory programs, reducing ORD's workload.
Cj. Science Advisory Board Report
The Research Strategies Advisory Committee (RSAC) of the Science Advisory
Board (SAB) reviewed the findings of the Mitre report. The RSAC reported that the
program office and ESD laboratories focused on near-term applications of science,
particularly those associated with monitoring, methods development, inspections
and enforcement of particular media statutes and regulations. There is frequent
interaction between these laboratories and their customers, and a general
understanding of the mission they support. The ORD laboratories tend to focus on
problem-oriented and long-term research which is more strategic in nature, leading
to new insights about mechanisms and interrelationships. Many of the interactions
with the ORD clients are controlled by Headquarters staff.
The findings and recommendations of the SAB focused mainly on the ORD
laboratories. They recognized the Administrator as the principal client and
spokesperson for the Agency. ORD scientists must be relieved of administrative
and contract management oversight responsibilities, and be allowed to return to
hands-on research. A more efficient, effective and mission-oriented research
management system, with minimal barriers to achieve scientific and engineering
goals, needs to be created.
10
-------
Actions should be taken to correct basic research management problems,
considering both the ORD laboratories and their Headquarters office, before any
initiative is taken addressing realignment. The RSAC opposed the proposal of
creating the new Environmental Services Organization. More analysis and
consideration needs to be conducted concerning human resource needs, and the
impacts that reorganization and realignment may have on them.
The Committee initially recommended that no particular option be selected until
management improvements were made. At that time, realignment or physical
consolidation may still need to be implemented. With these improvements made,
the Committee endorsed some variation of the Carnegie Commission option from
the Mitre report, providing for the creation of some mega-iaboratories tr\at would
represent particular themes related to EPA's mission. They recommended that risk
assessment be included as one of the themes.
The Committee concluded with the statement that the Agency's extramural
research program should be expanded to demonstrate the Agency's commitment
to environmental research. EPA should develop mechanisms that allows for a fully
competitive process, both internally and externally.
Qt Research. Development and Technical Services at EPA; A New Beginning -
Draft 6/13/94.
The EPA Laboratory Study Steering Committee (Steering Committee) convened in
Annapolis, MD on June 7 and 8, 1994 to evaluate the results of the Mitre EPA
Laboratory Study, and to develop its own opinion and plan of action that addresses
the Agency's science and technology program.
The Steering Committee began by defining the mission of EPA, and its unique role,
as the joint protection of environmentai quality and human health. It is noted that
effective environmentai policies depend on sound science. As a result; science
must be the fundamental basis for decisions at EPA.
The Steering Committee endorsed the following recommendations:
• EPA will change its research program to ensure a balance between research
resources support long-term research and research resources used to
support the applied research and implementation requirements of the
regulatory programs and the Regions.
11
-------
• The Administrator will designate a senior policy official to serve as the focal
point for the strategic planning and implementation of the Agency's
research, development and technical services as an integral part of the
Agency's Strategic Plan. A planning process will be developed that
integrates the needs and capabilities of the ORD, Program Offices and
Regions.
• The organizational concepts proposed by the Carnegie Commission will be
accepted by EPA. ORD will reorganize its national research laboratories into
four categories: a) Environmental Health and Effects; b) Exposure; c) Risk
Assessment, and d) Risk Management.
• EPA will provide for competitive, peer-reviewed grants for academia and not-
for-profit scientific community and work with other federal scientific
agencies to ensure coherent and integrated federal environmental science
programs.
• EPA will significantly increase the involvement of the broad scientific
community in EPA science activities through an enhanced peer review
process. ,
• EPA will improve the partnership among its science programs - ORO, the
program office laboratories and the ESO laboratories.
• ORD will take steps to decentralize research laboratory management and
administration, and use streamlining as an opportunity to enhance and
empower the science function in EPA.
• The Agency recognizes the importance of maintaining the Program office
laboratories because they, provide vital technical support to assist in the
regulatory development and enforcement in the missions areas of their
parent offices.
• The regional ESD laboratories provide scientific and technical support to the
RAs. These laboratories are important to maintain, and EPA will explore
ways to enhance and improve their functions.
The Rnal Report containing the EPA Laboratory Study Steering Committee
recommendations to the Administrator is scheduled to be completed in July 1994.
12
-------
IV. CROSS-AGENCY SUBCOMMITTEE CHARGE
After a presentation of the ESDs during the afternoon session on June 8, 1994 at
the Steering Committee Retreat, four actions were proposed as potential solutions
to existing problems experienced by the ESDs. They were establishing 1) a
champion for ESDs-in Headquarters, 2) dedicated resources (FTE/dollars) and a
program element, 3) a confirmed capital budget including, Building & Facilities
(B&F) and Repair & Improvement (R&l) resources for the regions, and 4) a
champion for methods development and validation.
The Steering Committee discussed a full-range of issues surrounding the p/oposed
actions. Following a lengthy discussion, the Deputy Administrator summarized the
discussion by stating that there was consensus that 1) a Headquarters advocate(s)
for the ESDs should be fully evaluated, 2) a national program element/budget
should be fully evaluated to provide a stable base of resources for the ESDs, and 3}'
dedicated support for methods development and validation should be explored.
OARM and ORD will lead the evaluation of B&F/R&I resources and methods
development/validation, respectively. ESDs will provide assistance in the
evaluation of these cross-cutting issues, as necessary.
The Deputy Administrator presented an unexplored issue as "Are we satisfied with
the current organization of ten regional laboratories?". Following a discussion of
the ESDs and their customer relationships, the Steering Committee agreed to
maintain the current organization with a regional laboratory in each Region. The
Steering Committee supported an initiative that future planning activities, both
strategic and budget, should provide opportunities to review the regional
organization and the Agency's scientific/technical mission.
An subcommittee was formed and charged by the Deputy Administrator and the
Steering Committee. The ESD evaluation was placed by the Deputy Administrator
on the "front burner" and must be completed by June 23, 1994. The
subcommittee consisted of representatives from all the ESDs, and the various
program offices. Region 6, the Lead Region for the ESDs, served as this Cross-
Agency Subcommittee coordinator, with assistance from Region 2 and OROS/LR.
13
-------
The following charge for the Cross-Agency Subcommittee was proposed by the
Deputy Administrator and concurred on by the Steering Committee.
0 To evaluate a central advocate(s) and its national planning functions for the
ESDs;
• To evaluate dedicated resources (FTE/dollars) base;
• To evaluate a budget mechanism (program element, line item) and location;
• To evaluate alignment and coordination options between ESDs, Program
Offices and ORO;
• To explore coordination options to the Agency budget and strategic planning
processes; and
• To explore processes to ensure that future planning includes a review of
organizational alignment of ESDs with the Agency's scientific/technical
mission.
14
-------
V. EVALUATION APPROACH
The following action steps were taken by the Cross-Agency Subcommittee to
complete the evaluation.
Ai Evaluation of Centraf Advocate(s) and Their National Planning Function for
ESDs
• Evaluate potential candidates (Pro/Con Analysis);
• Conduct ESD/candidate function analysis (Crosswalk);
• Analysis using evaluation criteria such as Science Quality/Utility,
Stature/Credibility, Mission Focus, Customer Satisfaction, Multi-media
Approaches, Priorities, Function alignment, Future Investment, Locus of
Control;
• Develop a roles/responsibilities description for national planning function;
and
• Develop a short list of candidates.
fij. Evaluation of Dedicated Resources for Base
• Determine current resource level and source (FTEs/dollars);
• Determine base resource requirement; and
• Develop Budget Proposal(s).
£*, Evaluation of Budget Mechanism and Location
• Evaluate program element vs.. line item mechanisms (Pro/Con Analysis); and
• Evaluate National Program Manager (NPM) location (Pro/Con Analysis).
EL, Evaluation of Alignment and Coordination Options between ESP. Program
Offices and ORD Activities
• Evaluate current communication process (formal, informal);
• identify contact points or liaisons; and
• Develop an improved communication integrated strategy that includes the
activities of ESDs, Programs and ORD.
£i Exploration of Coordination Potions to the Agency Budget and Strategic
Planning Processes
• Integrate the Agency Science/Technology mission into the Agency's budget
and strategic planning processes (being processed as management
improvement action in the lab study).
15
-------
•
•
Exploration of Processes fp Ensure that Future Planning Includes a Review of
Organizational Alignment ESDs with the Agency's Scientific/Technical
Mission
Evaluate a potential organization and function review process;
Develop mechanisms to integrate the review process into the Agency's
budget and "strategic planning process; and
Incorporate accountability as part of the Advocate's performance criteria.
16
-------
VI. EVALUATION ANALYSIS
The following sections describe a summary of the evaluation analysis conducted by
the Cross-Agency Subcommittee.
A^ Evaluation of Central Advocate(«?) and Their National Planning Functions for
1.
ESDs
Proposed Roles and Responsibilities
Noted during the June 7-8, 1994 Steering Committee Retreat was the absence of
a strong national advocate for the ESDs in the Agency's overall budget and
strategic planning process. The roles and responsibilities for this advocate are
proposed as follows:
• Serves as ESD national program manager with clearly defined
responsibilities, authority and accountability. Organization and reporting
responsibilities would be aligned with current Assistant Administrator
(AA)/RA relationships for existing Agency programs.
• Provides consensus building for the effective and efficient use of resources
to meet individual program and the overall Agency's science/technical
support requirements.
• Serves as the focal point for problem identification and solving for the
Agency's program offices, ORD and the Regions.
• Serves as a national forecaster ensuring that the development of the ESDs
are in line with the Agency's scientific mission, and that resources to meet
future demands are available.
• Serves as the national advocate ensuring that the Agency's senior
management both is aware and understands how the ESD mission integrates
into the overall Agency's scientific mission.
• Represents the ESDs as an equal partner during the Agency's budget and
strategic planning efforts.
• Provides leadership for the ESDs promoting national consistency.
• Facilitates communications between ESDs, the Administrator and national
program offices.
17
-------
ta. Potential Candidate^
Deputy Administrator
Science Poficy Council
Assistant Administrator, Office of Air and Radiation (OAR)
Assistant Administrator, Office of Prevention, Pesticides and Toxic
Substances (OPPTS)
Assistant Administrator, Office of Water (OW)
Assistant Administrator, Office of Solid Waste and Emergency Response
(OSWER)
Assistant Administrator, Office of Enforcement and Compliance Assurance
(OECA)
Regional Administrator (RA)/Assisfant Administrator (AA) Advisory Panel
Deputy RA/Deputy AA Advisory Panel
*
•
•
•
2. Analysis
The potential candidates were initially analyzed by looking at the following
approaches.
FOCAL POINT APPROACH
• Focal Point Approach is defined as a single point contact responsible for
national advocacy, budget planning, and strategic planning for the ESDs.
• Can include:
AA, OROSL/R
Science Advisor to the Administrator
Deputy Administrator
TEAMS APPROACH
• Teams Approach is defined as of a group of individuals sharing responsibility
for national advocacy, budget planning, and strategic planning for the ESDs.
18
-------
• Can include:
RA/AA Advisory Panel
DRA/Deputy AA Advisory Panel
Science Policy Council
INDIRECT STAKEHOLDER
• An Indirect Stakeholder is defined as an existing AA, who is not a
stakeholder, who will serve as the national advocate and be responsible for
budget and strategic planning for the ESDs.
• Can include:
AA, OARM
AA, OPPE
SINGLE PROGRAM DIRECT STAKEHOLDER
• A Single Program Direct Stakeholder is defined as an existing A A, who is a
stakeholder/customer for a single program, who will serve as the national
advocate, and be responsible foe budget and strategic planning for the ESDs.
• Can include:
AA, OAR
AA, OSWER
AA, OW
AA, OPPTS
CROSS PROGRAM DIRECT STAKEHOLDER
• A Cross Program Direct Stakeholder is defined as an existing AA, who is a
stakeholder/customer of more than one program, who will serve as the
national advocate, and be responsible for budget and strategic planning for
the ESDs.
• Can include:
AA, OECA
AA, ORD
19
-------
Further analysis provided five additional hybrid approaches (combinations):
FOCAL POtNTTTEAMS
• Focal Point/Teams is defined as a combination of a single focal point
responsible for national advocacy, and budget and strategic planning for the
ESDs with consultation from an advisory team.
• Can include:
A A, OROSL/R/Advisory Panel or SPC
Science Advisor/Advisory Panel or SPC
Deputy Administrator/Advisory Panel or SPC
INDIRECT STAKEHOLDER/TEAMS
• Indirect Stakeholder/Teams Approach is defined as an existing AA, that is
not a stakeholder, who will serve as a national advocacy, and be responsible
for the budget and strategic planning for the ESOs with consultation from an
advisory team.
• Can include:
. AA, OARM/Advisory Panel or SPC
AA, OPPE/Advisory Panel or SPC
SINGLE PROGRAM DIRECT STAKEHOLDER/TEAMS
• Single Program Direct Stakeholder/Teams is defined as an existing single
program AA, who is a stakeholder/customer for a single program, that will
serve as the national advocate, and be responsible for budget and strategic
planning for the ESDs with consultation from an advisory team.
• Can include:
AA, OAR/Advisory Panel or SPC
AA, OPPTS/Advisory Panel or SPC
AA, OSWER/Advisory Panel or SPC
AA, OW/Advisory Panel or SPC
20
-------
CROSS PROGRAM DIRECT
-------
QRD/TEAM
• This was defined as the AA from ORD who will share responsibility for the
national advocacy, and budget planning and strategic planning for the ESDs
with consultation from an advisory team.
ENHANCED OROS/LR/TEAM
• This was defined as a Modified Focal Point/Teams with the focal point being
the AA for OROS/LR. This option provides for the implementation of
management improvements and consultation from an advisory team to
improve and enhance the current situation.
• Proposed management improvements should include:
Clearly defined roles and responsibilities within OROS/LR;
Identification of senior manager within OROS/LR:
Development of a communication strategy (inreach and outreach);
Improved dedicated staffing with OROS/LR;
Evaluation of contractor support mechanisms;
Increased use of regional rotational assignments for special projects;
Development of a national ESD database;
Implementation of the national ESD strategic plan;
Establishment of Memorandum of Understanding (MOUs) between
OROS/LR and the Programs and Regions;
Successful Resolution of budget issues (Executive Office limitations);
Conducting of annual performance surveys;
Coordination between OROS/LR Unking regional operations (ESD
specifically) and state/local relations who are the ESD customers,
fostering leveraging of resources; and
Conducting of a national needs survey. .
22
-------
CO
uu
C
5
u
ui
O
O
O
CO
to
UJ
g
cc
UJ
(A
UJ
S
UJi
O
|
S
(A
Ul
a
H
s
UJ
cc
o
JVOCATE CANDIDATE APPROACH
—
X
(S
u.
UJ
Q
U
CO
<
iteria Reference Code
u
o
••
o
o
o
o
o
0
0
FOCAL POINT
uty Administrator
jnce Advisor to Admin.
OROS/LR
^ o w <
o
o
0
o
0
o
o
'
0
-!»
>;§ O
o > >•
(0 ^3 O
. < IE "5
CM CC O CO
+
-1-
I
O
o
o
•'
+
1
INDIRECT STAKEHOLDER
OARM
OPPE
«SS
•f
+
•
'
,
: •
•
+
0
£
3
o
••t
SINGLE PROGRAM DIRECT STAKI
OAR
OPPTS
OSWER
OW
-
+
i
t
-f
•
i
•
+
o
CC
o
o
x
CROSS PROGRAM DIRECT STAKE
OECA
QRD
555
o
1
o
o -
o
o
o
o
o
^
(O
00
FOCAL POINT/TEAMS
luty Administrator/Advisory Panels
snce Advisor/Advisory Panels or SP
, OROS/LR/Advisory Panels or SPC
«* .S ^
. « 0 <
in Q co <
* 1
-
-
+
II
' II
+
||
H
^ ij
-
+
°
ENHANCED OROS/LR/TEAMS
s
m
es
-------
CO
CO
s
O
5
1
UJ
S
o
o
a
<
§
CO
CO
UJ
O
i
UJ
CO
2
UJ
2
i
>
ut
•
UJ
3
2
P
2
O
U
fe
X
o
ce
CO
* *
UJ
_J
m
jS
1
E
1—
E
u
VOCATE CANDIDATE
Q
^f
U
0
U_
UJ
Q
O
ffi
*
teria Reference Code
'Si
o
INDIRECT STAKEHOLDER/TEAMS
9
^f
CO
-
+
O
-
0
4-
4.
+
O
AA. OARM/Advlsory Panels or SPC
.
-^f
CO
o
o
o
+
4-
O
0
+
+
AA, OPPE/Advisbry Panels or SPC
a
CO
-
-
•
+
•
0
+
+
o
CO
<
UJ
Ul
o
0
SINGLE PROGRAM DIRECT STAKEH
OAR/Advisory Panels or SPC
OPPTS/Advisory Panels or SPC
OSWER/Advfsory Panels or SPC
OW/Advisory Panels or SPC
. * * * »
^f ^t ^3» ^! *d[
r* < < < <
+
-
0
-
+
o
+
'+
•f
CO
i
e
HI
0
O
CROSS PROGRAM DIRECT STAKEH
a
-
+
o
-
+
i
0
+
0
. AA, OECA/Advlsory Panels or SPC
^»
a
+
-
o
*
-f
o
o
+
+
. AA, ORD/Advlsory Panels or SPC
cs
i^
r*
-------
4
Ht
a .g
to
0)
3
C/1
u
C5
.c
- « . £ < t/5
*
k
-*
— 1
^
o "
0. -0
5- £
3 f^
tfi
9
>.
O
;= c
re co
:= OT
*•
C
QJ
*Brf
.9- E S
«
S 3
*
«
>» c
^
0
0 03 ^
.2 5
•o
D
M
.±s *•* ~_ a; Q.
<0 ^ V) f
. (— T
•»
^
C
• •V
m
£
3 (0 Q SO •= 2 ^-3
cr c t/j •«
3 - e «
0 »4—
*- o MJ « 2 « .2.
S s « S S i i 8
» 1 ~ <
2 ? 2 If
£ 2 "S fc S > 55
i ! i 1 ! I i «
«*•
> "
» n
r
; t
1 v« ^
' «A ••
•* h
»
C
i 1 I M t 1 1
« S S -2
1 « « ? S?
h 2 ® •-
** _e e
: '
•j- M c .52 > a 'M 02
» J= 3 5
: « g S
« 5 "c
1 O
tS « « > c a
J 1 S | 5 «
i *^
! a
™ CA
1 CD fc-
i ° 5
S *
1 4 § .i § 8 *
§
- "O
1
(Q
« re c 4)
w u w -e c **
the scientific/technical staff?
MISSION FOCUS - Does the candidate's
(J
CUSTOMER SATISFACTION - Does the ,
*
o
MULTI-MEDIA APPROACHES - Does the
PRIORITIES - Will the candidate ensure t!
LU Lll
support needs?
FUNCTION ALIGNMENT - Does the alian
d
FUTURE INVESTMENT - Will the Candida
facilities and equipment?
X
09
O
'5.
(0
§
•r
.5
a
M
£
so
a
M
UJ
09
5
"5
i
so
i
o
**
S
(0
(0
in
CN
I
LL
Cfl
U
O
-------
3. Analysis Summary
The results of the Pro/Con analysis of advocate candidates for the ESDs has been
summarized in Table 1. Criteria utilized by the Cross-Agency Subcommittee during
their evaluation corresponds to the criteria development and utilized by Mitre
Corporation. Appendix A represents the detailed Pro/Con analysis conducted by
the Cross-Agency Subcommittee.
Based on the evaluation criteria, the following four candidates were identified as
potential candidates for further consideration by the Cross-Agency Subcommittee.
• AA, OROS/LR/Advisory Panels or SPC with Management
Improvements
• AA, OARM/Advisory Panels or SPC
• AA, OECA/Advisory Panels or SPC
• AA, ORD/Advisory Panels or SPC
26
-------
IL Evaluation Dedicated Resources (FTE/Dflllar) for Base
1. Overview
ESD resources, both Full-Time Equivalents (FTE) and support dollars, are provided
from various media-programs which use the ESDs' technical expertise to support
compliance, enforcement, monitoring and overall implementation of their programs.
ESO resources are provided through internal negotiations on a Region by Region
basis which has been identified as both an organizational strength and weakness.
Resource flexibility is a valuable asset in ensuring customer alignment and fulfilling
program requirements. Resource stability fosters national cohesion and .ensures
the availability of essential scientific and technical support services.
No national program element (PEJ exists which solely provides for ESD FTEs. Of
the estimated 110 PEs currently established, only two specifically identify ESD
functions (Watershed Management and Superfund). Seven others include line
items outlining program objectives which require ESD services. Line item refers to
support documentation, typically work load models, which provides the detailed
description of activities and cost estimates included within a national program
element. Office of Water's program element for watershed management-PE
includes 2.8 FTE per Region for the ESD Division Director and their immediate
office positions.
in 1993, two new PEs, one for the programmatic account and one for the
Superfund account, were establish which provide for ESD equipment purchases.
Prior to 1993, the ESD equipment fund was provided through contributions from
the national program offices; Supplemental resources were provided by regional
management. Over the past several years, the ESD equipment fund has averaged
approximately $3.8 million.
Other operating resources including B&F, and R&l, leases, utilities, supplies et,
cetera are funded with resources managed by OARM and their regional
counterparts.
27
-------
2. Objective
• To define a dedicated, stable pool of resources needed to ensure that the
ESDs have the resident expertise and capability to respond to the
Agency/Program Office requests for scientific/technical support services.
* To maintain Tesponsiveness to emergencies, and evolving Agency program
requirements for scientific/technical support services.
• To develop a system which facilitates a continual balance between the
dedicated ESD resources and Agency/Program Office requirements for
scientific/technical support services.
3. Considerations
Resources
A review of Agency's historical accounting information shows that a base for ESDs
has been informally established by the Agency's decision-makers. An analysis of
the results of regional negotiations for Full-Time Equivalents (FTEsS used to staff
the ESDs and support the Agency and program office functions was conducted by
the Subcommittee for fiscal years 1991, 1992 and 1993. More current resource
data was not available within the analysis timeframe. The analysis showed
marginal ESD resource shifts, less than 5%, from FY 1991 to FY 1993.
A preliminary review of a representative sample for FY 1994 resources continues
to support this analysis. Approximately 600 FTEs have historically been provided
in staffing the regional ESDs and meet the Agency's bjasjc scientific and technical
support services needs. This resource funding level represents the base resource
requirements necessary to assure that ESD scientific/technical support services can
be provided in support of the regional programs. These resources would need to
be augmented based on specific volume and types of services required by regional
programs.
[Note: Accuracy of Full-Time Equivalent (FTE) counts used in this analysis could
not be determined during the timeframe provided to the Subcommittee. FTE
counts presented in this review represent an average of 1991, 1992, 1993
estimates.)
28
-------
Scientific/Technical Support Services
An analysis of the results of regional negotiations for E5D scientific/technical
support service types and volumes varied from Region to Region. Highlighted
during the analysis was that flexibility and responsiveness are essential in
facilitating the programs to successfully meet a wide range of statutory
requirements and program commitments. Responsiveness and flexibility were
identified by Mitre to be essential elements for increased customer satisfaction.
Some basic scientific and technical services provided by ESD require development
expertise and special administrative considerations. Development of expertise is
accomplished both through the training of resident staff, appropriate skill mix and
external hiring. Special administrative considerations includes medical monitoring
program participation, credentials maintenance, supplies and scientific
instrumentation. These ESD scientific/technical services have fixed requirements,
below which they cannot continue to be offered to the programs.
Balance
By making available ESD scientific/technical services to competitive or negotiable
process, the Agency ensures that its science mission is adequately supported by
the ESDs. Competition ensures continued customer alignment by maintaining
responsiveness and system flexibility: Understanding and/or defining fixed
requirements (costs) ensures basic scientific/technical services can continue to be
provided to the Agency system as a whole.
Throughout the analysis, the need for complete flexibility by any individual
programs was weighed against ensuring the availability of basic scientific/technical
services.
29
-------
4. Budget Proposals1
Proposal 1
Proposal 1
ESD Base Budget
Programs
Additional
Capacity
Negotiated Services and Resources
ESD Base
(600 FTE)
Capacity
Capability
Overhead
Negotiated
Services
(66%)
Fixed Services
(33%)
Resources:
• Defines base as 100% of current ESD resources
• Establishes ESD budget using base resources (600 FTE)
• Maintains current distribution of resources
• Base and core are synonymous •
Scientific/Technical Services;
• Defines one-third of ESD services as fixed
• Allow two-thirds of ESD services to be negotiated
• Establishes ESD service "menus" for negotiated and fixed services.
» Establishes program "budgets" and "checking accounts" by which
negotiated services are provided and tracked.
• Establishes process to conduct program "needs" survey to ensure
ESD/program alignment, and aid in forecasting major resource shifts and
future budget requests.
Based on a preliminary evaluation, it was determined that approximately one
third of the ESD scientific/technical services should remain fixed to ensure
their availability to the programs. The remaining two thirds of ESD
scientific/technical services could utilize competitive or negotiable
mechanism based on specific program needs.
It should be expressly stated that the budget proposals presented do not
propose or endorse any redistribution of regional resources across the
Agency. Cost estimates do not include facility and fiscal management.
30
-------
Proposal 2
Proposai 2
Programs
ESD Base
(600 FTE)
Additional
Capacity
Capacity
Capability
Overhead
ESD Base Budget
Negotiated Services and Resources
Negotiated Services
Resources:
• Defines base as 100% of current ESD resources
• Establishes budget using ESD base resources (600 FIE)
• Maintains current distribution of resources
• Base and Core are synonymous
Scientific/Technical Services;
• Does not determine specific percentages of fixed/negotiated services noting
that each Region will have critical mass requirements
• Establishes ESD service "menus" for negotiated and fixed services.
• Establishes program "budgets" and "checking accounts" by which
negotiated services are provided and tracked
• Establishes process to conduct program "needs" survey to ensure
ESD/program atignment, and aid in forecasting major resource shifts and
future budget requests
31
-------
Proposal 3
Proposal 3
Capacity
Overhead and
Capability
Core Total
ESD Core Requirements
Adm.
QA
LAB
FIELD
Negotiated Services and Resources
4
4
8-9
8-9
20 - 21
20-21
16- 18
16- 18
Resources;
• Does not define base
• Core includes overhead and capability to perform services
• Defines core resources needed to provide for ESD functions: Administrative,
Laboratory, Reid and Quality Assurance
• Core is defined as 480 - 520 FTE nationwide; individual core requirements
will be identified for each Regioa
Scientific/Technical Services;
* Core reflects basic capability and overhead
• Variable cost reflecting capacity (volume or types of service) to support to
programs will be negotiated
32
-------
Proposal 4
Proposal 4
Programs
ESD Base
(600 FTE)
ESD Core
(480 - 520
FTE)
Additional
Capacity
Capacity
Capability
Overhead
ESD Budget
Negotiated Services and
Resources
Negotiated Services
Fixed Services
Resources;
Defines base as 100% of current ESD resources
Establishes program office targets using base resources (600 FTE)
Targets defined as resource levels needed to provide a volume of service
(capacity) in support of the program office
Core includes overhead and capability to perform services
Defines core resources needed to provide for- ESD functions: Administrative,
Laboratory, Field and Quality Assurance
• Establishes ESD budget using core resources (480 • 520) FTE; individual
core requirements will be identified for each Region
Scientific/Technical Services:
• Core reflects basic capability and overhead
• Variable cost reflecting capacity (volume or types of service) to support
program offices will be negotiated
• Establishes program "target" of the current base level (600 FTE) as a means
to establish for both the provider and user historical resource levels and
prevent major resource shifts
• Additional capacity for services can be negotiated on a case by case basis
33
-------
5. Summary
A common issue identified by the Cross-Agency Subcommittee during their
analysis of the options, was the impact of the option on the ability for ESD to
successfully negotiate with the program offices in the future.
By only establishing a core for the ESDs, a strongly negative effect on ESD's
capability to negotiate with the programs for resources would occur. A clear,
uniform definition would have to be transmitted by the Agency's senior
management. A difficult cultural change would be required to ensure that Agency-
wide personnel possessed a clear understanding of services included in core.
Historically, the definition of "core" is eventually replaced with the definition of
"base". Should this occur, the ESD would lose program resource support needed
to support and fund essential capacity.
Establishing a base for the ESDs would formalize the resource requirements for ,
providing scientific/technical support to the program offices. Determination of an
ESD base would enhance its ability in negotiations with the program offices for
resources. Again, a clear, uniform definition of base and the services provided
within its parameters would be essential. The identified base for ESD should be
institutionalized into the Agency's budget process.
34
-------
JIL Evaluation of Budget Mechgni^m and Lotion
Many issues involving the budget mechanism and location will be resolved by the
selection of the ESD advocate. Analysis of specific budget mechanisms location
cannot not be finalized the determination of the ESD advocate. The Cross-Agency
Subcommittee noted that the use of the selection of a budget mechanism and the
budget location should not be to ensure customer alignment; this should be
accomplished through improved management and coordination across the Agency.
To enhance and improve the Agency's Science and Technology program, it will be
necessary to encourage cultural changes involving resources. The following
provides discussion on various budget mechanism and location options, -
highlighting general advantages and disadvantages provided by the Cross-Agency
Subcommittee.
A. Mechanism
The Cross-Agency Subcommittee did not recommend a proposal for the Agency
petitioning Congress to develop a separate appropriation to provide for its internal
science and technical support services. Appropriations are readily targeted by
Congressional and special interest groups, resulting in the potential of significant
impacts on the programs they are meant to support. The Agency's Research and
Development appropriation has been negatively impacted based on the influence of
external parties.
A Program Element (PE) was identified as a viable fcudget mechanism. A PE
encourages resource stability within EPA by providing a readily identifiable account
for scientific and technical services. The present ESD capital equipment PE has
stabilized resources available for purchasing scientific equipment for the ESDs.
These funds were originally provided by each media office and aggregated by
OARM's Budget Division for distribution based on an agreed-upon methodology, it
should be noted, however, that because of its visibility of a PE in the external
budget process, it can be targeted for specific reductions rather than simply being
affected by global Agency-wide cuts. This would seriously impact the Agency*s
ability to provide the support services conducted by the ESDs for the program
offices.
The Cross-Agency Subcommittee identified line item as a viable budget
mechanism. Line items are sub-elements of larger PEs. This results in less
visibility and increased flexibility. However, historically line items have been
subjected to reductions by unilateral decisions.
Both mechanisms provide a means for establishing an Agency-wide definable
budget for the ESDs. As noted during the EPA Laboratory Study, the ESD
scientific and technical services-were not widely known and understood within the
35
-------
Agency. Their lack of involvement in the Agency's budget process has contributed
to this problem. Establishment of a PE or line item within existing budget or a new
budget specific for the E50 services ensures their participation in future budget
planning. This would facilitate the resolution of other management problems
identified by the Steering Committee concerning coordination and alignment of the
ESDs with ORD and program offices during the Agency's Strategic Planning
process.
B. Location
The Cross-Agency Subcommittee identified and evaluated three options for the
location of ESD NPM within the Agency's organizational structure. These are: 1)
a single NPM within the Agency solely responsible for the ESO budget, 2) a Mixed
NPM, that includes the National Advocate and one'or more NPMs in the Agency,
each having oars of the ESD budget process; and 3) Multi-program NPMs where ,
the ESD budget is managed outside the National Advocate office by one or more
NPMs :n the Agency.
The single NPM option would provide a centralized planning and budget process.
This is a streamlined, more efficient approach. A mixed NPM provides for stability
and flexibility by having some portion of the budget managed by a single NPM (the
advocate), and the remainder managed by one or more NPMs that are ESD
customers. Multi NPMs would completely distribute the budget outside of the ESD
advocate, allowing the customers to have full control. This is less efficient, and
allows for unilateral decisions that can affect the whole resulting in resource shifts.
it would require extensive coordination by all the NPMs.
36
-------
Dj. Evaluation of Alignment gnd Coordination Qotioris between ESP. Program
Offices and ORD Activities, and Exploration of Coordination Potions to the
Aaencv Budget and Strategic Planning Processes
During the Cross-Agency Subcommittee's analysis, the inter-relationship of
strategic planning, budget planning and program alignment and coordination was
determined to be essential in the success of any organization. Strategic planning
represents the driving force behind budget planning. Budget planning represents
the driving force behind program alignment and coordination. Originally, the Cross-
Agency Subcommittee was charged to address alignment/coordination issues
separately from budget/strategic planning issues. After careful consideration, the
Cross-Agency Subcommittee determined that the inter-relationship of these
activities was best emphasized when combined.
During the past year, the Agency has made great strides first by developing an
Agency-wide Strategic Plan, and secondly, by institutionalizing the Strategic Plan
into the Agency's budget process. The Subcommittee acknowledged these efforts
as instrumental in improving the coordination Agency-wide in the budget and
strategic planning processes. The Cross-Agency Subcommittee recognized the
often understated value of inreach and .outreach activities. The EPA Laboratory
Study itself has greatly accentuated cross program understanding which will lead
to enhanced alignment and coordination within the Agency. This awareness
across the Agency's national and regional programs is essential, and should
represent the cornerstone for building an effective outreach program for the
Agency's scientific and technical community and its customers. These combined
efforts provide the foundation upon which to build a more integrated planning
process and improved science and technology in the Agency.
The Steering Committee recommended that the Administrator designate a senior
policy official to serve as the focal point for the strategic planning and
implementation of the Agency'^ research, development and technical services as
an integral part of the Agency's Strategic Plan. A new Agency-wide planning
process for research, development and technical services will be developed. The
ESD Central Advocate, in coordination with the Regional Administrators, wiil have
primary responsibility for ensuring that ESD scientific and technical services are
integrated into the Agency's Strategic Plan.
The Agency-wide recognition and endorsement of a national advocate for the ESDs
will serve as a catalyst for improving alignment between the ESDs, the program
offices and ORD in the strategic and budget planning processes. The advocate
provides a focal point for the ESDs at the EPA Headquarters office providing easy
access to the national program offices and ORD. Options identified in Sections
VLB. and VI.C. of this evaluation that address a dedicated ESD budget and
37
-------
mechanism, would enhance ESDs' role in the budget and strategic planning
processes by making ESD a stakeholder.
A team or advisory panel would provide supplemental advice and guidance to the
national advocate on cross-Agency issues relating both to strategic planning and
budget. This creates a dual system that provides for two paths to better ensure
communication, alignment and coordination within the Agency.
In addition to having a national advocate, the establishment of liaisons between
the ESOs and the program offices and ORO would greatly increase communication
which is critical to alignment, strategic planning and budgeting issues. Direct lines
of communication should be established. Development of Memorandum of
Understanding with the ESDs could be used as a tool to formalize
this process.
Figure 1 depicts a flow chart that outlines this integrated process that
demonstrates these various coordination relationships for the alignment, budget
and strategic planning processes. It demonstrates the dual system which should
encourage consensus building instead of unilateral decision making.
Rgure 1: Integrated Process for Alignment, Budget and Strategic Planning
Science Policy
Council
*1
(Research, Development
and Technical Services L t
|^ Designee J
x— •
(lea
j j. \
\ OAR IIOARMI
•
\
m)« » ESD
/ Advocati
•^'x ^
\ y
. /
* \ ^ I
OECAI IOPPTSI
Administrator
Dep
Admir
9 *
1
*
Regi
Adwii
I
tllTf — — — ^— .
1**J OPOP/T T?|
istrator Ui*y,9:.V#'
/
/
/
/
/
/
/
* i .ci 4 : i ^ i
onal | OPPE II ORD lOSWERl OW
iistzator
ESDJ
38
-------
Ej. Exploration of Processes to Ensure that Fu^re Planning includes Review of
Organizational Alignment pf ESDS with Aoencv's Scientific/Technical
Mission
While attempting to meet its charge for this evaluation, the Cross-Agency
Subcommittee noted the difficulty and general lack of readily available information
relating to the ESDs. This was particularity true in the area of resource
management and future program needs. Review of resource management and
capacity requirements are essential elements in preparing for the future. An
accurate understanding of customer needs, both immediate and long-term, is
critical in future planning.
The following are a list of proposed activities to assist in gathering of information
for future planning purposes.
• Conduct a customer "needs" survey;
• Establish a forecasting system for short- and long-term program
requirements;
• Develop a national tracking system to determine progress and efficiency;
• Develop a national ESD database;
• Develop an inreach and outreach program to enhance communication and
coordination;
• Establish a customer satisfaction survey to evaluate performance;
• Develop a standardized process to be used Agency-wide providing
consistency;
• Conduct internal evaluations of the ESD organization on an annual basis;
• Conduct external evaluations every 5 years; and
• Develop national goals.
These elements can be implemented individually or formalized in an integrated
process. Roles and responsibilities for these activities will be established and
formalized in an integrated workplan.
39.
-------
Vii. RECOMMENDATIONS
Administrator!
• Research, Development.)
. and Technical Services I,
{ Designee J
\
Deputy
Administrator
Science Policy
Council
OROS/LR|<
N X
S X
OAR ilOARMI IOECA I lOPPTSi
Regional
Administrator
QPPE ii QRD~|[QSWER| I ow
The Cross-Agency Subcommittee proposes the following recommendations to the
EPA Laboratory Study Steering Committee for inclusion in their report to the
Administrator.
of ^ Qft"*ral Advocate
The ESD Central Advocate should charged with the primary responsibility of
the assurance and maintenance of customer alignment between scientific
and technical services of the ESDs and their customers. OROS/uR provides
the essential neutrality required in establishing and maintaining this customer
alignment across the Agency.
Modifications to enhance OROS/LR management and budget systems will be
necessary. These changes implemented, along with management
improvements already adopted by the Steering Committee, will greatly .
enhance the current organization.
OROS/LR should continue in Its national advocacy role for the ESDs. , If the
enhancements outlined by the Cross-Agency Subcommittee m the Danced
OROS/LR/Team Option cannot be achieved, supplemental analysis wouw
need to be conducted to determine an alternative advocate.
40
-------
Evaluation of Dedicated Resource for Base and Evaluation of Budget Mechanism
and Location
• By establishing a balanced ESD budget, EPA provides for the essential
organization stability and maintains flexibility to fulfill program requirements.
The balanced ESD budget fosters customer alignment.
• The Subcommittee does not propose any redistribution of the ESD scientific
and technical resources across the Agency. The Subcommittee proposes
that a national budget for the ESDs should be established in a single program
element placed within the central advocate's budget responsibilities
(Proposal 4). The national budget will be the sum of individual ^ore
requirements identified for each Region. The remaining targeted ESD base
should be established as line items with the respective program office
budget responsibilities. Additional negotiations for increased capability and
capacity would continue to be conducted through the existing negotiation
process.
Evaluation of Alignment and Coordination Potions between ESD. Program Offices
and ORD Activities and Exploration of Coordination Potion to the Agency Budget
and Strategic Planning Processes
• The Steering Committee has recommended that the Administrator designate
a senior policy official to serve as the focal point for the strategic planning
and implementation of the Agency's research, development and technical
services as an integral part of the Agency's Strategic Plan.
• A new Agency-wide planning process for research, development and
technical services should be developed. The ESD Central Advocate, in
coordination with the Regional Administrators, is charged with the primary
responsibility for ensuring that ESD scientific and technical services are
integrated into the Agency's Strategic Plan.
Exploration of Processes to ensure that Future Planning includes Review of
Organizational Alignment of ESDs with Agency's Scientific/Technical Mission
• To effectively plan for the future, accurate and readily available information
concerning the ESD's scientific and technical services must be available.
EPA should develop an integrated process to evaluate its current, and
forecast its future, science and technical service requirements.
41
-------
ESD EVALUATION
CROSS-AGENCY SUBCOMMITTEE MEMBERS
Co-Chair, Joe O. Winkle, Deputy Regional Administrator, Region 6
Co-Chair, Jeanne Fox, Regional Administrator, Region 2
Co-Chair, Shelley Metzenbaum, Associate Administrator for Regional Operations
and State/Local Relations ;
Frank M. Covington, Director, National Enforcement Investigative Centers
Tudor T. Davies, Acting Deputy Assistant Administrator, Office of Water
Gerald A. Emison, Deputy Regional Administrator, Region 10
Ann Goode, Acting Deputy Assistant Administrator, Office of ASr and Radiation
Dennis Grams, Regional Administrator, Region 7
John Hankinson, Regional Administrator, Region 4
Henry L. Longest II, Director, Office of Emergency and Remedial Response, Office
of Solid Waste and Emergency Response
42
-------
-------
1
I
1?
a
K
*•'
f
•§
|
I
M»
j
Pt
Ul
5
s
Q
Ul
^L
*
§
;.>|
"T
- •. .''
;•-•
•: v
1
i
•
jC
1
5
CO
&
s
£1
<
1
I
i
£
o
i
S.
1
en
i
1
i
•o
§
u
o
•
n
|r
0
c
1
,f
in
to
«9
o
0
^
CO
U9
•1
S
.i
i
M
Pro-Committee structure fostei
Con-Lacks focal point -
•
s.
'§
•o
__
re
a
»
s .
.s
u
1/9
"o
s-
1
£
n
a
i
re
u
1
T9
a
«1
D
M
w
i
'a.
a.
J2
S
>
0
V
3
u
^rf
Pro-Cross-cutting missions tha
peer review)
^
«
;countabili
a
u
i
8
1 Con-Have no specific mission;
o
CA
|
§
.52
U
,0
re
represent
1 Pro-Consensus process; equal
«
.£
v>
§
|?
s
re
^f
|
(O
s
1
s
en
0)
.c
^
01
E
fi.
o
a
"3
're
i
1 Con-Variable influence by pers
focus point
o
j
o
re
re
(A
^
U5
O
•g
§
1
i
a
Pro-Cross representation promi
"3
j
M
|
t
|
e
1
o
(0
1
i
Q.
<
JS
TS
0
••
2
Ul
|
Pro-Provides equal input for all
§
a
il
0
I
Pro-Potential for coordinated bi
^
i
^M
w
,5
T5
w
r
&
^L
g
i
i
e
a
a
M
0)
••
S-
.s
1
§
§
re
.H
"5
Con-Ad Hoc group; lack of spe
day implementation
0
^
i
•* ^T
tA
1
49
3
3
Z
(A
0
\
Ti
|
^
.£
0
u
0
£>
i
'Ci
n mission
«
e
i
Pro-ESO mission currently inclu
e
".
m
o
re
•o
S
e
^
M
^
I
S
i
s
o
M
Con-Team mission is broad - El
o
0. '
J
'o
(A
1
^
CM
<
-------
I
$
o
0
s
|
*
M
m
ut
I
5
m
5
o
i
•-,':1:-:
V::'v
1
••'^-
1
S
.;•§•
M
;' :.*'
s
fc
s
e
£
a
1
"5
1
ra
Iministrative opei
09
.e
•o
«
"o
»
Con-More in
?
1
>
1 •
O
09
i
U
< •
g
(0
^s
ion-maker; |
09
•o
„ e
1
V)
i
a
1
S
^
CO
"o
ature/Credibili
55
i
a
o
1
1
a
uj
1
1
'•S
I
S
e
'5
in
1
1
ss
"5
*
1 Con-Their ur
0
1
o
M
2
U
JS
£2
£
§
SS
0)
s
g
irganization sharing many
lervices/support <
w
S
I
M
Pro-Provides
• <•
09
'g
S
"S
IB
1
o
V)
Ul
•5
?
1
to
0
i
to
u
i
M
J Con-Low GU
_§
u
(O
ustomer Satis
u
o
i
nuiti-media approaches
c
"o
1
1
I
1
1
3
o
I
£
1
1
.2
1
i
Ul
w
1
a
Ul
irocess and Administrator';
a
I
A
r»
between AI
|
i
_
>
<£
1
0
tfl
u
1
«
M
O
W
1
I
M
3
S
£
S
.2
?
a
f
o
1
1
£
•^
ra
a
on; management
*<5
1 Pro-Neutral 1
10
i
i
i
f
s
ut
o
1 Con-Potentia
i
1
o>
5
_g
5
s
U
09
«
>•
M
;e
^
(B
V)
09
i
(0
1
s
• *
e
1
S
1
1
1
Q.
OJ u7
O dl
Pro-Knowled
concerns (Bl
integration and needs
of ESD mission, 1
lerstanding i
1
| Con-Lack of
•f
€
V
i ^
-------
—
3
£
5
o
1
S
i
Con-Historical internal and external perception
*
i
=5
09
i
!K
3
S)
03
^»
Jb»
O
1
n>
To
|
a
o
09
1.
a.
e
M
n
Pro-Mission relates 'to day-to-day implementation
u>
i
u
a
Ul
o
**
"•5
0
I
09
|
E
S
a
o
a.
a>
t
Con-Organizational mission is too focused on a si
program mission to meet specific program needs
•
U)
1
1
"35
CA
s
u
\
1
1 Con-Too focused on a single program
•
e
o
1
«•*
Si
o
M
3
U
0
1
n
«
E
1 Con-Majority of candidates would not foster mull
1
1
•fc
u
-------
-------
1
i
«o
V)
1
1
1
•1$
I"
in
1
.1
^1
.£.§
= S-
| I
11
« -s;
U
ii
a 2.
2 g
a o
2 =
c
-------
r
S
|
1
I
S
I
§5
*itft«ams Hybrid (AA. OROS/LR Only/Advisory Panel
a.
• *
in
5
1
IU
S
5
§
-
'
1
1
:':•>••
^
fc
1 re £
0 .£ c
S^l
ill
JM
(ft • * i££
|| a
fvs £
.. _ o
.2 « o
sl~
1 2£
£*|
c \ *3 «
Pro-Defined roles and responsibilities linked to Agent
tied to the Agency's strategic planning process; pro
coordinating and consensus-building role; direct acct
0
•9
£
_C
I
'£
S
o
8
re
re
o
1
§
**u
§
Con-Lack of direct control (more fundamental coordi
specific regulations
o
X
5
1
o
u
1
O
V)
<
0
(A
^
(0
>.
a
T3
i
a
O.
1
re
E
c
_o
"55
'o
09
•e
.S
S
WJ
«?
Pro-Proximity to the Administrator; political appointe
panel; defined SAT responsibilities and accountability
-
Con-Historical internal and external perception
*
>.
'S
1
y
8?
S
2
CD
V
2
|
a.
» *
1
2
1
^t
c «-
« c
i E
f -
re a
E &
•9 E
i S
w
W 3
e u
Pro-Enhancement due to the addition of advisory pai
national consistency; state/local relations enhances i
J
*
M
U
O
U.
c
p
»
2
"
fo
|i
™
||
o «
S'g
5 S
?5
»c
•• U
RI £
§ s
Pro-Centrafized focus and representation for the nati
and strategic planning processes; limited impact to <
services
-
*
.2
1
re
M
S
&
1
U
fi
re
I
3
hi*
I
To
|
£
i/t
"|
a.
Pro-Enhances organization's multi-media capabilities;
nationally
*
«A
U
i
I
.5
1
S
"i
^
tu
•o
w
I
§s
«« .£
if
re J
u ~
13 S
5 «
a ^
.il
"1
?I
&
s •£
Pro-Direct link to the Agency's priority decision maki
communication; Memorandums of Understanding wi
1
I
k.
i
I
u
*
.£
O
if
u.
VI
t>
re
£
S
^
S
5
• *
?•
i
Pro-Knowledge and experience in current ESD atignn
customer alignment.
J
*
0>
f
1
1
Uk.
0
o
5
re
•2
process ar
E
j
j
~ e
U
~ 1
c '5
j< £
Pro-Currently responsible for equipment PE for ESDs
work within it; advisory group fosters nationally and
"5
•55
u
1
1
(O
w
•js
1
1
o
>>
Con-Limitations of the Executive Office (OA); adviso
participation
*
S
OJ
01
5
<2
X
.f
a
'I
a
"re
u
.0
'S
E
^.
y
a
a
5
**
•£
Pro-Mult! media, multi-program approach is in line w
management improvements define accountability
1
,
II
11
I
O
u
-
"o
5
o
-------
2
s
1
1
o
"o
1
V)
I
**
(O
UI
g
a
I
u
5
VI
>
3
I
1
f
§
•
^
^3
K
«
>.
1
—
1
•e
e
1
i
n
"5
1
o
£
|
CO
8
X)
U)
"e
01
1
CO
"o
1
e
.2
i
•V
re
a
§
S
0
-s
ta
1
u
S
T3
§
U
+
sg
|
•^
§
0
l>
£
,B
w
<
^
£
o
"3
T3
IS
_O
.»
^
A
TJ
«
in
1
1
1
•a
I
63
(O
r
0
CO
Con-Conflict resolution may be difficult due to lack of
*
>.
1
u
, £
•*
(A
0
,
^
1
to
a.
o
'S
CO
2
8
"o
c
.2
i
J
Pro-Slightly enhancement of current situation due to t
ship promotes national consistency
0
'
u>
Q
J
«
2
'•S
^
1
'1
Con-Lack of S/T understanding; their current mission \
+
1
u.
e
W
S
U
I
1
co O
U V)
0 £.
i1
II
il
3 >.
« c
5 S
i ?
iJ
Pro-Provides a focal point and representation; limited i
disruption of services; services/support organization si
t
4-
j
1
«s
C/9
u
|
M
3
U
Q
*•'
Pro-Cross representation affords enhancement
•
•*•
in
1
I
1 »
I
3
T
Pro-Central focal point; parity
J
*
]5
o
U
"3
3
u
5
-
-------
§
o
scientifically
o
^
S
la
O
0
&
1
o
a
w
y
I
nt of current situation due
consistency
_g
u>
2
n
I
?
3
i
e
u
mited
ocal poin
rvices
s
of
i
s
<
V)
en
UJ
o
§
v>
I
I
1
o
o
u
i
|
Ii
Is
Ii
O)
<
i
• »
i
S
•5
-------
-------
1
OW/
!
0»
•5
a
§
1
»
•§
s
in
»
S
IB
J2
I
ds
M
01
rect
AA
sci
on
od
I
1
•>
2
•>
a
!
«>
in
2
w
hU
«
w
'I
1
ut
Ul
i
a
§
.s
u
y
I
2
CA
i
ingle
_Jg
CO
V)
d
5
1
0
i
in
in
v
I
€>
f
To
Pro-Have uate
of checks and bala
ade
J
v>
c .£
Con-Tncy to negatively impact resources not direc
advisory group effectiveness depends level of tial
«]
0
3
U
O
i
-------
O
S
^
}
Q
0
&
1
O
1
«
i
1
£
i
»•
0
*
Ul
i
s
z
o
Ul
~3
o
o
***
<
* •
I
1
§
o
•
: ^
nj
s
l§™
s
(A
ra
t)
E
1
o
15
o
.2
!
V
.a
.«
§
V
1
o
a
1
"5
to
CJ
O
I
(S
Ul
jt
6 _
£«
+•
i
4}
•e
i
t**
S
ta
i
e
S
IS
i
1
i.
™
1
>»
m
~S,
1
d
V
g
.S
O
CO
,
*
a
TS
"o
I
1
4)
"5
V9
i
.£
Pro-Senior decision makers; responsible and accountab
s
1
Con-Historical internal and external perception; turf iss
+ •
^
s
i
£J
0
5
re
V)
CO
^
re
^
2
current i
2:
e
!
s
s
10
1
W!
CO
•••
E
Con-ESDs have a different mission than ORD; OECA's
mission
o
(A
S
£
c
•5
5
i
U
Pro-Consensus process; equal representation
«)
o>
0
u>
S
"S
u
*~
a narrowei
«n
i
0
Con-ORD has different primary customers than ESDs;
potential to dilute the ESDs' current services
o
e
S
|
CO
E
o
s
0
1
0
Pro-Both are currently multi-media organizations
narrow
a
providing
O
M
1
"5
2
S
a
'I
e
f
•f
i
u
ID
2
a
n
J5
•s
3
s •
t
Ul
process
ta
3
I
*»
e
i
M
*U
•S
Pro-Provides a focal point; direct link to the Agency's
Con-Conflicting and competing priorities
o
w
£
•tv
.1
£
i
u.
e
i
a
1
ambient
o
,«
»
ID
I
O
•*
f*
Con-ORD and OECA are large organizations; some ESI
monitoring, special studies)
o
«.
c
o
1
,a
e I
o
5
tb
t
(9
£
V
«3
M
it process;
S
|
•e
5
f
u
ID
S
Pro-Have adequate support staff; senior decision-make
of checks and balances
M
>, m
i|
&
? O
•a t
I|
E "
II
5 e
ii
Con-Potential conflict with other programs; potential c
impact resources not directly in support of single progi
depends on level of participation
+
c
i
8
rl
|
3
•
X
Pro-Focal point; equal representation
.Con-lncomparability of some missions and functions
*
"s
O
U
"3
=
u
"•
CM
-------
•
Hybrid |AA
-------
CO
I
£.8*
I
«
jor
pla
S
U)
O
1
»
C
O
<£
U
0
t3
OJ
.a
I
|
n
2
I
5
=
u
to
i
(A
i
ORD; advi
ssi
have different
n is preserved
ESD mi
|
O
•5
in
*
U
to
(/)
»•
'01
o
1
s
m
=5
S
i
!
!
Con-Conflicting and
ec
ing
sory panel ha
Pro-
i
i
i
JD
s
o
s
ES
o
•s
i
.S *»
5 S
M *•
fl
i?
*S
• i
"?
i1
rt s
Pr
of
es
point;
Pro
E
o
M
u
o
------- |