THE PLANNING AND 'MANAGEMENT OF RESEARCH
AND DEVELOPMENT ACTIVITIES WITHIN EPA
A Report to the President and the Congress
U.S. Environmental Protection Agency
June 30, 1978
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EXECUTIVE SUMMARY
This report describes a study conducted by EPA in response to a
directive contained in Section 7(c) of the Environmental Research, Develop-
ment, and Demonstration Authorization Act of 1978. Specifically, this study
has two objectives: 1) to determine the causes of the operational problems
identified in recent studies of EPA's research management process; and 2)
to develop specific corrective measures to alleviate these problems and
assure the most effective use of the Agency's substantial research and
development (P.&D) resources.
Two intra-Agency groups were formed last year to achieve these two
objectives. The first group was a policy-level committee consisting of all
the Assistant Administrators, the Executive Director of the Science Advisory
Board and key Regional and laboratory representatives. This group was
responsible for overall direction and decision-making. The second group
consisted of Agency-wide senior staff members, whose function was to
provide necessary analysis and support to the policy-level group.
The analysis of the causes of the operational problems within EPA's
research management process revealed that the Agency lacked the following
fundamental components: 1) a coherent research strategy which related
program objectives and priorities to research activities; 2) effective
communication and decision-making mechanisms between researchers and
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programs; 3) an adequate program of long term and anticipatory research;
4) adequately responsive research results; and 5) consistent research
quality. In order to gain insight into the specific mechanisms which
might be used to alleviate these problems, the R&D management systems of
the Fish and Wildlife Service, the Nuclear Regulatory Commission, the
Food and Drug Administration, and the Occupational Safety and Health
Administration were examined. Certain aspects of each of these systems
were incorporated into EPA's revised R&D planning and management system.
The policy group determined that the Agency's R&D problems have not
resulted from the way the R&D program is organized so no provisions for
major reorganizations are included in the revised system.
The revised R&D planning and management system does, however, contain
five major components which differ significantly from previous EPA R&D
systems, and which are clearly linked to the five major deficiencies
identified above. Specifically, these components are:
1) the identification of distinct research planning units around
which coherent regulatory program/research strategies can be
developed;
2) the establishment of permanent Research Committees for each
research planning unit and a separate Research Oversight Committee
composed of top EPA managers who will review strategy develop-
ment and provide oversight throughout the R&D planning and imple-
mentation cycle;
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3) the tying of R&D planning and management processes into Agency-
wide management processes with decision rules focused on these
connections;
4) a Research Incentive System designed to encourage responsiveness
to Program and Regional research needs; and
5) the incorporation of peer review mechanisms throughout the plann-
ing and management process to improve research quality.
Sines tha revised system for R&D planning and management represents a
major departure from previous EPA systems, the policy-level group decided
that it should be tested on a pilot-study basis. Five pilot projects were,
th*=-"pfore, initiated on March 15 and will be monitored closely for a six
month period. The pilot areas include research activities in the areas of
drinking water, industrial wastewater control, mobile source air pollutants,
pesticides, and respirable particulate matter. A report on the pilot-study
results will be provided to the Committee on Environment and Public Works
and the Committee on Science and Technology by October 31, 1978. This
report will include a description of the experience of each pilot area,
recommended changes in the R&D planning and management system based on the
pilot experience, and steps undertaken to extend the approach to other EPA
research and development activities.
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THE PLANNING AND MANAGEMENT OF RESEARCH
AND DEVELOPMENT ACTIVITIES WITHIN EPA
A Report to the President and the Congress
I. INTRODUCTION
A. Purpose
This report has been prepared in response to a directive contained
in Section 7(c) of the Environmental Research, Development, and
Demonstration Authorization Act of 1978. It also reflects more
wide ranging efforts by EPA to improve its research management
capabilities.
The purpose of the report is twofold:
(1) To determine the causes of the operational problems
identified in recent studies of EPA's research management
process; and
(2) To describe the specific corrective measures that are now
being implemented in order to alleviate these problems
and assure the most effective possible use of the Agency's
substantial R&D resources.
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B. Recent Activities
Two intra-Agency groups were formed last year to address the
various concerns that have been raised in recent years. The
first was a policy level committee consisting of all the Assis-
tant Administrators, the Executive Director of the Science Advi-
sory Board and key Regional and laboratory representatives with
an interest in the coordination of program and research activity.
This group was responsible for overall direction and decision-
making. The second group was at the working level and consisted
of senior Agency staff members, whose function was to provide the
necessary analysis and support to the policy-level group. At the
direction of the policy group, the staff had three major responsi-
bilities:
(1) Identify current problems in the planning and
management of R&D activities;
(2) Examine systems used by selected other agencies to
plan and manage their R&D activities; and
(3) Develop organization and management options for the
conduct of the R&D program at EPA.
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II. ANALYSIS OF PROBLEMS
A. Summary of Problems
The problems facing EPA's R&D program have been described and
discussed by several Congressional committees, the National
Academy of Sciences, and the Office of Technology Assessment and
were confirmed by the EPA internal working group in its review.
These problems include insufficient attention to long-term
anticipatory research, a general lack of responsiveness to
the programs' regulatory concerns and the uneven quality of
EPA research.
An analysis was undertaken of each of these problems to determine
the underlyirsn causes, looking particularly at the inadequacies of
past EPA research planning and management systems. A summary of
this analysis is presented below.
B. Causes of Problems
1. Inadequacy of EPA's Program of Long-Term and Anticipatory
Research
Both the Committee on Environment and Public Works and the
Committee on Science and Technology have expressed a special
concern about the inadequacy of EPA's long-term and anticipa-
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tory research program. At the heart of this problem is the
need for a clear EPA commitment to devote a significant
part of its resources to well-thought-out research projects
which identify and address potentially significant environ-
mental hazards.
The appropriate balance between longer-term anticipatory and
shorter-term programmatic research is largely a matter of
experience and judgement. As described more fully below,
EPA's early experience was that of attempting to assimilate
pieces of existing programs and organizations while at the
same time trying to implement new legislation. The urgency
of legislative mandates and the demands of forming a new
organizational structure combined to create an atmosphere in
which immediate concerns inevitably assumed priority over
long-range needs.
In the past EPA has tried to improve research management and
coordination by reorganizing various elements of its research
program and by introducing a number of different planning and
control methods. While each of these changes was designed
to correct one or more perceived problems, one aggregate
result of so much change was to create the sense of continuing
instability, which promoted short-term problem solving, but
worked against a longer range perspective.
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Both the Agency and the Congressional Committees with over-
sight responsibility are now agreed on the need to correct
this imbalance in EPA's research perspective.
2. Unresponsiveness The staff group identified the following
causes for allegations that the research program is unresponsive
to EPA's "regulatory needs: (1) inadequate future planning by
the regulatory programs; (2) inherent differences in perspec-
tive between research and program staff; and (3) inadequate
communications between the two staffs.
Review of Agency program plans and interviews with Agency
program and research staff strongly indicate that the Agency
simply did not develop its program strategies in enough
detail and with specificity sufficient to permit identifi-
cation of research needs and priorities. Early research
planning was characterized by solicitation of research ideas
from the regulatory program offices. Although such a
relatively common approach did yield numerous "research
needs," it proved impossible to manage, since there was
no programmatic framework within which to assess potential
utility and to establish relative priorities.
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The second source of problems relates to the inherent
dichotomy between researchers and regulators. Researchers
tend to approach problems from a longer-term perspective,
whereas regulators must focus on more immediate concerns.
Even when attempting to address immediate needs, researchers
often require long lead-times, both in conductinr and in
redirecting their research efforts. Regu^cors, on the
other hand, are faced with immediat".-, often inflexible
deadlines which are established in legislation or court
decisions or which grow out of the need to address unantic-
ipated hazards. Regulators demand a degree of respon-
siveness which is antithetical to a stable research
environment.
Furthermore, researchers, by training and in response to the
standards of the research community, are deeply concerned
with quality of the research. Their motivation and pro-
fessional recognition is based on the quality, not the
timing of the work. Regulators, however, are primarily
interested in the timeliness and utility of information.
They are sometimes forced to make judgments on the basis of
the data which is available at the time the decision has to
be made.
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Thus, an inherent set of tensions is created because of
different professional experiences of and demands on
researchers and regulators. While these tensions can
never be fully resolved, they can be brought into a
reasonable balance that best supports the Agency's
regulatory mission.
Finally, and perhaps most significantly, there were few
effective communications channels at the appropriate oper-
ating levels of the organization. Effective linkages
between laboratory directors and their research staffs with
relevant program divisions and regional offices often did
not exist. The complex, discipline-oriented organizational
structure of the Office of Research and Development (CED),
with its fifteen laboratories, complicated communications
problems. While the discipline orientation is not an
insuperable problem itself, the lack of organizational
alignment with the structure of the regulatory program
offices tends to exacerbate the communications problems.
Without a systematic planning and management process to
compensate for these organizational complexities, decisions
have often been forced to the top of the organization, often
to the Assistant Administrator level, for resolution. But
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because of the limited time of top management to respond to
the demand for ad hoc problem solving, many problems are
simply never resolved, adding further to perceptions of
unresponsiveness and organizational isolation of ORD
within the program and regional offices.
Because of these long-standing communications problems, there
is great skepticism within the Agency as to whether any
research management system can function effectively. Fears
of paper-intensive planning systems, of undelivered promises
from ORD, of the unwillingness or inability of the regulatory .
programs to pay sufficient and knowledgeable attention to
identifying their research needs, of the conduct of "closet"
research by the program offices, and of th>e Continued
"isolation" of ORD from the rest of the Agency reflect a
history which must be appreciated in order to be overcome.
3. Uneven Quality of Research. Under these circumstances the
review, evaluation and quality control of research activities
has been extremely difficult. This has resulted in the
dissemination of research results of uneven quality. Also
complicating the problem of obtaining high quality research
are the inter-related problems of attracting and keeping
highly qualified staff within the constraints of civil service
salaries and rules and requiring that senior staff assume
supervisory duties in order to be promoted.
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This report addresses the research quality issues that can
be impacted by the planning and management process. The
research personnel issues are being addressed in an associated
study of EPA's overall personnel management efforts.
C. The Changing Situation
A brief look at the history of EPA shows that the atmosphere for
program and research coordination has changed significantly over
the last seven years. During its early years, EPA tended to
operate in a crisis mode. The enactment of a continuous stream
of new legislation during EPA's formative years demanded that
the top Agency priority be the development and implementation of
regulations. This occurred while EPA was simultaneously attempt-
"• ing to integrate a diverse set of programs and administrative
units into a viable and rational new organization. While the
research effort contributed vital information during this era
and provided expert witnesses for judicial proceedings, much of
OFD became increasingly detached from regulatory concerns and
came to be viewed as a bystander while the program and regional
offices struggled to put the major regulatory building blocks in
place.
Today, the legislative mandates of EPA are relatively stable.
All parts of the Agency have attained greater organizational
maturity. More time can now be devoted to the interaction of
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research with the regulatory efforts. Furthermore, the exper-
ience gained in the early years of the Agency's existence has
brought about a change in perspective that will be of great
assistance in this effort. A. heightened awareness of the
importance of timely, credible research is developing. There
is also a recognition of the need to use the Agency's research
resources more effectively.
Finally, and most importantly, top management now has a commit-
ment to manage the Agency. Research management is only one of
many activities under careful scrutiny. A wide range of reforms
are now being proposed and implemented which include regulatory
reforms, ZBB process improvements and personnel management
reforms. The reform of the research management process is a
significant element in this agenda for action.
D. Relating Solutions to Problems
In order to have impact, proposed solutions must be directly
related to, and able to solve, the problems being addressed.
While this seems obvious, organizational solutions are pre-
scribed, more often than not, when, in fact, the underlying
problems call for quite different remedies. This analysis
includes a careful linking of identified problems with proposed
solutions.
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The lack of a programmatic context for environmental research
calls for the development of a coordinated program/research
strategy. Only then can major goals and objectives be iden-
tified, coherent plans developed and implemented, and results
evaluated.
The lack of adequate communication channels and decision-making
procedures underscores the need for structured and meaningful
interactions among the appropriate research, program, and
regional staff, as well as outside experts.
The inadequacy of the current program of exploratory research
calls for provisions in the planning and management process to
protect and enhance those longer-term efforts which have the
potential to help solve future environmental problems.
The perceived inadequacy of research findings in terms of
usefulness and timeliness calls for innovative approaches through
which program and regional offices can assure responsiveness to
their regulatory and enforcement needs.
Finally, the uneven quality of research results emphasizes the
need for qualified peer review of research plans, protocols, and
findings—in fact, that quality must be built into each step of
the research planning and management process was an inescapable
conclusion.
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The following matrix summarizes the results of our analysis.
Problem
Corrective Action
Lack of research strategy Program context for
research management
Lack of adequate communi-
cations and decision-making
Inadequate program of long-
term anticipatory research
Inadequately responsive
research results
Communications and
problem solving at
operational levels
Protection of long-
term research activi-
ties
Greater program and
regional influence and
responsibility
Incorporation of peer
review throughout planning
and management process
E. Review of Systems Used in Other Agencies
In order to gain insight into the specific mechanisms which might
be used to address the problems identified above, the R&D planning
and management systems used in four other regulatory agencies were
examined:
Uneven research quality
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• Fish and Wildlife Service (FWS)
• Nuclear Regulatory Commission (NEC)
* Food and Drug Administration (FDA)
• Occupational Safety and Health Administration (OSHA)
For each agency, the review consisted of two components:
1) interviews with key staff in the research office, in a
program office, and in an administrative or planning office;
and 2) an examination of relevant agency documentation such as
organizational charts, functional statements and planning
manuals.
As shown in Table A, the missions of these four agencies are
quite different. There are also fundamental differences in the
way each agency obtains R&D support for its programmatic activi-
ties. In FWS, control of R&D funds rests with the program
offices while all research is performed by FWS's research
office. The NRC, on the other hand, gives funding control for
R&D to its research office which in turn "contracts" with the
Department of Energy (DOE), where most of the work is performed.
At FDA, R&D responsibilities are assigned to the program offices,
which have their own research labs. Finally, OSHA, which is
part of the Department of Labor, essentially has no research
capability. Instead, OSHA relies on HEW's National Institute of
Occupational Safety and Health (NIOSH) for the research needed
to support its activities.
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While it was determined that it would be impractical and inappro-
priate for EPA to adopt any of these R&D systems j.n toto, there
are features of each model which were found to be of significant
merit and were therefore incorporated into the design of EPA's
new R&D planning and management system. Table B presents a
summary of the major features of each agency's R&D planning and
management process. Those features which are particularly
relevant to EPA's R&D concerns are marked with asterisks. These
are the features that best addressed the basic problems identified
above.
1. Program/Research Strategies. The review of the four
indicated that none of their R&D plcinning and management
systems had evolved to the point where future planning such
as required for the development of well-coordinated strategies
was consistently being performed. Some, however, do have
formal planning procedures which show particular promise for
EPA. At NIOSH, the Director prepares a yearly research
strategy in cooperation with an OSHA-NIOSH policy group.
However, the strategy is quite broad in scope. EVJS, on the
other hand, requires its program managers to prepare detailed
strategy papers during the ZBB year which specify program
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objectives and required R&D support. These strategies are
relatively narrow in scope since they relate only to one
program manager's area of responsibility; If a middle
ground could be found between these two forms of strategy
development, a viable method of preparing well-coordinated
program/research strategies could be developed.
2. Communications Between Researchers and Programs. Each
agency examined had at least one mechanism in place for
resolving problems between program office and research
managers. The mechanism employed by NRC appears to us to
be the most adaptable to EPA's situation. Specifically,
NRC uses standing Research Review Groups which meet on a
periodic basis to resolve policy and technical issues
encountered in the research program. Each Research Review
Group, which consists of high level staff from the program
offices, the research office, and DOE laboratories, is
responsible for reviewing a particular research area. The
Research Group is also assisted by outside experts.
3. Ways to Assure Responsiveness and Protect Long-term Research.
Since responsiveness of research to program needs and the
maintenance of long-term research capabilities are inter-
dependent, both will be discussed here. The mechanism
used in EV7S offers one method for ensuring research respon-
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siveness. PWS gives R&D funding control to its program
offices. EWS feels that this arrangement gives the program
offices a vested interest in research since they must take
responsibility for seeing that R&D funds are spent on research
which supports their needs. At the same time, the researcher
feels the incentive to be responsive since funding could be
withdrawn if he does not perform in accordance with the
program's requests.
FVJS has no formal mechanism for protecting long-term research.
However, agency staff stated that there is an informal under-
standing that some of the program offices' R&D funds will,
in fact, be spent on long term research.
4. Research Quality. Maintenance of a consistent quality of
research is a goal that is not unique t^ *-he four agencies
examined or to regulatory agencies in general. Each of the
four agencies does have a procedure to be followed in the
evaluation of research (Table B). Some of the agencies also
have procedures established to ensure transfer of research
results. For example, at the NRC following the evaluation
of research, a Research Information Letter (RIL) is prepared
which includes a brief technical description and identifica-
tion of the user need, an executive summary of principal
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results and their significance to NRC, and a concise descrip-
tion of the evaluation of the results including the range of
applicability.
F. Analysis of "Organizational Solutions"
In reviewing the organizational arrangements in other agencies and
in EPA, the issue of a possible reorganization of the EPA research
program was addressed. Both centralized and decentralized systems
were analyzed. While there are advantages and disadvantages to
each approach, the critical issue becomes whether or not the
problems facing EPA's R&D program have resulted from the way it is
organized. The Policy Group reviewed a number of options for R&D
in EPA which paralleled the organizational arrangements in other
agencies, but ultimately rejected them. The reasons for rejecting
options requiring reorganization were:
o Current organizational arrangements are not at the core
of the problems facing the Agency's R&D effort.
o ORD has, in its short existence, already gone through
several reorganizations, each with an increasingly
severe impact on morale.
o A reorganization always disrupts ongoing activity. VJhen
that ongoing activity consists of research projects typi-
cally lasting two to four years, the potential costs in
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terms of projects that are aborted or seriously disrupted
is considerable.
• In examining the possibility of reorganizing EPA's research
function along program lines in a manner similar to that of
FDAf it was found that:
- Such a reorganization would be hindered by EPA's large
number of geographically dispersed laboratories and by
the fact that many are simultaneously supportive of
several different programs.
- A decentralized research program such as FDA's may
result in duplication of research effort.
• EWS's, and to a certain extent NRC's, organizational
arrangements are similar to EPA's.
e The OSHA/NIOSH arrangement where research and operational
programs are located in separate Departments does not
seem to offer a useful model for enhancing the responsive-
ness of research activities to regulatory needs.
The Policy Group, in rejecting solutions which were dependent on
major reorganization, asked rather that management system changes
be proposed which would bring about the desired improvements in
the functioning of the Agency's research program.
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III. RECOMMENDED SYSTEM
The system that is being recommended for implementation in the planning and
management of research and development in EPA has five major components:
1) the identification of distinct research planning units based on
regulatory programs;
2) the establishment of permanent Research Committees for each
research planning unit and of a separate Research Oversight
Committee composed of EPA's top management;
3) the tying of R&D planning and management processes to Agency-
wide management processes with decision rules focused on those
connections;
4) a Research Incentive System designed to assure responsiveness to
program and regional research needs; and
5) the incorporation of peer review mechanisms throughout the
planning and management process to improve research quality.
These design features are directly linked to the five major problem areas
identified earlier (See Table C). Each of these features is discussed in
detail below.
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A. Research Planning Units
This analysis has shown that many of the problems associated with
EPA's R&D program would be alleviated if a set of carefully laid-out
regulatory program/research strategies were to be developed around a
logical planning framework. The conceptual basis for the EPA R&D
planning and management system will be clusters of R&D activities
which, because of their inherent interdependencies, should be planned
and managed as a unit. The following are examples of possible
research planning units:
• hazardous air pollutants
• toxic pollutant control
• nonpoint source pollution control
* hazardous waste disposal
• safe drinking water
In many cases, research planning units will be "multi-media" and will
cross program lines or research category and budgetary boundaries.
"Toxic pollutant control" is an obvious example since three program
offices have a stake in this area of research activity. Within these
research planning units, major goals and objectives can be defined
and relative roles and responsibilities for the conduct of research
clarified. It is expected that 15-20 such research planning units
will eventually be identified with each having $10-25 million in
resources.
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B. Research Committees
In order to facilitate effective communication between ORD, Program
Offices, and Regions in overseeing the planning and conduct of
research during ZBB, planning, and implementation years, Research
Committees will be established for each research planning unit. Each
Research Committee will be chaired by a Research Manager designated
by ORD and will have representatives from relevant client offices
(Program Offices and Regions). Regional representatives will be
selected by the Regions collectively. The services of experts from
other Agencies and from outside the Federal Government will also be
used.
Each Research Committee will be a permanent body with continuing
responsibilities throughout all phases of the R&D cycle. Specifically,
the Research Committee will be responsible for:
• developing a multi-year research strategy which is based
on the relevant regulatory Program strategy, and which
identifies Agency research goals and objectives as well as
broad Program and Regional research output requirements,
• reviewing and suggesting appropriate modifications in related
ORD, Program Office and Regional ZBB decision units which
include research components in order to assure their respon-
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siveness to approved research strategies and their consistency
with regulatory components of those same and other decision
units;
• analyzing relevant research decision units in the ZEB process;
• monitoring progress during the planning and implementation
years against approved strategies and implemention plans and
suggesting corrections for significant deviations to the
relevant ORD unit;
• serving as the primary forum for resolving R&D issues encoun-
tered by the Program Offices, the Regional Offices, or ORB
during the planning and implementation years, or if unsuccessful,
referring the issues to the Research Oversight Committee;
• as time allows, reviewing and evaluating research results; and
• as time allows, recommending the appropriate timing and means
for disseminating specific R&D products.
The Research Committees, however, will act in an advisory capacity
only and will raise major unresolved issues to the Assistant Adminis-
trator for Research and Development, who will negotiate a resolution
with the appropriate Assistant and Regional Administrators. Issues still
unresolved will be raised to the Research Oversight Committee. Research
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Committees will not assume the operational responsibilities of ORD, the
Program Offices, or the Regional Offices. The development of Program
strategies, ZBB decision units, implementation plans, project workplans,
routine project evaluation, etc., will remain line management responsi-
bilities.
Research Committee Purview. Research and development activities in
EPA are grouped into three basic categories, not all of which may be
relevant to any particular research planning unit. These categories
are defined as follows:
a. Exploratory R&D* — research which is conducted primarily for the
purpose of developing fundamental knowledge and principles appli-
cable to the solution of currently intractable problems or scien-
tific questions, or research which is aimed at identifying or
understanding environmental problems on the horizon for which no
specific regulatory activity is currently contemplated.
b. Regulatory/Operational Support R&D—research in response to
identified program or regional office operational requirements,
or research designed to test current Agency, Program or Regional
assumptions but which is not immediately required in support of
* The Exploratory category will include, but not be limited to, the Anti-
cipatory Research activities funded under the Interdisciplinary budget
category.
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planned regulatory actions. It also includes technical assistance
support services in response to ad hoc needs or special
requirements that cannot be planned in detail during normal
budgeting and planning cycles.
c. Assigned Mission R&D—research in response to missions speci-
fically assigned to EPA by Congress, the White House or OMB beyond
the general requirements of the Agency's enabling legislation.
Examples include the Interagency Energy/Environment Program and
the Biological and Climatic Effects of Radiation (BACER) Program.
Most Research Committees will be responsible for research which is
primarily regulatory/operational support in nature. Nevertheless,
these Committees will be expected to address relevant activities from
all research categories that fall within the purview of the Committee's
research planning unit. This will include appropriate portions of the
Exploratory R&D and Assigned Mission R&D categories.
In addition, the Office of Research and Development will establish
Research Committees for the Exploratory R&D and Assigned Missions
R&D categories. These two Research Committees, which will be
chaired by the Assistant Administrator for Research and Development,
will include Program and Regional representatives and draw on
outside experts for consultation. The jurisdictions of these two
committees will partially overlap with those of the other Research
Committees. (See Table D).
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In addition to conducting their own independent deliberations, the
Exploratory and Assigned Mission Research Committees will receive
recommendations from the other Research Committees and will integrate
them into their priorities. The Exploratory R&D Committee will also
receive and incorporate recommendations from a "bottom-up" planning
process as called for in the report of the National Academy of Sciences,
Such a process would allow laboratories and bench-level scientists to
propose implementation of specific longer-term research projects.
In the case of Assigned Mission R&D, the Research Committee will
assure the consistency of its recommendations with priorities set by
Congress, the White House, and OMB. As with all Research Committees,
the activities and recommendations of these last two Committees will
be subject to review by the Research Oversight Committee (see below).
The Office of Research and Development will normally be responsible
for the detailed planning and implementation of projects in the
Exploratory and Assigned Mission categories. However, when changes
are made in the programs in either of these categories which might
directly or indirectly affect Regulatory Support R&D, it is the
responsibility of the Assistant Administrator for Research and
Development to inform the affected Research Committees.
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In addition to the Research Committees, a Research Oversight Committee
composed of the Assistant Administrators and of those Regional Adminis-
trators named by the Deputy Administrator will also be established.
It will be chaired by the Assistant Administrator for Research and
Development and have general responsibility for reviewing the activi-
ties and recommendations of all Research Committees and for resolving
all issues that cannot be resolved at lower levels. Specifically, it
will be responsible for:
o reviewing and approving multi-year strategies developed by
Research Committees;
o giving overall policy direction to the Research Committees
and to the Agency with regard to research activities and
resolving major operational problems regarding the conduct
of research or research planning; and
o overseeing, with the Science Advisory Board, evaluation by
the Research Committees of research products and, as neces-
sary, reviewing and approving Research Committee recommen-
dations regarding the appropriate timing and means for
disseminating research products.
C. Integration of R&D Management and Planning with EPA Planning Process
It is considered crucial that the planning and management system for
R&D be carefully tied to the ongoing management system of EPA and that
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clear well-defined decision rules be applied. Some of these decision
rules will act to foster long-term research and assure its relevance to
potentially significant regulatory needs.
The following section describes the relationship of the new R&D planning
and management System to the Agency strategy formulation and ZBB
processes and to planning and implementation activities.
1. Pre-ZBB Strategy Development. Each Research Committee will
develop a strategy that addresses all phases of the relevant
research activity. The research strategy will delineate the major
goals and objectives for the relevant areas of research activity.
Such a research strategy will, whenever possible, be developed
within the context of a pre-existing program strategy. Outside
experts will be asked to play a significant role in the development
and evaluation of this strategy. All EPA research funds (e.g., ORD,
Program, Regional) will be encompassed in the research strategy
document as appropriate.
Prior to the development of multi-year research strategies by the
Research Committees, it will be necessary for the Program and
Regional Offices to have carried out the following preliminary
activities:
• prepare an inventory of all statutorily mandated or court
ordered program requirements and of all other specific program
needs,
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28
• prepare a timetable of required completion dates for each of
the above activities,
• identify all technical information needed to carry out the
above activities, and
• identify all information gaps and the time frame within which
these gaps must be filled.
This last item will be the major Program/Regional input to the Research
Committees' strategy development process.
Completed strategies will then be reviewed and approved by the
Research Oversight Committee. The Assistant Administrator for
Research and Development, with the advice of the Research Oversight
Committee and after consultation with the Administrator, will define
the general resource levels by planning unit, for the Exploratory R&D
and Assigned Mission R&D categories.
2. ZBB. The R&D elements of the ZBB decision units will be based on
the specific research planning unit strategies developed by the
Research Committees. They must also be consistent with any associated
program decision units. Program decision units should, if possible,
be drafted prior to the drafting of research decision units.
3. Planning Year. Detailed research planning and execution in
response to approved strategies and objectives will normally be the
responsibility of ORD. Accomplishment plans for R&D activities will
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29
be prepared by ORD or the responsible Program or Regional office and
submitted to the Research Committee for review and comment. Reorien-
tation of the plans, as appropriate, will be recommended to ORD or
the other responsible office by the Research Committee. In the case
where Program or Regional Offices wish to implement specific extramural
R&D activities independently, ORD will be given the opportunity to
review the research proposals to determine if there is any duplication
with past, ongoing, or planned ORD activities, and to comment on the
technical quality of the proposed activities.
Finally, under the Research Incentive System, a portion of the research
funds may be allotted to a Program or Regional Office rather than to
ORD. When this does occur, ORD will, within agreed-upon time constraints,
be given adequate opportunity to negotiate for the opportunity to
conduct that research intramurally or to provide contract monitoring
services to the sponsoring Program or Regional Office. If the Program
or Regional Office accepts ORD's offer, the management details (costs,
timing, form of output) will be negotiated between ORD and the client
office.
4. Implementation years. The Research Committees will review progress
periodically in response to the research strategy and implementation
plans during the implementation phase of the R&D cycle, and report on
an exception basis to the Research Oversight Committee.
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As time allows, the Research Committees will also review and evaluate
results in terms of technical quality and operational responsiveness.
Both Agency and outside experts will be used to conduct such reviews.
The Research Committees will also, as time allows, identify the
appropriate timing and method of dissemination of specific R&D
outputs.
D. Research Incentives System
The Research Incentives System (RIS) will constitute an important
element of the proposed R&D planning and management system.
The primary purpose of the RIS is to establish a mechanism to encour-
age ORD to be responsive to Program and Regional needs and to encourage
Program and Regional Offices to take seriously their responsibilities
for clearly articulating their research needs and for following the
progress of key research projects. The RIS would establish a client-
contractor relationship between ORD and the Program and Regional
Offices. It would require ORD and Program and Regional Offices
to work together effectively to avoid the results of failure—loss of
research resources by ORD, and assumption of day-to-day research
management duties by the Programs or Regions.
We are now considering a number of variants of the RIS, one of which
will be discussed for illustrative purposes. During strategy develop-
ment, Program and Regional Offices would identify areas of research
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31
that they feel they should more closely manage because those areas
are key to the success of their regulatory efforts in the near-term.
Program and Regional Offices, with the assistance of ORE), would
develop appropriate proposals to incorporate into the ZBB decision
units. The ZBB ranking process would then be used to determine the
relative priority of such proposals.
Based on ZBB decisions and Congressional action, implementation plans
for activities assigned to Program or Regional Offices would be
developed by those Offices. The Offices would then negotiate with
ORD to conduct the research within its laboratories or to provide
contract management services for the Program/Regional Office projects.
Alternatively, the Program/Regional Offices, after consultation
with ORD, could contract directly with outside firms to conduct the
desired research.
Through judicious use of the RIS, all managers - Assistant Administra-
tors, Deputy Assistant Administrators, and Division Directors - can be
given a greater say in project direction for those projects that will
contribute significantly to meeting their program needs. The effect of
establishing a Research Incentive System will therefore be to enhance
the impact of the Research Committee System in promoting openess and
responsiveness in communications between research managers and program
managers at all three management levels.
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In order not to overshadow the positive effects of increased research
responsiveness which would grow out of this system, however, it is
necessary to build in safeguards against potentially negative conse-
quences. To avoid undue instability in ORD research efforts, it
could be specified that a percentage of research funds managed by ORD
in the previous year would continue to be managed by that organization.
For example, the Program/Regional Offices could be required to spend
90% of those funds within ORD. Further limits could be placed on the
extent of reprogramming of ongoing projects by the Program or Regional
Offices without the concurrence of the Assistant Administrator for
ORD. Since the Research Incentive System would be operated within
the context of agreed-upon research strategies, ZEE decision units
and implementation plans, changes in program emphasis or direction
would not be made beyond those necessitated by unanticipated needs.
Such an approach to the Research Incentive System would have obvious
benefits for the Program and Regional Offices which depend upon
research findings for their regulatory efforts. These Offices could
participate as they chose in the development and approval of research
protocols, thereby enhancing the likelihood that the outputs will be
specifically tailored to their needs.
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33
ORD also has much to gain from a Research Incentive System. Under
the current arrangement, requests for new research support are often
made to ORD without regard to the relative priority of those requests
and without a sense of what research activities are delayed or disrupted
by the new requests. The new system instead requires that the Programs/
Regions articulate and set priorities among the requests that they make
of ORD. By allowing ORD to choose whether or not to "bid" on key
projects, the RIS will allow ORD to set its prices competitively in
order to develop in-house research capability, especially in emerging
areas.
Clearly, whatever variants are selected by the pilot studies, the RIS
will have to be applied flexibly in order to meet the special condi-
tions of each research planning unit. In general, however, growth
areas or those with many short-term projects can probably respond
most effectively to such a system.
E. Research Quality. The incorporation of peer review mechanisms
throughout the planning and management process is fundamental to the
success of the proposed R&D planning and management system. Each
research committee will use such mechanisms during the planning,
implementation, evaluation and dissemination stages of research.
Committees will address the following questions:
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34
How should "technical quality" be measured?
What is the appropriate mechanism•for making the trade-off
between timeliness of response and thoroughness of analysis?
How and by whom should the product of research be presented to
the client/user?
What mechanisms should be used to ensure that researchers receive
feedback on the timeliness, quality, and utility of the products
of ongoing or completed research efforts?
IV. ACTIVITIES UNDERWAY TO IMPLEMENT THE SYSTEM
The Policy Group, after agreeing to the R&D planning and management
approach decribed above, concluded that it would be prudent to test
the system in several pilot projects. In this way, the many facets
of the system can be thoroughly tested and modified or possibly rejected
in order to increase the prospect for the system to work effectively
as it is applied to other parts or all of EPA's R&D program.
Five pilot areas have been selected. They represent five "natural"
areas of research planning which are of major importance in EPA's
regulatory and research efforts. They include one area (respirable
particulates) which both is specific to a regulatory program (air
quality) and cuts across all areas of research disciplines. The
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35
other four are also specific to a single regulatory program but
are concentrated in only one or two research disciplines (drinking
water, industrial wastewater control, mobile source air pollutants
and pesticides).
The jurisdiction of each of the five pilots falls within the boun-
daries of a single Program Office but this need not always be the
case. When the pilot project is completed and additional Research
Committees are established to cover the bulk of EPA's research
activity, some Committees may have responsibilities which cross
program boundaries.
During the pilot period, the recommended R&D planning and manage-
ment system is being applied within each of the five pilot areas.
The Research Committee established for each pilot is composed
of relevant ORD, Program, and Regional staff and will be assisted
by outside experts. Each Research Committee will develop a brief
research strategy, participate in the 1980 ZBB process, and review
and, where appropriate, make recommendations for reprogramming of
research activities planned for FY-79 and of research underway in
FY-78. To the extent possible, variants of the Research Incentives
System will be tested.
The pilot projects were formally initiated on March 15, and will be
monitored closely for a six-month period. A report on the pilot
experience will be provided to the Congress by October 31, 1978.
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36
This report will include a description of the experience of each
pilot study, recommended changes in the R&D planning and management
system based on the pilot experience, and steps taken to extend the
system to other parts of EPA's research and development activities.
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AGENCY
Table B.
STRATEGY
DEVELOPMENT
ling
Features of R&D Planning and Management Systems Used in Target Agencies
R&D PLANNING AND MANAGEMENT PROCESS
ZBB
PLANNING
IMPLEMENTATION
EVALUATION
III. FDA O
Program managers within
the bureaus recommend
program goals and objec-
tives. Subject to
concurrence by the bureau
management, the plans
are prepared and
presented to the
Commission during the
planning process as
the Bureau's Proposed
Accompli slime nt Objec-
tives.
o PMS updated annually
to assure coverage of
problem areas
o Level of effort for
R&D defined during
the Accomplishment
Objective phase of
the Planning Process
prior to ZBB.
o Program managers
prepare decision
units.
o "Bottom -up"
mechanism for
surfacing and
ranking R&D
proposals.
along with
all other
programmatic
proposals.
o Office of
Planning and
Evaluation and
Office of
Administration
identify
allocation
decisions for
Commissioner
o Commissioner
designates
fiscal year
priorities
and deter-
mines needs
for real loca-
tion of finds.
o Detailed plan-
ning performed
by program
managers.
o All research
implemented by
program office
labs, one or more
of the 20 field
labs, or NCTR.
Face-to-face brief
ing of Commissione
and his top staff
by prog ran manager
on program accom-
plishments.
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Table B. Features of R&D Planning and Management Systems Used in Target Agencies
R&D PLANNING AND MANAGEMENT PROCESS
STRATEGY
AGENCY DEVELOPMENT
IV. OSHA/ * Research development
NIOSH performed by NIOSH
Director with inputs
from OSHA-NIOSH Policy
Group
ZBB
Management Commit-
tee chaired by
NIOSH Director
and composed of
top NIOSH officials
appoints members
of Program Commit-
tee for Coordinat-
ing Research (PCCRs)
PCCRs surface
research needs,
and "weed out"
duplicative
research
NIOSH Division
Directors pre-
pare decision
units
PLANNING
o Appropriate
NIOSH Research
Division
Directors do
detailed plan-
ning but must
get PCCR
agreement on
outputs for
allocation of
funds and
positions
IMPLEMENTATION
o All research
implemented by
appropr iate
NIOSH Research
Division
o PCCR reviews
interim outputs
and progress
reports
o OSHA representatives
are also invited
to participate in
PCCR reviews
EVALUATION
*OSHA-NIGSH workit
Groups evaluate
quality and
responsiveness
of research prod-
ucts and brief
OSHA officials.
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Table B. Features of R&D Planning and Management Systems Used in Target Agencies
R&D PLANNING AND MANAGEMENT PROCESS
AGENCY
STRATEGY
DEVELOPMENT
ZBB
PLANNING
IMPLEMENTATION
EVALUATION
NRG/DOE O
Coordinators designated
by program offices to
oversee identification
of research needs
Coordinators "weed
out" unnecessary
duplication
and coordinate
actions required
to arrive at
agreement on
proposed research
Research proposals
submitted to
Office of Nuclear
Research (RES)
RES rules on
validity of pro-
posals; Programs
have appeal
rights to Execu-
tive Director
RES prepares
decision units
* RES does all
planning but
must have pro-
gran office
"sponsor"
before plans
can be final-
ized
* Standing Re-
search Review
Groups, (RRGs)
of high-level
staff from pro-
gram offices,
RES labs, other
agencies and
outside experts
act as over-
sight panels
on technical
problems
encountered dur-
ing the planning
year
o RES manages all
research projects
* RRGs reviews
interim outputs
and progress
reports
o RES Assistant
Director chairs
committee conpos-
ed of prograu
offices and RES
representation
and which may
include members
of RRG and out-
side experts to
review respon-
siveness of
research
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Table B. Features of R&D PlannH^ and Management Systems Used in Target Agencies
R&D PLANNING AND MANAGEMENT PROCESS
AGENCY
STRATHGY.
DEVELOPMENT
ZBQ
PLANNING
IMPLEMENTATION
EVALUATION
I. FWS
Program strategy state-
ments prepared by program
managers on a year-to-
year basis
* "Bottom up" and "top
down" mechanisms
for surfacing R&D
proposals to support
strategy
* Program Manager
Strategy Papers
prepared by program
to show which R&D
projects support
program objectives.
* Associate Director
for Research
"costs out"
proposals
* Decision units
prepared by area
and regional
offices
o Detailed
project
planning
performed
by Research
Office with
from program
offices
*A11 research funds
assigned to Program
Managers
o Program advice pre-
pared by Program
Managers which makes
funds available to
Research Office
o Formal program
reviews every 6
months
o Progran review
of completed
research every
6 to 12
months
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Table A. Target Agencies^ for R&D Program Analysis
AGENCY
MISSION
AGENCY ORGANIZATION
R&D PROGRAM CHARACTERISTICS
FUND
CONTROL
IMPLEMENTATION
RESPONSIBILITY
Fish and Wildlife
Service (FWS)
To conserve the
Nation's fish and
wildlife resources
Three Program Offices,
Six Regions and the
Alaska Area Office
(which include approx-
mately 600 field
stations) report directly
to the Director of FWS
in Headquarters.
Assigned to
operating
progran
managers in
Headquarters
Centralized under
the direct control
of the Associate
Director for Research
in Headquarters
I. Nuclear
Regulatory
Commission
(NRC)
To regulate all
civilian nuclear
activities
Five Program Offices:
o Office of Nuclear
Material Safety and
Safeguards
o Office of Nuclear
Reactor Regulation
o Office of Nuclear
Regulatory Research
(RES)
o Office of Standards
Development
o Office of Inspection
and Enforcement
All report to the Execu-
tive Director of NRC
Assigned to
RES
Centralized management
responsibility in
RES. Centralized
implementation
responsibility in
Department of Energy
(mandated by legis-
lation)
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Table A. Target Agencies for R&D Program Analysis
AGENCY
MISSION
AGENCY ORGANIZATION
R&D PROGRAM CHARACTERISTICS
FUND
CONTROL
IMPLEMENTATION
RESPONSIBILITY
III. Food and Drug
Administration
(FDA)
IV. Occupational
Safety and
Health Adminis-
tration (OSHA)
To regulate the
safety of the
Nation's foods,
cosmetics, drugs,
medical devices,
biologies, and
electronic radio-
logical products
To assure that no
worker suffers
diminished health,
reduced function
capacity, or
decreased life
expectancy as a
result of his
work experience.
Six Agency Bureaus:
o Foods
o Drugs
o Veterinary Medicine
o Radiological Health
o Biologies
o Medical Devices
o Diagnostic Products
report directly to
the Commissioner.
Also reporting
directly to the Com-
missioner are the
National Center for
Toxicological
Research (NCTR) and
the Executive Director
of Regional Operations
(EDRO)
OSHA located organiz-
ationally within the
Department of Labor and
has no research capability.
OSHA gets research support
from the National Institute
for Occupational Safety
and Health (NIOSH) which
is a part of the Department
of Health, Education, and
Welfare.
Assigned to
Bureaus and
EDRO
Centralized in
program office labs
Assigned to
NIOSH
Centralized implemen-
tation responsibility
in NIOSH
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TABLE D: RELATIONSHIPS AMONG THE PROPOSED RESEARCH COMMITTEES
REGULATORY/
OPERATIONAL
RESEARCH
COMMITTEES
EXPLORATORY
RESEARCH
COMMITTEE
ASSIGNED
MISSION
RESEARCH
COMMITTEE
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Table C: RELATIONSHIP OF PROPoSR) SYSTEM TO DEFINED PROBLEMS AND SOLUTION?
PROBLEMS
APPROACH
SYSTEM
FEATURES
LACK OF RESEARCH
STRATEGY
PROGRAM CONTEXT
FOR RESEARCH
NATURAL MODULES FOR
RESEARCH PLANNING
INADEQUATE
COMMUNICATIONS
AND
DECISION-MAKING
MECHANISMS
COMMUNICATIONS AND
PROBLEM SOLVING AT
OPERATIONAL LEVELS
RESEARCH COMMITTEES
INADEQUATE
LONG-TERM
RESEARCH
PROGRAM
PROTECT LONG-TERM
RESEARCH
R&D PLANNING TIED TO
EXPLORATORY RESEARCH
COMMITTEE; AGENCY
SYSTEMS IN DECISION
RULES AND SAFEGUARDS
INSUFFICIENTLY
TIMELY/USEFUL
RESEARCH
FINDINGS
GREATER PROGRAM AND
REGIONAL INFLUENCE
AND RESPONSIBILITY
RESEARCH INCENTIVES
SYSTEM
UNEVEN RESEARCH
QUALITY
MORE QUALITY REVIEW
THROUGHOUT PLANNING
AND MANAGEMENT
PROCESS
PEER REVIEW THROUGH
RESEARCH COMMITTEES
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