A Report to the President and the Congress
   U.S. Environmental Protection Agency

             June 30, 1978

                        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

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


     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;

     3)  the tying of R&D planning and management processes into Agency-

         wide management processes with decision rules focused on these


     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.


            A Report to the President and the Congress


     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

         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.

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-

        (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.


     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


             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-

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.

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.

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

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.

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


    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.

        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


    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


    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


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

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

The following matrix summarizes the results of our analysis.
                                         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-

                                         Greater program and
                                         regional influence and

                                         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
    Uneven research quality    	


    •  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


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.


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

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


    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-


    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


        results and their significance to NRC, and a concise descrip-

        tion of the evaluation of the results including the range of


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


       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.


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


     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.


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



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


    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-


        siveness to approved research strategies and their consistency

        with regulatory components of those same and other decision


     •  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


    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-


     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


    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).


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.


     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


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


      •  prepare an inventory of all statutorily mandated or court

         ordered program requirements and of all other specific program



      •  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

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


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.


    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


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


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.


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.


    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


    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:


         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?


    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


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.


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.

                          Table B.
Features of R&D Planning and Management Systems Used in Target Agencies

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-
    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
o "Bottom -up"
  mechanism for
  surfacing and
  ranking R&D
  along with
  all other
o Office of
  Planning and
  Evaluation and
  Office of
  decisions for
o Commissioner
  fiscal year
  and deter-
  mines needs
  for real loca-
  tion of finds.
o Detailed plan-
  ning performed
  by program
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-

                     Table B.  Features of R&D Planning  and Management Systems Used  in Target Agencies
                                            R&D PLANNING AND MANAGEMENT PROCESS

IV. OSHA/     *  Research development
    NIOSH        performed by NIOSH
                 Director with inputs
                 from OSHA-NIOSH Policy

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"
NIOSH Division
Directors pre-
pare decision

o Appropriate
  NIOSH Research
  Directors do
  detailed plan-
  ning but must
  get PCCR
  agreement on
  outputs for
  allocation of
  funds and

o All research
  implemented by
  appropr iate
  NIOSH Research
o PCCR reviews
  interim outputs
  and progress
o OSHA representatives
  are also invited
  to participate in
  PCCR reviews

*OSHA-NIGSH workit
 Groups evaluate
 quality and
 of research prod-
 ucts and brief
 OSHA officials.

                 Table B.  Features of R&D Planning and Management Systems Used in Target Agencies
                                        R&D PLANNING AND MANAGEMENT PROCESS
Coordinators designated
by program offices to
oversee identification
of research needs
Coordinators "weed
out" unnecessary
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
  before plans
  can be final-
* 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
  encountered dur-
  ing the planning
o RES manages all
  research projects
                                                                                 * RRGs reviews
                                                                                   interim outputs
                                                                                   and progress
o RES Assistant
  Director chairs
  committee conpos-
  ed of prograu
  offices and RES
  and which may
  include members
  of RRG and out-
  side experts to
  review respon-
  siveness of

                          Table B.  Features of R&D PlannH^ and Management Systems Used in Target Agencies
                                              R&D PLANNING AND MANAGEMENT PROCESS
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
* Program Manager
  Strategy Papers
  prepared by program
  to show which R&D
  projects support
  program objectives.
* Associate Director
  for Research
  "costs out"

* Decision units
  prepared by area
  and regional
o Detailed
  by Research
  Office with
  from program
*A11 research funds
 assigned to Program

o Program advice pre-
  pared by Program
  Managers which makes
  funds available to
  Research Office
o Formal program
  reviews every 6
o Progran review
  of completed
  research every
  6 to 12

                                   Table A.  Target Agencies^ for R&D Program Analysis
                                                                              R&D PROGRAM CHARACTERISTICS
   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
managers in
Centralized under
the direct control
of the Associate
Director for Research
in Headquarters
I. Nuclear
To regulate all
civilian nuclear
 Five Program Offices:
  o Office of Nuclear
    Material Safety and
  o Office of Nuclear
    Reactor Regulation
  o Office of Nuclear
    Regulatory Research
  o Office of Standards
  o Office of Inspection
    and Enforcement
All report to the Execu-
tive Director of NRC
Assigned to
Centralized management
responsibility in
RES.  Centralized
responsibility in
Department of Energy
(mandated by legis-

                                    Table A.  Target Agencies for R&D Program Analysis
                                                                               R&D PROGRAM CHARACTERISTICS
III. Food and Drug
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
   Research (NCTR) and
   the Executive Director
   of Regional Operations

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
Assigned to
Bureaus and
Centralized in
program office labs
Assigned to
Centralized implemen-
tation responsibility