United States Office of 600/9/79-033
Environmental Protection Research and Development September 1979
Agency Washington D.C. 20460
Energy, Minerals and Industry
S!>ERr\ The Federal Nonnuclear Energy
Research And Development
Act (P.L. 93-577)
Section 11,
Environmental Evaluation
Background Document
For National Hearings
October 3-5 1979
Washington, D.C.
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Public Law 93-577
93rd Congress, S. 1283
December 31, 1974
an act
To establish a national program for research and development in nonnuclear
energy sources.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SHORT TITLE
SECTION 1. This Act may be cited as the "Federal Nonnuclear Energy
Research and Development Act of 1974".
Federal Non-
nuclear Energy
Research and
Development
Act of 1974.
42 USC 5901
note.
88 STAT. 1878
ENVIRONMENTAL EVALUATION
.SEC. 11. (a) The Council on Environmental Quality is authorized
and directed to carry out a continuing analysis of the effect of appli-
cation of nonnuclear energy technologies to evaluate—
(1) the adequacy of attention to energy conservation methods;
and
(2) the adequacy of attention to environmental protection and
the environmental consequences of the application of energy
technologies.
(b) The Council on Environmental Quality, in carrying out the
provisions of this section, may employ consultants or contractors and
may by fund transfer employ the services of other Federal agencies
for the conduct of studies and investigations.
(c) The Council on Environmental Quality shall hold annual public
hearings on the conduct of energy research and development and the
probable environmental consequences of trends in the development
and application of energy technologies. The transcript of the hearings
shall be published and made available to the public.
(d) The Council on Environmental Quality shall make such reports
to the President, the Administrator, and the Congress as it deems
appropriate concerning the conduct of energy research and develop-
ment. The President as a part of the annual Environmental Policy
Report required by section 201 of the National Environmental Policy
Act of 1969 (42 U.S.C. 4341) shall set forth the findings of the Council
on Environmental Quality concerning the probable environmental
consequences of trends in the development and application of energy
technologies.
42 USC 5910.
Hearings.
Transcript,
availability.
Report to
President,
Administra-
tor, and
Congress.
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United States Office of 600/9/79-033
Environmental Protection Research and Development
Agency Washington D.C. 20460
Energy, Minerals and Industry
The Federal Nonnuclear Energy
Research And Development
Act (P.L 93-577)
Section 11,
Environmental Evaluation
Background Document
For National Hearings
October 3-5 1979
Washington, D.C.
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TABLE OF CONTENTS
Page
Number
Glossary of Terms iv
Executive Summary 1
I. OVERVIEW OF SECTION 11 ACTIVITIES AND PRE-HEARING
DOCUMENT 5
II. ENVIRONMENTAL INPUT TO DOE'S TECHNOLOGY
MANAGEMENT PROCESS 7
III. REGIONAL WORKSHOP SUMMARIES 11
IV. ASPECTS OF DOE'S DECISION-MAKING PROCESS
FOR DISCUSSION 13
APPENDICES
A. Atlanta Workshop Summary A-1
B. Denver Workshop Summary B-1
C. San Francisco Workshop Summary C-1
D. Pittsburgh Workshop Summary D-1
FIGURES page
Number
Figure 1. Major System Acquisition Decision Points 7
Figure 2. Overview of Major DOE Environmental Planning
and Review Documents 10
iii
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GLOSSARY
CEQ Council on Environmental Quality
DOE Department of Energy
EA Environmental Assessment
ECC Environmental Coordination Committee
EDP Environmental Development Plan
E1S Environmental Impact Statement
EPA Environmental Protection Agency
ERD Environmental Readiness Document
ESAAB Energy Systems Acquisition Advisory Board
NEPA National Environmental Protection Act
OEMI Office of Energy, Minerals, and Industry
PEP Energy System Acquisition Project Environmental Plan
PPMS Program and Project Management System
RD&D Research, Development and Demonstration
iv
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EXECUTIVE SUMMARY
Introduction
Under Section 11 of the Federal Nonnuclear Energy Research and Development Act
(P.L 93-577), the Environmental Protection Agency (EPA) has the responsibility for assess-
ing "the adequacy of attention to energy conservation methods and environmental protec-
tion ... and the environmental consequences of the application of energy technologies."
Last year's Section 11 activities focused on the allocation of research, development, and
demonstration resources by the Department of Energy (DOE). Witnesses at the public hear-
ings were deeply divided over the proper allocation of these resources. They did not under-
stand how DOE decides on particular allocations, and how environmental considerations
enter the process.
This year the Section 11 activities will examine the DOE management process. We are
specifically interested in the way information on "energy conservation methods and envi-
ronmental protection" is used in technology development decisions. The Program and Proj-
ect Management System (PPMS) was focused on because it provides for high-level
management review of large energy technology projects before any budget commitments
are made. An integral part of PPMS is the environmental planning and assessment process
through which environmental concerns are identified, research needed to address those
concerns is planned, and assessments of research results are made.
Public Interaction
To provide an opportunity for a regional evaluation of the DOE Management System and its
effect on projects which are being developed locally, a series of workshops were held in
July 1979 in Atlanta, Denver, San Francisco, and Pittsburgh. They were attended by a wide
range of representatives from federal, state, and local agencies, environmental and public
interest groups, labor, industry, and the general public.
This pre-hearing document is intended to: (1) summarize the concerns and questions raised
at the workshops and in EPA's own analysis of how environmental concerns are incor-
porated into the Department of Energy Management System, and (2) suggest topics for
discussion at the October National Hearing. The information developed through EPA's
analysis, the concerns expressed at the workshops and the testimony at the October Hear-
ing will be used in completing this year's Section 11 Report to Congress.
The DOE Technology Management Process
The Program and Project Management System is the principal DOE management system
governing the development, approval, and execution of DOE's technology development pro-
grams. The basic purpose of the PPMS is to define and review projects before major
resource commitments are made. Within PPMS comparisons between technologies are not
made.
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The PPMS was designed to facilitate the review of technical, economic, and environmental
factors of each energy technology at specifically defined stages in its development. These
reviews occur as technologies move in increasing scale from basic research through the
pilot and demonstration stages, and ultimately to commercial facilities. This review is con-
ducted by the Energy Systems Acquisition Advisory Board, made up of senior DOE officials
including the Assistant Secretary for Environment. This Board makes recommendations to
the DOE Under Secretary who determines whether a project should advance to the next
stage of development.
To synchronize required environmental research with the development stages of particular
technologies, DOE designed an environmental planning and assessment process within
PPMS. The major aspects of this process are:
• Planning—Two documents define environmental concerns and research needs. Environ-
mental Development Plans treat generic technologies such as oil shale processing or
coal liquefaction, and Project Environmental Plans identify the research to be conducted
at a specific DOE facility.
• Review and Assessment—Three documents are used to provide assessments of the
research conducted. Environmental Readiness Documents are independent assess-
ments by the Office of Environment which define the status of environmental issues
affecting the further development of a technology. Environmental Assessments and
Environmental Impact Statements, required by the National Environmental Policy Act,
are prepared by the DOE Program Offices and are reviewed by the Office of Environment.
To date only Environmental Impact Statements have received wide public distribution.
Aspects of DOE's Decision-Making Process for Discussion
The PPMS and the environmental planning and assessment process are intended to ensure
environmentally responsible decision-making. As designed, the total process exhibits
many aspects of an effective management system, and represents progress toward sound,
environmentally responsible decision-making. However, concerns and questions were rais-
ed about the DOE decision-making process in the four regional workshops and in EPA's
own analysis. These concerns center around five general issues:
1. Appropriate Governmental Levels for Treating Environmental Issues—The types of envi-
ronmental concerns associated with a technology range from site-specific impacts (e.g.,
resource requirements, socioeconomic impacts) to national concerns (e.g., basic health
effects of pollutants, development of environmental control technologies). For a tech-
nology to be made environmentally acceptable, environmental analysis should be car-
ried out at all levels. The present DOE Management System does not make clear who is
responsible for carrying out the analysis at the local and regional levels. A "tiered"
arrangement may be possible in which the responsibility and authority for conducting
analyses is given to the appropriate level. Environmental information from these levels
should be available before federal decisions affecting those levels are made.
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2. Types of Projects Receiving Major Management Attention—At present, DOE compre-
hensively reviews technology projects designated as "major systems acquisitions".
Several criteria—most notably cost—are used to designate these major projects.
Because of these criteria, smaller projects and some technology programs are not
covered by the PPMS. Concerns voiced at the workshops dealt with ways to modify the
PPMS criteria so that smaller projects which either have significant environmental im-
pacts or benefits receive the appropriate high-level management attention.
3. Criteria Used in Evaluating Individual Technologies—Explicit environmental criteria
should be developed and applied to all major decisions in DOE's management system.
Specification of such criteria would help ensure that all important environmental factors
are examined prior to decision-making, and that decisions across technologies are con-
sistent.
4. The Role of Non-DOE Groups in Evaluating Environmental Issues—Workshop attendees
were concerned about the lack of involvement of several non-DOE groups such as the
public, industry, labor and state and local governments in DOE technology decisions.
The concerns voiced at the workshops revolved around ensuring that adequate informa-
tion is actively disseminated, and that the appropriate interests are heard and effective-
ly considered at significant decision points.
5. The Integration of Environmental Factors into Technology Decision Making—Several
workshop comments dealt with the need for better integration of technology and en-
vironmental planning and decision-making. Better integration might be achieved
through: (1) allowing systematic environmental evaluations to play a greater role in
technology development; (2) making better use of National Environmental Policy Act
(NEPA) documents in planning and decision-making; and (3) designing pilot and
demonstration projects to ensure maximum generation of technical and environmental
research data.
The intent of this pre-hearing document is not to recommend a particular course of action
to address these issues, but rather to synthesize comments, questions, and recommenda-
tions from the workshops and our own analysis, and thereby provide a focus for further
thought and discussion at the National Hearings. The substance of these discussions will
then be incorporated into the final Section 11 Report to Congress, scheduled for submis-
sion in January 1980.
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I. OVERVIEW OF SECTION 11 ACTIVITIES
AND PRE-HEARING DOCUMENT
The Federal Nonnuclear Energy Research and Development Act (P.L 93-577) was passed in
December 1974 as part of the national response to the effects of the 1973 Arab Oil Embar-
go. The legislation created a comprehensive national research, development and
demonstration (RD&D) program for nonnuclear energy technologies, which presently ex-
pends over $1.8 billion annually. Within P.L. 93-577, Section 11 directs an annual review of
"... the adequacy of attention to energy conservation methods and environmental protec-
tion ... and the environmental consequences of the application of energy technologies."
The Office of Energy, Minerals and Industry within EPA's Office of Research and Develop-
ment has been assigned responsibility for the review and is charged with conducting an-
nual public hearings and preparing a Report to the President and Congress.
Last year's Section 11 activities focused on the annual allocation of RD&D resources
among competing energy technologies. These activities showed very deep differences of
opinion on the proper allocation of resources. These differences reflect fundamentally con-
flicting views about the attractiveness of competing supply-oriented and conservation-
oriented technologies. They also reflect conflicting views about the appropriate technology
development stage for addressing environmental questions.
During the 1978 public hearings, witnesses expressed a lack of understanding of DOE's
resource allocation process and the manner in which environmental considerations enter
the process. Consequently, in fulfilling the responsibilities of Section 11 this year, EPA's
activities have not stressed resource allocations. Rather, we are examining the manage-
ment process used by the Department of Energy (DOE) to ascertain how this process ad-
dresses concerns for environmental protection and energy conservation. This year the
"adequacy of attention" will be evaluated not in terms of the relative share of the RD&D
budget given to a technology, but rather in terms of how information on "conservation
methods and environmental protection" is used in the major management decisions con-
trolling DOE's research programs.
The Program and Project Management System (PPMS) is DOE's major management process
for its research, development and demonstration program. The PPMS is oriented toward
major hardware projects, so a great deal of DOE's management effort is concerned with
these projects. Within PPMS, an environmental planning and assessment process deter-
mines the environmental and health consequences of energy technologies, and guides the
environmental research programs for these technologies. The PPMS, including this envi-
ronmental assessment, is the fundamental management tool controlling the evolution of
the RD&D program. Much of this year's Section 11 review has been devoted to examining
PPMS and the associated environmental assessments.
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Information dissemination is a major component of the Section 11 activities. The 1979 Sec-
tion 11 activities have included four regional public workshops where the DOE Manage-
ment System was explained. These workshops provided an opportunity for a regional
evaluation of the DOE Management Systems and its effect on projects which are being
developed locally. The participants evaluated this system and expressed their own environ-
mental concerns about specific energy technologies and projects.
As part of the Section 11 activities, this pre-hearing document is intended to do three
things:
• Outline the DOE decision-making processes, notably the Program and Project Manage-
ment System and its environmental planning and assessment process (see Chapter II).
• Summarize the concerns and questions raised at the four Section 11 public workshops
(see Chapter III).
• Suggest topics for discussion at the October 3-5 National Hearing in Washington, D.C.
(see Chapter IV).
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II. ENVIRONMENTAL INPUT INTO DOE'S TECHNOLOGY
MANAGEMENT PROCESS
Overview of the Management Process
The Federal Nonnuclear Energy Research and Development Act of 1974 requires DOE to
accelerate the development of alternative energy technologies consistent with national
energy policy as laid out in the biennial National Energy Plans. In order to develop
technologies that are technically feasible, economically practical, and environmentally
acceptable, DOE conducts research, development, and demonstration (RD&D) programs.
An emerging technology moves through several stages of increasing complexity and
scale—laboratory, pilot, demonstration, and commercialization—as it progresses from
basic research to commercial acceptance. At the end of each stage, a decision must be
made whether or not to advance the technology to the next stage. This process is illus-
trated below:
LABORATORY
RESEARCH
I
PILOT
I
I
I
COMMERCIALIZATION
I
ESAAB
REVIEW AND
RECOMMENDATION
TO UNDER
SECRETARY
ESAAB
REVIEW AND
RECOMMENDATION
TO UNDER
SECRETARY
ESAAB
REVIEW AND
RECOMMENDATION
TO UNDER
SECRETARY
INCREASING SCALE AND COMPLEXITY
ESAAB = Energy System Acquisition Advisory Board
FIGURE 1. MAJOR SYSTEM ACQUISITION DECISION POINTS
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The Program and Project Management System (PPMS) is the principal DOE management
system governing the development, approval, and execution of DOE's development pro-
grams. The basic purpose of PPMS is to facilitate the review of projects at the end of each
development stage before major federal resources are committed. Technical, economic,
and environmental concerns for a particular technology, are considered within PPMS, but
no comparisons are made between technologies. This review is conducted by the Energy
Systems Acquisition Advisory Board (ESAAB), made up of senior DOE officials, including
the Assistant Secretary for Environment. As a result of its review, the Board makes recom-
mendations to the DOE Under Secretary who determines whether a project should advance
to the next stage of development. Participation in the ESAAB is important to the DOE Of-
fice of Environment because it is a direct link to the development, approval, and execution
of DOE's major technology projects.
Only projects designated as "major systems" are reviewed by the Energy System Acquisi-
tion Advisory Board. DOE uses many factors to determine whether a project will be
designated as a major system acquisition, including development cost*, technical com-
plexity, projected market penetration of the technology, time of entry, energy input require-
ments, and relationships to energy supplies displaced or substituted. Of approximately 100
large nuclear and nonnuclear DOE technology RD&D projects now underway, only 20 to 30
are major systems; these account for about 50 percent of the total Department budget for
energy RD&D.
DOE energy projects not designated major systems acquisitions are under the manage-
ment responsibility and direction of the appropriate program office. These projects are not
subject to ESAAB review; therefore, environmental review is not as comprehensive as call-
ed for by the PPMS. For these projects environmental concerns are addressed in the En-
vironmental Coordination Committee's subcommittee meetings.
For all RD&D projects, both major systems and others, environmental research is planned
and assessed in a series of documents.
1. Planning Documents—To identify environmental concerns and plan research to address
those concerns, Environmental Development Plans (EDPs) have been integrated into the
PPMS. EDPs identify and integrate required environmental, safety, and health research
at each phase of technology projects so that this information will be available to
decision-makers when resource commitments for further development are made.
Preparation of EDPs for each technology is the responsibility of the Environmental Coor-
dination Committee. This committee functions through subcommittees designated for
each technology. Subcommittees include representatives from both the Office of Envi-
ronment and the appropriate program office. Much of the research identified in EDPs is
conducted at particular project sites. The subcommittees prepare Project Environ-
mental Plans, which detail the site-specific environmental research to be conducted'
for all projects.
*For example, development cost criteria stipulate that a project is considered "major" if
there is an estimated $50 million annual or $200 million lifetime cost.
8
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2. Review and Assessment Documents—Three documents—Environmental Readiness
Documents (ERDs), Environmental Assessments (EAs), and Environmental Impact
Statements (EISs)—are used to assess the environmental acceptability of an energy
system acquisition project.
Environmental Readiness Documents serve several purposes. As assessments prepared
independently by the Office of Environment, they are used by the Assistant Secretary for
Environment to advise the Energy System Acquisition Advisory Board or program
manager about whether it is suitable for an energy technology to move to the next phase
of development. ERDs present the results of environmental research already carried out,
and provide further definition of concerns and research needs for subsequent phases of
development. As analytical reference documents, ERDs are also designed to be useful in
"scoping" environmental concerns and supporting Environmental Impact Statement
preparation.
The National Environmental Policy Act of 1969 (NEPA) requires Federal agencies to
prepare Environmental Impact Statements (EISs) for major actions that significantly af-
fect the quality of the environment. An Environmental Assessment (EA) is a preliminary
analysis to determine whether the impact of an action will be significant, and is used to
decide if preparation of an EIS is necessary. EISs provide at present the major opportun-
ity for public input into the DOE decision-making process through required review and
comment. Recently revised guidelines for the NEPA process (effective July 30,1979) in-
clude several other means for public involvement. For example, "scoping" meetings
must be held early in the process to help determine the issues and concerns to be
addressed in the preparation of an EIS.
A further description of NEPA and internal DOE environmental documents is given in
Figure 2.
Strengths of the Process
The PPMS and the environmental planning and assessment process are intended to ensure
environmentally responsible decision-making. As designed, the total process exhibits
many aspects of an effective management system, and represents progress toward sound,
environmentally responsible decision-making. The process has the following specific
strengths:
1. it provides a systematic means of managing technology development—It does this by
identifying the distinct phases through which every technology must pass, from initial
research to full-scale commercialization. It explicitly considers environmental concerns
at points where decisions on further development must be made.
2. It provides an opportunity for the Office of Environment to play a major role in DOE deci-
sions—through membership on the Energy Systems Acquisition Advisory Board
(ESAAB), chairmanship of the various Environmental Coordination Committees (ECC)
subcommittees, and review and approval of Environmental Assessments (EAs) and
Environmental Impact Statements (EISs).
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3. It has been successful In correctly identifying categories of environmental
issues—Classical environmental concerns (e.g., air and water pollution) are clearly
defined, and other types of concerns (e.g., socioeconomic impacts) have at least been
identified.
4. It attempts to systematically integrate technology development and environmental
research—This integration is achieved through several means:
• Linking of technology planning and environmental research planning through time-
tables and review procedures.
• Representation of both the program offices and the Office of Environment on the
ESAAB and ECC subcommittees. These subcommittees also foster day-to-day con-
tact between both groups at the working level.
• Joint preparation and approval of Environmental Development Plans (EDPs) and Proj-
ect Environmental Plan (PEPs) by the Office of Environment and program offices. The
documents lay out environmental concerns and identify the research needed to ad-
dress those concerns on a technology-wide and site-specific basis. These research
needs are then integrated and implemented through the budgetary process.
• Preparation of Environmental Readiness Documents (ERDs), which provide formal
environmental inputs to technology decision-makers.
5. It has substantial documentation requirements— Environmental planning and assess-
ment documents ensure that all decision-makers have the same data on which they can
base decisions. These documents also afford an opportunity for outside groups to audit
internal planning and decision-making.
DOCUMENT
1. Environmental Develop-
ment Plan (EOF)
2. Energy System Acquisition
Project Environmental Plan
(PEP)
3. Environmental Readiness
Documents (ERD)
4. Environmental Assessments
1EA) and Environmental
Impact Statements (EIS)
PURPOSE
Define major environmental
concerns associated with a par-
ticular energy technology and
general environmental research
requirements for addressing
those concerns.
Plan environmental R&D for a
specific project.
Review environmental status
of a particular technology and
serves as formal Office of
Environment input to DOE
technology development deci-
sions.
EAs evaluate if EISs should be
prepared in order to meet
NEPA requirements. EISs
assess environmental impacts
of proposed major Federal
actions.
CONTENTS
• Define environmental
concerns.
• Assess status and risk.
» Identify R&D needs.
• Describe R&D plan.
• List research projects
(including NEPA require-
ments).
e Identify the sponsoring
office.
• Specify funding require-
ments.
• Provide a research comple-
tion schedule.
• Assess environmental readi-
ness of a technology to
move on to the next devel-
opment stage.
• Discuss current and poten-
tial regulations affecting
technology and control
technology options.
• Assess delays and costs asso-
ciated with advene environ-
mental findings.
• Describe proposed actions.
• Describe probable Impacts.
• Describe unavoidable ad-
verse impacts.
• Describe possible alter-
natives.
PREPARER
Office of Environment in con-
junction with ECC subcom-
mittee for that technology.
Office of Environment in con-
junction wHh ECC subcom-
mittee for that technology.
Office of Environment In con-
junction with ECC subcom-
mittee for that technology.
Technology program manager.
PUBLIC ACCESS
Internal document, available
by request.
Internal document, available
by request.
Internal document, available
by request.
Public review required by
NEPA.
TIMING
Annual revision of EDPs is
formally called for, however.
major updates of EDPs will
likely coincide with PPMS
phases in the future.
In conjunction with site-
specific technology research
plan.
Prior to PPMS decision gates.
Contained in the EDPs and
PEPs.
FIGURE 2. OVERVIEW OF MAJOR DOE ENVIRONMENTAL
PLANNING AND REVIEW DOCUMENTS
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III. REGIONAL WORKSHOP SUMMARIES
Four regional workshops were held in July 1979 in Atlanta, Denver, San Francisco, and
Pittsburgh. In these workshops representatives from Federal, State and local agencies,
environmental and public interest groups, labor, industry, and the general public discussed
DOE's Management System and the adequacy of attention this system gives to environ-
mental protection and energy conservation.
Workshop participants expressed some skepticism that the management process actually
operates as designed, and stressed a need for it to be more open. They felt that a range of
non-DOE entities, including industry, state and local governments, and the public should
have more opportunities for meaningful involvement. There was also general agreement
that environmental concerns should be viewed from a broad perspective, and should
include human as well as natural factors. Most participants felt that environmental con-
cerns resulting from the development of specific technologies had been successfully iden-
tified in most cases. However, many felt that significant concerns had not been dealt with
adequately.
In addition to these overall themes, five specific areas of concern emerged about the
adequacy of DOE's attention to environmental factors in its decision-making. Each of these
is discussed briefly below, and is treated further in Chapter IV:
1. A concern expressed in each workshop was that state and local level agencies and
organizations were not given a clear role in the DOE decision-making process.
Participants felt that more responsibility should be delegated to these levels, and that
this would increase the likelihood that local concerns, as well as generic technology
concerns would be dealt with at appropriate times. However, there were some questions
that the participants could not resolve: In what environmental issues should State and
local agencies be involved? How should the appropriate level of responsibility be deter-
mined? How should this approach be implemented?
2. A concern expressed by some participants was that DOE's formal decision-making pro-
cess appeared to overemphasize large, high-cost, high-technology programs. These par-
ticipants felt strongly that DOE tended to ignore lower cost, decentralized technology
systems in their RD&D program. Thus, potentially cost-effective approaches could be
overlooked. Another potential risk resulting from limiting top management attention to
large projects was that smaller projects could involve serious environmental impacts.
Participants felt that a crucial question to be answered is: How can adequate attention
to environmental concerns be assured for all technology development programs,
regardless of size?
3. One specific suggestion was made by workshop participants to ensure that environmen-
tal considerations are incorporated systematically into DOE's decision-making process.
They felt that a set of explicit environmental criteria should be developed and applied to
all major decisions in the technology development process. Further, they felt that these
criteria should be explained to the public, and the results of their application to each
decision should be disclosed. Development and adoption of such criteria would require
resolution of several issues, such as: What specific environmental criteria should be
included? How can these criteria be measured and weighted? When and how should the
11
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criteria be applied in the process? Workshop participants began discussion of these
questions, but further review is clearly needed.
4. The role of non-DOE groups and individuals in the decision-making process was a major
area of concern. Participants felt that opportunities for meaningful involvement of the
public was totally inadequate. Their concerns focused on three issues: (1) the public
does not receive enough information, and what they do receive is very difficult to under-
stand; (2) the public does not have a formal role in reviewing internal documents and
decisions, and opportunities for participation afforded by the NEPA process occur too
late; and (3) local officials are not consulted adequately about projects planned in their
areas and are not systematically involved in decision-making after sites are selected.
Workshop participants made a number of recommendations for alleviating these prob-
lems which are discussed in Chapter IV.
5. A final area of concern was how to coordinate technology development and environmen-
tal assessment to ensure that adequate attention is paid to environmental issues. Some
participants felt that successful resolution of environmental questions often lagged
behind technology development. They felt that in decisions about whether or not to
move a technology forward in its development, too much emphasis was placed on tech-
nical feasibility, and too little attention was given to understanding the environmental
implications and availability of environmental controls. Thus, they felt that while poten-
tial environmental impacts were generally identified, they were not always dealt with at
the appropriate time. Participants suggested several approaches to improving the inte-
gration of technology development and environmental research, including better use of
local expertise and a more effective role for the DOE Office of Environment.
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IV. ASPECTS OF DOE'S DECISION-MAKING PROCESS FOR DISCUSSION
Review of the DOE management process has raised issues in five major areas:
The appropriate governmental level for treating environmental concerns.
The types of projects receiving major management attention.
The criteria used in evaluating individual technologies.
The role of non-DOE interests in evaluating environmental issues.
The integration of environmental factors into technology decision-making.
In discussing these five issues and preparing their testimony, we would like witnesses to
consider how their views would affect the adequacy of attention given to environmental
concerns, and how their recommendations might be implemented (i.e., what structures,
procedures, or policies should be established).
The intent of this pre-hearing document is not to recommend a particular course of action
for resolving these five issues, but rather to synthesize comments, questions, and recom-
mendations from the regional workshops and EPA's own analysis of the DOE management
process and thereby provide suggestions for further thought and discussion at the October
National Hearings. The substance of these discussions will be incorporated into the final
Section 11 Report to Congress, scheduled for submission in January 1980.
Appropriate Governmental Levels for Treating Environmental Issues
The development of an energy technology from its early research stage through its com-
mercialization stage usually requires that associated environmental concerns be address-
ed at three levels:
• Local site-specific concerns—These would be associated with the proposed construc-
tion of an emerging technology pilot, demonstration, or commercialization facility. These
concerns would typically include site-specific pollution impacts, resource requirements
(e.g., water or land) and socio-economic impacts (e.g., "boom town" problems).
• Regional or cumulative impacts—The potential environmental problems may be the
result of the proposed construction of several similar facilities or of severaj energy pro-
ducing facilities of differing types. Typical concerns would include competing resource
requirements such as interstate water use agreements, or cumulative pollutant levels.
• National concerns—These will need to be addressed no matter where specific energy
facilities are located. The overall national concern will be the development of a generic
energy technology which is technically, economically, and environmentally viable.
Associated environmental problems requiring national level attention are those related"
to basic health effects and pollutant characterization, and the development of appro-
priate environmental control technologies.
For the environmental concerns associated with a technology to be addressed adequately,
these concerns should be treated at all three levels in a timely manner. At present, the DOE
management process does not make explicit who has both the responsibility and the
authority for carrying out analyses at the local or regional levels. Thus, the question is how
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to design and implement a hierarchical arrangement where responsibility is given to the
appropriate level. Certain concerns, such as site selection, will be local—especially impor-
tant to individuals directly affected by a specific facility. Other concerns, such as water use
or transient populations, may be germane only in particular regions. Still other concerns,
such as sulfur emissions, will be national.
Although an environmental issue may cut across levels, its resolution may best be under-
taken by the level that is affected. Such an approach to resolving environmental conflicts
need not necessarily entail multiplying bureaucratic structures. The approach would also
permit a wider range of expertise to be tapped. Such a system would clearly identify envi-
ronmental responsibilities and establish the authority necessary to deal with them at the
appropriate level. Although authority would be decentralized, senior DOE management
would still coordinate programs, ensure effective information exchange, and review prog-
ress in resolving the environmental concerns of the regional and local levels.
Types of Projects Receiving Major Management Attention
The fundamental purpose of-the PPMS is to review energy projects before any commitment
of major resources occurs and to ensure that all major energy technology programs are
developed with clear, workable, multiyear objectives. However, only proposed projects
designated as "major systems acquisitions" receive the full review and management atten-
tion of the PPMS. Although DOE uses many factors to determine whether a proposed proj-
ect is designated as a major system acquisition, cost has been the single most important
criterion determining the level of management review a project receives.
DOE energy projects not designated major systems acquisitions are under the manage-
ment responsibility and direction of the appropriate program office. These projects are not
subject to ESAAB review; therefore, environmental review may not be as comprehensive as
called for by the PPMS. Instead the environmental documents are prepared and the environ-
mental concerns are addressed in the ECC subcommittee meetings.
The Section 11 review has raised two concerns related to the criteria for designating a pro-
posed project a major system acquisition:
• Workshop participants felt "potential environmental consequences" should be included
as a critical factor in leading to such a designation. The argument is that the potential for
critical, irreversible environmental impacts is at least as important a factor as cost.
• A question was raised whether small projects should be aggregated as programs and
treated, in effect, as "major" projects. Formal high level review could help improve the
evaluation of these technologies. Some workshop participants felt that "soft"
technologies and conservation programs are not getting the management attention their
favorable energy and environmental attributes deserve.
Since the PPMS requires a large part of DOE's management effort, perhaps it should be
used to review a larger fraction of the entire RD&D program. One result of such an expan-
sion would be that this forum could allow comparisons of competing technologies and pro-
grams. This, in turn, could allow environmental and conservation concerns to play a more
active role in resource allocation decisions.
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Criteria Used in Evaluating Individual Technologies
Explicit environmental criteria applied at all major decision points in DOE's management
process could ensure that environmental concerns are systematically treated. Specifica-
tion of such criteria would help assure that all important environmental factors are examin-
ed before decisions are made, and that decisions regarding environmental issues are more
consistent across technologies. Well-defined criteria would also add significantly to the
credibility of DOE's technology decision-making process.
DOE has to date used at least three specific criteria in evaluating environmental concerns:
• Comparisons of pollutant emissions, energy efficiency and resource required per unit of
energy produced;
• Estimation of the dollar cost of meeting present environmental standards per unit of
energy produced; and
• Estimation of the probability that adverse environmental impacts will ultimately rule out
commercialization of an energy technology.
Each of these quantitative criteria has affected DOE decisions, but none is used routinely
or is formally required in the management process.
Many workshop participants felt that more explicit criteria are needed, covering such ques-
tions as the following:
• What are the impacts of the energy technology on public and occupational health and
safety?
• What resources (e.g., water and land) will be required?
• What are the ecological impacts?
• What are the social and economic impacts?
• How will the proposed investment pay off in terms of increased energy supplies or
decreased demand?
• Will this technology lead toward a "decentralized" or "centralized" energy system?
In selecting criteria, DOE should try to develop them in quantitative terms and should
prioritize them. However, the question remains whether criteria and measurement tech-
niques can be developed which are scientifically credible, and technically feasible.
Specification of decision criteria could facilitate cross technology comparisons. It could
also improve research planning, since DOE would know ahead of time what specific infor-
mation would be required from environmental research programs.
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The Role of Non-DOE Groups in Evaluating Environmental Issues
Comments from the workshops made very clear the view that the interested public feels it
has not been provided enough information about emerging energy technologies, energy
alternatives, the DOE energy technology decision-making process, or even when or what
technology decisions are going to be made. The feeling is that the potential significance
and impact of emerging energy technologies at the national, regional, and local levels
makes it imperative that the public be informed and able to express its views in DOE's plan-
ning and decision-making process.
DOE seems to be aware of many of the frustrations expressed by the public at the
workshops. The Assistant Secretary for Environment has stressed the importance of involv-
ing the public in the process of considering the potential environmental consequences of
emerging energy technologies. A program within the Office of Environment has been
designed which should increase substantially the dissemination of information and the
opportunity for public involvement. The major elements of this program are:
• Additional DOE effort at the regional level to increase public awareness and involvement;
• Additional involvement of state and local officials;
• Assistance to outside groups in their preparation of energy-related EISs;
• The sponsoring of special energy-environmental conferences and projects at the local
and regional levels; and
• Improvement in the distribution of technical and environmental research information.
To date, however, DOE resource constraints have apparently not allowed this program to
proceed rapidly.
In general, comments at the regional workshops about involvement of non-DOE groups
centered around three concerns:
1. The public does not receive enough information—about emerging energy technologies,
research findings related to those technologies, or DOE's decision-making process. The
public frequently does not know that decisions are being made, the nature of the deci-
sions, and what options are available. Suggestions for improving information dissemina-
tion included:
• Making internal DOE documents available to the the public;
• Preparing and distributing summaries of information contained in these documents.
These summaries should "translate" bureaucratic and technical materials so that the
public can understand them;
• Publishing records of ESAAB deliberations and recommendations; and
• Establishing a central information source through which the public can get answers
to questions.
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2. The public does not have a formal role in reviewing internal documents and
decisions—The opportunities that do exist through the NEPA process often occur too
late in the DOE decision-making process after many important decisions have already
been made. There have been many suggestions which would result in earlier systematic
public involvement in the process, including:
• Establishing a formal review and comment system for some or all internal documents
related to environmental research;
• Providing public representation on the ESAAB or establishing a parallel public review
committee; and
• Establishing advisory groups for specific technologies.
3. DOE often does not sufficiently involve state and local officials and organizations—in
planning and reviewing projects that directly affect their jurisdictions. Involvement
should begin as soon as initial siting decisions are made and should include an active
role in research planning and technology decision-making, not simply the opportunity to
react to documents. Some suggestions for involving state and local entities at
appropriate points in the process are discussed under Section A. Others include:
• Establishing state or local boards or commissions with specific responsibilities and
authority; and
• Making greater use of local expertise in planning and interprmting research studies.
The Integration of Environmental Factors into Technology Decision-Making
In addition to establishing the technological feasibility of new energy technologies, DOE
must also consider environmental impacts resulting from the use of those technologies.
Comments from the workshops addressed several aspects of the integration of technology
and environment.
The first dealt with the role of the Office of Environment in technology development.
Several questions raised at the workshops noted that the PPMS was project-oriented and
that the Office of Environment's role is largely limited to one of influencing project develop-
ment, rather than effecting policy development. Further, because there are at present no
explicit, consistent environmental criteria for decision-making, the Office of Environment's
role in influencing cross-technology decisions appears limited and uneven.
Presently the Office of Environment influences the DOE technology decision-making pro-
cess through representation on the ESAAB, ECC subcommittee chairmanships, and review
and approval responsibilities of Environmental Impact Statements in conjunction with the
DOE General Counsel. However, it may be possible for the Office of Environment to play
more of an advocacy role, and to promote the development of those energy technologies
that are particularly positive from a conservation and environmental standpoint. For this to
happen the ESAAB should review a larger portion of DOE's RD&D programs, both major
systems and smaller projects, using explicit criteria for cross-technology comparisons.
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The second aspect of the integration question revolves around DOE's objectives in building
and operating pilot and demonstration plants. DOE's mission is to develop and commer-
cialize technologies that are economically practical, technically feasible, and environmen-
tally acceptable. One approach is for DOE to demonstrate at a smaller scale that it is feasi-
ble for a technology to operate before commercial development. Another approach is for
DOE to build "experimental" facilities for use as laboratories for refining the technology,
characterizing the health and environmental impacts and developing environmental control
technologies. The distinction between these approaches is important, because decisions
made at the plant design stage will differ according to the interpretation of the DOE objec-
tive. An integrated technology and environmental research orientation would lead to the
design of experimental facilities, rather than demonstration of the viability of a single
plant.
The last aspect of the integration of technology and environmental issues is the concern
voiced at the workshops about the extent to which EAs and EISs are a part of the PPMS
review, and whether they can or do have any real impact on DOE technology decision-
making. To date, there does not appear to have been a great deal of impact, nor have the
EAs and EISs built upon the internal environmental planning and assessment documents.
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APPENDICES
Background
The regional workshops—held in Atlanta, Denver, San Francisco and Pittsburgh, during
July 1979—were intended to give EPA initial feedback on participants' perceptions of DOE's
decision-making process, and to encourage participants to begin preparing testimony for
the October National Hearings. Specifically, the goals of the workshops were to:
• Present an overview of the research, development, and demonstration (RD&D) process.
• Obtain from participants their opinions about the adequacy of attention this process
gives to environmental issues, and opportunities for public participation in the process.
• Present a report on the decision-making process as applied to one or two specific
technologies.
• Discuss with participants their views of the future development of these technologies
and their recommendations for public participation in the process.
To accomplish these goals, a one-day workshop was designed which included both presen-
tations of information and opportunities for discussion. The morning session focused on
the formal DOE nonnuclear RD&D process for major systems acquisitions (especially the
Program and Project Management System), and the afternoon session was devoted to
discussion of the DOE process as applied to specific technologies. Materials describing
the process and its application to the specific technologies were mailed to participants
prior to the workshop.
Each session began with a brief presentation of highlights of these materials. Participants
were then divided into small, heterogeneous work groups which were given a list of ques-
tions to guide, but not limit, their discussion. The morning session focused on the following
issues:
• What specific environmental factors should be considered prior to DOE decisions?
• Is the DOE process sufficient for addressing the environmental problems of individual
energy technologies?
• What role should the public play in the process?
In the afternoon, work groups considered the following questions for the technologies
under consideration:
• What are the environmental concerns about the impact of the development of the tech-
nologies? Have DOE processes successfully identified and dealt with these concerns?
• Has DOE disseminated information about the technologies widely enough? What has
been the involvement of the public and state and local governments in the development
of this technology?
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The groups were not expected to reach a consensus, although there was a surprising agree-
ment on many questions.
Each work group chose a spokesperson to present its comments to the entire workshop.
The participants and EPA staff then had an opportunity to discuss the questions, concerns,
and recommendations developed by the work groups.
The workshop concluded with a brief discussion of the October National Hearings and an
open discussion of other issues or unanswered questions.
Approximately 200 people attended the four workshops. They represented a wide range of
organizations and interests, including industry labor, environmental, and public interest
groups, universities and research organizations, and state and local governments.
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APPENDIX A. ATLANTA WORKSHOP SUMMARY
The first regional Section 11 workshop was held in Atlanta, Georgia, on July 12,1979, at the
Peachtree Plaza Hotel. This workshop focused on the DOE nonnuclear RD&D planning and
assessment process and on two specific technologies, urban waste utilization and
cogeneration.
Invitations to participate in the workshop were sent to 250 individuals representing a wide
variety of organizations, interests, and areas of expertise. Fifty-five active participants and
several Government and other observers attended the workshop. The group was composed
of representatives of industry (29%), environmental groups (21%), state and local govern-
ments (16%), Public Interest Groups (11%), offices of U.S. Representatives and Senators
(9%), universities (7%), and other groups (7%).
The DOE Environmental Planning and Assessment Process
During the morning session, participants discussed the formal DOE planning and assess-
ment process for major system acquisitions (the Program and Project Management
System).* Specifically, work groups discussed the adequacy of attention given to
environmental concerns by this process and the opportunities for public participation in it.
Following a brief overview of the process, participants broke into work groups to discuss
these issues. The groups' comments and recommendations were then presented to the
entire workshop. Several major concerns and suggestions regarding the process emerged.
Although these comments do not necessarily represent a consensus of all participants,
they were repeated by several groups.
Skepticism was expressed about the extent to which the actual decision-making process
follows the formal design. Some participants felt that if the system does in fact adhere
closely to its design, it was unnecessarily complex and costly, and that its extensive
documentation did not necessarily increase the likelihood that environmental concerns
would be considered at appropriate points. In particular, separation of technology develop-
ment and environmental research into two "tracks" covered by separate plans (Technology
Program Plan) and managed by separate offices (Program Office and Office of the Environ-
ment) was viewed as having both positive and negative aspects from the environmental
perspective. On the positive side, participation by the Office of Environment should ensure
that environmental concerns will not get lost or ignored in the interest of development. In
fact, some participants felt that Office of Environment responsibility should be expanded
to include not only review but also preparation of NEPA documentation (Environmental
Assessments and Environmental Impact Statements) which is now performed by the Pro-
gram Office. On the other hand, separation of responsibility into two Offices could lead to
extra cost, poor coordination of environmental and technology research efforts, and,
ultimately, a lack of attention to environmental issues in planning and at key decision
points. Methods for achieving coordination between environmental and technology
research and for achieving a balance between the positive and negative factors cited above
were not suggested.
*This system was described in the Section 11, Environmental Evaluation Document used
as a reference document for all workshops.
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Participants questioned whether the Energy Systems Acquisition Advisory Board* had
specific criteria governing its deliberations, review of documents, and recommendations
about the readiness of technology to move forward to a further phase of development.
There was a general agreement that such criteria should exist, particularly for evaluation of
the Environmental Readiness Document, and should be made public. Among the environ-
mental criteria suggested were traditional environmental concerns (effects on water, air,
land, wildlife, vegetation) and the broader economic, human, and social effects of a
technology.
Timing of environmental research was viewed as important by several work groups. They
felt that relevant environmental research should be performed as early as is feasible in the
process, before major capital investments have been made in a technology. Several par-
ticipants questioned whether there is a point beyond which it is virtually impossible to halt
the development of a technology, regardless of the findings of environmental research.
Finally, several participants expressed the view that this process reflects DOE's overem-
phasis on large high-cost; high-technology projects. These participants felt strongly that
DOE tended to overlook lower-cost, decentralized, appropriate technology systems in their
RD&D programs. Thus, potentially cost-effective technological approaches might be lost
sight of early in their developmental process. In particular, several participants expressed
dissatisfaction that solar technologies had not been emphasized more by DOE and in these
workshops.
Public Participation in the Process
Work group reports indicated general consensus that public involvement in the Program
and Project Management System was inadequate. Representatives of environmental
groups, public interest groups, and industry stated that they did not have adequate infor-
mation or channels of access for systematic involvement. Many participants felt that the
public should be brought into the process earlier — by the time the public has an opportun-
ity to participate, primarily through review of Environmental Assessments and Environmen-
tal Impact Statements, it is too late for their opinions to affect many important decisions.
Two factors were presented as crucial for achieving effective public participation in the
process: better dissemination of information and some level of funding support. In citing
the need for more information, participants said that the public frequently does not know
that decisions are being made, the nature of the decisions, and the options available. Two
reasons for this were suggested: first, most relevant documents are not made available for
public review, and second, materials made available do not clearly outline the nature and
effect of decisions to be made. There is need for "translation" of documents, decisions,
and procedures so that interested members of the public can understand them. Summaries
of materials, with a minimum of bureaucratic and technical jargon, would be helpful in this
process. One work group also suggested that the media should be encouraged to sponsor
forums to promote discussion of issues and dissemination of information. Another group
*The Energy Systems Acquisition Advisory Board is an internal group which recommends
to the Under Secretary whether or not a technology should be advanced to a further phase
of development.
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felt that required environmental education in the schools would give more people the basic
knowledge needed to develop informed opinions. A third group praised the efforts of DOE's
Office of Consumer Affairs in responding to requests for information.
The second requirement for sustained public participation cited by several work groups
was funding to support such efforts. It was agreed that this funding should not be confined
to any one group or interest, but a method for apportioning money among interested groups
and individuals was not presented.
Several specific mechanisms for involving the public in the process were suggested. First,
several work groups recommended public involvement with the Energy Systems Acquisi-
tion Advisory Board. Some suggested that the public should be represented on the Board;
others felt that an outside public review board should be established. This public review
board should actually meet and discuss issues, not just review written materials and sub-
mit written comments. No method for electing public representatives for the ESAAB or an
outside board was suggested.
It was generally agreed that the EPA Section 11 regional workshops are a good idea and
should be continued. Some participants felt that local workshops would be helpful as well,
although they recognized that the cost would be prohibitive.
Many participants noted that one effect of public participation was to slow down the pro-
cess. This could be a distinct drawback, since many beneficial projects could be delayed.
On the other hand, early public involvement could enable DOE to anticipate and deal with
issues as research progresses, thus avoiding lengthy delays later on.
Finally, the groups discussed who should be included in public participation activities. The
major question they considered was whether the general public should be involved, or
whether systematic involvement should focus on the "informed" public. Although broad
participation was felt by many to be ideal, several groups concluded that major effects to
involve the general public might be too costly and the return too small. While no one should
be excluded from public meetings, it was most important to involve the "informed" public.
Environmental Concerns in Urban Waste Utilization and Cogeneration Technologies
The workshop in Atlanta focused on these two technologies for several reasons. These
technologies have the potential to contribute significantly to energy conservation pro-
grams in the United States and were 2 of 16 commercialization technologies selected by
the DOE Commercialization Task Force for development and promotion. Further, a number
of privately developed and DOE-supported facilities are operating in this region.
During the afternoon session of the workshop, participants were grouped by area of
interest — urban waste utilization, cogeneration, or both. The groups discussed their
perceptions of the historical development of the technologies; their concerns about
environmental, political, technical, and social factors affecting future development; and
their recommendations regarding the appropriate role of the public in the development of
the technology. Some of the work groups' comments related to particular projects or
technical problems. A number of more general observations are reported below. Although
these comments and recommendations do not represent a consensus of the total group,
they were repeated by several work groups.
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A major theme in the discussion of these technologies was a need for DOE to adopt a less
rigid stance, and to allow for more diversity. Many participants felt that the present system
is focused only on a few high-cost, high-technology programs, and that smaller-scale,
appropriate technology projects were not adequately encouraged. Participants cited the
lack of any reference to recycling programs in the issue paper prepared for the workshop
on urban waste utilization* as an example of this approach. In the same vein, some par-
ticipants felt that DOE should put more effort into promoting conservation in addition to
supporting energy production.
In the area of urban waste utilization, one group felt that DOE should concentrate on recycl-
ing and bioconversion rather than combustion technologies. Combustion was viewed as a
short-term solution only; it was felt that the other two offer more long-term benefits. Most
of the groups mentioned recycling as an important program. Participants emphasized that
successful recycling efforts could not depend on volunteers. In almost all volunteer proj-
ects, initial interest and enthusiasm eventually wanes, and the project fails. Funding must
be made available for continued operation, or recycling should become a regular municipal
function.
Participants felt that if urban waste utilization technologies are to be developed, source
separation should be encouraged. Most felt that people would be willing to cooperate with
these efforts.
Many participants felt that in assessing these and other technologies, DOE should
examine carefully the total impact of the technology, including its by-products and
associated expenses. This comprehensive and systematic analysis should encompass
primary and secondary effects on the traditional environmental areas (water, air, land,
vegetation, wildlife) and an assessment of human and social effects, total costs and
benefits, and net energy loss or gain. Participants felt that DOE should be assisted in this
analysis by local community groups, public interest groups, environmental groups and
industry. Some felt regional citizens' advisory committees should be established and meet
regularly to discuss issues affecting their area.
Public Participation in Urban Waste and Cogeneration RD&D
Participation was viewed as a two-way process that would benefit both the government and
the public. Both the public and DOE have responsibilities for making participation suc-
cessful. As was the case with the system as a whole, participants felt that the public need-
ed more information on specific technologies in order to participate fully.
* Issue Paper on Urban Waste and Cogeneration Technologies, Section 11 Workshop July
18, 1977.
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APPENDIX B. DENVER WORKSHOP SUMMARY
The second regional Section 11 workshop was held in Denver, Colorado on July 18,1979, at
the Environmental Protection Agency Regional Office. This workshop focused on the DOE
nonnuclear RD&D planning and assessment process and on DOE's involvement in oil shale
research and demonstration.
Invitations to participate in the workshop were sent to individuals representing a broad
range of organizations, interests, and areas of expertise: forty-six people attended the
workshop, representing universities and research organizations (24%), environmental
groups (17%), public interest groups (13%), state and local government (13%), industry
(6%), and other groups (26%).
The DOE Environmental Planning and Assessment Process
During the morning session, discussion focused on the formal DOE planning and assess-
ment process for major system acquisitions (the Program and Project Management
System).* Following a brief overview of this system, participants broke into work groups to
discuss the adequacy of attention given to environmental concerns by the system and the
opportunities for public participation in it. Each group's comments and recommendations
were then presented to the entire workshop. No attempt was made to reach consensus on
these issues, but this summary reports comments that emerged as major themes or con-
cerns.
Many participants felt that there were a number of shortcomings in the way this system
handles environmental research. Most participants felt that "environmental" factors were
defined too narrowly and that, in addition to the traditional concern with air, water, wildlife,
and vegetation, environmental effects research should include health and safety issues,
social and economic effects, and net energy questions. They also felt that cumulative and
synergistic effects of several projects in.an area should be examined in a regional or com-
munity Environmental Impact Statement. They expressed frustration with the existing
fragmented approach to environmental research and felt that a more comprehensive view
was needed. They were particularly interested in seeing a greater sensitivity to state and
local concerns and felt strongly that state and local officials should be included much
earlier in the planning process.
Timing was an important issue in this discussion. Many participants felt that environmen-
tal factors should be considered earlier in the process, so that major environmental issues
would be identified prior to the first major decision. After that, environmental and
technology research should go hand in hand. Participants also felt that monitoring and up-
dating of environmental research was crucial, particularly in terms of social and economic
impacts.
Finally, participants were concerned about the relative emphasis given to environmental
research. Some felt that the process was too "driven" by the Program Office. They felt that
This system is described in the Section 11, Environmental Evaluation Document used as a
reference document for all workshops.
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more interaction was needed between environmental and technology research before
people take sides and conflicts occur. Some felt that it would be more appropriate for
Environmental Assessments and Environmental Impact Statements to be prepared by the
Office of Environment rather than by the Program Office.
In a more general discussion of the Program and Project Management System, participants
said that a formal system incorporating a uniform accountability was needed for smaller
projects as well as major systems. Several groups also suggested that the process should
allow for more comparison of technologies as they are being developed including conserva-
tion and solar technologies. Several participants recommended better coordination be-
tween DOE and EPA to avoid duplication of effort whenever possible. Finally, several
groups felt that criteria and data bases used in the decision process should be standard-
ized and made public.
Public Participation in the Process
There was general agreement among the work groups that public participation in the pro-
cess was inadequate. One of the major recommendations formulated by the groups was
earlier, more meaningful involvement of state and local governments, industry, and in-
terested organizations. Participants felt that these groups should be included in planning
for projects as soon as siting decisions are made and that the role of these groups should
include shaping project development and preparing criteria, not just reaction or review. Ac-
tive involvement in a steering role of those who could be affected by a project would en-
courage a community's sense of ownership of a project and the building of cooperative
working relationships.
In addition to this site-specific recommendation, participants noted that improvements
were needed in DOE's information dissemination procedures. They felt that internal en-
vironmental documents should be more readily available and that there should be a system
for public comment on all documents, not just the NEPA materials. Further, if public par-
ticipation is to be effective and meaningful, some participants felt that better public educa-
tion and a central information source are also needed. It is difficult for the public to keep
track of the many small decisions made by various agencies and to be aware of when,
where, and how to attempt to have an impact.
The work groups agreed that the process should be more open and suggested several
means for achieving this. In addition to making documents more available, these included
publishing the recommendations of the Energy System Acquisition Advisory Board,
holding regional conferences to discuss policy questions, and establishing regular com-
munity boards for site-specific questions. Participants stressed that effective public par-
ticipation requires a sustained effort and some funding support. One group suggested that
a set proportion of each project's budget be set aside to support public participation ac-
tivities. Another participant recommended that U.S. Senators and Representatives should
sponsor attendance of people from their districts or states at meetings such as the
October National Hearing.
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Finally, participants noted the potentially negative aspects of public participation. They
warned against any system that would create more bureaucracy or that would slow the pro-
cess down too much. No specific suggestions were made about how these pitfalls could be
avoided.
Environmental Concerns in Oil Shale RD&D
In the afternoon, participants were asked to focus-in specifically on oil shale, and to
discuss how the DOE process had worked for this technology. Oil shale was selected as
the major technology for discussion at this workshop, because a large percentage of the
country's highest quality oil shale resources are located in this region. One major area of
uncertainty was the effect that President Carter's energy initiatives would have on oil shale
research and development and on the associated environmental research.
Participants reiterated several themes from the morning session. They stressed the need
for a holistic view of "environmental" impacts including the human as well as the natural
environment. Thus, in addition to traditional concerns, they said that oil shale environmen-
tal research should include long-term health effects; impacts on water rights, particularly
secondary impacts caused by increases in population due to the projects; and positive and
negative social and economic effects resulting from new jobs and increases in population,
such as increased cost of living, crime, etc. They also mentioned a need for cost-benefit
studies on control technologies to be included under environmental research.
The participants said that they did not have enough information to judge whether DOE's en-
vironmental research process had identified all these concerns and dealt with them.
Several believed that the concerns had probably been identified but that solutions had not
been developed for all of them, particularly the social and economic problems. Some felt
that this research should be subjected to a greater degree of outside peer review.
Finally, participants repeated their recommendation that environmental concerns be
addressed earlier in the process and that technology research and environmental research
be more closely coordinated.
Public Participation in the Oil Shale RD&D Process
There was almost unanimous agreement among participants that the DOE's information
dissemination procedures were inadequate. Several participants reported that they had not
been able to obtain documents through regular channels. One participant said that in order
to obtain a specific Environmental Readiness Document, it had to be "leaked" to him.
Another widespread complaint was that materials were virtually incomprehensible. They
requested that summaries of environmental documents be prepared and that these sum-
maries contain a minimum of technical and bureaucratic jargon.
As in the morning session, participants stressed the importance of involving appropriate
state and local officials and organizations in the planning phases of oil shale projects. They
felt that it was particularly important that this kind of involvement be incorporated into any
new groups and processes developed in response to President Carter's recent energy
B-3
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message. Participants were concerned that the President's emphasis on oil shale develop-
ment could have highly detrimental effects if environmental issues were not examined
comprehensively and with sensitivity to local concerns.
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APPENDIX C. SAN FRANCISCO WORKSHOP SUMMARY
The third regional Section 11 workshop was held in San Francisco, California, on July 24,
1979 at the Environmental Protection Agency Regional Office. This workshop focused on
the DOE non-nuclear RD&D planning and assessment process and on research and devel-
opment of geothermal technologies.
Invitations to participate in the workshop were sent out by the EPA Regional Office to
individuals and organizations that had been actively involved in discussion of geothermal
projects. Thirty-seven participants attended the workshop, representing state and local
government agencies (35%), relevant Federal agencies such as the Bureau of Land
Management and U.S. Geological Survey (16%), research laboratories and universities
(13.5%), industry (13.5%), environmental groups (8%), and other organizations and areas of
expertise (13.5%).
The DOE Environmental Planning and Assessment Process
The morning session of the workshop focused on the formal DOE planning and assessment
process for major systems acquisition (the Program and Project Management System).*
Following a brief overview of the process, participants broke into work groups to discuss
the adequacy of attention given to environmental concerns by this process and the oppor-
tunities for public participation in it. The groups' comments and recommendations were
then presented to the entire workshop for discussion. Although the groups were not always
able to reach a consensus, and no attempt was made to generate consensus among
groups, several issues emerged as major themes. These concerns were voiced by several
groups and received support from a number of workshop participants.
The initial reaction of most participants to the Program and Project Management System
was that it is irrelevant to their experience, since it applies only to projects that receive very
substantial DOE support. Their experience with geothermal development and other DOE
projects had not brought them in contact with the system. Many felt that this emphasis on
large projects was too limited and that criteria other than funding levels should be used in
assigning technologies to the process. These criteria could include breadth of applica-
bility, nationwide potential, and value to a specific site or location. These criteria should
also be applied to initial decisions about projects and in setting priorities. Many par-
ticipants felt that the system reflected a DOE philosophy that is too hardware-oriented, and
that more attention should be given to smaller scale technologies and projects.
In their discussion of how this process deals with environmental concerns, the work groups
had two general recommendations: "environmental impacts" should be defined broadly
and assessment should occur very early in the process. Participants suggested that there
should be an initial assessment for each geographical area in which a project is being con-
sidered to establish baseline data and to determine what environmental factors might be
affected. Several participants stressed the importance of gathering baseline data before a
project is initiated, then regularly monitoring project effects against this information.
*This system was described in the Section 11, Environmental Evaluation Document used
as a reference document for all workshops.
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There was general agreement that a broad range of potential impacts should be con-
sidered, including traditional elements, social and economic costs and benefits, land use
compatibility, qualitative changes in the resource brought about by development or occur-
ring naturally, conservation of the resource, aesthetics, specific needs and concerns of the
local community, and cumulative effects of more than one project in an area or one project
over time. These environmental issues can be broken down into those generic to the
technology and those which are site-specific.
Participants felt that the process described in the Program and Project Management
System might be adequate for making generic technology decisions, but that it needed
major additions to be appropriate for making site-specific decisions. These additions
would focus on early involvement of local officials and community groups in planning and
research so that local concerns could be brought into the decision-making process as soon
as siting decisions are made, and local expertise could be tapped in conducting research.
In this way, a balance between national goals and local effects could be achieved. It would
also enable DOE to put its efforts into areas that are of major concern to those affected by
a project. One participant summed up this discussion by saying that "DOE answers ques-
tions no one asks and then does not have information on issues of considerable local con-
cern."
Many participants criticized the timing of environmental research. They felt that research
to develop the technology proceeds ahead of environmental research. They felt that these
two areas should be more closely coordinated and that DOE should be supporting more
research and demonstration of control technologies.
Public Participation in the Process
As indicated above, there was general agreement that public participation in the process
needed improvement. Several specific suggestions were made by the work groups, most of
which focused on better dissemination of information.
Most of the groups agreed that better information dissemination was needed and
documents should be made more readily available for public review. A number of par-
ticipants had attempted to obtain internal DOE environmental documents in the past
without success. Public review would require that the public be informed of the existence
of the documents, the nature of the documents, and how to obtain them and submit com-
ments. One group recommended that DOE establish a Public Advisors Office which would
have responsibility for disseminating information and answering questions. This office
should undertake an aggressive outreach effort to a wide audience, including industry,
state and local governments, environmentalists, and technical experts. The group sug-
gested that this program be based in the regional offices and be coordinated with state and
local energy and environmental boards or commissions. Crucial to the success of such a
program in several groups' opinion, was access to a real person who could answer ques-
tions. It was suggested that a toll-free telephone number would be helpful.
Other mechanisms were suggested to improve the public's ability to use available informa-
tion. These included a system to make people aware of past and present research projects,
and a newsletter or computer access system containing updated information on the status
of projects. Other participants said that an understandable document summarizing
technologies and projects would be very useful. These suggestions grew out of a need
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expressed by several participants for DOE not merely to release the current internal
documents to the public, but also to make an effort to assist readers in understanding
these materials.
Environmental Concerns in Geothermal RD&D
The workshop in San Francisco focused its afternoon technology discussion on geother-
mal energy because California's hydrothermal resources account for over 70% of the elec-
trical energy potentially recoverable from such reservoirs in the U.S. The largest geother-
mal power plant in the world is located at The Geysers in California, and electricity will
soon be produced commercially from liquid-dominated reservoirs in Southern California's
Imperial Valley. Many of the workshop participants had been actively involved in The
Geysers project, through industry, local government, or citizens' action groups. They had
discussed many of the environmental issues surrounding geothermal development in the
past, and many conflicts had, over time, been resolved. One participant from industry and
one community representative presented a brief overview of their experience with this proj-
ect and perspectives on it.
The major conclusions from the work groups were that environmental research should
begin earlier in such projects, that more baseline data are needed before development
begins, and that a whole-system, coordinated approach to environmental research is need-
ed. They questioned how much environmental research should actually be conducted
before a demonstration begins. Finally, they said that there was a need for both generic
planning and study, and site-specific planning and study.
Public Participation in Geothermal RD&D
The experience of the participants with geothermal projects led them to conclude
that—although DOE has not been totally unresponsive, and in some instances, DOE staff
have been very helpful—there was a lack of systematic public involvement and information
dissemination. This major problem is exacerbated by the fact that summaries of informa-
tion do not exist.
A major issue raised by many participants was that DOE does not ask local officials and
the community what they want. There is no systematic method for involving local officials
and citizens after siting decisions are made. They felt that there should be much more
careful coordination of Federal, regional, state and local activities and clarification of the
roles and responsibilities of each level. During this discussion participants wrestled with
difficult questions concerning the appropriate role and scope of responsibility for DOE.
They recognized contradictions in some of their recommendations—asking DOE to take
more responsibility for follow-up on environmental research and long-term monitoring
while also asking for greater local autonomy and decentralization of responsibility.
DOE's role as an R&D agency was discussed in relation to other needs such as long-range
planning and long term support of environmental research. Questions were raised about
DOE's responsibility for environmental study in the case of private development, as oppos-
ed to publicly-supported projects; and about the extent of DOE's responsibility for site
specific studies in addition to generic research on a technology's environmental effects.
These issues were not resolved, but the questions provoked considerable discussion.
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APPENDIX D. PITTSBURGH WORKSHOP SUMMARY
The fourth regional Section 11 workshop was held in Pittsburgh, Pa., on July 31,1979, at the
Pittsburgh Hilton Hotel. This final workshop focused on the DOE non-nuclear RD&D plan-
ning and assessment process and on two specific technologies—coal liquefaction and
coal gasification.
Invitations to participate in the workshop were sent to 125 individuals representing a wide
variety of organizations, interests, and areas of expertise. Forty-five people attended the
workshop, from industry (24%), environmental groups (18%), public interest groups (16%),
state and local government (11 %), universities and research organizations (11 %), and labor
(4%). Also participating in the workshop were several private citizens who have been active-
ly involved in the local debates over the Morgantown, West Virginia, project, and a class of
students from California State College in California, Pennsylvania.
The DOE Environmental Planning and Assessment Process
During the morning session, participants discussed the formal DOE planning and assess-
ment process for major 'system acquisitions (the Program and Project Management
System).* Following a brief presentation of an overview of this system, participants broke
into work groups to discuss the adequacy of attention given to environmental concerns by
this process and the opportunities for public participation in the process. The work groups
then presented their comments and recommendations to the entire workshop for discus-
sion. No attempt was made to develop consensus around these comments; therefore, this
summary reports those concerns that were repeated by several participants and emerged
as major themes of the workshop.
An initial question many participants asked was whether this process actually worked as it
was designed. They suggested that it should be audited to see if in fact the process is hav-
ing an impact on decisions or if the information contained in the various documents is actu-
ally ignored. They also wondered if the process was now irrelevant because of President
Carter's proposed energy initiatives for "fast tracking" synthetic fuels.
Another major issue raised by the work groups was how decisions about overall energy
planning and management are made. Where in the process are technologies compared and
environmental trade-offs resolved, and how are priorities set among renewable and non-
renewable technologies? They also questioned how energy conservation fits in and
whether it is a factor in this process. Some participants expressed concern that, in their
view, DOE's philosophy tends toward the view that "the only solutions to energy problems
are technological."
Another overall criticism expressed by some participants was that the process deals only
with very large projects. They raised the possibility that some smaller projects could have
serious environmental effects, and although similar documentation is produced for smaller
*This system was described in the Section 11, Environmental Evaluation Document which
was used as a reference document for all workshops.
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projects, they were concerned that the Office of Environment does not have the same for-
mal input.
Several work groups said they felt that specific criteria were needed for Energy Systems
Acquisition Advisory Board* recommendations and for the decisions made by the Under
Secretary on whether to move a technology to a further phase of development. They sug-
gested that environmental factors be used to form a "threshold," or minimum standard par-
ticularly in decisions on whether to pursue a technology at all. If a project or technology did
not reach the environmental threshold, conditions should be placed on approval to move it
to the next phase. These conditions would require that environmental issues be resolved
before development was continued. Participants also felt that efficiency should form a
similar threshold, and that there should be serious consideration of how society would get
the greatest benefit from dollars spent, both short- and long-term.
In discussing specific environmental factors that should be considered in the process, par-
ticipants listed those associated with construction (noise, water, air, and social and
economic effects) and with operation (air, wastewater quality and quantity, equipment and
signal noise, climatic effects, social and economic costs, and effects on property values).
They agreed that the conventional technical environmental factors have generally been
identified but not necessarily dealt with and resolved. They felt, however, that it was crucial
to look beyond these elements and consider the site-specific effects of any project. A
number of participants felt that these site-specific issues were not receiving adequate
attention or satisfactory resolution. Several groups felt that Environmental Impact State-
ment preparation should be the responsibility of the Office of Environment instead of the
Program Office.
A final area that needs improvement, according to many participants, is coordination and
communication among various layers of Government.
Public Participation in the Process
One work group summed up the feelings of many participants in the statement that "public
input seems to get lost in the maze of a vast bureaucracy." It seems to go into a black box,
and there is no accountability to the public.
There was general agreement that better dissemination of information was of critical
importance to effective public participation. Participants said that active outreach was
needed and made several specific suggestions to improve public access to information.
These include summaries of reports that use less jargon and interpret what the data mean
to the public; putting copies of relevant documents in libraries; distribution of minutes or
synopses of meetings to interested parties; compilation of extensive mailing lists from
public meetings and inquiries for dissemination purposes; and establishing a toll-free
telephone number to a person who can answer questions.
*The Energy System Acquisition Advisory Board is an internal group which recommends to
the Under Secretary whether or not a technology should be advanced to a further phase of
development.
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Participants felt that the timing of public input is important and that review of Environmen-
tal Impact Statements is too late. They felt that earlier discussion of issues in public
forums was needed to encourage communication, rather than presentation of testimony
for or against an issue. It was suggested that this discussion be national in scope in the
initial planning phases, and that local committees should then be formed for siting deci-
sions and to operate throughout the rest of the process. Some funding support would be
needed but the participants did not agree about the level of this support. One work group
also recommended evening meetings to facilitate participation by working people.
Several groups requested that the public be given an opportunity to review Environmental
Development Plans and Project Environmental Plans, to ensure that all appropriate environ-
mental concerns are included, and to review the Environmental Readiness Document, to
ensure that some responses have been developed for each concern. They also felt that the
public should be able to review Energy System Acquisition Advisory Board recommenda-
tions and the process and rationale for their decisions.
Environmental Concerns in Coal Liquefaction and Coal Gasification RD&D
During the afternoon session, the discussion focused on two specific technologies,
liquefaction and coal gasification. These two technologies were chosen for discussion by
this group because of the potential development of a coal synthetic industry in the region.
Within DOE, a Commercialization Task Force Study recommended coal liquefaction and
gasification as candidate commercialization technologies, and three gasification projects
and two liquefaction projects were designated "major systems" within the Program and
Project Management System. Recently, President Carter's energy messages have given
further impetus to the development of these technologies.
Participants were skeptical of the capacity of a new process (the Program and Project
Management Process) to govern an ongoing program. This may be a particularly acute
problem in the case of synthetic fuels because of the political pressures generated by
Presidential and Congressional support for the program. Participants noted that many
decisions appear to have been made without any regard for the formal process. One partici-
pant voiced a fear that "DOE has created a monster which it now cannot control."
Some participants felt strongly that technology development had progressed far beyond
environmental research. They felt that this was a clear indication that the process was not
working. They said that most technical environmental factors have been identified, but that
not all had been dealt with satisfactorily. In particular, they felt that site-specific issues re-
quired more attention. Some participants thought that DOE simply had too much con-
fidence that it knows the answers to environmental questions and that it should be more
tentative.
Specifically, some participants questioned whether research on a pilot or demonstration
scale truly represents the environmental effects of a commercial operation. The potential
carcinogenic effects of synthetic fuel production was cited as a major concern, along with
water and air quality, waste disposal, noise, climatic effects, social and economic impacts,
and effects on property values. Participants also noted the effect on land use and asked
what criteria are used in making siting decisions. Other criteria that participants felt should
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be considered in examination of coal synthetic fuels were net energy and net cost, includ-
ing opportunity costs. They urged that DOE compare technologies and determine where the
most benefit can be derived from its investment.
Participants expressed concern over the effects that the President's proposed "fast track-
ing" will have on synthetic fuels research. They worried that environmental research may
be cut short, and that opportunities for public participation in the process would have little
chance of expanding as they have recommended.
Public Participation in Coal Liquefaction and Gasification RD&D
There was general agreement among participants that mechanisms for public participation
and information dissemination were inadequate. Desire for a more open process was ex-
pressed by many groups, but a basic question was raised: does DOE really want public par-
ticipation? Some participants expressed skepticism about this and said that if information
dissemination and public participation do not appear in DOE's budget, then DOE does not
perceive them as a priority.
Participants noted that the role of state and local government in the process was not clear.
Participants felt that state and local governments should be more actively involved in
gathering and interpreting information. Many also felt that state and local governments
should be involved in decisions as to whether a project should occur, in addition to where
and how.
Participants repeated several of the concerns expressed in the morning session: that
documents should be readily available locally and in a form that the public can understand,
and that active outreach is needed. They also questioned how decision makers can be held
accountable when the public knows so little about their deliberations and decisions. They
felt that publishing decisions would be an initial step in increasing accountability.
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