\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON D.C. 20460
OFFICE OF THE ADMINISTRATOR
SCIENCE ADVISORY BOARD
March 30, 2006
EPA-SAB-ADV-06-003
The Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
Subject: Science and Research Budgets for the U.S. Environmental Protection Agency
for Fiscal Year 2007; An Advisory Report by the Science Advisory Board
Dear Administrator Johnson:
Over the past few years, the chartered Science Advisory Board (Board) has been working
with EPA to review the Agency's science and research programs and budget on a systematic and
ongoing basis. This year the Board met in Washington, DC on March 2-3, 2006 to review the
EPA science and research budget for FY 2007. The Board appreciates the opportunity to provide
you with advice on this important matter.
The Board is aware of the budget pressures that we face as a nation in these difficult
times. However, as in previous years, the Board is gravely concerned with the declining
resources available to EPA's Office of Research and Development (ORD). On March 16,1
provided testimony before the U.S. House of Representatives Committee on Science
Subcommittee on Environment, Technology and Standards on EPA's science research budget.
My testimony is attached to this report. Between 2004 and the current FY 2007 proposal, the
inflation adjusted budget for ORD has declined by as much as 16%. Yet, the environmental
problems faced by the Agency have grown and become increasingly complex, a trend that will
surely continue over the coming decades. The erosion of research and development remains a
serious impediment to the Agency's ability to meet its mission of protecting human health and
the environment through science-based initiatives. This fall-off in the development of scientific
knowledge will increasingly have international competitiveness dimensions as we lag our
competitors in developing new technologies using new approaches. It is the opinion of the Board
that EPA's research and development resources are grossly inadequate to address the scientific
complexities of the nation's environmental protection needs.
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Given the available limited resources, the Board understands that the Agency must make
hard choices to best accommodate EPA's five environmental goals areas, i.e., clean air, clean
water, land preservation and restoration, healthy communities and ecosystems, and compliance
and stewardship. However, there are several issues in the FY 2007 request that concern the
Board, some of which have persisted for several years.
• The proportion of EPA's research budget devoted to basic science or
"core" issues has markedly and rapidly been reduced from as much as
60% only a few years ago to about 30% in the FY 2007 budget. The level
of near term problem driven research has increased from about 40% to
nearly 70%;
• There appears to be a systematic bias against ecosystem research in the Agency -
this program has sustained a decrease of nearly 26 percent since 2004. The $79
million for ecological research in the proposed 2007 budget amounts to just 15%
of the overall ORD research budget. Over the past several years the Board has
called on both the Agency and the Congress to revitalize, raise the profile of, and
increase the funding for ecological research at EPA. We are distressed that
instead, work in this area continues to decline;
• The Board is concerned that EPA's Homeland Security Program appears to be
drawing resources away from other essential research programs. We are also
concerned that the work may be too focused on individual devices and sub-
systems, without first understanding broad level issues such as how effective
alternative approaches can hope to be in providing needed protection at an
affordable cost. The Board is also concerned that current programs are not
sufficiently informed by the behavioral and social sciences to effectively manage
and communicate the homeland security research and risk results to the general
public.
• The Board is troubled by the ongoing difficulty that EPA has had with the
application of the OMB Performance Assessment Rating Tool or "PART." EPA
should continue to work to improve its performance, outcomes, and accountability
systems to better communicate the benefits of research, including fundamental
research, for the protection of human health and the environment.
• EPA has mature scientific staff reaching retirement age, and the Agency will face
significant staffing challenges in environmental sciences, engineering, economics,
behavioral, and decision sciences in the next five to ten years. The proposed
reduction in the STAR Fellowship program will further exacerbate the workforce
planning for the coming years.
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The Board plans to have further discussions with ORD soon and we will provide
additional advice as the Agency plans for its budget request for FY 2008. We look forward to
receiving your response to this advisory report.
Sincerely,
/signed/
Dr. M. Granger Morgan, Chair
EPA Science Advisory Board
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NOTICE
This report has been written as part of the activities of the EPA Science Advisory Board
(SAB), a public advisory group providing extramural scientific information and advice to the
Administrator and other officials of the Environmental Protection Agency. The SAB is
structured to provide balanced, expert assessment of scientific matters related to problems facing
the Agency. This report has not been reviewed for approval by the Agency and, hence, the
contents of this report do not necessarily represent the views and policies of the Environmental
Protection Agency, nor of other agencies in the Executive Branch of the Federal government, nor
does mention of trade names of commercial products constitute a recommendation for use.
Reports of the SAB are posted on the EPA website at http://www.epa.gov/sab.
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U.S. Environmental Protection Agency
Science Advisory Board
2007 Budget Review Participants
March 2-3, 2006
CHAIR
Dr. M. Granger Morgan, Carnegie Mellon University, Pittsburgh, PA
MEMBERS
Dr. Gregory Biddinger, ExxonMobil Biomedical Sciences, Inc, Houston, TX
Dr. James Bus, The Dow Chemical Company, Mildland, MI
Dr. Trudy Ann Cameron, University of Oregon, Eugene, OR
Dr. Deborah Cory-Slechta, University of Medicine and Dentistry of New Jersey and Rutgers
State University, Piscataway, NJ
Dr. Kenneth Dickson, University of North Texas, Denton, TX
Dr. Baruch Fischhoff, Carnegie Mellon University, Pittsburgh, PA
Dr. A. Myrick Freeman, Bowdoin College, Brunswick, ME
Dr. James Galloway, University of Virginia, Charlottesville, VA
Dr. Rogene Henderson, Lovelace Respiratory Research Institute, Albuquerque, NM
Dr. Steven Heeringa, Chair, FIFRA SAP and Liaison to the SAB, University of Michigan, Ann
Arbor, MI
Dr. Philip Hopke, Clarkson University, Potsdam, NY
Dr. James H. Johnson, Howard University, Washington, DC
Dr. George Lambert, UMDNJ-Robert Wood Johnson Medical School/ University of Medicine
and Dentistry of New Jersey, New Brunswick, NJ
Dr. Jill Lipoti, New Jersey Department of Environmental Protection, Trenton, NJ
Dr. Genevieve Matanoski, Johns Hopkins University, Baltimore, MD
Dr. Michael J. McFarland, Utah State University, Logan, UT
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Dr. Jana Milford, University of Colorado, Boulder, CO
Dr. Rebecca Parkin, The George Washington University, Washington, DC
Mr. David Rejeski, Woodrow Wilson International Center for Scholars, Washington, DC
Dr. Joan B. Rose, Michigan State University, E. Lansing, MI
Dr. Kathleen Segerson, University of Connecticut, Storrs, CT
Dr. Kristin Shrader-Frechette, University of Notre Dame, Notre Dame, IN
Dr. Deborah Swackhamer, University of Minnesota, Minneapolis, MN
Dr. Thomas L. Theis, University of Illinois at Chicago, Chicago, IL
Dr. Valerie Thomas, Georgia Institute of Technology, Atlanta, GA
Dr. Robert Twiss, University of California-Berkeley, Ross, CA
Dr. Lauren Zeise, California Environmental Protection Agency, Oakland, CA
SCIENCE ADVISORY BOARD STAFF
Mr. Thomas Miller, Designated Federal Officer, U.S. Environmental Protection Agency,
Washington, DC
in
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TABLE OF CONTENTS
1. INTRODUCTION 1
2. AIR RESEARCH PROGRAMS 2
2.1. CRITERIA POLLUTANTS AND MULTI-POLLUTANT ANALYSES 2
2.2. EPA's GLOBAL CHANGE PROGRAM 5
2.3. MERCURY RESEARCH PROGRAM 5
2.4. RESEARCH PROGRAM EVALUATIONS 6
3. WATER RESEARCH PROGRAMS 8
3.1. DRINKING WATER PROGRAM BUDGET COMMENTS 8
3.2. WATER QUALITY 9
4. ECOLOGICAL RESEARCH 11
5. HUMAN HEALTH RESEARCH 14
5.1. HUMAN HEALTH RESEARCH 14
5.2. COMPUTATIONAL TOXICOLOGY 15
5.3. HUMAN HEALTH RISK ASSESSMENT 15
5.4. SAFE PESTICIDES AND SAFE PRODUCTS RESEARCH 16
5.5. ENDOCRINE DISRUPTORS 17
6. TECHNOLOGY 18
6.1. LAND RESTORATION AND PRESERVATION RESEARCH 18
6.2. NANOTECHNOLOGY 20
6.3. ADVANCED MONITORING INITIATIVE (AMI)/GEOSS 21
7. HOMELAND SECURITY RESEARCH 23
7.1. BACKGROUND INFORMATION ON THE PROGRAM 23
7.2. THE CRITICAL INFRASTRUCTURE PROTECTION PROGRAM 23
7.3. PREPAREDNESS, RESPONSE, AND RECOVERY 24
7.4. SAB COMMENTS 26
8. ECONOMICS, DECISION SCIENCES, AND SUSTAINABILITY 31
8.1. ECONOMICS AND DECISION SCIENCES 31
8.2. SUSTAINABILITY RESEARCH 35
9. STAR FELLOWSHIPS 37
ATTACHMENT A: STATEMENT OF DR. M. GRANGER MORGAN, CHAIR U.S. ENVIRONMENTAL
PROTECTION AGENCY SCIENCE ADVISORY BOARD BEFORE THE SUBCOMMITTEE ON
ENVIRONMENT, TECHNOLOGY AND STANDARDS COMMITTEE ON SCIENCE, U.S. HOUSE
OF REPRESENTATIVES MARCH 16, 2006 A-l
IV
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1. INTRODUCTION
Over the past few years, the chartered Science Advisory Board (Board) has been working
with EPA to review the Agency's science and research programs and budget on a systematic and
ongoing basis. This year the Board met in Washington, DC on March 2-3, 2006 to review the
FY 2007 EPA research budget.
The Board is traditionally guided in its consideration of EPA's research budget by a
charge that asks if EPA's science programs align with the strategic priorities that have been
articulated to guide the EPA mission; whether the programs reflect coordination and cooperation
both inside and outside of EPA; and whether EPA's science programs are positioned to address
the nation's emerging environmental issues. For the FY 2007 research advisory, the SAB also
considered the program from the strategic perspective of whether significant research was
missing and also the changing trends in EPA's overall research program. This year, the SAB
also expaneded its consideration of Regional Office science issues as a result of several events
that occurred during 2005 that highlighted the need for science research and technical support to
the EPA Regional Offices.
The Agency provided several types of background information to the SAB, ranging from
budget documents to research program descriptions. Included were: a) EPA's FY 2007 Budget
Summary (www.epa.gov/ocfo/budget/2007/2007bib.pdf); b) Portions of the FY 2007 Annual
Performance Plan and Congressional Justification (www.epa.gov/ocfo/budget/2007/2007cj.htm);
c) US EPA ORD Program/Project Descriptions (18 separate summaries), and d) several resource
tables.
Members of the SAB were assigned the lead on one or more specific research Program/
Projects prior to the date of the meeting. During the March 2-3, 2006 meeting, Members
discussed Program/Projects with EPA reprentatives using logically grouped clusters and then
developed their consensus remarks on each as they decided to be necessary. The groupings used
were: a) Air, b) Water —including Ecosystems, c) Human Health, d) Technology, e) Economics
and Decision Sciences, f) Homeland Security, and g) STAR/Fellowships. These discussions led
to a series of conclusions by the SAB which are discussed in the report sections that follow.
They also provided the basis for the Congressional testimony delivered on the issue by Dr. M.
Granger Morgan on March 16, 2006 (this testimony before the Subcommittee on Environment,
technology and Standards of the Committee on Science of the U.S. House of Representatives,
The Honorable Vernon J. Ehlers, Chair, is in Attachment A).
Between 2004 and the proposal for 2007, the inflation adjusted1 budget for EPA's Office
of Research and Development has declined by just over 16%. However, the environmental
problems that face EPA have grown in number and complexity, a trend that will continue over
the coming decades, and thesse environmental issues will also increasingly be linked to the
international competitiveness and relationships of the United States and other nations.
1 Computed using the NASA Gross Domestic Product Deflator Inflation Calculator, available at
http://cost.jsc.nasa.gov/inflateGDP.html
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2. AIR RESEARCH PROGRAMS
The Air Research Program provides knowledge, information/data, and tools that provides
the scientific foundation for the Agency to fulfill its responsibilities under the Clean Air Act.
The Agency focuses its research on National Ambient Air Quality Standards (NAAQS)
pollutants and also studies Hazardous air pollutants (HAPs). This research intends to improve the
efficacy of science-based regulations that protect human health and the environment from
significant exposures to certain air pollutants. In FY 2007, EPA's air research will continue to
strengthen the scientific basis for the periodic review and implementation of air quality
standards. This research is concentrated on particulate matter (PM), but includes other NAAQ
pollutants in a cycle that repeats (nominally) every 5 years. Air toxics research will begin to
transition toward a Multiple Air Pollutant Program (MAPP) focus in FY 2007. The budget
proposal is that Air Research be funded at $77.7 million, down from $90.4 million in 2006 (note:
$7.4 million of the 2006 total reflected Congressional add-ons thus, the actual comparative
figure for 2006 would be $83.0 million - thus the drop in funding without the add-ons would be
a decrease from $83 to $77 million or about $6 million across air toxics, NAAQS, and Global
Change).
There is a need for greater funding for the Air Research Program. The subsections
immediately below point to a number of key issues and needs.
2.1. Criteria Pollutants and Multi-Pollutant Analyses
Multi-Pollutant Focus of the Air Program: The Agency has correctly determined that we
need to move from addressing one pollutant at a time to addressing sources of mixtures of
pollutants in a Multiple Air Pollutant Program, as recommended by the National Research
Council. Of key importance is the fact that we are exposed to a mixture of criteria and hazardous
air pollutants at any given time and thus there is a need to examine health and welfare effects
on a holistic basis. This shift in emphasis has a potential to save money in the future. However,
realizing the benefits of a multi-pollutant focus will require an initial increase in funding to
conduct research to develop the tools and information necessary to support the Agency's air
programs. This initial investment will have the potential to pay future dividends in the form of
regulations that are more reflective of real world exposures.
Particulate Matter Research: EPA's air research program has played a major role in
helping to determine the role of fine particles in causing adverse human health effects. Most of
the research related to fine particles comes from urban environments, because that is where there
are sufficient people to conduct quality epidemiology studies.
There is now a critical need to determine the toxicity of coarse particles, especially rural
dusts generated from such industries as mining and agricultural activities. A new NAAQS for
coarse particles (PM10-2.5) has been proposed for promulgation later this year and because the
current understanding of the role of coarse particles in producing adverse health effects is weak,
the Agency needs more information on the nature of coarse particles in urban and rural settings
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and the potential health effects of these particles from a variety of sources including agriculture
and mining. Additional resources will be required to begin the study of coarse particles (e.g., the
relationship of the composition of particles and their physical size on associated health effects)
and at the same time continue to make the significant investments needed to understand the
health and ecological effects of fine particles. Thus, more research and continued funding is
urgently needed in the area of particulate matter where it is necessary to integrate criteria and
hazardous pollutants and increase the depth of study on coarse particulate matter. Decreasing
the overall air pollution research budget is clearly counterproductive.
Criteria Documents: There is an urgent need for increased staffing to get the Agency out
of the vicious cycle of rushed development of criteria documents. The development of criteria
documents is an essential step in linking the output of the EPA's experimental research to the
development of science-based regulations for criteria pollutants. The ORD group responsible for
preparing Criteria Documents is greatly under-staffed and often only one person is available to
both oversee the production of these documents and for writing the critical synthesis chapters
that pull together the voluminous amounts of research data from specific chapters of the
document into conclusions on the available science. The result of this is that completion of
Criteria Documents is continually behind time resulting in lawsuits and Court Orders that create
a work environment of duress that impedes the completion and quality of these documents and
lead to the need for additional revisions of draft documents
Need for Resources for Emission Monitoring and Modeling: EPA needs resources for
emissions monitoring and modeling (e.g., to deploy monitoring networks that can provide data
on fine particles and mercury).
EPA has made major research investments in evaluating the role of ultrafine particles in
inducing adverse health effects. However, EPA has yet to deploy a monitoring network that will
provide the data sets needed to support health effects modeling and enhanced epidemiologic
study. These data, and the subsequent studies and modeling will help to inform EPA policy-
makers on the need for a particle number NAAQS.
EPA promulgated the Clean Air Mercury Rule (CAMR) and the Clean Air Interstate
Rule (CAIR). There is a monitoring infrastructure in place to determine the changes in sulfate
and nitrate levels in the air (CASTNET, IMPROVE, STN), but there is no capability for EPA to
measure total gaseous mercury (TGM) and reactive gaseous mercury (RGM) over the spatial and
temporal scales needed to assess the effectiveness of the CAMR. Further, there is virtually no
capability to examine the global mass-balance of mercury. This baseline is likely to be changing
because of the rapid increase in the use of fossil fuels in Asia (China, India, etc.). (See
subsection 2.3 below for more information on Mercury research).
The Agency did an excellent job of strategically evaluating their current air monitoring
system and matching their data needs and monitoring approaches for collecting critical data.
However, rather than using the results of this strategic approach to maximize the benefits of their
current investments in this area, the strategic analysis was used to reduce their monitoring
resources. These reductions will diminish EPA's ability to make informed decisions on the
effective and efficient management of air quality.
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As part of the monitoring strategy, EPA properly identified the need to integrate new
technology into the monitoring network through a limited number of "supersites" that will
evolve and change over time. However, resources have not been available to support this
activity that is an important and integral part of the overall air monitoring network.
The Agency also has a need for research information on atmospheric fate and transport to
support their consideration of regulatory mechanisms. In the Program Area for Air Toxics and
Quality, we commend the Agency for its efforts to support market-based methods for allocating
emissions reduction. Even though benefit-cost analysis is not to be used for setting ambient
standards, economists advocate the importance of its use in devising mechanisms to meet
standards at the lowest possible overall cost to society. Market-based methods, such as tradable
emissions permits, have been very successful in the 862 allowance program and for RECLAIM
in Los Angeles.
However, the idealized marketable emissions permit program applies to uniformly
mixing pollutants, where it does not matter which sources generate the pollution (e.g.,
atmospheric carbon — as CC>2 — is an approximately uniformly mixing pollutant). Trading
programs may need to be modified where pollutants are not uniformly mixing (i.e. when there
may be "hot spots"). Sometimes, these modifications can be very crude, such as a restriction that
permits may not be sold upwind (e.g. RECLAIM'S differentiation between inland and coastal
zones), but more sophisticated modifications are potentially available.
In theory, it is possible to design elaborate systems of "ambient permits," where firms
purchase the right to contribute a certain amount to ambient concentration levels at one or more
receptor sites (permits for each receptor site form a distinct market). To implement such an
ambient permit system, however, it is necessary to "map," back to each source, the quantity of
emissions that is associated with a given change in ambient concentration at the receptor site.
This connection requires a statistically estimated empirical model that connects changes in
emission levels from each source with changes in ambient concentrations at receptor sites
(presumably located at suspected hot spots).
Research resources are needed to improve the quantification of the connections between
ambient levels (what matters to human and ecosystem health) and the patterns of emissions from
different sources (what can be controlled).
The SAB is concerned that the success of simple tradable emissions permits programs
will degrade as they are implemented more widely, in contexts that lie farther from the idealized
case of a uniformly mixing pollutant. Tradable ambient permits programs have much greater
information demands. If it is necessary to worry that a tradable emissions permit program might
exacerbate hot spots, despite controlling overall emissions levels, then it is necessary to plan for
empirically based and defensible fate-and-transport models that will form the basis for ambient
permit systems (see the mercury case in "c" below for more information on this issue).
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2.2. EPA's Global Change Program
The EPA Global Change Program received $19.6M in FY2005, $18.6M in FY2006, and
is proposed to receive $17.5M in FY2007. This proposed amount represents an approximate
15% decrease over the time period, in standard dollars.
As designed, the Global Change Program has five components: a) Assessments at the
National/Regional level, b) Air quality, c) Ecosystems, d) Water quality, and Human health. The
assessment activity is legislatively mandated and occurs through the Climate Change Science
Program. The other four components have both intramural and extramural activities.
Because the Global Change program's has mandated obligations for assessment within
the Climate Change Science Program, the cuts in the FY2007 budget will have to be taken from
the other four program components. These cuts will eliminate almost all of EPA's research on
the impacts of global change on water quality, and will essentially eliminate EPA's intramural
research programs on the effects of global change on air quality and ecosystems health. These
cuts cause two serious problems. First, the lack of an EPA based program on the impact of
global change on national water quality and the elimination of intra-mural research on air quality
and ecosystems are inconsistent with EPA's mission. Second, the elimination of intramural
programs will seriously impact EPA's human infrastructure resources (human capital) and make
it much more difficult to address these issues in the future. These two issues are discussed
further in the paragraphs that follow.
Climate change and water quality: The Agency's climate change research appears to be
limited to impact of and adaptations to climate change, rather than mitigation. Other agencies
are concerned with the implications of climate change on the supplies of water (i.e. water
quantities) but not water quality. EPA should retain its interest in the implications of climate
change for water quality.
Human Resources: Many EPA scientists and science-based professionals are moving
toward retirement age. In addition, fewer investments in intramural research will lead to fewer
opportunities for providing persons with expertise in specific areas such as global change. It will
be important to ensure the continuation of resources to support EPA's inhouse development of
such expertise and to continue to support graduate fellowship and grants programs to help
provide the knowledgeable staff to fill these positions and to meet EPA's needs.
2.3. Mercury Research Program
The proposed FY 2007 budget for mercury research represents a reduction of
about 29% from the level of two years ago (2005 enacted), although at $3.7-million the proposed
FY 2007 amount is an increase of $300k over 2006 enacted.
Because mercury is persistent in the environment and because it is a serious neurotoxin,
the agency has mounted a major control effort, to limit emissions from sources such as large
coal-fired power plants. In the past this program largely supported work on monitoring and
control technology. From this work, measurement of "wet deposition" is available in some
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regions, but measures of "dry deposition" are still being developed and ambient concentrations
are more challenging to devise.
With the passage of the Clean Air Mercury Rule, this program acquired additional
responsibilities to evaluate the effectiveness of control measures. It is apparent that EPA can not
adequately address all its current mercury-related responsibilities at the current budget level.
With respect to the CAMR, it is therefore important to determine whether hot spots exist
for mercury. Tradable permit programs are best-suited to "fund pollutants" for which the
environment has some assimilative capacity. They are less well-suited to stock pollutants, where
the social costs of pollution depend on the cumulative amounts received in the environment.
Stock pollutants may imply that constraints need to be place not on annual emissions, but on
total cumulative emissions. This would make the stock of available permits an "exhaustible
resource," and a need for firms to manage these as a mine-owner might manage the exploitation
of an exhaustible mineral resource.
EPA's lack of adequate research resources to meet its programmatic mission for mercury
is troubling, but there is a much more fundamental reason why the very low level of support for
mercury research poses a serious problem. As acknowledged in the Agency's background
information for this review, mercury pollution exists on a planetary scale because mercury is
transported across oceans and continents. While some comes from human sources, such as
power plants all over the world, much comes from natural sources such as volcanoes and other
geological sources. We simply do not know where all the mercury comes from, where it goes,
how much exists in different chemical forms, and how all the transport and transformation
occurs. Without this knowledge, it will be impossible to know how well the current or future
control programs will be able to reduce human and ecological exposures. There is a US
interagency group responsible, as well as an international (UNEP) group considering this issue.
However, in our view the support for research on global sources, transport, and fates is seriously
deficient. EPA should be funded to play a leading role in such an effort, but at the current
budget levels can not even begin to address the issue.
2.4. Research Program Evaluations
It is apparent that evaluations of research program effectives will continue to be
conducted using the Program Assessment Rating Tool (PART). Therefore, it will be important
for the Agency to anticipate the "outcome" measures that will be used in these evaluations and to
collect data explicitly on these different outcome measures. In the Air Toxics and Quality
Program area, it appears that the outcome measures to be used consist almost entirely of data
such as a cumulative percent reduction in population-weighted ambient concentration of
"pollutant X" from a 2003 baseline. Presumably, this measure translates into some expected
improvement in human health.
Human exposure and health outcomes are indeed important concerns. However, since
only human populations seem to be counted in developing these outcome measures, it appears
that ecosystem health does not "count." The Agency should be very careful not to build into
their accountability data a systematic bias against ecosystem health or against the more
fundamental types of research that are often needed to develop a proper understanding of
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complex environmental and ecological systems. Admittedly, the greatest ambient concentrations
of many pollutants will occur in conjunction with the greatest concentrations of people (i.e. in
urban areas). Ambient concentration monitoring in less-populated areas may await more-
sophisticated remote-sensing technologies, but the fact that current measures disenfranchise
ecosystem health should not pass unnoticed and the Agency should work with OMB to educate
them on the need to adopt a broader metric.
The existing evaluation process (PART) apparently requires a significant use of Agency
resources. In some cases, these may be one-time costs, since one program's scrutiny and
measures development could help other Agency programs to realign their ongoing investments
in accountability data development towards outcome measures that are more useful to the current
evaluation process. However, it is essential for the Agency to negotiate the weights to be used
for evaluations in less-standardizable programs. In particular, EPA should insist that while one-
dimensional summaries are useful in evaluating program successes, they necessitate the use of
weights on different program attributes and that those attributes are measured in different units
that are difficult to compare. Further, for the current system, many of these weights likely do not
reflect social preferences for the country as a whole. Instead, they appear to be negotiated
between OMB and the Agency. Arbitrary weights merely reflect the preferences of the group(s)
involved in negotiating them. It is possible that neither group may have the overall
(intertemporal) welfare of society as its objective function. The "right" set of weights to use in a
metric such as the PART is normative (a matter of opinion, rather than a matter of fact), should
include inputs from the most affected, and depends upon what one is seeking to maximize.
Also somewhat troubling about the current evaluation process is the discreteness of the
categories into which different programs are placed. Inappropriate weights, and inappropriate
formulas for combining the components of the PART formula, both contribute to "errors" in the
assignment of numeric scores. The PART score is interpreted as a point value, and the score for
a program places it into one of five categories, creating an artificial impression of certainty.
Ideally, the rating would acknowledge the existence of some doubt about the correct magnitudes
of the weights and the correct functional form used to combine program attributes with these
weights. A PART score should be a range, at best. That range may lie entirely within one of the
five designations, or it may span two or more categories.
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3. WATER RESEARCH PROGRAMS
3.1. Drinking Water Program Budget Comments
The SAB believes that the Goals and Metrics for meeting the Safe Drinking Water Act
mandates will be attained and measured with the support of ORD's research products developed
for the Office of Water, Regional Offices, States, and municipalities.
The drinking water research program has been reviewed by the EPA SAB, the ORD's
Board of Scientific Counselors, and by OMB using the PART. In the PART evaluation, the
drinking water research program was rated as adequate. The Board of Scientific Counselors
recently produced a final report (Oct. 17, 2005) on the "Review of the Office and Research and
Development's Drinking Water Research Program at the U.S. Environmental Protection
Agency" and had a series of recommendations. These recommendations are incorporated into
the recommendations made by the SAB that follow.
1) The drinking water research program Multi-Year Plan is being revised during FY 2006.
In addition, the Agency has decreased their three Long Term Goals into two in this area.
It appears that collapsing the three LTGs from the past into two was driven by
considerations associated with the PART process and not by a scientific rationale. From
a science perspective the themes that were in Long Term Goal 3 [source water protection
(watershed) and distribution systems] have some commonality in that both the source
water protection (watershed) and distribution systems are highly complex, difficult to
monitor and require multiple-scale assessments involving in-situ systems (gauges and
sensors) as well as extensive modeling efforts. Therefore, the Agency should consider
returning to three Long Term Goals in this area instead of the two which now exist
because of the possibility that parts of the program (e.g., source water and distribution
systems) might not receive adequate consideration if merged into the other LTGs. In
revising its plan, EPA should clearly reflect the need for long-term basic research and
work to clarify their Long Term Goals, as well as to develop initiatives that recognize
their expanded client base that now includes communities. EPA should incorporate this
into their efforts to identify measurable outcomes of activities covered by this program.
2) EPA intends to initiate research on drinking water distribution system infrastructure (e.g.,
leak detection, assessment of high risk mains, cost effective rehabilitation and
replacement, distribution system design). Research on technologies to decrease operating
costs of distribution systems provides an opportunity to define outcomes that can be
readily achieved via EPA's external and internal research programs. Currently, these
programs have different emphases, i.e. the internal program focuses on applied research
and the externally funded research focuses on basic research. EPA should articulate a
budget and activity plan that will clearly show the research strategies that will be used to
implement this new distribution system research initiative.
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3) EPA's research budget reduces the regulated contaminant activity by nearly one million
dollars. Even though EPA considers this research to be a "low priority research area"
there is a need to continue research on regulated contaminants because some are still in
the implementation stage of regulation and all drinking water standards will undergo a 6
year review to determine whether there is a need to revise their existing standard. These
reviews are mandated by the US Congress. Thus, EPA should determine the critical level
of funds required to achieve its legislated mandate in this area. In addition, the strategy
for meeting the mandate under this reduced funding scenario should be outlined.
4) EPA's CCL research is one area that focuses on the risks associated with emerging
contaminants. In evaluating whether these contaminants might need to be regulated,
EPA must evaluate both exposure pathways (transport and fate, removal by treatment,
exposure to the public, as well as the ability to reduce the exposure (e.g. treatment
controls) and health impacts. Thus, funding in the Water Quality Research side may
impact the effectiveness of the Drinking Water research in achieving the LTGs and
perhaps Annual Performance Measures. This interrelationship among these two research
programs should be better articulated.
5) The SAB supports and encourages EPA's research collaborations with other agencies
(e.g. USGS); however, it is ultimately EPA that must link the environment and human
health together thus, EPA's research programs must be funded at a level that is adequate
to do the task. EPA is leading the research in pathogen studies in water particularly via
molecular characterization. Pharmaceuticals and Mercury are other examples of
contaminants that move through the environment via various matrices (land/air/water)
and these contaminants and others, require a national data base on water quality to
eventually understand the impact on drinking water and human health.
6) EPA's Program in Drinking water research needs to ensure that it includes activities that
will allow the Agency to include scientific advances in microbial risk assessment in its
evaluations of the public health benefits from reduction of contaminants that are
microbial pathogens.
7) The SAB supports EPA's goal to achieve national and global scientific leadership in
issues relevant to safe drinking water. An assessment of the critical areas where EPA can
position itself to take the global lead is needed as is a strategy to move the leadership
program forward. Thus investment and participation in organizations like the Global
Water Research Coalition is appropriate and EPA could incorporate this activity within
its drinking water research program in the future.
3.2. Water Quality
The water quality research program provides ORD's research and expertise in support of
the development of water quality criteria for designated uses of aquatic systems that are intended
to protect human health and the environment and research on the beneficial use of biosolids.
The research program also develops tools to assist in the selection of watershed management
technologies in protecting and restoring these systems and in forecasting their effectiveness. The
Water Quality Research Program budget has a net increase of nearly $6 million dollars in FY
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2007. These increases are for new activities on the protection of ecosystems with an emphasis
on the impacts of multiple stressors from CAFOs on water quality (~$2.8M), and a new
investment in innovative strategies for sustainable wastewater infrastructure (~$5M). These
investments are worthwhile and fit with the mission and goals of the program.
The water quality research program is clearly relevant to EPA's mission and it is
effectively coordinated with other program and regional offices within the Agency. There is also
a history of coordination with the European Union and the private sector in certain areas such as
ecological risk assessment. It is less clear how it coordinates with other Federal agencies that
also have responsibilities for water resources.
The Water Quality Research Program has linkages to research needs in several other
EPA programs, for example, EPA's ecological research program and EPA's drinking water
program. However, the interrelations among these programs are not clearly articulated in the
materials provided to the SAB. By definition these programs are related and require
coordination. Specifically, the SAB is concerned that the substantial decreases in funding
ecological research have not been mitigated by any funding or corresponding increase in funding
or programs in water quality research. Further, decreases in funding for mercury fate and
transport and exposures to endocrine disrupting chemicals are not being replaced by efforts in
water quality research. All funding for the impact of climate change on water quality has been
eliminated. Thus while some goals within the water quality research program are being
adequately funded, the ecosystem goals are not being adequately funded by either water quality
or ecological research.
The Agency is also considering implementation of watershed pollutant trading as a
means of achieving water quality goals. To do this, EPA will need to evaluate and align the
goals of the water quality and ecological science research programs. This will also require that
EPA also strengthen its scientific knowledge base and research activities that address ecological
uncertainties.
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4. ECOLOGICAL RESEARCH
The Ecological Research Program has three major components:
i) condition assessment and accountability,
ii) development of methods and tools (primarily diagnostic), and
iii) research on ecological services and restoration.
In the FY 2007 budget, ecosystems research programs are once again the target of
significant resource reductions (approximately 10% relative to FY 2006). The SAB is greatly
concerned with EPA's continuing reductions in Ecological research funding. The ecological
research budgets have removed nearly $30million since 2004. Even though the Congress has
restored some of these reductions, real reductions of approximately $20 million have been taken
in the STAR ecosystems grant program during that time.
The total budget for Ecological research is down $6.1 million in the 2007 budget. This
reduction in budget is inconsistent with the prevailing position that such research is critical for
the Agency to better manage and track the benefits of such management of the environment. A
number of external Agency Advisory groups, such as the Board of Scientific Counselors, the
National Academy of Sciences, and even EPA Science Advisory Board groups such as
Environmental Processes and Effects Committee and Committee on the Valuation and Protection
of Ecological Systems and Services, have explicitly expressed support for greater research in this
area.
Understanding the response of ecosystems to biological, chemical and physical stress is
essential for protecting the environment and the humans that live in it. The short-sightedness of
the continued ecosystems research budget decreases is clearly demonstrated by events of the
2005 U.S. hurricane season. Ecosystems such as coastal wetlands and forests provide significant
ecological service by acting as natural buffers to dampen the damaging force of such severe
storms. Had the nation possessed the scientific understanding of the services provided by those
coastal ecosystems and used that information to manage their protection, the costly damage
associated with storms such as Katrina and Rita would most likely have been greatly diminished.
The SAB recommends that the funding for this key area should be reestablished and
expanded in future years. Further, the Agency needs to do a better job of communicating the
importance of this research area and the breadth of substantive supporters that it has for these
research efforts. While motivated by real-world problems, a significant portion of the Agency's
ecosystem research needs to be fundamental in nature, and the Agency also needs to do a better
job of explaining this fact.
The U.S. Environmental protection Agency's Ecological Research Program directly
supports EPA's mission objectives and it appears to be effectively linked to programs within the
agency and to the Agency's Regional Offices and laboratories, as well as to the states. However,
the linkage to other federal agencies, and non-government ecological organizations has not been
articulated as clearly. The agency needs to advance its efforts to demonstrate this coordination
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with other agencies so that it can better communicate those connections and their collaboration
in future PART assessments and budget discussions.
The budget for Ecological Research is actually part of a budget area titled "Human health
and Ecosystems. Although there is no indication that this is a barrier to effective planning, it
seems this valuable area should stand on its own as a research focus area. The Agency should
consider separating this budget category into a separate area.
It was noted during further discussions with the agency that two principle factors may
well have contributed to the reduction in the 2007 budget for Ecological research. First, the most
recent update of the OMB PART assessment resulted in a rating of'ineffective for this program.
It appears that the PART assessment focused primarily on one aspect of the Ecological Research
program, i.e., the Environmental Monitoring and Assessment Program (EMAP), which is only
about 1/3 of the actual budget expenditures. In efforts to justify this program the agency either
failed to communicate or OMB did not understand the EMAP program's value to environmental
management decisions and actions. In particular the program was given low scores in areas of
the PART assessment related to the uniqueness of the research, clarity on aggressive timelines
for achieving deliverables and related cost-effectiveness methods rather than the scientific
relevance of this area of research.
The Ecological Research Program has developed important probabilistic tools (e.g.
Environmental Monitoring and Assessment Program) to assess the status and trends of aquatic
and terrestrial resources (streams, lakes, estuaries, forests, etc.) at a variety of scales (regional,
and national).
It is important to recognize that although Water Quality research and Ecological research
are placed into different budget areas these two programs are critically linked to each other. The
SAB emphasizes that reductions to ecosystems research can and will lead to time, data or other
resource limitations for accomplishing EPA's Water Quality research objectives. The agency
needs to aggressively improve its communication of the broader value of its Ecological Research
program and its critical and systematic linkage to other research and also program areas such as
the Water Quality program.
Additionally, losses in several ecosystems programs may have much greater or amplified
impacts on progress on other research programs. The logic seems to be to cut programs because
of perceived redundancies with programs of other agencies or because of perceived redundancies
with other programs within EPA. However, those making budget decisions need to recognize
that some research that seems to be redundant because of the superficial information available to
them can in reality be a lynch-pin in a larger, overarching and integrated research program that is
conducted by multiple organizations, each of which specializes in areas where they have explicit
missions and expertise. Examples of this include the elimination of the global climate change
program funding of water quality research, and the reduction in extramural research in mercury
fate and transport. It is difficult to see how EPA will achieve some of its strategic goals with
continuous erosion of these small but important pieces that are not understood within a larger
context.
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It is obvious that in the broad area of Ecological research there are many important gaps
in EPA and the nation's knowledge of the environment that are worth bringing into the research
program as other projects are completed. Answering a small piece of the puzzle does not
remove the need to study other issues that are also quite important to EPA's mission. Ecological
Research is not a small definable set of activities that can be reduced one-by-one like a list of
steps in a project. There are many of important research initiatives waiting to be addressed.
These are not of lower importance rather they may only be waiting on other research to be
completed so that they can be placed onto the active research agenda.
An important consideration was highlighted for the SAB through anecdotal information
on how EPA sets its specific goals for research. It seems to be that the agency must negotiate the
specific language that specifies its goals. In one example of this practice, it appears that EPA
staff was not allowed to include a goal that focused on regional and local decision-making needs.
The practical outcome of this was that EPA was not able to include an important focus of ORD's
activity, support of real-world decision-making on actions needed to respond to localized events.
Therefore, it appears that assessments of value and performance of the research is constrained to
National policy making. In reality the more likely key audience for the ecological research is a
regional, state, and local scientific communities that assesses real problems at regional and local
levels (e.g., regional ecological systems such as watersheds) while implementing specific federal
regulations in their own localities. During its meeting on March 2-3, 2006, the SAB received an
excellent and effective presentation of such an example by Regional and ORD representatives
(i.e., the Georges Creek, MD case that demonstrated an explicit link between EPA ORD research
and an outcome of improved stream quality in Maryland). The SAB believes that this is a
powerful example showing an important real-world environmental improvement outcome that
was directly related to EPA's research program. This lack of linkage to of ecological research to
Regional benefits may well have constrained the agency as it attempted to demonstrate the value
of the ecological research during the PART review.
The SAB believes that the agency should not be constrained in setting goals that
demonstrate the alignment of its research with attaining real world outcomes that assist state and
local governments to implement Federal mandates.
Finally, Long Term Goal 3 (Ecological Services & Restoration) appears to address
impacts on ecosystem services. This is an important emerging environmental issue. EPA must
continue to move beyond status and trends data and focus more on linking their regulatory
efforts to ecological services protected or restored. EPA should pursue research to develop the
capability to demonstrate how regulatory programs impact ecological services. EPA also needs
to develop analytical approached for regional and local assessments and at the same time not
abandon research on national level tools.
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5. HUMAN HEALTH RESEARCH
5.1. Human Health Research
The Human Health Research Program is one of only two core research programs
in the Agency, the other being ecology. Core research programs generate, and provide incentive
for researchers outside EPA to generate critical parts of the basic scientific knowledge that
underpins EPA's applied science program and the regional and headquarters operating programs
that carry out EPA's human health and environmental protection missions. According to
comments made by EPA's Assistant Administrator for Research and Development, during the
SAB March 3 session, the proportion of EPA's research budget devoted to core science issues
has changed from what used to be close to 60% core to 40% program driven research to about
30% core and 70% problem driven research. The purpose of this program is to provide to risk
assessors, and other interested parties, scientific data that are necessary to assess and to make
important decisions regarding human health risks. The program develops and collects the
scientific information to make decisions about exposure that provide appropriate protection to
the health of humans. These policy decisions often involve substantial monetary impacts to
industry, governmental agencies, and eventually to the public that may amount to many millions
of dollars. In contrast, errors in these policy decisions may lead to risks to living persons or even
to future generations.
EPA focuses on four long-term goals, to provide the science necessary for risk assessors
and managers to make the best informed decisions based on science. These Long Term Goals
include efforts to: reduce uncertainty using mechanistic information, to characterize the
cumulative and aggregated risks from multiple chemicals to characterize the susceptible
populations to provide adequate protection for all groups by age and by factors related to
genetics such as race and ethnicity and develop principles to evaluate risk management
decisions.
This program has been evaluated by both the ORD Board of Scientific Counselors and by
EPA and OMB using the PART process. The BOSC determined that the mission of this research
program was being well conducted. In addition, the SAB's scientific panels have also given
parts of the programs that have reviewed their general approval. At the same time, the SAB has
also asked for more and more science from EPA as it carries out the Agency's mandates. The
SAB has also asked for a greater level of review of the science that is used in regulation.
As the program has continued to work to fulfill these demands, the science and
technology surrounding the information about human risks has grown rapidly. For example, the
development of the fields of "omics" and the relationship of the information in these areas to
human disease is increasing at previously undreamed of speeds. Therefore, EPA has more
science to gather for each pollutant that it evaluates both from internal and external sources. In
addition, the data are very complex and requires even more time, effort, and resources to
integrate into a rational scheme for developing a regulation. As the agency science budget
continues to be reduced, the number of evaluations that it can conduct decreases and evaluations
that are carried out are delayed. In turn, this means that when a document is subjected to peer
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review by scientific experts, the data are often old and more uncertainties have often dentified.
There is no easy solution to this problem. Thus, if EPA continues in this "spiral," it may be
important to consider just how closely the scientific demands can be met in the future.
The preceding paragraphs have discussed primarily the problems encountered by a
reduced capacity in Long-Term Goal 1. The SAB believes that all four goals are important and
thus is concerned with the potential impacts associated with the reduced budgets in the other
three goals. There, considering the risks of joint exposures to multiple chemicals will likely
experience major delays. In goal 3, the Agency has had to withdraw their financial support for
the National Children's study although they continue to look at the risks from exposures in the
youngest of our population. However, other factors that can influence the risks both by life
stage, especially the elderly, and the potential genetic differences by race or ethnicity will not be
part of the current activities in any serious effort. The fourth aim is essentially to look at the
public health consequences of the decisions made by the agency. This effort is also delayed.
There are also areas that the Human Health Program is not able to address adequately.
While the Agency is collecting the data relevant to humans it has not, they have not extensively
addressed the issue of the exposures. Its effort at collecting relevant data from other sources is
also greatly delayed by lack of funds.
5.2. Computational Toxicology
The Computational Toxicology program focuses on improving the linkages in the source-
outcome paradigm; providing tools for screening and prioritizing chemicals under regulatory
review; and enhancing quantitative risk assessment. Efforts in this program appear to be
targeted at supporting both human health assessments and ecological assessments. The program
has a planned increase of about $2.0 million in FY 2007.
The SAB commends the expanded investment in the Computational Toxicology research
program. This investment is essential to providing EPA with the expertise and technologies
necessary to keep pace with the rapid expansion in genomic and modeling sciences occurring in
biomedical research. However, because the Computational Toxicology program is highly
dependent on data inputs from other EPA human health and ecosystems research programs, the
SAB is concerned that the flat or declining research investments in these associated areas will
likely compromise the future effectiveness of this research investment.
5.3. Human Health Risk Assessment
EPA's Human Health Risk Assessment program includes the Integrated Risk
Information System (IRIS) and other health hazard assessments; development of risk assessment
guidance, methods, and models; and development of Air Quality Criteria Documents. The
program reduces from $39.4 to $38.3 million in 2007. The cuts are in the children's health area
while a $0.5 million increase is provided to obtain peer reviews of IRIS assessments by the
National Academy of Sciences.
Resources are planned to decrease in this program area, even though there is an
increasing need for high quality risk information and increasing requirements for complex
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scientific analyses at the EPA. There is a need to increase risk assessment research resources to
support these efforts. For example, pharmacokinetic analyses are an essential component of
dose response evaluations; data permitting, and exploration of pharmacodynamic approaches
have also been recommended to the EPA. At a minimum such approaches would help to
articulate the range of model uncertainty. It is important to recognize that even if EPA does not
conduct research to improve how it incorporates more and more complex data into assessments,
data continue to be gathered at a high rate, thus, without better methods, EPA will fall further
behind in the risk assessment area.
Past involvement by outside groups in the review of EPA assessments, as well as the
development of additional review requirements, have resulted in the advice that increases this
complexity further. For example, the SAB strongly recommended the development of
methodologies for quantitative uncertainty and variability analyses of toxicological parameters
such as cancer unit risk values and reference doses (EPA SAB, 20042). Further, the OMB's Risk
Assessment Bulletin, if adopted in its present form, could in essence make such analyses a
requirement. Demands on Agency risk assessment resources have also resulted from the Data
Quality Act and OMB's Peer Review Bulletin. The need to address multiple pollutant exposures
to support air program efforts is also clear. Agency products such as certain IRIS assessments
and other health effects assessments (e.g., dioxin and trichloroethylene) are undergoing
expensive reviews by the National Research Council. Without an increase in resources, the
ability for the Agency to produce high quality assessments for the large number of chemicals of
public health interest will be severely limited, as will the number of peer reviews that EPA can
obtain from independent groups, such as the NAS as is planned in its IRIS program.
5.4. Safe Pesticides and Safe Products Research
This program focuses on research that addresses specific issues managed by the
EPA Toxic Substances program and the EPA Pesticides program. This program complements
research efforts in the Human Health and Ecosystem Research programs as well as those in the
Human Health Risk Assessment, and Endocrine Disrupter programs. The efforts in this area: i)
provide predictive tools for prioritization and enhanced interpretation of exposure, hazard
identification and dose-response information; ii) create the scientific foundations for
probabilistic risk assessment methods that protect natural populations of birds, fish and other
wildlife; iii) provide the scientific foundation for guidance to reduce risks to human
environments within communities, homes, workplaces; and iv) provide strategic scientific
information and advice concerning novel or newly discovered hazards.
The Safe Pesticides and Safe Products Research program Presidential Budget for FY2007
is set at $26.2M, down $4.1M from the enacted budget funding for FY2006. The $4.1M cut in
the President's FY2007 budget is in fact funds in the FY2006 budget that were allocated to this
program from a special allocation designated by Congress for added science and technology
projects. These one-time funds were applied to special initiatives and grants related to this
2 EPA Science Advisory Board. 2004. EPA 's Multimedia, Multpathway, and Multireceptor Risk Assessment
(3MRA) Modeling System. EPA-SAB-05-003, November, 2004. Available at: http://www.epa.gov/sab.
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program's long term goals. The EPA budget notes that these decreases will impact
biotechnology, and collaborative and risk related research efforts.
Projects included under Long Term Goals 1-4 are funded in the FY2007 budget. The
major areas covered by these projects appear to be consistent with both the short-term and long-
term research needs of the Office of Pesticide Programs and Toxic Substances (OPPTS). The
SAB's greatest concern for this program area is not the proposed level of funding for FY2007
but the fact that the level of funding has remained flat for several years (not withstanding the
one-time increase in 2006) and in real dollar terms has consistently declined. The scientific
demands on ORD research staff and OPPTS regulatory functions are becoming increasingly
complex, and involve genomics, proteomics, genetic engineering, and endocrinology. The SAB
recognizes that ORD cannot be expected to maintain large intramural or extramural research
programs in each of the rapidly expanding areas of science and technology. However, ORD
must have senior scientists who are capable of understanding these areas at an expert level and
who can integrate research results from other government agencies, industry and academic
research programs into its support of OPPTS policy formation and regulatory activities. If the
ORD budget in this program area continues to decline in real dollar terms, it will not be able to
maintain the scientific staff and infrastructure to fill this critical role.
Finally, the proposed FY2007 budget for this program will not permit ORD to launch a
planned initiative to develop standard biomarker measures that the FIFRA Scientific Advisory
Panel and other EPA panels have regularly stated are essential to the validation of the
probabilistic risk assessment models that are increasingly important components used in the
aggregate and cumulative risk assessments of pesticides and herbicides
5.5. Endocrine Disruptors
The endocrine disrupters program is organized to address a major nationally
recognized human health and ecosystem health concern. The program long term goals are to: i)
improve the underlying science regarding the effects, exposures, assessment, and risk
management of endocrine disrupters; and ii) to determine the impact of endocrine disrupters on
humans, wildlife, and the environment. The budget proposal for FY 2007 is for $9.1 million,
down from $10.5 million in FY 2005 (as enacted).
The Endocrine Disrupter program was evaluated (using the PART process) during 2004
and it was the first USEPA program that received a passing score (adequate), a score not
surpassed by any other program in the EPA. The Board of Scientific Councilors (BOSC) also
evaluated this program in 2005. The BOSC found the endocrine disrupters program to be highly
effective especially in view of an extremely limited budget in FY 2005 ($10.4 million) and 2006
($10.5 million). The BOSC indicated that this budget was grossly under funded.
Despite the Endocrine Disrupter Program's focus on addressing a high national priority, and
despite its conduct of this program in a scientifically high quality and efficient manner, the
proposed 2007 President's budget cuts this program by $1.4 million (10%). All of the cuts
occurred in the STAR program, the extramural program that recruits the nation's academic
community to address the endocrine disrupters science program needs. The SAB recommends
that the budget for endocrine disrupters be reinstated.
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6. TECHNOLOGY
6.1. Land Restoration and Preservation Research
The Land Research Program supports that Agency's objective of reducing or controlling
potential risk to human health and the environment at contaminated waste sites by providing
science to support decision making at complex sites. The program has two themes restoration
and preservation. Resources come from the Science and Technology account (about $10.5
million is budgeted for FY 2007) and the trust funds ($21.9 million from Superfund; $650
thousand from UST; $900 thousand from Oil Spills). The S&T account that primarily supports
the RCRA program research decreases by about $1.0 million in 2007 and the Superfund account
decreases by about $1.0 million as well. Overall, the Goal 3 FY07 budgetary priorities have
changed little from those in FY06, although the overall goal budget is down by 15% ($40.0 to
$34.1).
Three programs have either been eliminated or maintained at a minimal level (Oil spills,
Superfund Innovative Technology Evaluation, and Underground Storage Tanks). The Board is
satisfied with the notion that elimination of mature programs that can be assumed by the private
sector, or other agencies is justified, however there is concern that there has been little planning
associated with the phase outs in this program. These programs contain expertise and
capabilities that should not be lost in the future, since there remain many waste cleanups yet to
be carried out. In addition, the Board believes that there are still significant research needs
associated with the waste cleanup program, particularly related to site characterization.
The strategic targets for Goal 3 are certainly worthy, but it is not clear how the S&T
budget will be used to achieve these goals. The Resource Conservation Challenge (RCC) is
presented as an important tool for promoting voluntary cooperation, but the research budget for
RCC is still unclear (anecdotal evidence suggests that about $1 million has been allocated—if
this is so it would indeed represent an increase).
The only specific information on the RCC research program is from page S&T-99 in the
budget document that notes that RCC is ".. .a major national effort to reduce waste and conserve
natural resources by promoting the use of recycled products. EPA will continue to develop
effective options for minimizing waste, and for assessing the performance of waste minimization
programs through multimedia risk assessments...In FY 2007, utilizing its multimedia modeling
risk assessment methodologies, EPA's research and development program will provide an
estimate of the benefits realized (i.e., reduction in risk to human and ecological receptors) in
reducing priority chemicals waste streams." As the Board pointed out last year in its
commentary, areas of relevant research are many and varied, ranging from material flow and life
cycle studies, to data certification, to appropriate policy instruments to create incentives for
material conservation.
The Board notes that the goals and objectives of the RCC are consistent with the
Agency's Sustainability Research programs, which appear to have emerged from the previous
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"pollution prevention" and "technology for a sustainable environment" programs. The SAB will
soon review EPA's Sustainability Research Strategy and the Board will have more to say on this
in the future. However, we believe that among the important topics to include in a Sustainability
program would be: re-engineering processes, the implications of new products for commerce,
and the need to provide meaningful incentives for maintaining and improving environmental
performance. The Board believes that it is possible to articulate Sustainability - RCC research
budgets, strategies, and plans in a way that shows their relationships, and their individual focus,
e.g., the RCC might provide the basis for the kinds of research needed as drawn from
connections with EPA's partners, and Sustainability Research might focus on using the best and
most appropriate research tools. The RCC would then serve the dual purpose of mining
information from its partners for relevant research needs, and then to the extent possible
transferring the results of Sustainability Research to the field.
In carrying out this task, the Board suggests that it be subjected to PART review as soon
as practicable so that the PART tool can be used for program design and documentation, as well
as ex post evaluation. The Board looks forward to the presentation of a coherent
Sustainability/RCC research program next year.
Science programs in Goal 3 reflect coordination among EPA organizations. The Board
notes that the targets of Goal 3 and those of Goal 5 overlap, with the latter supporting S&T
research on pollution prevention. It is important that these functions be closely coordinated if the
research is to be relevant and useable in the short term.
The Board is on record as stating that the Agency does coordinate well with other
agencies, but the SAB has requested more specific information on the quantitative amount of
leveraging that is actually achieved (see the Board's FY 2006 advisory). Such information
should be developed across the Federal government routinely as part of the science and research
budget evaluation. It would be helpful if this information would include trends over the
preceding five years. This information on Agency resource leveraging is important if all
involved are to understand the degree to which environmental research portfolios across the
federal government intersect and how well they are coordinated. As noted during the Board's
review meeting, the EPA S&T research budget accounts for about 7% of the total federal
environmental funding. Without a more detailed knowledge of research supported by other
agencies, it is difficult for the Board to assess the impacts of EPA's programmatic cuts and
reallocations, in this and other Goals, and how they impact overall federal research on specific
topics (an example is the continuing de-emphasis in EPA's ecosystems research program and its
impact on other agencies having complementary research programs and mission areas.
Accordingly the Board renews its longstanding request for more detailed information on the
cross-agency collaborative research funding.
This year the SAB was able to examine emerging research programs in the general area of
nanotechnology, and also the GEOSS/Advanced Monitoring Initiative
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6.2. Nanotechnology
EPA's nanotechnology program increases from $4.6 million to $8.6 million in FY 2007. In
FY 2007 EPA's program will conduct nanotechnology research through its extramural
exploratory grants program which funds investigator initiated projects and they will develop an
intramural research program.
The Board notes the significant (more than 80%) increase in funding devoted to the national
nanotechnology initiative for pursuing environmental impact research. The increase in EPA's
nanotechnology budget is encouraging, though the absolute amount is still small when compared
with other agencies in the National Nanotechnology Initiative and given the level of public
concerns about the environmental impacts of nanotechnology.
The SAB has noted over the past two years that nanotechnology will have immediate impacts
on the environment. This will occur in two ways: i) nanotechnology support for environmental
improvements (e.g., development of new sensors, water purification membranes, etc.), and ii)
potentially negative environmental impacts associated with nanotechnology products or
manufacturing processes.
Thus far, most studies seem to have focused on the fate, transport, and human health effects
of fine particle structures. The Board has noted in its previous reports, and re-emphasizes again,
the need to include nano-manufacturing within the EPA research portfolio. This trend is already
well underway, in the industrial sector, yet it is unclear if the Agency understands the differential
impacts of old versus new technologies, and if it has the correct regulatory tools at its disposal to
address these issues.
The SAB supports the decision by EPA to build up internal capacity on nanotechnology.
This will become increasingly important as more nano-based substances and products penetrate
the marketplace. The federal government will increasingly need good science to permit it to
evaluate and underpin the need for possible regulations in this area (e.g., under the TSCA, the
Clean Air Act, the Clean Water Act, and RCRA).
EPA is still planning its intramural research on nanotechnology for 2007. The objectives
of this program will be to understand the potential human health and ecological impacts of
manufactured nano-materials, and to investigate how nanotechnology can be used safely in
commercial and environmental applications. EPA's background information indicated that it
was still planning its 2007 nanotechnology efforts and that from 60 to 80% of its new intramural
research would likely focus on nanotechnology's environmental implications and the remainder
would address nanotechnology's potential applications (e.g., nano-scale sensors for
environmental monitoring).
The SAB believes that the current planning underway for EPA's nanotechnology
program is appropriate and important to the design of both EPA's intramural and extramural
programs. However, before investments are made planning should include an analysis of
previous nanotech implications research (by EPA and other agencies) to identify the important
gaps which might exist (e.g., in areas such as ecosystem impacts — terrestrial and aquatic--,
bioaccumulation, or chronic effects). Further, EPA should focus its efforts on research that is
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not likely to be undertaken by any other agency in the government. NIOSH, for instance, can do
nanoparticle characterization, and NIEHS can cover many areas related to human toxicology.
There are, however, gapping holes in our understanding of the environmental impacts of
nanotechnology, and EPA should include these in its research program.
The EPA will need to work closely with other agencies depending on the products (the
FDA for cosmetics, for instance). The proposed emphases on dissipative uses and techniques to
detect and remediate nanotechnology in the environment are also important.
EPA should carefully consider how much money it spends on applications research, what
impacts that will have on their ability to undertake key implications research, and how they can
partner with other agencies on applications development (DOD, for instance, funds work on
nano-scale sensor systems).
The SAB has stated several times that the EPA's research program in nanotechnology
should fund complementary research that industry either can not or will not fund. But partnering
with industry, in order to leverage meager Agency funds, makes much sense because it is the
various industries that understand the technologies involved. By partnering, EPA gets to learn
the basis of new technologies and their environmental implications, and industry gets to have
their input to Agency thinking on how best to manage the problems that might be associated with
these new technologies. Proprietary issues will undoubtedly come up, and will have to be dealt
with creatively, and diplomatically.
The Board in particular points to the need for a life cycle approach for existing and
emerging nano-based substances and products in order to more fully evaluate systems on a
"cradle-to-grave", and "gate-to-end-of-life" basis (product cycle). The EPA will need to work
closely with other agencies to better understand the life-cycle impacts of products not under EPA
jurisdiction (drugs and cosmetics would be examples, which fall under FDA). The proposed
emphases on dissipative uses (such as fuel additives) and techniques to detect and remediate
nanotechnology in the environment are also important areas of focus.
A key problem in this area is how to efficiently manage any risks that nanotechnology
may pose without seriously impeding the development of thse important new technologies. A
simple extrapolation of past risk management strategies does not look like it will get us the kinds
of results we need. EPA needs to work harder on developing strategies to create new and
iinnovative ideas for risk management in the area of nanotechnology.
6.3. Advanced Monitoring Initiative (AMI) /GEOSS
EPA's Advanced Monitoring Initiative (AMI) is linked to the interagency U.S. Global Earth
Observation initiative and the international Global Earth Observation System of Systems
(GEOSS) program. Resources in FY 2007 decrease from $5.3 million to $5.1 million. Overall
GEOSS intends to provide planet-wide information to be used in policy making. EPA has begun
its work in this area and continued funding of the Advanced Monitoring Initiative will permit
EPA to continue its participation in this initiative and to develop its strategy and plans for the
future use of the promising data that GEOSS will make available to users.
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This is a new program that only started in the current fiscal year and thus, it is difficult to
evaluate. There is certainly great potential for space-based and other dispersed observations to
support protection of human health and the environment. The Board has been given little
specificity as to how the technology will integrated into the Agency's efforts. The focus seems to
be more on the data collection and archiving systems and less on disseminating the information
across the Agency or building a clientele for their results.
The SAB believes that cuts in the Climate Change program will impact the effectiveness
of the modest EPA piece of the GEOSS program. The Societal benefits identified in regard to
water, weather, climate and human health identified in GEOSS will be integral to the science in
the Climate Change program. Thus while EPA is a minor player in terms of funding GEOSS,
the unique role that EPA has [contaminant sources, discharges to water, transport, exposure and
health impacts] suggests that these cuts will place EPA at a scientific disadvantage nationally
and more importantly internationally (as this is developing as a global endeavor). In addition,
this will impede the realization of the societal benefits in regard to water quality and health.
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7. HOMELAND SECURITY RESEARCH
7.1. Background Information on the Program
Budget and Components: EPA documents available to the SAB indicate that during FY
2007, EPA proposes to allocate some $184 million to activities in support of its total U.S.
Homeland Security effort. This total investment increases by about $55 million from FY 2006
to 2007. Of this increase, some $33 million is in the S&T account for the EPA Office of Water
and $9 million is in the S&T account of the EPA Office of Research and Development. The
total Homeland Security resource is allocated across five Program/Projects as follows (amounts
shown are in the aggregate of all accounts funding the work):
i. Homeland Security: Critical Infrastructure Protection - $54 M
ii. Homeland Security: Preparedness, Response, and Recovery - $98 M
iii. Homeland Security: Protection of EPA Personnel/Infrastructure - $20 M
iv. Homeland Security: Communication and Information - $7 M
v. Categorical Grants: Homeland Security - $5 M
Themes: The predominant theme in the EPA Homeland Security program is the conduct
of research and operations to better prepare the Agency to deal with emergencies associated with
intentional releases of chemical, biological, and/or radiological agents. Most of EPA's offices
are working on Homeland Security issues, among them the Office of Water, Office of Air and
Radiation, Office of Research and Development, the Office of Solid Waste and Emergency
Response, the Office of Prevention, Pesticides and Toxic Substances, and the Office of
Administration and Resource Management. Efforts include the development, enhancement, and
deployment of monitoring networks, data systems, and laboratory capacity to allow EPA to
detect releases of agents and/or determine the levels and risk associated with released agents.
EPA is also working to protect water infrastructure, evaluating and developing decontamination
technologies, preparing responders to respond, assessing the efficacy of antimicrobial agents,
and determining clean up guidelines for high priority agents. Two of these, Critical
Infrastructure Protection and the Preparedness, Response and Recover Program/Projectsare
further summarized and commented upon below.
7.2. The Critical Infrastructure Protection Program
EPA documents available to the SAB indicate that the Critical Infrastructure Protection
Program aims are to lead and support state and water utility efforts to secure their water
infrastructure from terrorist threats and other intentional harm. The overall program budget for
FY 2007 is approximately $54 million. Approximately $45 million of this is S&T (an expansion
of funding of about $33 million S&T from FY 2006). This program supports the water sector by
implementing protective measures directly and by improving such measures through an
expanding pilot program known as WaterSentinel. Homeland Security Presidential Directive-7
"... designates EPA as the Sector-Specific Agency 'responsible for infrastructure protection
activities' for the water sector (drinking water and wastewater utilities)." "HSPD-9 directs EPA
to develop a 'robust, comprehensive, and fully coordinated surveillance and monitoring system'
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for drinking water and a water laboratory network that would support water surveillance and
emergency response activities. The overall goal of Water Sentinel is to design and demonstrate
an effective system for timely detection and appropriate response to drinking water
contamination threats and incidents through a pilot program that would have broad application to
the nation's drinking water utilities." The WaterSentinel program provides the context for some
of the research and development activities that are to be conducted by the Office of Research and
development during 2007 and which are discussed in the next section of this report.
In FY 2007 EPA will expand the number and diversity of pilot projects initiated in the
U.S. The pilots will integrate information from contaminant-specific sampling and laboratory
analysis, on-line water quality monitoring, public health surveillance, customer complaints, and
physical security to form a comprehensive contamination warning system. The WaterSentinel
program is intended to prove the concept of an effective contamination warning system, so that
drinking water utilities of all sizes and characteristics can adopt such a system. EPA will also
provide critical tools, training, and exercises that will help utilities detect, prevent, and respond
to threats. This program is largely implemented by the Office of Water with some support from
the Office of Research and Development in at least the training aspect. It is not clear how much
ORD involvement is planned for this program. Some of this work appears to have operational
components, though the extent is not clear from the information available to the SAB.
7.3. Preparedness, Response, and Recovery
EPA documents available to the SAB indicate that the goal of this program is to increase
the Agency's preparedness, and its response and recovery capabilities for homeland security
incidents involving chemical, biological or radiological threats through the conduct of research,
development, and technical support activities. The total budget for ORD in this Program/Project
is about $40 million with most coming from the S&T account and $2.0 million from the
Superfund account.
Efforts in this program project are intended to increase EPA's knowledge of potential
threats and its response capabilities by assembling and evaluating private sector tools and
capabilities so that preferred response approaches can be identified and evaluated for future use
by first responders, decision makers, and the public. There is a substantial collaborative nature
to this program among EPA and other Federal institutions. EPA intends to focus its own
activities on topics were EPA has unique knowledge and expertise.
It appears that much of the work in the Program/Project could at least indirectly supports
the work within the Critical Infrastructure Program/Project summarized above. The
Program/Project is broken into areas of National Homeland Security Research Center (NHSRC),
Radiation Monitoring, and Biodefense.
1) National Homeland Security Research Center:
The NHSRC oversees research in preparedness, risk assessment, detection, containment,
decontamination, and disposal associated with chemical, biological, and radiological
attacks. The NHSRC work supports responsibilities assigned in HSPDs 7, 9, and 10.
Specific programs address the following areas:
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- Water infrastructure protection research directly supports the CIP by
developing, testing, demonstrating, communicating and implementing enhanced
methods for detection, treatment, and containment of biological and chemical
warfare agents; certain radiological contaminants; and bulk industrial chemicals.
- Threat and Consequence Assessment focuses on risk assessment of
decontamination byproducts, refining toxicology databases, developing
fate/transport/dispersion/exposure parameters, and develop computer-based tools
to aid decision makers in assessing risks from biological and chemical attacks and
determining cleanup and/or guidance goals.
- Standardized Analytical Methods (SAM) efforts will expand the SAM document
for Homeland Security and include development, validation, and testing of non-
standard methods and additional methods for chemicals/biologicals/radiologicals
in new matrices. Efforts also establish an applied measurement science research
program to administer the activities of a national laboratory network that will
manage methods development, validation, and application for contaminants
resulting from terrorist attacks. This work appears to support the WaterSentinel
program though it could also support other parts of EPA's Homeland Security
program.
- Decontamination Systems efforts will do critical research to improve
decontamination methods, and develop new ones for new contaminants in
buildings/large structures/outdoor areas. Field studies will also be conducted to
validate decontamination methods for anthrax. Efforts will also continue to
develop decontamination methods for building materials
- Risk Characterization for Bio-Contaminants evaluates toxicity, infectivity, and
mode of action for biological contaminants in order to develop dose-response
information for cleanup guidelines. Technologies for in situ management of
crops/animal carcasses contaminated with agents will also be evaluated..
2) Radiation Monitoring:
EPA is responsible for maintenance and enhancement of the RadNet monitoring Network
(previously known as ERAMS). EPA is responsible for personnel and asset readiness for
radiological emergency responses and it will participate in responses and provide
technical support. EPA will upgrade RadNet to get near real-time information to support
decision making and build upon work already begun to augment EPA's existing applied
science radiological labs to meet emerging Homeland Security needs and to serve as the
EPA radiological reference lab.
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3) Biodefense:
Efforts will continue to develop and validate methods for evaluating the efficacy of
products employed against bioterrorism agents; address gaps in efficacy testing
knowledge and knowledge of microbial resistance; begin to address viruses and emerging
pathogens; and propose the development and evaluation of efficacy test protocols for
products designed to control viruses during decontamination.
7.4. SAB Comments
The SAB considered these issues in two ways. The first was in a recent 2006 SAB
Homeland Security Advisory Committee meeting during which the SAB held an official
consultation with EPA representatives on the WaterSentinel and Standard Analytical Methods
programs associated with Homeland Security. That meeting was held as a closed meeting
because it discussed aspects of the program that are considered to be sensitive in nature.
Remarks that follow in this budget report reflect publicly available documentation from that
meeting as well as additional open discussions between SAB members and EPA representatives
during the Board's advisory meeting on the EPA research budget for FY 2007 (i.e., the SAB
March 2-3, 2006 meeting) which did not involve sensitive information.
WaterSentinel Strategy and Priorities. The SAB is not able to comment on the
underlying strategy, in terms of the allocation of resources to specific threats or approaches to
address specific threats. Those strategic directions reflect determinations made largely outside
of EPA, and they are at least partially based on sensitive information. As a result, the SAB
cannot offer any opinion regarding whether any program passes a cost-benefit test (i.e., is it
worth doing at all). We could only address the cost-effectiveness test, regarding how allocated
resources are invested.
It is often the case that as programs begin to address critical issues with near-term needs,
such as the development of technologies to monitor and respond to identified threats, they focus
on adapting existing technologies to the new situation. While this is deemed to be a reasonable
tactic, it can often have unintended consequences. For example, it could result in developing a
technology that turns out to be useable only by highly specialized laboratories and persons with
expertise far above that likely to be available in the new area of application. Thus, we are
concerned that EPA might be investing in techniques that will not be useful to laboratories near
an attack, at times when rapid response is essential. Even if some specialized laboratory
equipment and personnel are available, the capacity for large throughput of many analyses may
not be. The materials made available to the SAB did not allow it to make a confident assessment
that a systems analysis had been conducted and produced a satisfactory result that provided
guidance to EPA's currently planned activities in this area.
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The SAB has commented over the last two years about the lack of significant investments
in organizational or behavioral science. Behavioral science activity will be necessary as part of
any Agency systematic evaluation of technology needs in this program. These issues go beyond
just the physical sciences that are used in developing technologies and they include such issues
as usability, first responder training and protection, decision rules for acting on signals from
sensors (embedded in their social, political, economic context), risk communication, recovery,
and acceptability of decontamination standards. EPA's program managers have stated to the
SAB that these issues are not intended to be a focus of EPA's program. The SAB believes that
EPA is aware of these issues, and that staff does the best that they can to address them in
practical matters of design; however, that means relying on professional judgment, typically with
professionals trained in other disciplines. The SAB has serious concerns about the threat to
system design posed by this lack of the necessary behavioral sciences base.
The SAB understands the need for security that surrounds the Homeland Security
program across government. Those needs are important and valid. However, the SAB is
concerned with the lack of transparency in some aspects of the Homeland Security program. An
example of such an issue is related to the "usability" issue discussed immediately above. During
the March 2, 2006 discussions, the SAB questions concerning whether the products of this
research would be publicly available were met with ambiguous statements. It is the SAB's
opinion that much of the homeland security research would benefit from public input and
participation, which would necessitate open discussion. Part of the need for the behavioral
science activities noted above play out in the area of restoring public confidence in the ability of
government to handle emergencies, whether natural, accidental, or intentionally triggered by a
terrorist is essential to obtaining public cooperation. A strong investment in the social science
component of homeland security projects will be of tremendous benefit to the Agency. For the
FY2008 budget, the SAB hopes to see this aspect integrated into the Agency program.
Resource impacts to other programs. The SAB was concerned about potential impacts
associated with the growth of the EPA Homeland Security program because of the substantial
increase in its budget for FY 2007. The SAB was concerned that this growth in the budget
reflected a redirection of funds from other critical EPA research activities including its important
research on hazards other than terrorism (e.g., ecosystem protection, watershed preservation,
economic evaluation of non-market goods). In addition to the SAB's concerns about the EPA
research budget erosion over the last several years, the SAB has also observed a trend and
preference for funding short term applied research over research that has a longer time horizon.
It appers to the SAB that this shift toward short-term activities is being facilitated by the lack of
appropriate procedures for measuring benefits of longer-term, core research programs.
Homeland Security, with its urgency and perceived immediate need for concrete research and
developmental products, appears to be exacerbating this trend to displace programs like
ecological research or research fellowships that produce more diffuse results (even though those
results are critical to the nation's human health and environmentl goals). Agency staff assured
the SAB that there was no 'one for one trading" of longer term research focused on traditional
EPA topics for shorter term applied research. Even so, it seems that this has been the practical
result of increased funding for Homeland Security. A large portion of the increase in Homeland
Security activities for FY 2007 under the S&T account (approximately $42 million) had to come
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at the expense of other traditional S&T activities). Though tradeoffs were not explicitly made,
they seem to have occurred.
Beyond just the notion of the need for a balance in longer term core research with shorter
term problem driven research in ORD's program, is the notion that research funds should be
applied to research and not to operations. This was stated in the SAB's report on the FY 2006
budget and it continues to be the case. It is of course difficult to assign parts of EPA's research
program to core vs. problem-driven research categories. Further, at EPA it is possible that
results from core research rapidly move to the applied arena because of EPA's need for data for
use in decision making. However, it appears that core research is declining rapidly. Over the last
several years, the SAB has observed that core research occupied some 50 to 60 % of ORD's
budget. Now, it is closer to 30% core and 70% problem driven research. The SAB recommends
that the EPA budget office adopt a transparent scheme for categorizing individual projects in
terms of where they fall on the continuum for core research to operating the products, methods,
and processes that are the product of research and development. We suggest considering the
scheme proposed in the report of the committee chaired by Frank Press, former President of the
National Academy of Science (NAS 19953).
There is a further concern, then, when the SAB considers the general nature of research
that goes beyond the core vs. problem driven issue. That is, many research programs transition
into operating programs in the fast paced issues that EPA must address. The SAB has a
longstanding concern for the former and a growing concern with the latter - funding operations
with research funds. Many of the activities within the CIP appear to be at least transitional
activities toward a routine operating program, if not frank operating programs themselves. It
also appears that some of the activities within ORD's PR&R research and development program
that supports the CIP, could also be operational. If that is correct, the SAB would be concerned
that the trend toward diverting long-term research support to short-term applications support
might finally be reaching its extreme and shifting research resources to operating programs
which is the province of EPA's program offices which have funds that are appropriated for those
purposes. As mentioned, the SAB is also concerned that the Homeland Security budget is itself
disproportionately weighted toward short-term solutions, using existing technology, despite
being a domain where the technology is changing rapidly and the threats may change as well.
Exacerbating the issues raised just above about including operational activities within a
Science and Technology account is the clear recognition that some of the Homeland Security
projects have equipment purchases in the first year. The SAB cautions the agency to consider
the continuing costs, for equipment calibration, maintenance, and for training of individuals to
use the equipment. With emergency response functions, there is a tendency to conduct one
initial round of training, but if there are no opportunities to put the training into practice, skills
deteriorate. Stable and predictable funding is needed for these homeland security projects so the
equipment will be operable and there will be individuals skilled in using it when the need arises.
The Agency also assured the SAB that an "all hazards" approach was embraced which would
guarantee the use of the equipment and skills for natural disasters, as well as for terrorist
incidents. The continuing need for operational funding to support these activities will only
3 NAS. 1995. Allocating Federal Funds for Science and Technology. National Academy Press. 1995. Frank Press,
Chair.
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further exert pressure on the budget process to continue to shift funds from basic to applied
research and thence to operations. Stable and predictable funding suggests long-term
commitments. This deviates from the defined role of "research" and moves to a program area.
There is serious concern that, once developed, these technologies will become the
operational responsibility of the program that develops them. That will reduce the Agency's
capacity for future innovation, in an arena where the science is advancing and the threats may
change. Three measures that could address this concern: (a) Explicit Agency commitment to
transition, (b) research into usability (at the operation, organizational, and institutional levels),
ensuring that transition is feasible; and (c) budgeting that explicitly characterized the research
and development stage of specific projects. A proposal for (c), endorsed by the National
Research Council can be found in Allocating Federal Funds for Science and Technology (see
footnote 3).
It appears tht the Homeland Security portfolio has not been subject to PART review. If
PART is viewed as a critical evaluative tool, it would be sound administrative policy to make it
central to these new programs as early as possible in their development.
The SAB has several additional comments to offer about the efforts in this area. These
include issues of dual application of research; program integration; local community
involvement; compliance; and collaboration.
Dual Use of Research Results: The SAB sees a number of opportunities for the
integration of projects which were initially funded and designed for homeland security purposes,
to application in the regular goal areas of the agency. In particular, the monitoring systems such
as WaterSentinel, RadNet, and Biowatch, the dispersion modeling, fate and transport modeling,
analytical techniques, decontamination methods, and disposal options can be useful in the
regular goal areas of the EPA.
Program Integration: A key component in the Critical Infrastructure and Preparedness,
Response and Recovery programs is integration of systems. It is difficult to get a clear picture of
the integration of functions across time frames and operating agencies (e.g., water utilities of
different sizes). Although EPA staff expressed an all-hazards perspective, it is hard to see from
the planning documents. An organizational science question is how to integrate new systems
with existing operations, in order to ensure that they are properly used and exercised, so that they
are not expected to attain peak performance the first time that they are used.
Local Community Involvement: The programs have not obviously budgeted for research
ensuring their integration with local communities, environmental justice, etc. These will be
critical for decontamination, among other things. There is no obvious consideration of impacts
of contamination on ecosystems and their role in food supplies, amenities, etc.
Compliance and stewardship. Although the programs have some operational connections
with government and industry, these are treated as matters of practice, rather than science. There
is not an obvious place for understanding the impacts of changes on reporting, inspection, etc.,
on the prevention and detection of attacks.
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Collaboration: The SAB hasbeen told that there is good communication and coordination
among EPA, Department of Homeland Security, and other federal agencies. For the EPA's four
major areas of direct responsibility, there appears to be no duplication of effort. In fact, if the
EPA does not receive full funding for these research areas (water infrastructure,
decontamination/disposal, chemical/biological detection and laboratory capacity, and
establishment of risk-informed clean-up levels, significant gaps in national preparedness will be
left.
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8. ECONOMICS, DECISION SCIENCES, AND SUSTAINABILITY
8.1. Economics and Decision Sciences
Economics and Decision Sciences Research (EDS) is designed to improve our
understanding of human and organizational environmental behavior. Since its inception, this
program has contributed many articles to the literature on this behavior and thus supported
policy-making at both the Federal and State levels. Research is guided by the Environmental
Economics Research Strategy that outlines the research needs and priorities in this area. The
program is proposed to receive $2.5 million in FY 2007 a small increase from 2006. The EDS
program is a part of EPA's Goal 5 program area of Sustainability which seeks to minimize or
eliminate environmental liabilities, integrate management of problems across media; and change
traditional methods of creating and distributing goods and services.
In FY 2007 EDS research will focus on three long-term goals: identifying and reducing
uncertainties and potential biases associated with benefits transfer methods; improving our
understanding of decision making with respect to compliance behavior and environmental
performance in response to interventions; and identifying regulated entities response to market
mechanisms and incentives. Benefits transfer research will work toward methodological
advances on existing datasets and thus enable faster attainment of results. Research will be
conducted to help design practical trading programs for local and new markets (e.g., water
quality trading programs; pesticide trading; and local air pollution trading programs).
Research will be carried out through STAR EDS Requests for Applications as well as
other activities.
SAB comments on this area are summarized below and expanded upon in the following
sections.
• The scope of Economics and Decision Sciences seems not to be fully appreciated in the
EDS section of the budget information given that component issues of this area are
pervasive across almost all other categories in the budget justification (e.g., 66 quotes can
be extracted from other categories of the budget justification document that refer to
economics and decision sciences issues).
• The resources of the National Center for Environmental Economics are increasingly
strained by the requirement that all "large" regulations be subjected to a benefit-cost
analysis, whenever such an assessment is requested. In addition, the ORD STAR is
inadequately funded to cover all basic research needs in Economics and Decision
Sciences. As a consequence, the STAR program for economics has been unable to offer
funding to a full complement of RFAs in each cycle (some have been skipped).
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• It is inappropriate to categorize practical exercises in benefit-cost analyses, especially
those based solely on benefit-transfer methods, as "basic research." Benefits transfer will
continue to be necessary, however, so basic research that will actually broaden the
inventory of available benefits estimates/functions for use in benefits transfer is essential.
Research on how to do benefits transfer is not a substitute for research on benefits, since
the existing inventory of benefits is not yet sufficiently comprehensive.
• Data, especially for longitudinal analyses, are critical to researchers in Economics and
Decision Sciences—i.e. the TRI and the PACE data must be maintained; there are also
many smaller and unique datasets (some of which have been funded by the EPA) that
could be archived in a form that makes them more widely available.
• Economics and Decision Sciences within the Agency continues to be hampered by a
long-standing emphasis on risk assessment and safe minimum standards as endpoints.
These approaches do not necessarily provide information in a form that is useful for
benefit-cost analysis.
• Risk communication and an understanding of public risk perceptions are critical to the
Agency's mission and these topics require expertise beyond the purview of
environmental economists and decision scientists. Other social science disciplines have
expertise in these areas, yet they remain under-represented and underutilized in the
Agency's research portfolio.
1) Pervasiveness of Economics and Decision Sciences: Economics and decision science
are more pervasive across the Agency's Science and Technology programs than many people
may realize. Among the 32 other sub-categories of the budget justification, beyond the
document's very limited 2.5 page discussion devoted specifically to the topic of "Research:
Economics and Decision Sciences (EDS)," at least 66 different discussions of
economic/decision-science issues can be found.
The only portion of the Agency's Economic and Decision Sciences activity that is officially
funded as part of the S&T budget is the STAR grants (extramural) program. Given how
pervasive economics and decision sciences issues are, across all of the Agencies science
activities, it is unreasonable to expect that extramural research can completely fulfill the
Agency's needs in this area. As in other disciplines, the Agency has internal expertise in
Economics, collected within the National Center for Environmental Economics. While these
researchers represent a pool of expertise for basic research, it appears that their energies are
devoted mostly to benefit-cost analysis for other units within the Agency.
2) NCEE Staff Involvement in OMB-Required Benefit-Cost Analysis: The resources of
NCEE are increasingly strained by the requirement that all "large" regulations be subjected to a
benefit-cost analysis. The SAB finds it appropriate that the Agency should be able to
demonstrate that its policies and activities produce improvements in net social benefits.
However, an increasingly large share of NCEE staff seems to be is devoted to reviewing or
assisting with economic analyses for other programs within the Agency (e.g. over 20 economic
analyses were dealt with in the last year). These benefit-cost analyses increasingly rely upon
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benefits transfer, which typically amounts to the application of existing research, rather than the
undertaking of new research. Basic research under the S&T budget amounts solely to the STAR
grant program.
3) Benefits Transfer: In the past, basic (and very expensive) research concerning society's
willingness to pay for improved environmental quality in some contexts was occasionally
stimulated by large legal cases. Now, in the face of restricted budgets, the Agency is often
forced to rely on benefits transfer, i.e., to assess benefits essentially by using interpolation or
extrapolation methods, based on an existing inventory of benefits estimates. This strategy may
be viable for some types of human health effects (e.g. sudden mortality from accidents).
However, existing research that covers a wide range of risks, with different latencies, that affect
a wide range of subpopulations, is still sparse. Even more problematic are the challenges
involved in measuring ecosystems benefits. Ecosystems are far more heterogeneous than
humans and there is not much depth at all in the inventory of established and robustly measured
values for ecosystems endpoints. The Agency will need to continue to fund basic research in
both human health and ecosystem benefits.
4) Data for Research in Economics and Decision Sciences: The development and
maintenance of crucial environmental data sets for cross-sectional and longitudinal analysis is
fundamental to research in Economics and Decisions Sciences. At least three data-related issues
deserve attention:
a) The Pollution Abatement and Control Expenditures (PACE) survey. Several years
ago, the Environmental Economics Advisory Committee argued that the EPA should step
in to reinstate the PACE survey. (The Bureau of the Census had discontinued the
collection of these data.) NCEE's budget for FY06 apparently includes $650K for the
PACE survey, and significant expenditure for this item will continue. The PACE is the
main source of data related to the costs of environmental regulation. The SAB notes that
other data collection activities are not charged against the "research" budget of the
Agency.
The PACE data represents a large share of the budget for the NCEE. It may be necessary
to demonstrate that this expenditure is justified by the nature and results from the
research that uses it. Should this program be subjected to a PART analysis, it will be
useful for the Agency to be queuing up some appropriate "outcome" measures that
document the social value of the PACE data.
b) The Toxics Release Inventory (TRI). The TRI represents a very important public
good, not just to communities under EPCRA, but also to intra- and extramural
Economics and Decision Sciences researchers concerned with the causes and
consequences of such releases. Recent proposals involve changes in TRI reporting
requirements, including changes in which firms will report and what they will report, as
well as a plan to cut back from annual to bi-annual reporting. These changes (the
proposed "Toxics Release Inventory (TRI) Burden Reduction Proposed Rule") would
jeopardize the value of this database for longitudinal research. The SAB shares the
concern of its Environmental Economics Advisory Committee (EEAC) that substantive
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changes in reporting requirements for the TRI have the potential to seriously compromise
its usefulness for longitudinal analyses. Maintenance of databases that support a
significant category of research in Economics and Decision Sciences should be a
significant concern for the Agency. However, it is not clear that funding to preserve
collection of these data should be allocated away from basic research activities.
c.) Preservation and distribution of various unique data sets. EPA-funded research in
economics and decision science often creates specialized data unique to each study.
Funding should be made available so that it would be possible to further develop these
original data sets so that they are widely accessible and useful for replication or for new
studies. There is presently no requirement that Agency-funded data collection be made
publicly available, and no incentive for individual researchers to do so. The only grant-
related requirement is that the Agency be provided with a plan to make the data available.
SAB Economists have argued that it would be appropriate for the Agency to assist in
establishing a national clearinghouse for specialized data relevant for environmental
economics and decision analysis. The Inter-university Consortium for Political and
Social Research (ICPSR) Archive housed at Michigan might perhaps be an appropriate
home for these data. EPA-funded data, in particular, represent public goods that could
sometimes be exploited much more thoroughly in many cases. Like the major databases
that have traditionally been widely used by labor economists—for example, the Panel
Study on Income Dynamics (PSID), the National Longitudinal Survey (NLS), and the
Health and Retirement Survey (HRS)—the existence of accessible and well-documented
environmental databases could do much to foster more environmental economic research
without incurring large fixed costs for data every time.
5) STAR Program RFA's: The SAB notes that the Agency has lately been forced to
skip some of its three regular RFAs in the Economics and Decision Sciences area. In its review
of the budget last year, the SAB noted the Agency's interest in reliance upon voluntary programs
but emphasized that our understanding of the potential for success of these programs was still
limited. The SAB called for more research into incentives and constraints. This year,
approximately one-quarter of current STAR funding for Economics could be characterized as
research to increasing our understanding of "voluntary programs" (i.e. programs that do not
involve Agency enforcement).
In response to the President's FY06 budget, the SAB also called for the Agency to spend
more of its own research money to conduct research on market mechanisms and incentives
directed at pollution prevention. There has been no RFA for Market Mechanisms and Incentives
(MMI) since 2003. For FY 2007, STAR programs appear to devote about $1 million for
research on trading programs and about $1 million for benefits transfer studies. Additional
money to support extramural research could go a long way towards supporting the basic research
needs of the Agency.
6) Risk Assessment versus Benefit-Cost Assessment: It must be noted that the Agency
has traditionally been far more concerned with risk assessment (predicting the sizes of existing
risks and the risk reductions to be expected from environmental policies) than with
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understanding the social values of risk reductions and thus society's willingness to pay for
environmental management. Unfortunately, traditions change only slowly. At present, it seems
that these traditions are definitely not changing quickly enough to keep up with the demands for
benefit-cost assessments.
7) Risk Communication and Risk Perceptions: Social science research and genuinely
interdisciplinary efforts that span multiple social sciences and integrate with physical and life
sciences continue to be under-funded and under-utilized. Before a society is willing to incur the
costs associated with environmental risk reductions, its members must recognize, understand and
appreciate the risks in question. Much of the risk perception and risk communication research
upon which the Agency currently relies predates the Internet Age. Risk communication has
changed dramatically with this new technology. The relevant disciplines include more than just
Economics and Decision Sciences. Also relevant are other behavioral and cognitive sciences,
including (but not limited to) psychology, sociology, and anthropology. Information—how it is
perceived, processed, and utilized—is critical to an understanding of social preferences and
choices with respect to environmental policies.
While EPA enjoys reasonable staff expertise in the areas of economics and decision
science, it has far less capability in the area of behavioral social science. The SAB has noted this
gap on a number of occasions in the past (and in the discussion above of the new programs in
Homeland Security). The Agency needs to continue to work to find ways to fill this gap, both
with new staff and through external collaborations (such as the now defunct collaborative
research program that was conducted with the National Science Foundation (NSF-DRMS).
8.2. Sustainability Research
EPA has considered sustainable and preventive approaches to health and environmental
problems since the Pollution Prevention Act of 1990. Sustainable approaches require innovative
design and production techniques that minimize or eliminate environmental liabilities; integrated
management of air, water, and land resources; and changes in the traditional methods of creating
and distributing goods and services. The defining characteristic of sustainability research is the
need to evaluate impacts of the flows of material and energy on future generations, a practice
that has not been a common feature of past societal and industrial development. In addition to
conducting research related to human health and environmental threats, EPA is committed to
promoting sustainability—achieving economic prosperity while protecting natural systems and
quality of life. The Sustainability research program is proposed to receive about $21 million in
FY 2007 (a decrease of about $4 million from 2006 levels).
Specific areas of sustainability research include:
Pollution Prevention Tools for improved environmental decision making (e.g., P2 Tools
will develop Life Cycle Impact Assessment analytical techniques that are cost effective
and take less time and provide high priority life cycle benchmark data).
Small Business Innovation Research (SBIR) Programs that develop and
commercialize new environmental technologies.
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National Environmental Technology Competition that funds a student competition to
develop solutions to sustainability challenges.
Sustainable Environmental Systems research to develop methodologies for
understanding and managing large, complex environmental systems such as metropolitan
areas and watersheds.
This program emerged from the former "Pollution Prevention and Technology for a
Sustainable Future" program. The topic is of great importance, and research on technology for
sustainability creates opportunities for reducing pollution, reducing costs, and increasing
economic competitiveness. Technological innovation has the potential to provide substantial
environmental and economic gains. By working with major industrial partners and by
addressing new designs, technologies and processes, we can avoid problems before they start.
Sustainability research offers the opportunity to take a strategic approach to environmental
protection which should also help to improve the international competitive position of U.S.
industry involved in "green" technology. Research in this area needs to become a priority for
EPA.
The Board stated in the "Technology" section earlier in this report, that the goals and
objectives of the Resource Conservation Challenge are consistent with the EPA's Sustainability
Research Program. The SAB will soon review EPA's Sustainability Research Strategy and the
Board will have more to say on it in the future. However, we believe that among the important
topics to include in a sustainability program would be things such as: re-engineering processes,
research on the implications of new products for commerce, and the need to provide meaningful
incentives for maintaining and improving environmental performance. The SAB believes that it
is possible to articulate—RCC and sustainability research budgets, strategies, and plans in a way
that shows their relationships, and their individual focus, e.g., the RCC might provide the basis
for the kinds of research needed as drawn from connections with EPA's partners, and
Sustainability research might focus on using the best and most appropriate tools. The RCC
would then serve the dual purpose of mining information from its partners for relevant research
needs, and then to the extent possible transferring the results of Sustainability research efforts to
the field.
A small-business focus is appropriate, but EPA should also give major attention to
leveraging EPA's efforts with major industrial partners, and with emerging technology
companies. The current emphasis appears to stress recycling at the local level, which is
important, but does not appear to address the increasing globalization of economies, industrial
design, and the evolution of main-stream industrial processes.
During the discussions with EPA, and in the documents and presentations provided to the
SAB, there seemed to be no sense of urgency or high priority associated with this program.
A revised program, once designed and in its initial stages, could be subject to PART review
as noted in the "Technology" section of this report; so that it could be used as a tool for program
design and documentation, as well as post-hoc evaluation.
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9. STAR FELLOWSHIPS
The Agency acknowledges the importance of the "White House Report 'Science for the 21st
Century" that articulates the Administration's top priorities for maintining and enhancing the
scientific enterprise of the nation. The Office of Research and Development has for the majority
of the past decade pursued the goals of this report through the Graduate Research Fellowship
Program of its Science to Achieve Results (STAR) efforts. This program awards fellowships to
leading science graduate students throughout the United States. However, the agency has
identified the STAR Graduate Fellowship program as an area for declines in each of the last
several years's budgets. The program has been funded at nearly $9.5 million from 2004 through
2006, mostly because the Congress has increased the requested levels each year. Again, EPA
proposes the lowered level of $5.9 million for the Fellowships program.
The Agency's adoption of the White House goals for education and workforce development
can not be met with the level of resources requested for this program. Even at a full funding
level of $10 million, the program would not meet the full need. At the requested level this
deficiency is even bigger. This is inconsistent with the articulated goals, and nearsighted in view
of EPA's looming loss of an aging population of scientists to retirement. The Board
recommends that the STAR Graduate Fellowships program be restored to its full funding level of
$10 million.
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ATTACHMENT A: STATEMENT OF DR. M. GRANGER MORGAN, CHAIR
U.S. ENVIRONMENTAL PROTECTION AGENCY SCIENCE ADVISORY BOARD
BEFORE THE SUBCOMMITTEE ON ENVIRONMENT, TECHNOLOGY AND
STANDARDS COMMITTEE ON SCIENCE, U.S. HOUSE OF REPRESENTATIVES
MARCH 16, 2006
Good morning Mr. Chairman and members of the Subcommittee on Environment,
Technology and Standards. My name is Granger Morgan. I chair EPA's Science Advisory Board
(SAB or Board). I am a faculty member at Carnegie Mellon University where I am a University
Professor, hold the Lord Chaired Professorship in Engineering, and am Head of the Department
of Engineering and Public Policy, a department in the Engineering College.
Thank you for this opportunity to present the SAB's views about the Agency's 2007
Science and Research Budget Request. The Board is completing approval of its final report, and
with the permission of the Chairman, we will submit that report for the record.
Over the past few years, the Board has been working with EPA to review the Agency's
science and research programs and budget on a systematic and ongoing basis. The Agency now
presents that information to the Board in ways that correlate with EPA's Strategic Plan.
Between 2004 and the proposal for 2007, the inflation adjusted4 budget for EPA's Office
of Research and Development has declined by just over 16%. Yet, the environmental challenges
that face the Agency have grown and EPA will face increasingly complex and difficult science
challenges over the coming decades. It will also face opportunities to improve our
environmental and international competitiveness with new technologies - but, to paraphrase the
microbiologist Louis Pasteur, opportunity favors those who are prepared.
We all want environmental decision-making to be based on sound science. However, our
nation is not investing adequately in producing that sound science.
I know a number of people who argue that this lack of investment reflects a hope that if
the science is not there, somehow additional regulation will not follow. A much more likely
outcome is that, if we don't do the needed research we will simply get poorer regulation - which
could end up costing the nation a great deal more in the long run.
In my view we all need to work harder on explaining the importance of investing in R&D
at EPA if we want to ensure that America will enjoy a clean, safe, healthy and sustainable
environment in the years to come.
You have specifically asked if the Agency's overall level of Science and Technology
funding is appropriate and whether its research priorities are adequately balanced among core
research, mission-driven research, emerging issues, and homeland security. I will elaborate
below, but the short answer is no.
4 Computed using the NASA Gross Domestic Product Deflator Inflation Calculator, available at
http://cost.jsc.nasa.gov/inflateGDP.html
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You have also asked what impacts the proposed budget reduction may have on the Office
of Research and Development's ability to use the latest scientific methods and information in its
regulatory decisions, and to build strong ties to the external scientific research community and
foster graduate student work in the environmental sciences. Again, while I'll elaborate below, the
short answer is these impacts will be serious and negative.
In the discussion below I elaborate on these, and related points, in three contexts:
1. The need for government-wide, systematic tracking of environmental research;
2. Some specific aspects of EPA's proposed 2007 research budget; and
3. The critical problem of continuing reductions in long-term, more fundamental
environmental research at EPA.
1. Need for a Government-wide View of Environmental Research and Development
EPA is not the only federal agency that collects environmental data or performs
environmental research. The Departments of Agriculture, Energy, Homeland Security, and
Interior, as well as the CDC, NASA, NIEHS, NIH, NSF, USGS, and a number of other Federal
entities all make significant contributions. Some of these organizations work on topics that may
sound similar; in many cases the details turn out to be different in important ways.
In many specific areas of research, there are examples of excellent coordination and
cooperation between some of these programs.
But today, across the Federal system as a whole, it is virtually impossible to develop an
informed understanding of what research is being done; where it is being done; where there are
duplications; and where there are critical gaps. A simple list of topics is not sufficient. Just
because the same noun appears in two agency lists of research topics does not mean that they are
doing the same thing, or that there is duplication.
Before we on the Science Advisory Board, or you in the Congress, can hope to determine
if the U.S. has a balanced and comprehensive national strategy for environmental research, we
need a clear picture of what is being done in the form of concise substantive descriptions of all
the environmental research programs across the federal system. Conceivably, things could be
better than they look from the isolated EPA's budgetary perspective. I suspect that they are
worse. However, we need a comprehensive picture.
I urge the Committee to work with the executive and independent agencies to realize the
development of such a comprehensive description of all our nation's environmental research.
Such a summary would assist everyone involved in ensuring: that needed federal environmental
research is being done efficiently; that the different federal agencies involved are sharing
information; and that the results are readily accessible to the scientific community, the public,
and environmental decision-makers.
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2. Comments on Several Proposed Changes in Individual EPA Programs
Now I'd like to offer four examples of how the proposed cuts to the EPA 2007 research
budget will adversely impact the Agency's mission to protect human health and the environment
as well as offer some brief comments in response to you question about the expansion of the
Agencies program related to Homeland Security.
First, I will address mercury research. While some of the mercury in our food and water
comes from power plants and other human activities, much comes from natural sources or is
carried across the Pacific from natural and anthropogenic sources in Asia. On a global scale,
science cannot yet accurately tell us where all the mercury in the U.S. comes from, where it
goes, or in what chemical forms it exists. If we are going to be able to assess the adequacy and
effectiveness of the costly mercury controls that EPA regulation is imposing on U. S. industry,
we need to understand those planetary flows. However, last year's EPA research budget for
mercury was reduced approximately 35% to $3.4 million. This year's budget proposes only a
slight increase. Funding at these levels is too small to even adequately address the issues that
EPA-ORD has been addressing, let alone to allow any work on the key problem of planetary
flows of mercury.
A second important and undervalued area of research, that the Board is especially
concerned about is Ecology and Ecosystems Research which has been systematically cut for
several years. While we all value and marvel at the beauty and complexity of natural
ecosystems, it is easy to forget that every year these systems also provide us with billions of
dollars worth of services that are critical to our way of life.
As an example, the salt-water marshes of the Gulf Coast provide more than wildlife
habitat. They also provide protection against erosion, and they buffer the effect of storms on
coastal lands. How are we to protect such vulnerable natural systems as the salt-water marshes
of the Gulf Coast, the Great Lakes, the Chesapeake Bay, the Mississippi River Basin, and
countless other smaller natural systems in every state in the country, if we don't adequately
invest in understanding them?
The $79.2 million for ecological research in the proposed 2007 amounts to just 15% of
the overall ORD research budget. For well over a decade the Board has called on both the
Agency and the Congress to revitalize, raise the profile, and increase the funding of ecological
research at EPA. Since 2004, the Board has watched budgetary support for ecological research
decline by 26%. This is not the route to a clean and healthy future for either us, or for our air,
land and waters.
Third, I will say a word about research in human health. The SAB was delighted to see
a proposed increase of just under $3-million in Computational Toxicology. This work holds
great potential to streamline the process of assessing the safety of chemicals, speed approval of
new products, and in so doing, enhance the productivity and competitiveness of American
industry.
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However, to make effective use of these powerful new computational tools, researchers
also need data to put in the computer models. The Board is deeply troubled by proposed cuts in
human health research areas that are needed to provide the data necessary for computational
toxicology to be effective. These cuts include a proposed 13% reduction for work on endocrine
disrupters, a proposed 14% reduction for pesticides, and an increase of only 3% for other core
programs in human health research.
Finally, the Board is concerned about research in Global Change and Sustainability. For
each of the past two years, research support for global change has declined by roughly one
million dollars. The current budget proposal of $17.5 million will only allow the agency to meet
its impact assessment obligations under the government-wide Climate Change Science Program.
The Agency will be forced to terminate, in midstream, research vital to understanding ongoing
changes in temperature, precipitation, flooding, snow pack, and other factors will affect water
quality across the U.S. To our knowledge, no other federal agency is supporting such work on a
national scale.
Following $9.6 million dollar reduction in 2006, sustainability research is slated for
further reduction of $4.4 million in 2007. These reductions are coupled with the termination of
the Superfund Innovative Technology Evaluation Program and Environmental Technology
Validation Program. This means that the Agency will lose much of its ability to test and verify
new environmental technologies. This loss harms American industry's competitive position for
environmental technology in world markets, at a time when other nations treat these technologies
as opportunities.
I turn now to your questions about appropriate science priorities and needs for Homeland
Security. The proposed 2007 budget calls for an increase of almost 25% to $39.5-million for
Homeland Security research in ORD, and an increase of just under 30% to $58.1 million for
work in other parts of the Agency. These increases will support research and other activities
related to increased preparedness and better response for water security, analytical methods,
decontamination, clean-up goals, radiation monitoring and biodefense. Clearly improving our
ability to deal with terrorist and other threats is a critical national need and the SAB has been
most favorably impressed by the dedication and hard work of the staff addressing these
important national priorities. However, while all of us on the SAB agree that this is an important
area of national need, we are concerned that it not be met through serious erosion of support for
the Agency's core research needs in health and environmental research.
I would like to offer two other cautions regarding the Agency's current research program
in homeland security research. First, there is some risk of focusing too much at the level of
individual devices and sub-systems, without first understanding at a broad level such key issues
as how effective alternative approaches can hope to be in providing needed protection, and
whether the nation can afford them. Second, we are concerned that current programs are not
sufficiently informed by the behavioral and social sciences, which are crucial to effectively
organizing the complex systems needed to manage these technologies and communicating
research results and risk to the general public.
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You also asked about sole reliance on Science and Technology funding for the
WaterSentinel pilot program expansion, and if EPA has adequate plans for transit! oning
WaterSentinel to an operational program. The SAB understands the need for WaterSentinel, but
EPA's strategy for allocating resources to this program is unclear. Science and Technology
funding is probably appropriate for developing the scientific aspects of WaterSentinel, but other
aspects of the program appear to be operational. Accordingly, the SAB believes that operational
aspects of WaterSentinel should be funded by appropriate operational funds. The SAB Panel
that reviewed WaterSentinel recommended development of a plan to transition WaterSentinel
from research and development to and operational program. The SAB is concerned that
WaterSentinel funding comes at the expense of the Agency's other responsibilities.
3. Longer-term More Fundamental Research
EPA is a mission-oriented agency, charged with assuring that America enjoys, and will
continue to enjoy, a clean and healthy environment. Earlier I paraphrased Louis Pasteur. Don
Stokes, the former dean at Princeton's Woodrow Wilson School wrote a wonderful little book5
that argues that research cannot simply be sorted out along a line between basic and applied.
Some important real world problems, such as those that lead Pasteur to understand how to
preserve milk, can only be addressed by doing fundamental research that is motivated by real-
world needs. Many environmental problems fall into this category - what Stokes termed
"Pasteur's quadrant." Much of the knowledge that is needed to assure continued success in
EPA's mission requires research of this kind - research which is not being done anywhere else
across the Federal system.
In our meetings with agency research managers, we were deeply troubled when we were
told that the basic or "core" portions of ORD's research budget have shrunk from roughly 40% to
25% of current research investments. Environmental issues are complex, and often subtle. If
EPA does not continue to invest in a significant amount of basic environmental science, we will
likely find ourselves making costly regulatory mistakes in the future. We also run the risk of
paralyzing innovative industries, like nanotechnology, uncertain about the regulatory rules that
they will face.
The SAB is especially troubled by the ongoing difficulty that EPA has had with the
application of the OMB Performance Assessment Review Tool or "PART" process. My own
view is that both the agency and the OMB need to work harder to resolve this issue, especially in
the context of ecosystem research. On the one hand, OMB needs to recognize the need for a
portion of EPA's research to be fairly fundamental in nature. As I have argued above, not all
EPA research has immediate short-term applications - nor should it have. Long-term
investments in developing basic understanding of environmental and ecological science are very
important if we are to achieve sensible and efficient environmental protection. At the same time,
EPA needs to do a better job of refining and communicating several of its research programs,
especially those in ecosystem research, a topic whose importance has been stressed by both the
SAB and National Academy of Sciences. Simply continuing to cut the budget is not a viable
strategy for achieving future improvement.
5 Donald E. Stokes, Pasteur's Quadrant: Basic science and technological innovation, Brookings Institution Press,
180pp, 1997
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Looking back at the analyses that the SAB has done of EPA's science and research
budgets over the past several years, the SAB has become convinced that the Agency is in danger
of losing core scientific expertise in both conventional and emerging environmental issues. A
number of the agency's research programs are in need of major rejuvenation and modernization,
but this is almost impossible in the face of ever shrinking resources. On top of this, a significant
number of retirements is anticipated over the coming decade. If proposed cuts in the STAR
Doctoral Fellowship program are not restored, where will the next generation of U.S.
environmental scientists come from?
Thank you again for the opportunity to testify about EPA's science and research budget
request. My colleagues and I would be pleased to answer your questions.
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