UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON D.C. 20460
                                                               OFFICE OF THE ADMINISTRATOR
                                                                 SCIENCE ADVISORY BOARD
                                     June 23, 2005

EPA-SAB-ADV-05-002

The Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

       Subject:      Science and Research Budgets for the U.S. Environmental Protection
                    Agency (EPA) for Fiscal Year 2006; An Advisory Report by the EPA
                    Science Advisory Board

Dear Administrator Johnson:

       The EPA Science Advisory Board (SAB) appreciates the opportunity to review and to
provide you with advice on the EPA science and research budget for FY 2006.  Conclusions in
this report reflect a fundamental belief that effective science-based actions by EPA require a
continuing and credible investment in developing scientific knowledge, methods, and
assessments. This investment in science is important irrespective of whether management
approaches envisioned by EPA involve partnerships, market-based techniques, or command and
control regulations. Even though the FY 2006 budget has been sent to the Congress for
consideration, there is still an opportunity for the advice in this advisory to be considered and
integrated into EPA's planning efforts as EPA prepares its Fiscal Year 2007 budget request for
science. There may also be opportunities for the Agency, with the  assistance of the Congress, to
implement some critical changes as it develops its FY 2006 operating plan.  The Board would be
pleased to assist EPA as it deals with this issue by offering its services earlier in EPA's science
planning activities.

       The Board applauds EPA's strong collaborative efforts to integrate environmental
research within EPA, and to coordinate this research with that of its other Federal partners. With
the continued real-dollar erosion of EPA's science and research budget, enhancing this
integration will be critical to the successful achievement of EPA's goals.

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       The Board is generally enthusiastic about the science and research activities proposed in
this budget.  However, there are a number of issues in the FY 2006 request that concern the
Board, some of which have persisted for several years. These include:

       a) the continuing real-dollar erosion of the EPA science budget—inadequate funding of
       research will lead to greater, not reduced, regulatory burdens, and it can lead to
       significant morale problems among EPA scientists that could induce serious long-term
       problems and loss of key staff;

       b) inadequately funded anticipatory research that could help to identify and plan for the
          use of, and possible environmental hazards from, emerging technology and issues;

       c) continued reductions in the highly-regarded Science to Achieve Results (STAR)
          program, EPA's premier program for obtaining timely outside  scientific research; and

       d) continued reductions in EPA's ecological research program (STAR and other
          programs).

       In the Board's view, there are several additional issues in the FY 2006 science and
   research budget request that are noteworthy.

       a) In recent years, EPA developed a coherent economic research program and this
          appears to continue in the FY 2006 budget. EPA should adopt a similar attitude
          toward other social and behavioral sciences (e.g., risk communications, voluntary
          actions, non-market ecosystem benefits, etc.) and begin to implement them as soon as
          possible. Currently, the budget does not include a significant effort in this area.

       b) The new Pilot Project that would provide funding and other support in the Office of
          Research and Development (ORD) for certain near-term program-specific research,
          information, and development needs could be beneficial to EPA. The Board believes
          that careful consideration  should be given to the project's goals and to how EPA can
          obtain the greatest benefits from the Pilot.

       c) The Board is concerned that EPA's homeland security research needs may be drawing
          resources away from other essential EPA research programs. While the Board
          recognizes the important role EPA plays in this research area, and that some
          homeland security research may provide data and methods that are of general
          environmental interest and applicability, the level of resource allocation to these
          projects must be carefully considered in the face of declining budgets for scientific
          research and other important environmental issues.

       d) Much of the federal  climate change program occurs outside of EPA. However, many
          EPA mandates are influenced by global climate change. EPA should enhance its
          technical capacity to evaluate the links among global climate change and its mandated
          responsibilities to protect human health and the environment, and as needed to
          evaluate and manage the technologies and activities to respond to the problem (e.g.,
          deep geologic injection of carbon dioxide).

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       The Board will be pleased to expand on any of the findings described in this report and
we look forward to your response.

                                 Sincerely,
             /Signed/
           /Signed/
       Dr. M. Granger Morgan, Chair
       EPA Science Advisory Board
Dr. Genevieve Matanoski, Chair
Science and Research Advisor

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                                       NOTICE

       This report has been written as part of the activities of the EPA Science Advisory Board,
a public advisory committee providing extramural scientific information and advice to the
Administrator and other officials of the Environmental Protection Agency. The Board is
structured to provide balanced, expert assessment of scientific matters 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 or commercial products constitute a recommendation for use.
Reports of the EPA Science Advisory Board are posted on the EPA website at
http://www.epa.gov/sab.

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                     U.S. Environmental Protection Agency
                            Science Advisory Board
                     Science and Research Budget Advisory

ADVISORY CHAIR
Dr. Genevieve Matanoski, Johns Hopkins University, Baltimore, MD (also participated in the
Cross-Goal Team)

SAB MEMBERS
Cross-Goal Team:

Dr. Robert Twiss, Leader Cross-Goal Team, University of California-Berkeley, Ross, CA
Dr. Baruch Fischhoff, Carnegie Mellon University, Pittsburgh, PA
Dr. M. Granger Morgan, Chair, EPA SAB, Carnegie Mellon University, Pittsburgh, PA

Goal 1 Team:

Dr. Trudy Ann Cameron, Co-Leader Team 1, University of Oregon, Eugene, OR
Dr. Jill Lipoti, Co-Leader Team 1, New Jersey Department of Environmental Protection,
Trenton, NJ
Dr. James Galloway, University of Virginia, Charlottesville, VA
Dr. Rogene Henderson, Lovelace Respiratory Research Institute, Albuquerque, NM
Dr. Philip Hopke, Clarkson University, Potsdam, NY
Dr. David Rejeski, Woodrow Wilson International Center for Scholars, Washington, DC

Goal 2 Team:

Dr. Kenneth Dickson, Co-Leader Team 2, University of North Texas, Denton, TX
Dr. Lauren Zeise, California Environmental Protection Agency, Oakland, CA

Goal 3 Team:

Dr. Thomas Theis, Leader Team 3, University of Illinois at Chicago, Chicago, IL
Dr. A. Myrick Freeman, Bowdoin College, Brunswick, ME
Dr. Michael J. McFarland, Utah State University, River Heights, UT

Goal 4 Team:

Dr. James Bus, Co-Leader, Team 4, The Dow Chemical Company, Midland, MI
Dr. Deborah Swackhamer, Co-Leader Team 4, University of Minnesota, Minneapolis, MN
Dr. Henry Anderson, Liaison CHPAC, Wisconsin Division of Public Health, Madison, WI
Dr. George Lambert, Robert Wood Johnson Medical School/ University of Medicine and
Dentistry of New Jersey, Piscataway, NJ
Dr. Terry Young, Consultant to Environmental Defense, Oakland, CA

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Goal 5 Team:

Dr. Catherine Kling, Leader Team 5, Iowa State University, Ames, IA
Dr. Domenico Grasso, University of Vermont, Burlington, VT
Dr. Rebecca Parkin, George Washington University, Washington, DC
Dr. Kristin Shrader-Frechette, University of Notre Dame, Notre Dame, IN

SCIENCE ADVISORY BOARD STAFF

Mr. Thomas Miller, Designated Federal Officer, Washington, DC
                                        in

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                               TABLE OF CONTENTS

1.  INTRODUCTION                                                              1

  1.1 Background	1
  1.2 Charge to the Science Advisory Board	1
  1.3 Format of this Report	1

2. RESPONSE TO THE CHARGE                                                  2

  2.1 Summary Conclusions and Remarks	2
  2.2 Cross-Goal Issues: Identifying Critical Needs and Opportunities	8
  2.3 Goal 1 - Clean Air and Global Climate Change	14
    2.3.1 Alignment:	14
    2.3.2 Coordination	15
    2.3.3 Collaboration	16
    2.3.4 Emerging Issues:	17
  2.4 Goal 2 - Clean and Safe Water	18
    2.4.1 Alignment	18
    2.4.2 Coordination	19
    2.4.3 Collaboration	19
    2.4.4 Emerging Issues	20
  2.5 Goal 3 - Land Preservation and Restoration	21
    2.5.1 Alignment	21
    2.5.2 Coordination	21
    2.5.3 Collaboration	22
    2.5.4 Emerging Issues	22
  2.6 Goal 4 - Healthy Communities and Ecosystems	24
    2.6.1 Alignment	24
    2.6.2 Cooperation	27
    2.6.3 Collaboration	27
    2.6.4 Emerging Issues	28
  2.7 Goal 5 - Compliance and Environmental Stewardship	29
    2.7.1 Alignment	29
    2.7.2 Cooperation	32
    2.7.3 Collaboration	32
    2.7.4 Emerging Issues	33

REFERENCES	R-l
                                        IV

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                                 1.  INTRODUCTION

1.1 Background

       This report transmits the advice of the U.S. EPA Science Advisory Board (SAB) on the
Fiscal Year 2006 budget request for EPA's science and research activities.  This report was
prepared by the Board after discussing the request with EPA during meetings held in November,
2004 and February, 2005, and deliberating on the issues during its April and May 2005  meetings.

1.2 Charge to the Science Advisory Board

       The following four charge questions were the focus of the Board's attention during its
evaluation of the science and research budgets for FY 2006:

          a) Based upon the SAB's knowledge of EPA's science programs, do the planned
          science and research activities included in EPA's FY 2006 budget align with the
          Strategic program priorities identified by EPA's Research, National Program, and
          Regional Offices?

          b) Do the science programs of EPA's National, Regional, and Research Offices
          reflect coordination among EPA organizations and do they complement one another?

          c) Based on EPA's presentations to the SAB, and Board members' own knowledge of
          efforts in the broader scientific community, how well does EPA's science program
          appear to complement environmental science programs elsewhere? Is there  evidence
          that EPA's efforts are coordinated with the  science efforts of other governmental
          organizations and relevant organizations outside of government? Is there evidence
          that EPA has an approach for capturing the science products from these other
          organizations?  Are there ways the Board could suggest that will enhance this
          coordination?

          d) Based upon the SAB's knowledge of EPA's science programs, are those  programs
          positioned to address the nation's emerging environmental issues in the coming years?

1.3 Format of this Report

       Following this Introduction, the report provides a summary section (section 2.1) that
highlights the major advice of the Board. Specific responses to the charge questions are
provided in succeeding sections of the report for each strategic agency goal (sections 2.2 through
2.7). These sections were developed by the Board's Goal-specific Teams and approved by the
Board during preparation of this advisory.

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                           2. RESPONSE TO THE CHARGE

       Each year, the EPA Science Advisory Board (SAB, the Board) evaluates EPA's science
and research budget request.  The report of this activity is used by the EPA Administrator and
Congressional Staff in their budget and planning activities. In recent years, this advisory
function has been conducted by the chartered EPA Science Advisory Board, thus enhancing the
visibility of the activity and increasing the resources and expertise available for its
accomplishment.  The Board has organized itself into six Teams (one for each Strategic Goal and
a Cross-Goal Team) to carry out this advisory activity.

       Throughout this report, the terms science and research are used to refer to separate parts
of EPA's overall science program. This language suggests a dichotomy that does not exist in the
practice of science. However we use it to reflect the difference in how EPA plans and prepares
its budget for science activities. For planning and budgeting, EPA describes how scientific
information is generated in a "research objective" and how scientific information is used in a
"science objective." This reflects a general division of labor in which the Office of Research and
Development conducts, or funds, most of EPA's research and EPA Program and Regional
Offices use the results of scientific research in assessing and managing risk under a variety of
legislative mandates.  Of course, ORD uses science in conducting assessments of its own, and
Program and Regional Offices directly support the conduct of some research, so this division of
labor is not absolute.

2.1  Summary and Conclusions

       Comments in this report focus on the  President's Fiscal Year (FY) 2006 EPA science
and research budget request (USEPA, 2005). Even though the FY 2006 budget is in final
form, the Board believes that there is an opportunity for its advice to be integrated into EPA's
planning efforts as it prepares to develop its FY 2007 budget request for science.  There may also
be opportunities for the Agency, with the assistance of the Congress, to implement some critical
changes as it develops its FY 2006 operating plan.  The Board would be pleased to assist EPA as
it deals with this issue by offering its services earlier in EPA planning activities.

       Conclusions in this  report reflect a fundamental belief that effective science-based actions
by EPA require a continuing and credible investment in developing scientific knowledge,
methods, and assessments.  This investment in science is important irrespective of whether
management approaches envisioned by EPA  involve partnerships, market-based techniques, or
command and control regulations.

       The EPA Science Advisory Board is generally enthusiastic about the science and
research activities proposed in the FY 2006  budget.  These programs, generally, align well with
the  Agency's strategic priorities in all goals; however, confining the Board's consideration to
alignment only would miss a major factor in meeting EPA's science and research needs.
Attention must also be given to the overall resources available for conducting EPA science and
research programs.

       The Board has observed for several years that EPA's real-dollar investment in
science/research continues to erode. This is often compounded by resource shifts from

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traditional, long-standing research programs to newly recognized problems and priorities.  This
is a sound approach when resources are shifted from programs that are being completed.
However, it appears that this also happens in situations where there is a continuing need for
existing programs.  Inadequate research funding could well lead to greater, not reduced,
regulatory burdens, and to significant morale problems among EPA scientists that could induce
serious long term problems and loss of key staff.  The size of EPA's science and research budget,
and its focus, is largely a matter of policy choices that have been made. The  SAB encourages the
Agency to ensure that in making such choices, that careful consideration is given to whether
changes might lead to unintended consequences that diminish the Agency's ability to conduct an
integrated research program to support its needs now and into the future.

       The SAB evaluation of EPA's out-year budget (in the current case, FY 2006) occurs
before the current year's resources are officially allocated (in this case, FY 2005) and before the
information on those  allocations is available to the SAB. This lack of current information acts as
a barrier to external evaluations of EPA's science and research programs. More timely access to
data on funding of current year science and research programs would enhance these external
evaluations.

       The Board applauds EPA's internal collaborative planning efforts that help to integrate
environmental research activities within the Agency and those activities that help to coordinate
EPA's research with the environmentally relevant research of other Federal organizations. With
the continued real-dollar erosion of EPA's science and research budget, enhancing this
collaboration will be  critical to EPA's successful achievement of its mission. The Board also
encourages EPA to pursue collaborative ventures within and beyond the Federal government
sphere, including other levels of government, nonprofit organizations, and the private sector, and
to share information on these ventures with  the SAB and other interested parties. Examples of
EPA's internal science and research program coordination are noted in the body of this
advisory (e.g., contaminated sites and RCRA research plans and the development of the complex
3MRA model).

       EPA's approach to collaborative research and science planning could serve as a model
for other agencies.  Effective science and research planning requires the full cooperation across
EPA offices to attain  an appropriate balance among the EPA science and research programs.
Ideally, this coordinated planning should involve a continuing  dialog among EPA's Office of
Research and Development and various program and regional offices.  ORD, Program Offices,
and Regional Offices should openly discuss all science and research activities across EPA in this
collaborative planning in order to develop a cohesive and complementary overall EPA
science/research program.  The Board encourages EPA to continue its internal coordination and
to bring even more transparency to these interactions. The Board also encourages EPA to
increase its interactions with Regional Offices to ensure that their science needs are met.

       The SAB sees evidence of progress in EPA's coordination of science and research with
other federal partners.  Though this coordination has not been quantified for the SAB, in some
programs, it has clearly been extensive (e.g., the drinking water research program is coordinated
nationally and now internationally, endocrine disrupters, children's health, CAFOs, the
Advanced Monitoring Initiative, the Computational Toxicology Center, and the Pollution

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Abatement Control Expenditures survey). There is room for enhanced cooperation and
partnering in other areas (e.g., risk assessment for air toxics, ecosystem endpoints associated
with air pollution, water quality research). Documentation of current leveraging efforts could
emphasize the intersections among the environmental research portfolios of different government
agencies, the extent of coordination across these various portfolios, and any nuanced differences
in the research being conducted in one agency versus another.

       The Board is concerned about EPA's limited ability to conduct research to identify
emerging issues and to build the tools necessary to deal with them. The shrinking infrastructure
for anticipatory research on future environmental issues is attributed by the Board to decreases
in science/research resources at EPA, as well as to a growing trend toward addressing short-term
information needs at the expense of longer-term research. In each Goal area, EPA science and
research tends to concentrate on "legacy" issues, i.e., familiar, near-term, and mission-specific
topics associated with known issues.  A greater ability to conduct anticipatory research would
allow EPA to exploit windows of opportunity to understand the environmental implications of
new technologies (and their associated social systems) that are now developing in the United
States and abroad.  The  Board recommends that EPA identify opportunities for major
innovations or new approaches needed to enhance our understanding of (increasingly complex)
emerging environmental issues.

       The Science to Achieve Results program (STAR) has been reduced significantly over
the last two years and within STAR the ecosystem research program has been the focus of most
of these reductions. The SAB is concerned with the continued reductions in the STAR
program. STAR has been evaluated and judged to be of significant merit (e.g., NAS/NRC, 2003,
The Measure of STAR). STAR is vitally important to EPA's development of the science
necessary for meeting the nation's environmental  goals.  STAR benefits the nation by:

             1) contributing to EPA's research program balance. - STAR addresses
       significant mid-  and long-term Core research issues and it compliments EPA research
       programs that focus on near-term, problem-driven information and methods.  For many
       years, EPA has conducted both "core" and "problem-driven research." The problem-
       driven component of the program develops methods  and generates data needed by EPA
       program and regional offices as they fulfill their day-to-day environmental management
       roles.  The core program develops basic knowledge on environmental science issues.
       The need for EPA to remain intimately involved in both types of research has been
       considered in the past. Both the National Academy of Sciences and the EPA Science
       Advisory Board have noted the importance of both core and problem-driven research to
       the attainment of the nation's environmental goals. Cuts to the  STAR program degrade
       EPA's overall science capability by removing significant core research assets.

             2) giving EPA access to academic scientific research institutions  - EPA's
       total science and research programs are conducted internally using EPA's own scientists
       and through a variety of extramural arrangements, including grants, co-operative
       agreements, and contracts—that engage universities or other institutions that conduct
       research.  Continued cuts to the STAR program compromise the essential extramural
       grant component of EPA's overall science and research program which, historically, has

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       provided EPA with access to a network of academic contacts that facilitates cross-
       pollination of ideas and opportunities with EPA's own scientists; alliances that are nimble
       enough to help the EPA identify and adapt to emerging issues and to leverage funds with
       other agencies and partners. If these investments are allowed to lapse, the fixed costs of
       re-establishing them are likely to be substantial.  A significant reduction in extramural
       funds is analogous to liquidating one's investment principal.  Such a strategy is likely to
       have significant long-term costs in terms of the nation's ongoing ability to summon the
       knowledge needed to inform policy development.

              3) providing EPA with a mechanism to address research issues that have a
       diffuse constituency and less immediate information needs. — Research with longer-
       term time horizons, and on issues having a diffuse constituency, often do not have near
       term champions in a regulatory agency. Thus, it is often difficult to maintain a research
       presence in those areas even though they address important aspects of the Agency's
       overall mission. Two examples of environmental issues illustrate this problem: a)
       emerging environmental threats, and b) viability of ecosystems.

              4) supporting a Fellowship Program that provides one of the few opportunities
       to develop highly trained environmental scientists and engineers for the future. - The
       STAR fellowship program was established to support the development of highly trained
       environmental scientists and engineers. STAR Fellowships encourage promising
       students to pursue careers in environmental fields, and this is the only federal fellowship
       program exclusively designed for students pursuing advanced degrees in environmental
       sciences. The Board urges continued support of the STAR fellowship program at an
       increased level given the  country's need for well-trained and accomplished scientists and
       engineers.

       Continued reductions in EPA's ecological research program concern the SAB. —
Ecosystem health is an important part of the nation's environmental quality. Among the major
elements of EPA's strategic plan is a commitment to ".. .protect, sustain, and restore the health of
natural habitats and ecosystems." Fundamental to this objective is the creation of scientific tools
to assess the overall current condition of the nation's ecosystems.  Ecological research supports
objectives in all of EPA's strategic goals. Deep cuts in ecosystem programs have been taken in
the FY 2005 and FY 2006 budgets. The importance of this objective is underscored by the
conclusions of the Agency's Draft Report on the Environment (US EPA, 2003a) which was
recently reviewed by the SAB (EPA SAB, 2004a), as well as an independent "State of the
Nation's Ecosystems" report (The Heinz Center, 2003). Both of these reports conclude that little
of the nationwide information required to characterize and track changes in ecosystem health is
currently available. The Board strongly urges the Agency to reverse the erosion in ecological
research resources.

       Current plans call for placing specific amounts of ORD's FY 2006 funding at the call of
five separate EPA offices (i.e., $4.5-million each for the following programs: air, water,
pesticides  and toxic substances, and waste, and $2-million for policy and economics) in a Pilot
Research  Program. This would allow those offices to obtain specific, near-term, science and
research projects either by calling on ORD itself to conduct the work, or working with ORD to

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obtain the efforts from outside groups.  In the future, the agency might do well to consider
whether prior allocation of "office-specific shares" is the best strategy for distributing resources
in such a program, or whether within some limits the allocation might be adjusted in response to
the quality of research questions identified.  The Board believes that this pilot program could
provide valuable research results that contribute to the near-term needs of EPA Program Offices.
It will be important to design such a pilot program with specific objectives in mind and to
include an independent evaluation which will allow it to be improved with time.  The Board
suggests that EPA not allow too large a proportion of ORD's research to become too tightly tied
to the day-to-day information needs of Agency offices and regulatory schedules, because that
could begin to seriously erode EPA's science base and its ability to address new problems and
improve future performance.

       EPA should develop a coherent social and behavioral sciences research program,
much as it has done in recent years for economic research. This program should be implemented
as soon as possible. Some examples of needed social and behavioral science research include;
how best to communicate risks, how to develop effective voluntary programs, how to better
evaluate ecological damage, and how to improve the application of benefit-cost and cost-
effectiveness methods for setting environmental priorities, etc. (see below).

       1) Risk Communications — EPA was once a leader in supporting risk communication
       research and has produced many publications with risk communication guidance;
       however, the new generation of risk communication knowledge is significantly under
       funded and now appears to be undervalued by much of the Agency. To increase the
       impact of the agency's research on public policy, it is essential to take  a broader view of
       risk communication and the array of social sciences that underpin strategic approaches to
       solving environmental problems.  This cannot be achieved without greater recognition
       and incorporation of social science knowledge and methods into the agency's research
       and operating programs.  Two areas that demonstrate this need include homeland security
       for water and building systems. EPA should systematically use the research literature in
       risk perception,  risk communications, risk aversion, uncertainty, adaptability, and
       discounting.   A commitment should be made to rigorous empirical performance
       evaluation under realistic field conditions, for real  people, under real time pressures, and
       (often) real fears. With this information, the Agency will be able to demonstrate the
       efficacy or cost-effectiveness of different solutions and to provide decision makers with
       the realistic characterizations of system performance that are essential to effective
       planning.

       2) Voluntary Actions: A major theme running throughout the EPA 2003 - 2008 Strategic
       Plan  is the need to move forward where possible from the largely command and
       control regulatory regime.  Such a shift raises the question of how to encourage
       voluntary actions and how to determine the proper mix of public sector and privately
       funded research on improved waste management practices, innovative pollution control
       technologies, and pollution prevention.  There are important differences in types of
       voluntary actions. In some, voluntary actions that are not specifically required will be
       undertaken because they are in the best narrow cost-minimizing interests of polluters. In
       others, voluntary actions will be contrary to the direct profit-maximizing interests of

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       polluters, but these actions will be taken for other broader reasons (e.g., enhancing the
       green reputation of the firm with an eye to improving either demand for the firm's
       product or the firm's ability to raise capital from environmentally sensitive investors).
       The behavioral, social, and decision science research necessary to support
       environmentally effective programs that rely on voluntary incentives are at an early stage
       of development. Understanding incentives and constraints is important to explaining
       actions and choices.

       3) Non-market Ecosystem Benefits: Additional socioeconomics research is needed on
       valuing the non-market ecosystem benefits of reducing pollution. For such valuations, it
       is necessary to demonstrate that people are able to perceive differences in ecosystem
       quality sufficiently to be able to form values that can be measured and incorporated in
       benefit-cost analyses. This topic has been identified by the Agency as a high priority
       research area in its Environmental Economics Research Strategy (US EPA, 2003b).  Yet,
       the information provided to the Board does not reflect investments in this area.

       4) Neighborhoods: There is increasing attention in the literature to the longer-run
       consequences of environmental problems to neighborhoods.  These effects have
       environmental justice implications. For example, a temporary environmental problem
       can have effects on community dynamics that are completely reversed when the problem
       is corrected,  provided that perceptions of risk are not changed permanently by the event.
       However, longer-term environmental hazards can set in motion systematic shifts in
       neighborhood composition that can affect neighborhoods long after the hazard has been
       removed (as  in the case of the identification and clean-up of a Superfund site).
       Socioeconomic research that is important to this issue  include the overall long-run effects
       of environmental problems—and their resolution—on housing prices and other
       neighborhood attributes.

       Homeland Security research has grown at EPA in the last several  years.  The Board is
concerned that EPA's homeland security research needs may be drawing resources away from
other essential EPA  research programs. While the Board recognizes the important role EPA
plays in this research area, and that some homeland security research may provide data and
methods that are of general environmental interest and applicability, the level of resource
allocation to these projects must be carefully considered in the face of declining budgets for
scientific research. Research funds allocated to EPA's Homeland  Security  mission should
address research issues and not be diverted to operational program needs.

       EPA has very limited resources available for research  into global climate change. Much
of the federal climate change program occurs outside of EPA.  However, many EPA mandates
are influenced by global climate change. EPA should enhance its technical capacity to evaluate
the links among global climate change and its mandated responsibilities to protect human health
and the environment, and  as needed to evaluate and manage the technologies and activities to
respond to the problem (e.g., deep geologic injection of carbon dioxide).

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2.2 Cross-Goal Issues: Identifying Critical Needs and Opportunities

       The Cross-goal Team of the SAB considers issues that may not be the sole focus of any
other Goal-specific Team.  Some of these issues are shared by several programs ("in-common
issues"). For these issues, the total ongoing science effort and planning for the future, is not able
to be adequately addressed by any one program (e.g., information technology, sensing and
monitoring networks, linkage to external science programs, the science-policy interface itself).
Other issues are those that may link separate programs ("bridging issues"). Examples of
bridging issues include models, tools, and emerging research and technology that enable cross-
media or multi-program efforts (increasingly, problems in human health and  environmental
degradation are of this kind). Finally, there are issues that may "fall between the cracks"
("unnoted issues"). These issues, especially emerging ones, may lie beyond the scope of any one
program and may go unseen or be given insufficient attention and investment.  Here, time can be
important and attention to time  horizons of planning across all programs is needed. The hope for
many of these issues is that they may identify opportunities for science input that might solve
problems at their inception, and thus  avoid costly reengineering and control.  Failure to notice,
inform and invest can create bottlenecks in our nation's advancement of technology and
economic growth. The Board notes a number of each of these issues in the following
paragraphs.

       a) Preparing for Tomorrow: While the agency has been making good  progress in
developing a more systematic approach to identifying research needs for its normal operations
(often referred to as "legacy" issues), it still needs to work on developing strategies for
identifying and focusing on opportunities for major innovations or new approaches that could
have large impacts on improving our nation's future understanding of environmental issues and
regulatory performance, especially new and emerging environmental problems. The Agency has
not demonstrated significant attention to and investment in the types of exploratory research
that would allow it to take advantage of current windows of opportunity to understand and work
on the social and technological  systems that are now developing in the United States and in the
world.  This approach will not only affect EPA's ability to meet its mission of protecting human
health and the environment, it also risks influencing the future U.S. economy by opening our
products to safety, recycling, and other challenges from other nations when they compete for a
place in the international market. The agency must be more forward looking in its preparation
for tomorrow's issues.

       b) Cross Cutting Issues: The agency should also increase its attention to cross-cutting
issues which now seem to receive too little attention because they "fall between the cracks" in
the media-by-media organization of the agency. In calling for increased attention to these issues,
the Board is not calling for a massive new agency-wide strategic planning effort. Rather, it is
urging the agency to put in place a process by which, at any given time, two or three topics of
this sort have been identified and are receiving serious cross-office analytical attention. While
we do not want to prescribe any specific topics for such attention, this need can be illustrated
with a few examples:

     1) Are the networks, instruments and programs of routine nation-wide monitoring of
         pollutants in air and water producing time series data that are adequate for the research

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         and regulatory needs which the agency will likely face over the next couple of
         decades?1
     2) If an influence diagram was constructed to illustrate all the elements of the processes by
         which nano-particles and materials could lead to beneficial or negative impacts, which
         links in that diagram are most critical in understanding the potential health and
         environmental factors that may be involved? How adequately is ongoing research (in
         the agency or elsewhere in or outside of the government) likely to be able to address
         these links in the future?
     3) Is the science base that the Department of Energy is currently developing on deep
         geological sequestration of CC>2 likely to produce the understanding that the EPA will
         need to implement science-based regulation of this technology if and when that need
         arises?
     4) Can traditional risk assessment methods based upon multiplicative uncertainty factors be
         effectively replaced with probabilistic methods?

       While the need for EPA to look beyond its immediate agenda has existed for some time,
it has become more pressing because shrinking budgets tend to force the Agency to concentrate
on traditional legacy issues. New and cross cutting issues thus become disadvantaged (e.g., nano-
particles, pollution prevention, ecosystems). Without an ongoing effort to identify important
neglected needs and a process to focus attention on emerging issues, the EPA will  not be able to
adequately meet its mission of protecting the nation's environmental components, including
humans, in the coming years.

       c) New Research Pilot on Programmatic Research Needs: Current plans call for $4.5-
million of EPA ORD research funds to be made available for on-call needs of each of several
specific EPA program offices: air (i.e., OAR), water (i.e., OW), pesticides and toxic substances
(i.e., OPPTS), and waste (OSWER), and $2-million for policy and economics (i.e., OPEI).  In the
future, the agency might do well to think about whether prior allocation of "office-specific
shares" is the best strategy or whether, within some limits, the allocation might be  adjusted in
response to the quality of research questions identified.

       In the Board's view, it is important to design this pilot program with specific objectives
in mind and to include an independent evaluation which will allow it to be improved with time.
It would be desirable if an allocation strategy could be developed which requires that written
proposals be developed and independently reviewed, and which gives preference to those which:

          1) Make a strong case that the proposed work involves research, not simply funding
              for ongoing operations;
          2) Address an important programmatic problem for which funding is currently scarce
              and is receiving too little attention; and
          3) Provide a specific discussion of how the proposed activity will be evaluated so as
              to contribute to the overall evaluation of the pilot program.
         This approach has been taken for air quality. It is less clear that it has been done for water issues where
         routine monitoring has been spotty, or for cross-media issues.

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       Proposals that address problems that are likely to be of concern to more than one office,
or that contain multi-media, multi-program, or multi-regional elements should be preferred to
those that do not.

       The Board believes that this program could be very valuable to improving the ability of
Agency research and development to contribute to the daily needs of the Agency's programs. At
the same time, we caution that it is important to not allow too large a proportion of ORD's
research to become too tightly tied to the day-to-day information needs of Agency offices and
regulatory schedules, because that could begin to seriously erode EPA's science base and its
ability to address new problems and improve future performance.

       d) The Importance of Ecosystems: Ecosystem health is an important aspect of the nation's
environmental quality. Unfortunately ecosystem research has long received too little attention at
EPA, and this review produced evidence that the situation is getting worse.  Issues such as how
best to deal with invasive species, how to protect valuable wetlands and the services they provide
to society, and how to protect important ecosystems in the face of changing climate, can not be
efficiently and adequately addressed if the Agency does not have  a strong base in ecosystem
research.

       Unlike environmental health, ecosystem health does not have the same level of
immediate constituency. But American's have clearly demonstrated that they care about the
quality of their wild and managed lands and waters and expect government to provide adequate
protection.  If the Agency does not improve its research capabilities in this area, it will not be
able to meet that public expectation. Nor will it be able to meet its regulatory responsibilities.
Cuts in funding ecosystem research programs,  such as EMAP, will also have an impact on EPA's
ability to meet objectives to protect water quality.

       e) Sustaining and Building Social and Behavioral Research: The EPA has long suffered
from a deficiency of expertise and research activity in social and behavioral research: research on
how best to communicate about risks; on how to better evaluate intangible impacts such as
ecological damage; on how to improve the application of benefit-cost  and cost-effectiveness
methods to setting environmental priorities; or how to develop effective voluntary and
participatory programs, etc.

       In the current review several Board Teams noted what appears to be a further erosion of
support for what is already a very inadequate effort in social and behavioral research. If this
process can not be reversed it will seriously damage the efficiency and effectiveness of the
agency's programs in the future.  This is especially true in the area of homeland security.

       The agency does have expertise in economics but it has very limited expertise in other
fields of social and behavioral science. As a consequence, when a program realizes that it needs
a social dimension in its work, it often does not understand the current state of expertise in the
relevant fields, does not know what to ask for,  and ends up with less than adequate research
designs.
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       This problem is especially apparent in the Agency's new work in improving homeland
security for water and building systems. The descriptions to the Board of EPA's plans to design
and evaluate options (e.g., sensor arrays, decontamination procedures) did not seem to be making
any systematic use of the research literatures in risk perception and communications.  Nor did
they seem to have any explicit commitment to rigorous empirical evaluation of performance
under realistic field conditions, with real people, under real time pressures, and, often, real fears.
Without such work, the Agency will not be able to demonstrate the efficacy or cost-effectiveness
of its solutions. Nor will it be able to provide decision makers with the realistic estimates of
system performance that are essential to effective planning.

       The options being developed will provide imperfect signals regarding risks (e.g., has an
attack occurred, what is the residual after decontamination). Recommended practice is to couple
risk analysis and risk communication, so that systems produce the information that people need,
which is then communicated to them in a cogent, authoritative, and comprehensible way. The
program's approach to these issues did not seem to involve either using or conducting such
research. Communication outward will, apparently, be approached by drafting common sense
procedures, without accessing the research relevant to their feasibility and without commitment
to empirical evaluation.  There was no expressed intention to involve the public and its
representatives in questions like acceptable decontamination standards.  These were deferred to
some other body, which could not be described to us.  If this is the case,  then the Agency will be
producing incomplete, possibly counterproductive solutions, without increasing its own research
capacity for topics that arise in many areas of its operations (e.g., water contamination from non-
terror sources).

       f) The Importance of Sustaining and Nurturing Extramural Research: As EPA's research
needs continue to grow and the resources to support this research either remain constant or
contract, it is not surprising that the agency may consider moving support out of extramural
programs to sustain internal programs.  During the course of this review several indicators made
it apparent that such erosion is indeed occurring.

       The STAR program and other programs of extramural support operated by the Agency
have provided an essential source of new scientific understanding and have played an important
role in growing the next generation of environmental  scientists across the nation. The Board is
troubled that support for these extramural programs has been significantly reduced and urges the
agency and the Congress to work hard to protect, restore, and sustain them.

       Extramural research programs are not as elastic as is often suggested. Interruptions and
steep reductions in extramural research weaken the relationships that EPA needs with scientists
outside the Agency to maintain a strong research program.

       g) Investments in Homeland Security Research: While Homeland Security research
should address homeland security as its first priority, many of the issues involved have "dual
use" dimensions  and can often be approached so as to  serve multiple Agency objectives. Also,
funds allocated to Homeland Security research should address research issues and not be
diverted to Homeland Security operational programmatic needs. The dual nature of research also
applies to many other Agency research programs that are nominally tied to supporting EPA's
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mission under a variety of media- and program-specific statutes (e.g., SDWA, TSCA, CERCLA,
FIFRA, etc.). Homeland Security should not undermine the basic research supporting Agency
activities, rather it should help EPA further develop its research programs in an integrated
manner, and with an eye toward obtaining broader utility from specific research efforts when that
is possible.

       The analysis presented to the Cross-Goal Team on options for planned homeland security
research did not seem to involve any systematic, formal analysis, sufficiently transparent as to be
open to peer review.  Rather, "analysis" seemed to connote information gathering, followed by
an internal deliberative process. If so, then there will be no way to tell if the Agency has fulfilled
its homeland security assignments in the best way possible. Nor will there by any growth in the
Agency's core analytical capacity.  Such consultative processes may be subject to internal
processes and vendor push.

       h) Needs for investments in computing hardware, information infrastructure, and
management support for science: EPA needs information resources both for internal research
support and for participation at a high level in cross Agency and international programs such as
GEOSS. EPA scientists need access to 21st century information resources to collaborate with
scientists in other agencies and universities, make use of models, and take advantage of
converging technologies.

       The Board believes that EPA must strengthen both its high performance computing
abilities for modeling and networking and the more mundane, but still critical, day to day
computing needs of the science community. In both cases, a high level of connectivity to the
outside world is essential. EPA currently has a low level of access to electronic journals,
analytical and other special purpose software, and data-sharing resources, compared to scientists
at universities.

       i) Morbidity Data: Most estimates of the human health benefits of environmental
protection have focused on reductions in life expectancies. There should be more attention given
to benefits in the form of reduced non-fatal morbidity and reductions in pre-mortality morbidity.
People care about their quality  of life and about how they die.  Research on society's willingness
to pay to prevent or limit different types of health consequence s through environmental
protection has been hampered by the absence of data  on the prevalence of different types of
illnesses. Mortality data, by cause of death and at a relatively fine level of geographic
disaggregation, have been available through the National Center for Health Statistics. Since few
diseases are reportable, however, it has been more difficult to assemble comparable data on
morbidity in terms  of hospital admissions or emergency room visits. Such data are important in
risk assessments used in support of standard setting.

       In terms of collaboration with other agencies, the EPA's efforts to better understand the
health inventory, and to make causal connections between environmental quality and this health
inventory, are vitally important. Willingness to pay for environmental protection will depend on
the types of illnesses prevented, their latencies and endpoints,  as well as on the characteristics of
the population that would be affected.  Research that  extends the health benefits estimation effort
beyond reliance on just a single one-size-fits-all value of a statistical life (VSL) estimate will be
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greatly enhanced by the availability of detailed morbidity information.  In addition, the Agency's
Environmental Economics Research Strategy (US EPA, 2003b) which was reviewed during 2004
by the SAB's Environmental Economics Advisory Committee (US EPA SAB, 2004b), also
called for more research on the valuation of nonfatal health effects.

       Benefits assessment is necessarily limited by the way in which risk assessment
information is often reported for non-cancer endpoints. When based on animal data, dose
response is often characterized by a single value without any indication of the degree of risk at
given exposure levels or the uncertainty or variability in the risk. For cancer endpoints,
uncertainty and variability are typically not characterized quantitatively in dose response
assessments.  The Board strongly endorses research that would result in movement toward more
extensive development of probabilistic risk assessment for the inclusion of in agency health and
benefits assessments. Given the significant scientific limitations and difficulties characterizing
uncertainty and variability in toxicological parameters, this goal can only be accomplished with a
substantial commitment of resources for research.

       j) Environmental Justice: There has been an increased attention in the literature to the
idea of "locational" equilibrium and what it means for the longer-run consequences of
environmental problems in specific neighborhoods.  This is an important environmental justice
issue. A temporary environmental problem can have "impact" effects that are completely
reversed when the problem is resolved, provided that perceptions of risk are not changed
permanently by this temporary environmental issue.  However, longer-term environmental
hazards can set in motion systematic shifts in neighborhood composition that can affect
neighborhoods long after the hazard has been removed (as in the case of the identification and
clean-up of a Superfund site).

       In the case of air quality, there has  been some interesting work on the general equilibrium
consequences of improved air quality, when such improvements set in motion an adaptation
where sensitive populations who previously avoided more polluted areas now find them
attractive, moving back in and driving up housing prices  in those areas in a manner that will tend
to offsets the initial welfare gains to populations that previously suffered more from pollution but
were compensated to some extent by lower housing prices. If the Agency's goals are strictly to
improve environmental quality, then the subsequent  increase in housing prices is of no concern,
but in environmental justice cases, one needs to be careful about "giving with one hand while the
other one takes away." While it is unlikely that housing price increases that occur upon
environmental improvements will be sufficient to completely offset the initial welfare gains from
a cleaner environment, the extent to which this happens is an empirical question.  Behavioral
adaptations to cleaner environments are very important to a complete understanding of the
environmental justice consequences of Agency activities.
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       k) Accountability: Accountability is important and it is prudent for the Agency to
continue to invest in an improved understanding of the actual benefits of its programs and
policies. In terms of benefit-cost analysis, these efforts serve to reduce uncertainty about the
benefits of environmental management strategies, which in turn reduces uncertainty about the net
social benefits of these policies (after social costs are subtracted) and about whether specific
policies pass the benefit-cost test. In a budgetary climate where all forms of government
expenditure have come under increasing scrutiny, it is more important than ever to be confident
that those programs which will inevitably need to be cut are the right ones to cut, and that those
to be kept are the right ones as well.

       There is also the ever-present need to improve our understanding of discounting and the
extent to which it should be employed,  especially with stock pollutants. Last year, the SAB
commented more extensively on the fact that research providing short-term results was funded
preferentially over research with long-term implications.

2.3 Goal 1 - Clean Air and Global Climate Change

       2.3.1 Alignment: Based upon the SAB's knowledge of EPA's science programs, do the
       planned science activities included in EPA's FY 2006 budget align with the Strategic
       program priorities identified by EPA's Research, National Program, and Regional
       offices?

       EPA managers made an important change this year by expanding the position of National
Program Manager for Particulate Matter Research to become  the National Program Manager for
Air Quality Research.  An appointment has been made to this more broadly defined position.
This is an important step toward planning and conducting a more integrated research program to
improve air quality. The Board commends EPA for taking this action.

       The planned science and research activities reflected in the FY 2006 budget align with
the Agency's strategic priorities in Goal 1. While the planned science activities do align with the
strategic priorities for Goal 1, there are unmet needs in the proposal.  These are discussed in the
paragraphs below.

       a) Mercury Monitoring: There is an urgent unmet need for monitoring programs that will
provide an appropriate set of background data on mercury.  The agency will need to evaluate the
effectiveness of the mercury controls on airborne concentrations during its implementation of the
Utility Mercury Reductions Rule. There are monitoring systems in place (CASTNet,
IMPROVE, NADP) that will permit the evaluation of the changes in sulfate and nitrate
concentrations that are expected to change with the implementation of the Clean Air Interstate
Rule (CAIR).  However, there are currently no  systematic measurements being made on gas
phase mercury species.  Mercury in wet deposition is being measured in a small supplemental
network to the NADP. Monitoring will ensure  that the implementation of the cap and trade
program is not producing disproportionate benefits to  different downwind regions. Even if these
regulations are superseded by legislation like Clear Skies, additional coordinated monitoring will
be needed to assess the long-term benefits of the legislation.
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       b) Ammonia Monitoring: Another pollutant for which there is an urgent need for
improved monitoring is ammonia.  Ammonia has a significant effect on the formation of
particulate matter through nucleation of sulfuric acid and water or the formation of ammonium
nitrate. Existing emissions inventories for ammonia are poor. There are currently limited
measurements being made and the need for improved ammonia monitoring is noted in the
National Ambient Air Monitoring Strategy.  The SAB encourages EPA to begin this effort soon.
This monitoring should occur within the context of the overall nitrogen cycle, and the other
cycles with which nitrogen interacts (e.g., sulfur and carbon).

       c) Emissions Inventories: Major gaps remain in our quantitative knowledge of emissions
and the quality of the resulting emissions inventories.  For example, in the case of particulates,
the National Research Council (NRC) Committee on Research Priorities for Airborne Particulate
Matter highlighted such problems.  However, EPA has been able to mount only a limited effort
and much of the focus to date has been on Concentrated Animal Feeding Operations (CAFOs).
A need remains for up-to-date chemical characterization of emitted materials as well as  better
estimates of mass emission rates.

       2.3.2 Coordination: Do the science programs of EPA's National, Regional, and
       Research Offices reflect coordination among EPA organizations and do they
       complement one another?

       Coordination is evident among EPA offices on Goall issues. However, it is difficult to
determine its extent. EPA's organizational structure (i.e., being divided into water, air and
research divisions, etc.), while useful for some purposes, creates barriers that make coordination
difficult.  While EPA staff clearly sees the need for more coordination, these barriers and the
increasing expectation that divisions have to do more work with fewer resources, increase the
difficulty in gaining greater coordination. As a case in point, CAFOs are recognized as  hot spots
for losses of nitrogen and other material to the atmosphere and to the water. CAFOs produce
significant quantities of biosolids. However, EPA does not have  a systems approach for research
on these losses.  This approach was recommended in a recent NRC study commissioned by the
EPA and the USDA (NAS/NRC 2003b, Air Emissions from Animal Feeding Operations). Thus,
science and research activities among OAR, OW, OSWER, and ORD have the potential to be
less complementary than they might be due to the narrower needs of each party. Additional
resources would greatly increase the potential  for a coordinated and complementary  science and
research program on this issue.

       An example of a data-gathering effort demonstrating good coordination among EPA
organizations is the redeployment of monitoring resources in the National Ambient Air
Monitoring Strategy program.  This effort has the potential for providing the long-term data
needed to support health studies on chronic exposure to air pollutants.  Part of the plan is to
move monitors from urban areas where they are duplicative to rural areas where they can provide
additional data on transport, as well as serve as the basic data sources for the more extensive
assessment of ecosystem risk.  This is an OAQPS endeavor,  but the data produced can support a
number of possible ORD research initiatives.
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       2.3.3 Collaboration: Based on EPA's presentations to the SAB, and Board members'
       own knowledge of efforts in the broader scientific community, how well does EPA's
       science program appear to complement environmental science programs elsewhere? Is
       there evidence that EPA's efforts are coordinated with the science efforts of other
       governmental organizations and relevant organizations outside of government? Is
       there evidence that EPA has an approach for capturing the science products from
       these other organizations? Are there ways the Board could suggest that will enhance
       this coordination?

       Within the Goal 1  objectives, the SAB sees evidence that coordinated work with other
federal partners is progressing.  EPA has made a reasonable effort to look for opportunities to
partner with other agencies and they have utilized science products from other organizations.
Examples of existing cooperation and collaboration, as well as a few examples of additional
needs for collaboration, are noted in the following paragraphs.

       A good example of collaboration has been the work on CAFOs. Here, the air program
has coordinated its efforts with USDA in air quality. There  are opportunities to improve
coordination with EPA's counterparts in agencies beyond USDA, and as mentioned above within
EPA.

       Another example of partnering is EPA's contribution to the Advanced Monitoring
Initiative (AMI).  EPA decided to combine the Tropospheric Ozone and PM Research Program
projects into the NAAQS Research Program to  allow better integration and coordination of their
research. EPA completed work on the development of tools to specifically implement the
NAAQS on tropospheric ozone and reallocated funding to the multi-agency AMI effort with
NOAA, NASA, DOE and others.

       In the area of risk assessment for air toxics, EPA has undertaken a near-roadway
exposure health effects assessment. The Department of Transportation has a major role but the
partnership between DOT and EPA has not been strong.

       A different kind of cooperation has been shown by EPA in the establishment of its
Computational Toxicology Center. This Center has been recognized by other agencies as a center
of excellence. Genomics and proteomics researchers need this type of center for interpretation of
data for risk assessment.  The Computational Toxicology Center is important for making
progress in developing biomarkers  of exposure  and effect that will be necessary to link
environmental changes to subtle changes in biological systems (people and the environment).
EPA's leadership in establishing the Center has benefited other agencies and enhances cross-
agency cooperation on this topic.

       An example of an area in which additional cooperation is needed is in the area of
quantifying ecosystem endpoints associated with air pollution.  Little progress can be made on
valuing the non-market benefits of reducing air pollution until we can demonstrate the
connections between air pollution and ecosystem structure and functioning. We then need to be
able to demonstrate that people  are able to perceive differences in ecosystem quality (or at least
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understand their implications) sufficiently to be able to form values that can be measured and
incorporated in benefit-cost analyses.

       It is important to keep in mind that giving people more of something than they would
choose for themselves, and requiring them to pay for it, does not really improve their welfare.
However, if we are paternalistic about the bundle of goods and services (including environmental
services) that they consume, we may feel better if they are consuming more environmental
quality, even if this forces them to consume less of other things. At a superficial level, it is very
easy to think that improved  environmental quality for low-income and minority populations will
be desirable from an environmental justice standpoint. What is missing from that superficial
impression is that there can  be important behavioral responses in housing markets that can offset
or even overwhelm these initial benefits, especially for disadvantaged groups for whom
willingness to pay for environmental quality falls short of what they are forced to pay through
higher housing  prices. Additional insights into this issue are discussed in section 2.2}. above.

       2.3.4 Emerging Issues: Based upon the SAB's knowledge of EPA's science programs,
       are those programs positioned to address the nation's emerging environmental issues
       in the coming years?

       EPA's ability to identify emerging issues in Goal 1 is hampered by funding decreases and
inflationary erosion.  Over the long-term continued decreases will have serious consequences on
EPA's ability to both identify and address emerging issues. Additionally, existing regulatory
mandates continue to be in place, so EPA must continue all of its statutory responsibilities with
legacy environmental issues.

       A long-term, newly recognized issue that needs to be considered is the intercontinental
transport of pollutants.  It is now clear that such transport from Asia, Africa, and Central
America affect  air quality in the United  States.  This transport can produce  a background
concentration, especially at  continental margins, that reduces the ability of controls to achieve
the increasingly stringent air quality standards that are being promulgated to protect public health
and welfare. There needs to be additional efforts to quantify the extent of such transport. The
use of remote sensing such as is incorporated in the Advance Monitoring Initiative (AMI) is a
promising starting point for such efforts. A more comprehensive effort should be mounted to
provide the critical information relevant to EPA policy development and as the basis  for enabling
the United States government to negotiate emissions reductions in pollutants in source areas.

       The rapidly growing use of nanotechnologies for a variety of purposes is a potential
emerging environmental issue.  There is already concern about the presence of ultrafme
nanoparticles in ambient air arising from combustion sources or through new particle formation
in the atmosphere.  The current PM program is positioned to address this issue as an extension of
its studies on ultrafme particles. Initial toxicological studies at universities are currently being
conducted with support from other agencies. The SAB recommends that the EPA consider
partnering with other agencies (e.g., NIOSH, NIH, NSF) to ensure that there is sufficient
toxicological testing of nanoparticles to  support future statutory evaluations of the need for EPA
action.  In terms of ambient ultrafme particles, EPA should be deploying particle size monitoring
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systems in major urban areas to provide the input data for time series epidemiological studies
that could inform the Agency about the need of a particle number ambient air quality standard.

2.4 Goal 2 - Clean and Safe Water

       2.4.1 Alignment: Based upon the SAB's knowledge of EPA's science programs, do the
       planned science activities included in EPA's FY 2006 budget align with the Strategic
       program priorities identified by EPA's Research, National Program, and Regional
       offices?

       The Board found good alignment between EPA's science and research activities and the
priorities reflected in the Agency Strategic Plan for Program and other offices involved in Goal
2.  However, the Board believes that some adjustments should be considered as the Agency plans
for its FY 2007 program.  Some of the recommendations could also be considered as the FY
2005 and 2006 programs are implemented.

       The Board wants to emphasize that there are many research areas in support of EPA's
Clean and Safe Water programs that can only be addressed through long-term research. These
research areas will suffer in the future if they are held only to short-term criteria and long-term
performance criteria are not considered to be important. EPA is the  only federal Agency focused
on certain water quality and water resource protection topics, such as watershed-based water
quality control approaches and tools (e.g., TMDL). If long-term research of this kind is not
supported by EPA, it will receive no attention at all in the country.

       a) Safe Drinking Water: The Drinking Water research funds are allocated as follows: 1)
Regulated Contaminants - 40 percent, Unregulated Contaminants - 52 percent; and Distribution
and Source Water Protection - 8 percent.  The Board believes that a greater allocation of
resources to unregulated contaminants is warranted, particularly for emerging contaminants (e.g.,
Pharmaceuticals and personal care products that are widely found in surface waters). The Board
also believes that resources for Distribution and Source Water Protection are inadequate,
particularly for research directed toward microbial growth and corrosion.

       b) Water Quality: The Water Quality program is a well established and highly developed
component of the EPA research agenda. It focuses on aquatic stressors, sources of impairment,
restoring and protecting aquatic systems, and biosolids. The criteria development section of the
program is mature, and the Board believes it would be prudent to consider advancing the newer
areas of the program more aggressively.

       The Agency is currently facing a major challenge under the Clean Water Act on Total
Maximum Daily Load (TMDL) allocations associated with impaired water bodies.  Therefore,
the Board believes it would be prudent for the Agency to increase its emphasis on TMDL
scientific and engineering research associated especially in the areas of diagnostics for Sources
of Impairment and acceptable in-stream conditions. Experience has shown that developments in
impairment assessment and protection and restoration inform the process of criteria
development. The board believes that the apparent Agency shift from chemical to habitat and
biological criteria is appropriate.  The board also recommends that EPA consider a greater
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allocation for restoring and protecting aquatic systems in Goal 2. Results and lessons learned
from these programs need to be leveraged and better disseminated for water quality planning and
management across the country.

       Given the scope and scale of biosolids treatment, disposal, and land application on a
national basis, the biosolids allocation is inadequate and the Board recommends that it be
increased.

       The Office of Water (OW) Science and Technology Funds for Homeland Security, are
propsed to be $47M in FY 2006. The dual nature of this research has been noted earlier in this
report.  The development of real time sensors under Homeland Security is a good example of
this duality and the products from this program will have great potential for chemical and
microbial monitoring.  However, the remaining Science and Technology funds are meager.

       c) Ecosystem research: Cuts in funding Clean and Safe Water Research areas (e.g.,
EMAP) and extramural STAR grants in Goal 4 (healthy communities and ecosystems) will have
a negative impact on Goal 2's water quality research and will adversely affect the available data
to support environmental management decisions.  Results of the EMAP program provide
quantitative information on the condition of the Nation's aquatic and terrestrial resources and
information on causes of impairments.  This information is essential to inform the planning and
design of water quality research. Extramural grants programs, such as STAR, provide a unique
vehicle for rapidly delivering scientific  advancements and capabilities for better environmental
management as EPA carries out its mission. For example, the Agency has used the STAR grants
program to explore the integration of economics, the social sciences, and the natural sciences.
Research results developed in this program have rapidly moved to the applied arena and have
been used to advance more effective decision-making on water quality at the watershed level.

       2.4.2 Coordination: Do the science programs ofEPA's National, Regional, and
       Research Offices reflect coordination among EPA organizations  and do they
       complement one another?

       Clearly, the science developed by ORD complements other EPA Regional and National
efforts.  This reflects ORD's planning process and responsiveness to the strategic and
implementation needs of National and Regional programs. Nevertheless, there may be regional
needs that are not being fully addressed. Examples of Region-specific problems that deserve
greater representation in the research budget are:  1) invasive species and 2) the impacts of urban
development (sprawl). The Board recommends that these issues be incorporated into future
agency planning for water quality and that efforts in this area be considered for earlier
implementation as well.  Within the Goal 2 budget there is also a need for  identification and
exploitation of opportunities for research synergies. For example decision tools developed for
the Drinking Water area could also have application in the Water Quality area.
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       2.4.3 Collaboration: Based on EPA's presentations to the SAB, and Board members'
       own knowledge of efforts in the broader scientific community, how well does EPA's
       science program appear to complement environmental science programs elsewhere? Is
       there evidence that EPA's efforts are coordinated with the science efforts of other
       governmental organizations and relevant organizations outside of government? Is
       there evidence that EPA has an approach for capturing the science products from
       these other organizations? Are there ways the Board could suggest that will enhance
       this coordination?

       a) Drinking Water: In the area of Safe Drinking Water, ORD research is generally well
   coordinated with other national and international research programs. Significant
   coordination in drinking water research within the U.S. has been in place for some time.
   More recently, a global effort has been made through the auspices of the Global Drinking
   Water Research Coalition.  This effort has reduced duplication of effort in drinking water
   research. Areas of collaboration that deserve attention include: better coordination between
   OW, OSWER, and OAR for contaminants that impact several environmental media; better
   coordination between drinking water and water quality programs; and better collaboration
   with FDA on pharmaceuticals and personal  care products in source waters.

       b) Water Quality:  The Water Quality research agenda is more difficult to coordinate.
   Unlike drinking water, where the EPA is the only federal agency, there are multiple federal
   agencies addressing this issue.  Coordination across these federal agencies does occur. There
   has been significant coordination between EPA and USDA on  Concentrated Animal Feeding
   Operations. However, there are significant  opportunities for additional leveraging of aquatic
   ecosystem restoration research with USDA  and DOI that should be pursued. EPA also
   coordinates with US Industry through the Water Environment Research Foundation (WERF)
   and the American Water Works Association. Research on water quality in the Great Lakes is
   also a good example of international coordination, but this is at a much lesser level of
   coordination than that in drinking water. The Board recommends that the Agency take the
   lead in establishing an organization to coordinate water quality research both at the national
   and global level following the model that has been used in the drinking water arena.

       2.4.4 Emerging Issues: Based upon the SAB's knowledge of EPA's science programs,
       are those programs positioned to address the nation's emerging environmental issues
       in the coming years?

       There appears to be no Agency-wide focus on emerging issues in the Water Quality and
Drinking Water research areas.  Examples of emerging issues that  do not seem to have adequate
funding include: 1) Pharmaceuticals and Personal Care Products in water; 2) watershed
ecosystem/landscape research; 3) the need for new, cost effective approaches for water and
wastewater infrastructure renewal, and 4) urban sprawl impacts and control.  EPA appears to be
well positioned to serve as a catalyst for collaborative research in these areas.  From discussions
with ORD and program office staff, it is evident that horizon scanning for emerging issues is
given a low priority.  The SAB could play a role in providing advice to the Agency on horizon
scanning and priority setting.
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2.5 Goal 3 - Land Preservation and Restoration

       2.5.1 Alignment: Based upon the SAB's knowledge of EPA's science programs, do the
       planned science activities included in EPA's FY 2006 budget align with the Strategic
       program priorities identified by EPA's Research, National Program, and Regional
       offices?

       The EPA Contaminated Sites and RCRA Multi-Year Plans, which describe the research
needs under Goal 3, were reviewed by a Panel of the Science Advisory Board during FY 2004.
The Board agrees that research proposed in the FY 2006 budget for Goal 3, largely aligns with
the strategic program priorities relating to legacy issues in waste management (i.e. issues related
to site remediation, USTs, and oil spills). There is much important and relevant research that
needs to be addressed in these areas, however, the Board is dismayed at the lack of research
proposed for non-legacy issues. In particular the Board endorses the Agency's long-term vision
for transforming environmental policy from a waste-centered to a materials-centered approach.
Although the EPA Strategic Plan, and the Resource Conservation Challenge (RCC) Strategic
Plan, articulate this vision in a highly inspirational manner, science and research issues important
to "transformation of the Nation's current waste handling system and approach towards materials
management," is proposed to receive the smallest allocation of S&T dollars.

       The Strategic Plan calls for a move toward pollution prevention (Goals 4 and 5),
development of innovative waste management practices (Goal 3), and development of voluntary
programs of materials management and resource conservation; under the Resource Conservation
Challenge (Goal 3).  The decreases in the economics and decision sciences (EDS),  STAR, and
overall sustainability budget are inconsistent with such goals. The Board believes it would be
desirable to increase funding for research in support of the RCC initiative, even if that requires
reprogramming of current research funds within Goal 3. Areas of needed research are many and
varied, and range from material flow studies and data certification,  to cooperative ventures with
industries (the Board notes and encourages the planned  effort with the electronics industries), to
appropriate policy instruments to create incentives for materials recycling/reuse/and
remanufacturing (this is treated more extensively under the Board's comments under Goal 5).

       2.5.2 Coordination: Do the science programs of EPA's National, Regional, and
       Research Offices reflect coordination among EPA organizations and do they
       complement one another?

       Science programs in Goal 3 reflect coordination among EPA organizations and these
programs do complement one another. The SAB review of the Contaminated Sites and RCRA
Multi-Year Plans demonstrated that the regions, program offices and the Office of Research and
Development have worked closely with one another. In that review, the SAB panelists observed
that researchers had an intimate understanding of the problems faced by their colleagues in the
regions and the program offices and the research needed to assist them.  In addition, their clients
were well informed of the research completed and underway that was intended for their benefit.
Also,  a separate review of the 3MRA modeling system by the SAB demonstrated close
coordination across EPA offices (ORD and OSWER).
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       2.5.3 Collaboration: Based on EPA's presentations to the SAB, and Board members'
       own knowledge of efforts in the broader scientific community, how well does EPA's
       science program appear to complement environmental science programs elsewhere? Is
       there evidence that EPA's efforts are coordinated with the science efforts of other
       governmental organizations and relevant organizations outside of government? Is
       there evidence that EPA has an approach for capturing the science products from
       these other organizations? Are there ways the Board could suggest that will enhance
       this coordination?

       There is considerable evidence, albeit anecdotal, that the Agency greatly values
cooperative research with other government agencies and organizations outside of government.
In the review of the Contaminated Sites and RCRA Multi-Year Plans the Agency documented
that they engaged in extensive coordination with other agencies and organizations. Still, the
exact amounts of leveraging of Agency S&T dollars, the nature of the cooperative research, and
trends over time have not been reported. The Board believes there is a need to quantify the type
and amount of support received from other agencies and organizations both inside of and outside
of government for specific research. Such information should be made available to the Board
routinely as part of the science and research budget advisory and for each such review.  It would
be helpful  if this information would include trends over the preceding 5 fiscal years.

       Information on the amount of Agency resource leveraging can be helpful in showing 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 (importantly,
one needs  to recognize that this statistic reflects the presence of substantial Earth sensing
programs at the NASA, DOD energy programs, and NSF grants). 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 (e.g., the de-emphasis of EPA's ecosystem
research funding  and its impact on other agencies having complementary programs). The Board
understands that its purview is limited to EPA's science and research budgets, and it does not
suggest that its review be extended to the entire federal environmental research budget, but it is
concerned that lack of this additional information might cause it to underestimate the overall
national impact of resource changes in EPA's science and research program. The Board also
understands that research conducted with other agencies' support, although similar in topical
area to EPA's, may lack the nuance needed for EPA which is charged with the responsibility of
regulating environmental risk. However, this underscores the need for the Agency to present the
Board with more information on the type of cooperation on research in which they interact
across and beyond the government.

       2.5.4 Emerging Issues: Based upon the SAB's knowledge of EPA's science programs,
       are those programs positioned to address the nation's emerging environmental issues
       in the coming years?

       The SAB  believes that EPA science programs in support of strategic Goal 3 are not well
positioned to address the nation's emerging waste management issues. The distribution of Goal
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3 funds is heavily weighted towards legacy problems, in part because this is a requirement of the
trust funds that have traditionally supported many of these programs. This is inconsistent with
the visionary environmental plan presented in the Resource Conservation Challenge, which is an
effort within the Agency that engages various stakeholders in voluntarily examining their
material flows with the aim of identifying opportunities to limit waste without diminishing
profits.  Currently, few resources exist to address emerging environmental issues relating to
waste management.  One possible use of a portion of the $20 million set aside  in the new pilot
project to support Program Office initiated research within ORD, would be to invest in
structuring a framework  for identifying and addressing emerging environmental issues across  all
five goals.

       The Board believes that the transformation of environmental policy will require
significant investment in education, as specified in the RCC.  The Agency may wish to consider,
as part of its research portfolio,  the funding of innovative environmental education programs
beyond the STAR graduate fellowships, perhaps in partnership with the Department of
Education or National Science Foundation.

       Finally, in support of Goal 3's emerging research needs, the Board recommends that the
Agency undertake a long-term project on the establishment of National Material Flow Accounts,
and relate this information to existing national income accounts (GDP, etc) and/or economic
input/output tables.  Such information could provide benefits to the Nation in three essential
areas:

   1) Improvement of economic, trade and national security, and technology development policy
   by enhancing our understanding of the material basis of the economy.

   2) Improvement of natural resource policy (minerals, forest products, fuel, etc.) by enriching
   system-wide, life-cycle information on the status and trends of materials sources and uses,
   final disposition and other aspects of supply/demand.

   3) Improvement of environmental policy by helping to identify categories of pollution
   sources, develop materials-based and product-based environmental strategies, and promote
   reuse of what is currently discarded.

Allocation of resources for such a project would be an important advance and represent a
tangible commitment toward the stated goal (Goal 3) of transit!oning US environmental policy to
a material flow basis. Many countries (including the US) already collect most of the information
necessary for MFA (for various other purposes), and many are already assembling it into MF
accounts (OECD 2004).
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2.6 Goal 4 - Healthy Communities and Ecosystems

       2.6.1 Alignment: Based upon the SAB's knowledge of EPA's science programs, do the
       planned science activities included in EPA's FY 2006 budget align with the Strategic
       program priorities identified by EPA's Research, National Program, and Regional
       offices?

       The FY 2006 science and research budget aligns with many of EPA's strategic priorities.
However; there are some areas where this alignment fails, and the cause of this failure is largely
the continued erosion of EPA science and research resources that need to be applied to critical
areas of EPA's mission to protect human health and the environment.

       The human and ecosystem health request, in support of Strategic Goal 4, is very similar
to the President's requested budget for 2005 (US EPA, 2004a). Thus most of the Board's
comments on that budget apply to the current request (US EPA SAB, 2004c). While the Board
recognizes the limited resources available for domestic spending, this budget continues the
pattern of essentially level-funding for most programs, resulting in a gradual erosion of EPA
research capacity due to inflation. As  in the 2005 budget request, there is significantly reduced
funding for ecosystems science and research, in particular in the Agency's extramural funding
(STAR program).  The fact that funding for STAR extramural grants in the area of ecosystems
health was not included in this year's request continues to be troubling, for reasons that are
discussed later in this section.  Below, we also discuss some aspects of significant programs that
are identified in the FY 2006 science and research budget.

       a) The Advanced Monitoring Initiative (AMI):  The FY 2006 request includes a new
program, the AMI. Initiatives proposed such as the AMI and the nanotechnology program are
laudable and address EPA strategic priorities and hold great potential to advance environmental
health sciences (see additional discussion of the AMI in section 2.3.3 above). Integrating EPA
AMI activities into a recognizable program will strengthen the ability of EPA to leverage the use
of other agencies'  data to address EPA needs. Unfortunately the EPA AMI is clearly funded by
realignment of funds currently supporting other EPA strategic priorities  such as mercury, air
quality standards and persistent, bioaccumulative toxic chemical (PBT) research.

       The AMI leads a trend toward more observational and less basic research activities.
Although the overall funding in Goal 4 is nearly level, the goal includes considerable
programmatic change implemented via a budgetary strategy of funding realignments. This
strategy allows the agency to propose new or expanded initiatives without new funds. However,
the Agency should carefully consider whether an extensive realignment  strategy may have
unintended and negative consequences.  The SAB cautions that there may be little or no net gain
as the potential utility of any scientific advances may be offset by the loss of the activities
previously supported by the realigned funds. Realignment may also create additional imbalances
in the Agency's research portfolio.

       b) Disparities Between the Budget and Priorities: Mercury and Endocrine Disruptors:
Some of the Agency's most important programs have been progressively reduced over the last
few years.  These programs include the mercury research program, the endocrine disrupters
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program, and the STAR research program (including the exploratory research program).
Endocrine disrupters and mercury are among the agents that may have the greatest impacts on
ecosystem and human health and the SAB is concerned that the reduction of the programs is not
in accord with the Agency's stated goals. These programs have been progressively reduced in
funding even though they are already funded at relatively low levels. Given the high priority of
mercury as a contaminant, and the fact that not enough is known about its sources, fate,
transport, and health effects, we caution the Agency to prioritize the research needs for mercury
and continue to address them aggressively (see section 2.3.1 above for additional comments on
mercury research).

       c) Ecosystems Research: Among the major elements of the Agency's strategic plan is a
commitment to "protect, sustain, and restore the health of natural habitats and ecosystems."
Fundamental to this objective is creation of scientific tools to assess the current condition of the
nation's ecosystems and the application of these tools to assemble a coherent picture of the state
of our ecological systems. The importance of this objective is underscored by the conclusions of
the Agency's Report on the Environment (US EPA, 2003a), as well as the independent "State of
the Nation's Ecosystems" report of the Heinz Center (The Heinz Center, 2003), that most of the
information required to characterize and track changes in ecosystem health is not currently
available nationwide. This research not only informs Goal 4 objectives, but also supports efforts
under EPA's other strategic Goals. For example, the ecological indicators that were being
developed under ecosystems research were to be the next generation of integrated indictors for
use by the States to meet their assessment requirements under the Clean Water Act (303 listings).
Yet, the FY 2005 budget made deep cuts in the programs related to ecosystem assessment (e.g.
ecological indicators) and the FY 2006 budget request makes even deeper cuts, including nearly
$5M from Western EMAP, National Coastal Assessment, and Regional Vulnerability
Assessment programs. These cuts appear emblematic of a broader trend to cut ecosystem
research, despite its  fundamental importance to the Agency's mission.  To some degree, the
erosion in ecosystem research may be due to the unfortunate mismatch between accountability
evaluations that seem to emphasize near-term results and the long-term nature of ecological
research. We strongly urge the Agency to reverse the erosion in ecological research, determine
the most effective ways to proceed with ecological assessment, and reinstate funds to pursue
them.

       d) Extramural Research: The Science to Achieve Results (STAR) grants programs
corresponding to ecological indicators, endocrine disrupters, and mercury that were  eliminated in
the FY2005 EPA science and research budget are also not included in the FY 2006 budget. This
program was highly regarded in the NAS review "The Measure of STAR: Review of the U.S.
Environmental Protection Agency's Science to Achieve Results (STAR) Research Grants
Program" (NAS/NRC, 2003).  The Board restates its belief that the sacrifice of extramural
research programs comes at a significant and long-term cost to the Nation's need for knowledge
on important issues that will permit the development of environmental  policy and  that will be
necessary for informing international debates on U.S. products that compete in the international
market place.

       Extramural research provides four essential functions, which are lost when such funding
is diminished.  Extramural research: a) allows access to expertise outside of the Agency; b)
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invigorates the science being conducted; c) provides a flexible mechanism to identify and
address emerging issues; and d) allows EPA to leverage funds with other agencies or partners.
Thus, reducing extramural funds has both direct and indirect effects, and can be equated to
spending one's investment principal.

       e) The Exploratory Research portion of the STAR program within Goal 4 (historically
funded at approximately 10% of the total STAR budget) provides a small but important pool of
funding for innovative and cutting-edge research that intends to provide EPA programs with
knowledge and understanding that anticipates issues of concern for the future.  Exploratory
grants have served as the Agency's long-term investment in exploring future emerging issues.
The Exploratory Research program has been cut in half in the F Y 2006 budget, (about $5M), and
the remaining $5M will be dedicated to research related to nanotechnology.  While research on
nanotechnology is  a clear priority and at the cutting edge of environmental science, there are
severe limits to funds to explore other emerging issues (some limited exceptions  are discussed
in section 2.6.4 below).

       The Board believes that this situation makes the Agency more vulnerable to being
blindsided by future issues or challenges, and will place EPA further behind in its ability to use
and/or evaluate new technologies and new problems. This gap in exploratory research will not
be filled by the private sector; in fact a recent survey showed that when the government invests
less in basic research,  the private sector follows suit.

       f) The Pilot Research Program: Current plans call for specific program offices to have a
call on EPA ORD resources to support near term research efforts.  These are now allocated to
offices in shares, $4.5-million for each of several specific programs (i.e., air, water, pesticides
and toxic substances, and waste). Another $2-million is identified for policy and economics
research. In the future, the agency might do well to think about whether prior allocation of
"office-specific shares" is the best strategy or whether, within some limits, the allocation might
be adjusted in response to the quality of research questions identified.

       In the Board's view, it is important to design this pilot program with  specific objectives
in mind and to include an independent evaluation which will allow it to be improved with time.
It would be desirable if an allocation strategy could be developed which requires that written
proposals be developed and independently reviewed, and which gives preference to those which:

          1) Make a strong case that the proposed work involves research, not simply funding
             for ongoing operations;
          2) Addresses an important programmatic problem for which funding is currently
             scarce and is receiving too little attention; and
          3) Provides a specific discussion of how the proposed activity will be evaluated so as
             to contribute to the overall evaluation of the pilot program.

Proposals that address problems that are likely to be of concern to more than one office or that
contain multi-media, multi-program, or multi-regional elements should be preferred to those that
do not.
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       We believe that this program could be very valuable to improving the ability of Agency
research and development to contribute to the day-to-day needs of the Agency's programs. At
the same time, we caution that it is important to not allow too large a proportion of ORD's
research to become too tightly tied to the day-to-day information needs of Agency offices and
regulatory schedules, because that situation could begin to seriously erode EPA's science base
and its ability to address new problems and improve future performance.

       g) Climate Change:  The Board applauds the continued support of the Climate Change
Science Program. It is encouraged to learn that the CCSP program has done an internal budget
analysis across the participating agencies, including EPA, and notes that while the Climate
Change program has been asked to expand their activities, that funding is similar to last year.

       2.6.2 Cooperation:  Do the science programs of EPA's National, Regional, and
       Research Offices reflect coordination among EPA organizations and do they
       complement one another?

       Over the years that the SAB has reviewed the EPA science and research programs it has
seen a steady improvement  in the coordination between EPA administrative units and the
alignment of the extramural research funding to complement research at EPA. EPA science and
research coordination are a  model that other agencies should emulate. This  approach has allowed
EPA research to remain highly productive in the face of stagnant or decreasing funding.
Examples  of successful intra-Agency collaboration include the endocrine disrupters research
program, the computational toxicology program, and the genomics program. The Board notes
that the leveraging of extramural research programs and partnerships can be readily quantified;
however, this has not been done and thus the full extent of intra-Agency cooperation is not as
transparent as it might be.

       The increased emphasis within the Agency on expressing research outcomes rather than
outputs also  underscores the need for improved coordination within and outside of the Agency.
For example, the Office of Water may need the results from specific Regional office REMAP
projects to demonstrate the  effectiveness of an outcome measure, or evaluation of the NHANES
data from CDC may  assist the Agency in assessing the effectiveness of a given rule aimed at
reducing exposures to pollutants.

       2.6.3 Collaboration: Based on EPA's presentations to the SAB, and Board members'
       own knowledge of efforts in the broader scientific community,  how well does EPA's
       science program appear to complement environmental science programs elsewhere? Is
       there evidence that  EPA's efforts are coordinated with the science efforts of other
       governmental organizations and relevant organizations outside of government? Is
       there evidence that  EPA has an approach for capturing the science products from
       these other organizations? Are there ways the Board could suggest that will enhance
       this coordination?

       EPA  has not only organized its programmatic and research efforts to align with the
agency strategic goals, but also is a leader in partnering with other federal agencies with shared
interests. These highly successful partnerships have provided results of utility to EPA far
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beyond what could have been anticipated had they attempted to build the programs alone.  The
proposed AMI effort and the EPA participation in the National Children's Study continue this
tradition.

       EPA's research programs complement specific programs in many other federal agencies
(NIH, CDC, NASA, NOAA, and others), state agencies, University-based programs and
industrial research programs. An excellent example includes the endocrine disrupters program,
which partners with other Federal agencies and industry, and funds extramural research with
academia. These coordinated efforts allow the EPA to leverage their limited funds to conduct
more of the necessary research required to make science based regulatory decisions.

       Another excellent example of these coordinated activities is EPA's leveraging funds with
other agencies including NIH and CDC and universities in the support of the Children's Centers
for Environmental Health Disease Prevention programs and the National Children's Study. In
addition, the Agency has begun to work with industry in establishing basic and clinical research
endeavors. Other examples include the EMAP program, which collaborates with the States by
transferring statistical designs for probabilistic monitoring to their agencies; the collaboration of
EPA with NIOSH and NIST on nanotechnology research; and the collaboration of EPA with
NIEHS and DOE on computational toxicology.  Such programs, when conducted with the
highest scientific and ethical standards, provide an opportunity to leverage EPA research needs
and industry and other resources and research needs to protect the environment and human
health. In complementing and coordinating their research programs the EPA captures a broad
array of scientific products (data and technology). The Agency understands that, with limited
resources, they must complement, coordinate, and encourage the entire community of
stakeholders including the Federal and State agencies, universities and local communities,  and
industry.

       The SAB recognizes that the cooperative efforts of all stakeholders will be greatly
facilitated with additional efforts to enhance the ability of the Agency and other stakeholders to
access and share data that each agency may have, such as EPA environmental data, CDC
NHANES data, and health disease tracking and local registries of cancer, autism or other
diseases.  The Board strongly encourages the Agency to pursue such collaborative ventures to
maximize leverage of limited resources, including joint extramural  research programs,
cosponsored initiatives, and the like.

       2.6.4 Emerging Issues: Based upon the SAB's knowledge of EPA's science programs,
       are those programs positioned to address the nation's emerging environmental issues
       in the coming years?

       The Agency is  losing ground in its ability to address emerging issues, and its current
efforts are at the margins. In the past, EPA steadily improved its capacity to anticipate and
respond to emerging issues in part by maintaining a strong science program  that included a
substantial commitment to "core" or long-range research. The ability to outsource research on
emerging issues also helped the Agency to nimbly investigate new issues without permanently
building in-house capacity.  This positive trend appears jeopardized, however, by the current
budget environment in which significant cuts have been made to long-range ("core") research in
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areas such as ecosystem condition and the outsourcing programs (i.e. competitive research grants
under STAR). The Board noted last year that cuts in the STAR program, particularly in the area
of ecological indicators, weakened the Agency's ability to address new issues and we reiterate
that concern again this year.

       To its credit, the Agency has identified many emerging issues that are important (e.g., the
promise and potential threats associated with nanomaterials, the ecological disruption caused by
invasive species, the non-linear dose response of low level exposures of endocrine disrupting
chemicals, and the effects of genetically modified organisms on natural systems). Activities in
these areas are ongoing within the Agency, although at a relatively low and static funding level
that is not conducive to developing a strategic response that ultimately can address the challenge.
In the case of nanomaterials, the Agency has dedicated $5M in Exploratory Research grants to
the issue which we view as a minimally appropriate level of extramural funding; as with the
other emerging issues, the internal Agency effort in both science and strategic planning appears
inadequate to the challenge.

       The SAB stresses the need for the Agency to develop and support a mechanism for
addressing emerging issues, one that is integral to the Agency's operations.  The current budget
erodes, rather than enhances, this  capability.  The SAB recommends that the Agency develop a
new strategy for addressing not only legacy issues, but also to addressing issues for the future.

2.7 Goal 5 - Compliance and Environmental Stewardship

       2.7.1 Alignment: Based upon the SAB's knowledge of EPA's science programs, do the
      planned science activities included in EPA's FY 2006 budget align with the Strategic
      program priorities identified by EPA's Research, National Program, and Regional
       offices?

       A major reorganization of the science and research funding areas in Goal 5 is planned for
FY 2006, attributed at least in part, to the U.S. government's performance assessment system. In
particular, funding for the pollution prevention (P2) and green chemistry programs (as well as a
few others) have been reassigned  to "Economic and Decision Sciences" and "Sustainability."
Concurrent with this reorganization is a major cut in funding. The S&T portion of this area is to
decrease from about $50 million to about $44 million. The total science and research dollars
attributed to the goal is to decrease from $69 million to about $58  million.  Specific Board
comments on Goal 5 science and research are in the following paragraphs.

       a) Voluntary Programs and Incentives: A major theme running through all the strategic
goal descriptions in the EPA 2003 - 2008 Strategic Plan (US EPA, 2003c) is the need to move
forward where possible from the largely command and control regulatory regime that is now the
cornerstone of U.S. national environmental policy. For example, the Strategic Plan calls for a
move toward pollution prevention (Goals 4 and 5), development of innovative waste
management practices (Goal 3), and development of voluntary programs of materials
management and resource conservation; under the Resource Conservation Challenge (Goal 3).
This proposed shift raises two important questions.  The first is how to encourage such voluntary
actions.  The second is determining the proper mix of public sector and privately funded
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research on improved waste management practices, innovative pollution control technologies,
and pollution prevention.

       1) Research on Incentives: The Strategic Plan expresses the hope that voluntary actions
       by individuals and industry can be relied upon to improve the state of the nation's
       environment.  However, the behavioral, social, and decision sciences necessary to
       support environmentally effective programs that rely on voluntary incentives are at an
       early stage of development.  In particular, while the literature has identified some
       effective, targeted programs that have led to real environmental improvement at small
       scales, there is little or no research supporting the view that costly or major changes in
       the production processes of firms or individuals  can be expected to occur in the absence
       of major financial incentives. There is also little research to support the provision of
       guidance on the design of programs to encourage voluntary actions.  Understanding
       incentives and constraints is important in explaining actions and choices of people.  A
       useful analogy is the volunteer army: while it is true that volunteers can staff an army,
       much higher incentives (wages and benefits) are needed than when the army is
       conscripted.  The move to a voluntary army was undertaken only after a substantial body
       of research was  done on the labor market and the potential supply of labor to the military.

             If the EPA is to try to increase its use of voluntary mechanisms to achieve
       increased environmental improvement and compliance, it must significantly invest in the
       appropriate disciplinary and interdisciplinary research to provide the basis for this
       approach. This  research would need to assess the magnitude and form of incentives, such
       as tax breaks, direct payments, non-financial compensation, information provision, etc.,
       necessary to achieve increased environmental performance by a broad variety of private
       sector agents (industries, households, farmers, etc.). Previous STAR grant projects have
       made useful contributions to our knowledge about these issues. For example, studies that
       1) identify the sectors where voluntary programs will be most effective, 2) identify
       community actions that effectively motivate firms to improve environmental
       performance, and 3)  develop communication methods to improve the management of
       hazardous waste by households at lower costs. But, there is much to learn, and more of
       this kind of research is needed.

       2) Public vs. private  research funding: The Board questions the appropriate mix of private
       and public and spending on research for pollution prevention. The Board believes that
       the need is for stronger incentives that will induce more private sector research on
       pollution prevention. There is a special need for market-based incentives that reward
       pollution prevention with lower costs and higher profits.  These incentives could take the
       form of cap and trade programs, taxes on pollution discharges, deposit-refund systems,
       disposal fees, and so forth.  The Board believes that the Agency should devote more of its
       own resources to research on market mechanisms and incentives aimed specifically  at
       rewarding pollution prevention. This could be done by some combination of increased
       support for the market mechanisms and incentives component of the Economics and
       Decision Sciences program under ORD and additional support for the National  Center for
       Environmental Economics.
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   b) Strategic Approaches to Risk Communications: A strategic approach to risk
communication is crucial to ensuring that the agency's investments in data collection and
research have public value.  The goals of increased compliance, pollution prevention, and
environmental stewardship elucidated in Goal 5 relate fundamentally to social science and/or
interdisciplinary questions.  Yet, social science research and genuine interdisciplinary efforts
that span the social and hard sciences and, thereby, yield new conceptualizations remain
vastly under funded and underutilized.

   Risk communication serves various purposes and takes on different forms throughout the
risk evaluation and management process (PCCRAM 1997; CSA 1997). It is integral to
defining a risk issue, gathering the data to  assess the technical and societal dimensions of the
issue, selecting the risk management option/s, and evaluating the impacts of the option
implemented. Effective risk communication is more than applying a set of skills - e.g.,
crafting a message, segmenting an audience, and writing a brochure or public service
announcement.  Strategic risk communication relies on a comprehensive systems orientation
and is based on scientifically derived facts - not guesses - about risk perception, social
dynamics, linked contexts, and cultural views.  The sciences that contribute to strategic risk
communication approaches include but are not restricted to the decision sciences,
psychology, behavioral sciences, sociology and anthropology. Unfortunately, although EPA
was once a leader in supporting risk communication research and has produced many
publications with risk communication guidance, the new generation of risk communication
knowledge is significantly under funded and now appears to be undervalued by much of the
Agency.  To increase the impact of the agency's research on public policy, a much broader
view of risk communication and the sciences that underpin strategic approaches to
communication is essential. This cannot be achieved without greater recognition and
incorporation of social science knowledge and methods into the agency's research and
programs.

   c) Compliance: Environmental compliance activities are another area in which EPA's
scientific research does not align effectively with its priorities. One of EPA's strategic
objectives is to "strengthen the scientific evidence and research supporting
environmental...decisions on compliance, pollution prevention, and environmental
stewardship." EPA's subobjective 5.1.3 calls for a 5% increase in enforcement actions." Yet
this strategic objective is undercut by deficiencies in research funding for enforcement.  The
overall S&T research funding is low and the increased needs of homeland security have
resulted in the shifting of some NEIC assets within this key, specialized investigative unit of
EPA, to homeland security issues. While some of NEIC's science in this area may be useful
for non-homeland security issues, the Board is concerned that this change might significantly
restrict EPA's ability to continue to prosecute the most significant violations of EPA
regulations and enforce them using evidence derived from scientifically credible methods.

   d) Social Sciences: The funding of the science and research supported by the NCEE as
well as the "Economics and Decision Sciences" within ORD supports the attainment of goals
1-4 as well as goal 5. The agency has made progress in developing a coherent economics
research program by establishing the NCEE; however, there is no evidence of such progress
for any of the other social sciences. Expanding EPA's science and research activities in
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   social sciences, to include more than environmental economics, is essential if EPA is to be
   able to address emerging environmental issues in the future.

       2.7.2 Cooperation: Do the science programs of EPA's National, Regional, and
       Research Offices reflect coordination among EPA organizations and do they
       complement one another?

       Agency staff who work in this Goal area described information sharing activities for EPA
research during their discussions with the SAB at its February 2005 meeting.  However, those
discussions did not make clear the full extent to which offices coordinate their research programs
that generate needed knowledge, tools, or methods. Much of this appears to be agency scientists,
who have different though complementary disciplinary backgrounds and who work on different
pieces of specific problems, having occasional interactions to share their individual research
progress. This provides a very limited cross-disciplinary and/or cross-mission integration of
EPA's  scientific program.

       The more complex an environmental issue the more important it is that related problems
be addressed using a comprehensive, systems-based approach and inter- or trans-disciplinary
models (pp. 3-4 of Stokols et al, 2003). The number  and complexity of emerging environmental
concerns (e.g., global warming, ecosystem degradation, and water source protection) demands a
meaningful re-conceptualization of the agency's research enterprise to addresses these issues.
Full integration of diverse sciences, with appropriate  structures and incentives to sustain that
integration, is difficult but essential. New knowledge about effective ways to initiate and
implement scientific collaborations should be utilized by the agency (Rhoten, 2004; Stokols et al,
2003). Without redesigning the agency's approach to such research activities, scientific  progress
will be too slow to effectively address these combined legacy and emerging environmental
problems.

       2.7.3 Collaboration: Based on EPA's presentations to the SAB, and Board members'
       own knowledge of efforts in the broader scientific community, how well does EPA's
       science program appear to complement environmental science programs elsewhere? Is
       there evidence that EPA's efforts are coordinated with the science efforts of other
       governmental organizations and relevant organizations outside of government? Is
       there evidence that EPA has an approach for capturing the science products from
       these other organizations? Are there ways the Board could suggest that will enhance
       this coordination?

       EPA should think in broader terms about ways to leverage their research resources within
the research community outside of EPA. One approach may be to partner more extensively with
other public agencies and private, nonprofit entities to jointly fund research, especially in the
social sciences area. Both the NIH and the CDC have followed such strategies. EPA's own ETV
program is a good model, though it is limited to technology transfer. Partnering with private
sector resources may be useful as well. While it is important to recognize that in some areas,
EPA will be the exclusive source of science because of EPA's specific mandates and authorities,
private research can be effective in developing cost saving methods for pollution reduction
and/or prevention.
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       The Pollution Abatement Control Expenditures (PACE) survey is the sole source of
significant amounts of information concerning the costs of meeting environmental regulations. It
is developed through the collaboration of the EPA's NCEE and the Bureau of the Census and it
has been responsible for developing a useful time series of data on this topic. It is critical that
EPA's funding for this critical survey be continued.

       2.7.4 Emerging Issues: Based upon the SAB's knowledge of EPA's science programs,
       are those programs positioned to address the nation's emerging environmental issues
       in the coming years?

       With the growing U.S. population, increased demands for environmental resources,
changing standards of living, and performance expectations, as well as the increasingly complex
nature of emerging environmental issues (noted in section 2.7.2 above), there is a need to
improve our understanding of people's views and responses to environmental concerns.  Thus,
increased research in the social sciences is essential to understand organizational, individual, and
group concepts and behaviors associated with environmental issues.
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                                     REFERENCES

Barnes, K.K, et al. 2002. Water-Quality Data for Pharmaceuticals, Hormones, and Other
   Wastewater Contaminants in U.S. Streams, 1999-2000.  United States Geological Survey
   Open File Report USGS OFR-02-94, Iowa City, Iowa.

CSA. 1997. Q850 Risk Management: Guideline for Decision-Makers. Canadian Standards
   Association. Toronto, Canada.

NAS/NRC (National Research Council). 2003. The Measure of STAR: A Review of the US
   Environmental Protection Agency's Science to Achieve Results (STAR) Research Grants
   Program. National Research Council of the National Academy of Sciences, Board of
   Environmental Studies and Toxicology. Washington, DC, 192 pp.

NAS/NRC (National Research Council). 2003b. Air Emissions from Animal Feeding Operations:
   Current Knowledge, Future Needs. National Research Council of the National Academy of
   Sciences, Board of Agricultural and Natural Resources.  Washington, DC, 286 pp.

Organisation for Economic Co-operation and Development (OECD). 2004. Material Flows and
   Related Indicators: Overview of Material Flow Related Activities in OECD Countries and
   Beyond. ENV/EPOC/SE(2004)/ADD.OECD, Washington, DC.

PCCRAM. 1997. Risk Assessment and Risk Management in Regulatory Decision-Making: Final
   Report., Vol. 2. Presidential/Congressional Commission on Risk Assessment and
   Management. Washington, DC.

Rhoten, D. 2004. "Interdisciplinary research: Trend or transition." SRRC Quarterly: Items and
   Issues. 5(1-2):6-11.

Stokols, D, et al. 2003. "Evaluating transdisciplinary science." Nicotine &  Tobacco Research.
   5(Supplement 1):S21-S39.

The Heinz Center. 2003. The State of the Nation's Ecosystems. The H. John Heinz  III Center for
   Science, Economics, and the Environment, http://www.heinzctr.org/ecosystems/report.html.
   Washington, DC.

US EPA. 2003 a. Draft Report on the Environment 2003. EPA Office of Environmental
     Information and Office of Research and Development. EPA-260-R-02-006, June 3, 2006.

US EPA. 2003b. EPA Environmental Economic Research Strategy. US EPA ORD, National
   Center for Environmental Research  and National Center for Environmental Economics.
   Review draft dated January 21, 2003.

US EPA. 2003c. 2003 - 2008 EPA Strategic Plan: Direction for the Future. U.S. Environmental
     Protection Agency. EPA-190-R-03-003. September 30, 2003.

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US EPA. 2004a. Fiscal Year 2005 Justification of Appropriation Estimates for the Committee on
     Appropriations.  EPA-205/R-04-001. Office of the Chief Financial Officer, U.S.
     Environmental Protection Agency.

US EPA. 2005. Fiscal Year 2006 Annual Performance Plan and Congressional Justification.
     Office of the Chief Financial Officer, U.S. Environmental Protection Agency.
     http://www.epa.gov/cgi-bin/epaprintonly.cgi.

US EPA SAB. 2004a. EPA 's Drft Report on the Environment (ROE) 2003; An Advisory by the
   ROE Advisory Panel of the EPA Science Advisory Board. EPA-SAB-05-004.

US EPA SAB. 2004b. Review of the Environmental Economics Research Strategy of the U.S.
   Environmental Protection Agency; A Report by the EPA Science Advisory Board,
   Environmental Economics Advisory Committee. EPA-SAB-04-007. July, 2004.

 US EPA SAB. 2004c. Advisory Report on the Science and Research Budgets for the U.S.
     Environmental Protection Agency for Fiscal Year 2005; A Report by the EPA Science
     Advisory Board. EPA-SAB-ADV-04-003. March 19, 2004.
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