United Stales
Ervironmental Protection
Agency
Office of
Research and Development
Washington D.C. 20460
EPA 600/9-80-008
January 1980
Office of Environmental Engineering and Technology
The Federal Nonnuclear
Energy Research and
Development Act
(Public Law 93-577)
Section 11
Environmental Evaluation
Report to the President
and Congress
-------
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 Rept-eseHtatires of the
United States of America in Congress assembled,
SHORT TITLE
SECTION 1. This Act may be cited as the ''Federal Xonnuclear 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 1009 (-12 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 EPA 600/9-80-008
Environmental Protection Research and Development January 1980
Agency Washington D.C. 20460
Office of Environmental Engineering and Technology
The Federal Nonnuclear
Energy Research and
Development Act
(Public Law 93-577)
Section 11
Environmental Evaluation
Report to the President
and Congress
-------
\
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
LETTER OF TRANSMITTAL
THE ADMINISTRATOR
THE PRESIDENT AND CONGRESS OF THE UNITED STATES
I am pleased to submit herewith the Environmental Protection Agency
Report to the President and Congress of the United States in accordance
with the direction contained in Section 11 of the Federal Nonnuclear
Energy Research and Development Act of 1974 (PL 93-577).
The Act calls upon the Agency to analyze the effect of applica-
tion of nonnuclear energy technologies to evaluate - (a) the adequacy
of attention to energy conservation methods; and (b) the adequacy of
attention to environmental protection and the environmental consequences
of the application of energy technologies.
This report sets forth the Agency's findings concerning the conse-
quences of trends in the development and application of energy technologies,
In our report5 we have sought to define both the scope and context of
these issues. By presenting and considering the comments of other inter-
ested parties obtained in public hearings mandated by the Act, the report
reflects the full range of opinions available to the Agency during our
deliberations.
I trust that the report proves fully satisfactory. If such is
not the case, or if there are any additional questions, please contact
me.
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Abbreviations
Executive Summary
SECTION I.
SECTION II.
SECTION III.
APPENDICES
REFERENCES
Figure 1.
Figure 2.
TABLE OF CONTENTS
Page
viii
1
Overview of 1979 Section 11 Activities 5
DOE Technical and Environmental Project Review Process 7
Findings and Recommendations 13
A. Regional Workshop Summaries 27
B. National Hearing Summary 37
FIGURES
Major System Acquisition Review Process 7
DOE Environmental Documents 9
vu
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ABBREVIATIONS
DOE
DOI
EAC
EA
ECC
EDP
EIS
EPA
ERD
ESAAB
MSA
NEPA
PEP
PPBS
PPMS
RD&D
Department of Energy
Department of Interior
Environmental Advisory Committee
Environmental Assessment
Environmental Coordination Committee
Environmental Development Plan
Environmental Impact Statement
Environmental Protection Agency
Environmental Readiness Document
Energy Systems Acquisition Advisory Board
Major System Acquisition
National Environmental Policy Act
Project Environmental Plan
Planning Programming and Budgeting System
Program and Project Management System
Research, Development, and Demonstration
vm
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EXECUTIVE SUMMARY
Introduction
Under Section 11 of the Federal Nonnuclear
Energy Research and Development Act of 1974
(Public Law 93-577), the Environmental Protection
Agency (EPA) is now responsible for an annual
review of
the adequacy of attention to energy conservation
methods and environmental protection...and the envi-
ronmental consequences of the application of energy
technologies...within the Federal Nonnuclear Energy
Research and Development Program...
Past Section 11 reviews have revealed that the
public is deeply divided on how research resources
should be allocated and has h'ttle knowledge of
how the Department of Energy (DOE) plans and
manages research, development, and demonstration
(RD&D) for nonnuclear technologies. Consequently,
this year's Section 11 program examined DOE's
"adequacy of attention" not in terms of the
relative share of the RD&D budget given to par-
ticular technologies, but rather in terms of how
information on "conservation methods and envi-
ronmental protection" is used in major DOE
management decisions controlling technology
RD&D.
The 1979 Section 11 review initially focused its
attention on the Program and Project Management
System (PPMS) which was DOE's basic system for
reviewing major technology RD&D projects. Dur-
ing the course of the analysis, however, it became
clear that many problems associated with the envi-
ronmental aspects of technology development were
not a function only of PPMS but resulted also
from conflicting program and policy priorities.
Many of these conflicts extend far beyond the
Department's control and reflect the differing
views of the American public regarding energy
policy. The findings and recommendations pre-
sented in this report are not limited to this project
review system, but also address certain aspects of
the nonnuclear energy RD&D policy process. How-
ever, since the scope of this review is limited to
environmental and energy conservation concerns,
comments on the overall policy process are made
from that perspective and may not reflect all the
factors which bear on the process.
A number of changes have occurred within DOE
since the 1979 Section 11 analysis was completed.
These include the following:
• PPMS has been superseded by a new Project
Management System. A manual describing this
new system is currently in preparation.
• A Planning, Program, and Budgeting System
has been developed for the Department that
integrates programs, projects, and the
budgetary process.
• A Conservation Strategy prepared by the
Office of Conservation and Solar Energy is
being revised by that Office and Secretary
Duncan's staff.
• Two new DOE committees have been established
to enhance Federal, State, and local coordina-
tion and cooperation.
• A Health Effects Assessments Program has
been initiated within DOE's Office of Environ-
ment to improve the Office's ability to conduct
cross-technology analyses.
• A Citizen Participation Manual was published
to assist all DOE Offices in designing and
implementing public involvement programs.
• The Office of Environment commissioned a
study of the Environmental Advisory Committee
(EAC) "assessing its first year's operation
and identifying areas that needed improvement
and suggested actions to enhance the effec-
tiveness of the Committee." The results of the
study are to be presented during the mid-
January 1980 meeting of the EAC.
It is likely that some of the problems discussed in
this report will be alleviated by these changes.
Organization of the Report
The two major Section 11 activities for this year
are detailed in Chapter I. They involved: (1) an
analysis of DOE's review and decisionmaking pro-
cess for nonnuclear RD&D projects, and (2) wide-
ranging discussions with the public, structured
through workshops and hearings. Appendices A
and B summarize the workshops and Hearing.
The mechanism established by DOE in 1978 for
setting the pace of federally supported energy
technology development and for undertaking the
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technical, economic, and environmental review of
RD&D projects was the Program and Project
Management System. This system is described in
Chapter II. The 1979 Section 11 review was based
on this project review system and other DOE proce-
dures in operation until the fall of 1979. Chapter II
also summarizes recent changes in DOE that are
relevant to this report.
Analysis of the findings gained from the Section
11 review resulted in recommendations in six areas.
These recommendations have the following overall
goals:
• To suggest areas in which DOE's attention to
environmental issues in its management and
decisionmaking process could be improved.
• To indicate steps DOE can take to improve its
credibility with the public and demonstrate that
it is giving "adequate attention to energy con-
servation and environmental protection."
Chapter III discusses in detail the findings and
recommendations from the Section 11 program.
These recommendations are summarized briefly
below.
energy RD&D is to generate information to reduce
this uncertainty and to solve the problems
associated with various technologies. DOE pro-
gram and project plans should be based on an
evaluation of the barriers preventing the develop-
ment of energy technologies, such as the availability
of effective environmental control technologies.
Research should be specifically directed toward
overcoming these barriers.
C. Project Review Process
In the past, high-cost, large-scale projects have
appeared to receive a disproportionate share of
senior DOE management attention through the
project management system. Research programs
such as those in the area of conservation which
involve numerous small projects have not received
comparable senior Department-wide review. Fur-
ther, projects with potentially severe environmen-
tal impacts do not appear to be assured of compre-
hensive review. DOE's project review process
should be modified to provide a more balanced
and comprehensive review that includes more
evaluation of such programs as energy conservation.
Major Findings and Recommendations
A. Nonnuclear Energy RD&D Priorities
DOE's priorities do not appear to reflect
systematic comparative evaluations of alternative
technologies. In particular, environmental attri-
butes are not compared and supply technologies
are not evaluated against the potential for reducing
demand through energy conservation measures.
An approach to such comparisons is to base them
on the ultimate "end use" of the energy. DOE
priorities should reflect systematic and explicit
comparisons of production and conservation alter-
natives. The comparisons should establish prior-
ities on the basis of energy efficiency and environ-
mental attributes.
D. Evaluation Criteria for Technology
Development
It is not clear what formal environmental
criteria, if any, DOE uses as a basis for project
reviews and priority-setting. The development of
explicit criteria and consistent, systematic applica-
tion of them would contribute significantly to
DOE's credibility in addressing environmental con-
cerns. DOE should develop explicit environmental
criteria for use in formulating energy policy and
evaluating technology development, and submit
those criteria for public and peer review. The
criteria should facilitate quantitative cross-
technology comparisons, where possible, and
include explicit examination of health, environ-
mental, and socioeconomic impacts.
B. Purpose of DOE Nonnuclear RD&D
The major barrier to commercial use of a
technology is, in many cases, a high degree of
uncertainty. This includes uncertainty about
environmental performance, engineering perfor-
mance, and process costs. The primary purpose of
E. Resolution of Environmental Issues at the
National, Regional, and Local Levels
The development of an energy technology
requires that environmental problems be addressed
at three levels: local site-specific (e.g., ground
water contamination); regional or cumulative (e.g.,
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water resource use); and national (e.g., health
effects). DOE's management process does not
appear to assure that potential problems at each level
are clearly identified and resolved in a timely and
effective manner, or that responsibility for analysis
of regional and site-specific impacts is clearly
defined. DOE should clearly assign organizational
responsibilities, and allocate resources for effec-
tively treating environmental issues at local,
regional, and national levels. DOE should involve
State and local agencies in the resolution of
environmental issues in order to both expedite and
improve the process.
F. Public Participation in Nonnuclear RD&D
Workshop and Hearing participants felt strongly
that DOE does not systematically involve the
public in the energy technology development deci-
sion process except as required by the National
Environmental Policy Act. Since the public has not
routinely been offered the opportunity to comment
on the environmental documents associated with
the project review process, it has been hindered in
its participation in early decisions on energy
technology development. DOE should systemati-
cally involve the public in a timely and meaningful
manner in consideration of the environmental
aspects of policy development, program planning,
and project management.
Hearing witnesses claimed that well-funded
public interest groups, industry and scientists have
been overrepresented in DOE public participation
forums, and that members of the general public
who are well-educated on energy matters often can-
not afford the time and cost of presenting their
views. DOE should actively pursue means by which
a broader cross section of the public can be
represented in the Department's decisionmaking
processes.
DOE has few effective mechanisms for dis-
tributing information to the public, and many of
the materials disseminated are difficult for the
public to read and understand. DOE should
improve its efforts to provide citizens with the
information necessary for them to understand and
comment effectively on energy development.
The DOE Environmental Advisory Committee
was established in early 1979 to advise the Secretary
on "policies that affect the environment and the
safety of the general public." However, the com-
mittee's role within the Department is not well
understood. DOE should clarify the role of the
Environmental Advisory Committee and link the
Committee's functions more directly to Depart-
mental activities.
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I. OVERVIEW OF 1979 SECTION 11
ACTIVITES
The Section 11 Mandate
The Federal Nonnuclear Energy Research and
Development Act (Public Law 93-577) was passed
in December 1974 as part of the national response
to the effects of the 1973 Arab Oil Embargo.
The legislation created a comprehensive national
research, development, and demonstration (RD&D)
program for nonnuclear energy technologies, with
total Federal investments of nearly $20 billion over
a 10-year period. Further, it required the development
of the
...technological capabilities to support the broadest
range of energy policy options through conservation and
the use of domestic resources by socially and environ-
mentally acceptable means.
Section 11 of Public Law 93-577 directs an annual
review of
...the adequacy of attention to energy conservation
methods and environmental protection...and the envi-
ronmental consequences of the application of energy
technologies.
The Office of Environmental Engineering and
Technology within the Environmental Protection
Agency's (EPA) Office of Research and Develop-
ment has been assigned responsibility for the
review and is charged with conducting annual
public hearings and preparing this Report to
the President and Congress.
Focus of Activities
The Section 11 activities in 1978 focused on the
allocation of the Department of Energy's (DOE)
RD&D budget resources among competing energy
technologies. During the public hearings, it became
apparent that there were deep differences of opinion
on how research dollars should be spent. However,
there was one point on which witnesses did agree:
outside the Department of Energy there is a general
lack of understanding of DOE's decisionmaking
processes and the manner in which environmental
considerations enter these processes. This lack of
understanding appears to have damaged DOE's
credibility with the public, generating controversy
rather than consensus on how to deal with the
Nation's energy problems.
Consequently, the 1979 Section 11 program did
not evaluate specific budget allocations. Rather,
the planning and management processes were
examined to ascertain how they address concerns
for environmental protection and energy conserva-
tion. In other words, this year the "adequacy of
attention" was evaluated not in terms of the relative
share of the RD&D budget given to particular
technologies, but rather in terms of how informa-
tion on "conservation methods and environmental
protection" is used in the major management
decisions controlling DOE's technology RD&D.
Specific Section 11 Activities
The 1979 Section 11 activities had two compo-
nents: an analysis of how environmental concerns
are treated in DOE nonnuclear RD&D, and discus-
sions with the public about the adequacy of DOE's
attention to these environmental concerns. Specific
activities of the Section 11 program included pre-
paring and distributing background documents,
and conducting regional workshops and a National
Hearing.
This year's program began with an investigation
of the procedures and documents used by: DOE to
guide the development of energy technologies,
focusing on environmental review and its integration
with technology development. The investigation
resulted in publication of a document describing
DOE's major project review system and associated
environmental assessments.* This document also
provided a case study of the application of these
procedures to geothermal energy RD&D. Five
other case studies were prepared to describe how
the project review system and associated environ-
mental assessments were related to the develop-
ment of additional technologies. A range of
technologies was selected—from environmentally
benign or beneficial, such as cogeneration, to those
with the potential for serious environmental effects,
such as coal liquefaction.**
* The Federal Nonnuclear Research and Development Act
(Public Law 93-577), Section 11, Environmental Evaluation,
EPA 600/9-79-020, June 1979.
** EPA Issue Paper on Urban Waste and Cogeneration
Technologies, July 12, 1979; EPA Issue Paper on Oil Shale
Technologies, July 18, 1979; EPA Issue Paper on Coal Liquefaction
and Coal Gasification Technologies, July 31, 1979.
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These documents were distributed to a wide
range of public interest, environmental, govern-
ment, labor, and industry representatives, along
with invitations to one of four workshops where
one or two technologies and the project review
process would be discussed.
Workshops were held in Atlanta, Denver, San
Francisco, and Pittsburgh. At the workshops,
technology development and environmental assess-
ment were reviewed, with workshop members partici-
pating in an evaluation of these processes. Each
workshop focused specifically on technologies under
development in that region. A summary of the
workshop proceedings is included in Appendix A to
this report.
Following the workshops, a document synthesizing
participants' comments, questions, and concerns
was prepared.* This document outlined five issues
which had emerged as overall themes during the
workshops:
• The appropriate level for treating environmental
concerns;
• The types of projects receiving major manage
ment attention;
• The criteria used in evaluating individual
technologies;
• The role of the public in evaluating environ-
mental issues; and
• The integration of environmental factors into
technology decisionmaking.
These issues served as focal points for the
National Hearing. Although Hearing witnesses
were not limited to consideration of these partic-
ular issues in their testimony, they were encouraged
to examine them and present recommendations. In
Background Document for the National Hearing,
EPA 600/9-79-033, September 1979.
preparing testimony, witnesses were asked to con-
sider how their recommendations would affect the
adequacy of attention given to environmental
concerns within DOE, and how they might be
implemented by the Department.
The National Hearing, mandated by Section
ll(c) of Public Law 93-577, was held October 3-5,
1979, in Washington, D.C. Thirty-five witnesses,
representing the general public, various interest
groups, environmental and alternative energy
groups, State and local governments, research
scientists, and industry, testified during the 3 days.
Hearing panel members included the DOE Assis-
tant Secretary for Environment, and represen-
tatives from EPA, the Council on Environmental
Quality, Congressional Staff, environmental
groups, State government, and industry. A
transcript of the Hearing will be published sepa-
rately but a summary of comments and testimony
at the Hearing is included in Appendix B.
Organization of this Report
The remainder of this report is organized as
follows:
Chapter II presents a brief description of DOE's
major project review system, upon which the
workshop and Hearing discussions were based,
and outlines recent changes in DOE which are
relevant to the 1979 Section 11 review.
Chapter III discusses the issues raised in the
1979 Section 11 Program, and presents recom-
mendations for resolving these concerns and
improving DOE's energy technology decision-
making.
Appendices A and B are detailed presentations
of the comments made during the regional
workshops and National Hearing, respectively.
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II. DOE TECHNICAL AND ENVIRON-
MENTAL PROJECT REVIEW
PROCESS
Overview of the RD&D Project Review 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. As part of its
responsibility to implement energy policy, DOE
conducts research programs to develop technol-
ogies that are technically feasible, economically
practical, and environmentally acceptable. Within
each program, specific projects are funded to move
an emerging technology from basic research to
commercial acceptance. The projects progress
through several stages of increasing complexity and
scale—laboratory, pilot, demonstration, and
commercialization. At the end of each stage, a
decision must be made whether or not to advance
the technology to the next stage.
The 1979 Section 11 Program examined a
number of DOE management systems to determine
how environmental concerns affect nonnuclear
RD&D. The Program and Project Management
System (PPMS) was selected for indepth analysis
because it was the principal DOE system guiding
the review and approval of DOE's major tech-
nology development projects. The basic purpose
of PPMS was to structure the review of individual
projects at the end of each development stage
before additional Federal resources were commit-
ted. Each project was evaluated at these decision
points for technical feasibility, cost, and environ-
mental acceptability—but no comparisons were
made between projects. This review was conducted
by an Energy Systems Acquisition Advisory Board,
consisting of senior DOE officials, including the
Assistant Secretary for Environment. As a result of
this review, recommendations were made to the
DOE Under Secretary who determined whether a
project should advance to the next stage of
development. Participation in this review was
important to the DOE Office of Environment
because it provided a direct link to the develop-
ment, approval, and execution of DOE's major
technology projects. A general outline of the
process is illustrated below.
LABORATORY
RESEARCH
PI 1 I"»T
1
1
DEMONSTRATION
1
1
COMMERCIALIZATION
' 1
ESAAB
REVIEW AND
RECOMMENDATION
TO UNDER
SECRETARY
ESAAB
REVIEW AND
R ECOMMENDATION
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 REVIEW PROCESS
7
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Only projects designated as "Major System
Acquisitions" are consistently reviewed by senior
DOE management. DOE uses many factors to deter-
mine whether a project will be designated as a Major
System Acquisition, however, the principal factor is
the level of Federal support.* Of approximately 300
nuclear and nonnuclear DOE technology RD&D
projects now underway, only 25 to 30 are Major
System Acquisitions. These account for about 50 per-
cent of the total Departmental budget for energy
RD&D.
DOE energy projects not designated Major System
Acquisitions are under the management responsibility
and direction of the appropriate energy technology
Program Office. These projects are reviewed only by
the appropriate Assistant Secretary or the Director of
Energy Research. For these projects, environmental
concerns are addressed by an Environmental Coor-
dination Committee (ECC). The functions of the
ECC are to provide a forum for the exchange of
viewpoints between the Office of Environment and
the technology Program Offices, and to oversee the
preparation and implementation of environmental
planning documents.
Environmental Planning, Review, and
Assessment Documents
For all RD&D projects, both Major System
Acquisitions and others, environmental research is
planned and assessed in a series of documents:**
A. Planning Documents
Environmental Development Plans identify
environmental concerns and plan research to address
those concerns. These plans describe environmental,
safety, and health research required at each stage
of program development so that decisionmakers
will have this information as they consider
budgetary allocations for further development of
technology projects. Preparation of the Environ-
mental Development Plan for each program is the
* For example, development cost criteria stipulate that a project is
considered "a major system acquisition" if there is a total estimated
Government cost share in excess of $50 million in the technology
development phase or $200 million over the life of the system
or project.
** Many of these documents existed before the PPMS was imple-
mented, and it seems likely they, or some variant of them, will be
retained in any new management system.
responsibility of the Environmental Coordination
Committee. This Committee functions through
subcommittees designated for each technology.
Subcommittees include representatives from both
the Office of Environment and the appropriate
Program Office. The subcommittees prepare Project
Environmental Plans, which detail the site-specific
environmental research to be conducted for each
major project.
B. Review and Assessment Documents
Three documents—Environmental Readiness
Documents, Environmental Assessments, and
Environmental Impact Statements—are used to
assess the environmental acceptability of energy
projects.
Environmental Readiness Documents serve
several purposes. As assessments prepared inde-
pendently by the Office of Environment, they are
used by the Assistant Secretary for Environment to
advise the Energy Systems Acquisition Advisory
Board or a Program Manager as to whether it is
suitable for an energy technology to move to the
next stage of development. Environmental Readi-
ness Documents present the results of environ-
mental research already carried out, and provide
further definition of concerns and research needs
for subsequent stages of development. As reference
documents, Environmental Readiness Documents
are also designed to be useful in "scoping"
environmental concerns and supporting Environ-
mental Impact Statement preparation.
The National Environmental Policy Act of 1969
(NEPA) requires Federal agencies to prepare Envi-
ronmental Impact Statements for major actions
that significantly affect the quality of the environ-
ment. An Environmental Assessment is a prelim-
inary analysis to determine whether the impact of
an action will be significant, and is used to decide if
preparation of an Environmental Impact State-
ment is necessary. At the present time, Environ-
mental Impact Statements provide the major
opportunity for public input into DOE decision-
making through legislatively required review and
comment.
A further description of NEPA and internal
DOE environmental documents is given in Figure 2.
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DOCUMENT
PURPOSE
CONTENTS
PREPARER
PUBLIC ACCESS
TIMING
1. Environmental Develop-
ment Plans (EDP)
2. Energy System Acquisition
Project Environmental
Plans
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Recent Changes in the Department of Energy
Several changes have occurred recently in DOE
organization and procedures which are relevant to
the issues raised in this report. Some of these
changes may alleviate specific problems described
in our findings and recommendations. However,
timing of the changes has precluded an indepth
assessment of their effects, so they have not
generally been incorporated into the discussion of
issues.
A. Program Planning and Policymaking
The Department of Energy is in the process of
updating several Internal Management Directives
and Secretary-level memoranda to improve its
policymaking and program planning. A Planning,
Program, and Budgeting System (PPBS) is under
development within the Department to provide a
multiyear system relating budget cycle evaluation
and program/project reviews.
A draft Policy, Programming, and Fiscal
Guidance Document in support of PPBS is now
under review within DOE. This document is an
attempt to describe the Department's energy policies
and programs/projects and their rationale. It is
primarily to be used as guidance for preparation of
5-year DOE program requirements for Fiscal Years
(FY) 1982-1986. The FY 1982-86 program develop-
ment cycle began when the Policy, Programming,
and Fiscal Guidance Document was drafted and
distributed for internal DOE comment in mid-
December, 1979. The PPBS will be the manage-
ment system used by the Department to establish
and maintain the 5-year Energy Program and the
Departmental budget.
B. Project Management
A recently completed DOE Project Management
System Study reviewed the PPMS and other
project-level systems and recommended changes to
"tighten and simplify procedures, establish clear
lines of responsibility, ensure appropriate delega-
tion of authority, and establish management
accountability for project activities."*
*Department of Energy, Project Management System Study,
DESM 79-1, Summary of the Report, p. 1.
A manual which describes the new Project
Management System is under preparation and
scheduled to be completed in early 1980. Following
is a description of the new system taken from the
Study.
The DOE Project Management System is intended to be
an umbrella system tying together and integrating all
Departmental organizations and systems which have
roles in project management... The requirements of
this management system are mandatory for the
Department's Major System Acquisitions and Major
Projects; the general principles should be used for other
projects as far as practical. Uniform guidelines for appli-
cation to other projects may be developed, if needed,
after additional experience with the system has been
gained...*
C. Environmental Evaluation
A newly formed Health Effects Assessment
Program within DOE's Office of Environment is
attempting to develop information on health and
ecological effects of energy-related pollutants.
Specifically, it is attempting to formulate scien-
tifically defensible, quantitative criteria and data,
assessing health risks from energy technology-
related pollutants.
D. Conservation Strategy
In the fall of 1979, Energy Secretary Charles
Duncan requested that the DOE Office of Conser-
vation and Solar Energy complete a conservation
strategy paper that detailed current government
conservation programs and possible new initiatives
to cut energy consumption. A draft Conservation
Strategy Paper was completed in early November
1979.** The strategy paper was divided into several
sections, including an overview of U.S. conserva-
tion strategy, "cross-sectoral" programs and ini-
tiatives, and conservation in the residential/com-
mercial, the industrial, the transportation, and the
utility sectors. In the overview of the paper, it was
stated that "greater energy efficiency and reduced
petroleum consumption can be achieved without
adverse effects on present or future economic well-
being," but that "this potential will only be achieved
through a concerted effort to overcome a variety of
significant barriers."
*ibid. p. 2.
**Draft U.S. Conservation Strategy, DOE Office of Conservation
and Solar Energy, November 2, 1979.
10
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During the fall, the document was modified to
incorporate more specifically the Department's
1980 conservation objectives. The DOE Office of
Conservation and Solar Energy is now preparing a
fully documented strategy and program objectives
report.
E. Intergovernmental Coordination
DOE has recently taken two significant steps to
enhance intergovernmental coordination and
cooperation. On October 1, Secretary Duncan
established an Intergovernmental, Affairs Council
within the Department to promote internal coor-
dination and to facilitate the close cooperation of
the Department with State, local, and Indian
governments.* The purposes of the Council in-
clude: providing a forum for resolving issues;
involving State, local, and Indian governmental
leaders in developing energy priorities, policies,
and programs; and coordinating DOE resources
for intergovernmental initiatives. The membership
of the Council consists of 20 officials and delegates
from within the Department, representing every
principal operating and staff component and
including Regional Representatives.
On November 30, Secretary Duncan announced
the establishment of a Local Government Energy
Policy Advisory Committee which "will focus,
first and foremost, on developing procedural
mechanisms that will enable local government offi-
cials to participate actively in the formulation and
implementation of national energy policies."**
The specific purposes of the Committee are to
help ensure that energy programs and legislation
reflect and respond to the needs of local govern-
ments, that components of the Department of
Energy are coordinating their activities with local
governments, where appropriate, and to enhance
intergovernmental communication generally.
Thirty-three State, county and city officials nation-
wide were asked to serve on the Committee.
F. Public Participation
Over the summer, DOE published a Citizen
Participation Manual to assist DOE officials in
designing and implementing public involvement
*DOE Intergovernmental Affairs Council Charter, October 7, 1979.
**DOE News Release, "Energy Secretary Establishes Local Govern-
ment Advisory Group." R-79-510, November 30, 1979.
programs. In general, the Manual presents a
positive commitment to the concept of public
participation:
The legislation establishing the Department of Energy
(DOE) (Public Law 95-91, Title I, Section 102) directs
DOE to provide for, encourage, and assist the public to
participate in the development and execution of national
energy programs.
Public understanding of the complexities of energy
issues and public involvement in the decision process
addressing these issues are essential steps in achieving an
effective national energy policy. Because of time and
resource constraints in the past, many of our programs
and activities have not been well understood by the
general public, resulting in a lack of basic understanding
of the nature and objectives of such programs. We must
improve our ability to effectively communicate with and
respond to the energy concerns of the American people.
Only through open and constructive communication can
we work together to develop acceptable solutions to the
energy problems facing the Nation."
(Cover memorandum from former Deputy Secretary
John F. O'Leary.)
The Manual indicates that there are four
categories of DOE administrative processes which
call for public participation: regulation develop-
ment, policy development, planning, and program
operations. It stresses that
public participation must be integrated into the total
process so that events are relevant to the decisions and
schedules of the administrative process.
G. Environmental Advisory Committee Study
A study of the operation of the Environmental
Advisory Committee was commissioned by the
DOE Assistant Secretary for Environment for use
at the Committee's January 1980 meeting. The
purpose of the study was to "identify areas that
needed improvement and suggest actions to
enhance the effectiveness of the Committee."* The
study found that, although the Committee contained
a good mix of member capabilities and leader-
ship potential, neither DOE nor Committee
member expectations had been met during the first
year. The study's major recommendations call for
DOE and the Committee to clarify their expecta-
tions, and to agree upon "a new covenant" to
meet them.
*The First Year: An Assessment, Delphi Research Associates,
January 1980, p. 2.
11
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H. National Environmental Policy Act
On July 18, 1979, DOE announced proposed
guidelines for compliance with the Council on
Environmental Quality (CEQ) Regulations issued
as a result of the National Environmental Policy
Act. The DOE guidelines state that the Department
will "incorporate into early planning processes a
careful consideration of the potential environ-
mental consequences of its proposed actions, and
appropriate alternative courses of action."*
The CEQ Regulations require that environmental
analyses concentrate on alternatives and include
"scoping, an early and open process for deter-
mining the scope of the issue to be addressed." In
addition, they require a tiering concept
which provides for focusing on the actual issues ripe for
decision and eliminating repetitive discussions of the
issues already decided. Accordingly, environmental
documents prepared for a policy level decision will pro-
vide the foundation for subsequent program and project
environmental documents.*
The proposed DOE guidelines were published on
an interim basis pending publication in final form.
Written comments were requested by DOE in the
Federal Register notice of the proposed guidelines.
Final regulations are expected to be published in
February 1980.
•Department of Energy: Compliance with the National Environ-
mental Policy Act, Proposed Guidelines, Federal Register,
Volume 44, No. 139, Wednesday, July 18, 1979.
•Council on Environmental Quality. National Environmental
Policy Act — Regulations, Federal Register, Volume 43, No. 230,
Wednesday, November 29, 1978.
12
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III. FINDINGS AND
RECOMMENDATIONS
Background
This chapter discusses major concerns regarding
nonnuclear RD&D management which were raised
during the 1979 Section 11 program. The recom-
mendations have two overall goals:
• To suggest areas in which DOE's attention to
conservation and environmental issues in its
management and decisionmaking processes can
be improved.
• To outline steps DOE can take to improve its
credibility with the public and to demonstrate
that it gives "adequate attention to environ-
mental protection and energy conservation
methods...and the environmental consequences
of the application of energy technologies."
There are several Sections within Public Law
93-577 that relate to energy conservation and
environmental protection in the Federal Non-
nuclear Energy Research and Development Pro-
gram. These Sections and the recommendations
suggested in this chapter are based upon the
conviction that disclosure, feedback, and account-
ability are integral to improving DOE's decision-
making in the nonnuclear RD&D program.
Initially, the 1979 Section 11 review focused its
attention on the DOE Program and Project
Management System (PPMS) to determine how
environmental and energy conservation concerns
had a demonstrable impact on technology RD&D
projects. During the course of the analysis,
however, it became clear that many concerns
associated with the environmental aspects of
technology development were not a function only
of PPMS, but resulted from other DOE priorities
and the conflict of overlapping decisionmaking
processes. Many of these conflicts extend far
beyond the Department's control and reflect the
differing views of the American public regarding
energy policy. The concerns and recommendations
presented in this chapter are not limited to the
PPMS, but also address certain aspects of the non-
nuclear energy RD&D policy process. However,
since the scope of this review is limited to
environmental and energy conservation concerns,
comments on the overall policy process are made
from that perspective and may not reflect all the
factors which bear on the process. Before presenting
these concerns, however, it is useful to discuss
lessons which can be learned from DOE's experience
with PPMS.
During the time it was in effect, PPMS, with its
associated environmental assessments, exhibited
several aspects of an effective review and documen-
tation system. Specifically:
• It provided a systematic means of reviewing
emerging energy technologies by identifying
distinct stages through which every technology
must pass, from initial research to full-scale
commercialization.
• It provided formal procedures which enabled
the Office of Environment to play a role in
DOE project decisions through membership on
the Energy Systems Acquisition Advisory Board
and chairmanship of the various Environmental
Coordination Committee's subcommittees.
• It attempted to integrate energy technology
development projects and environmental
research through timetables and review
procedures.
Despite these positive design features, there were
problems with the environmental planning and
assessment process associated with PPMS. There
was an overall concern regarding the extent to
which the system actually operated as it was designed.
As one hearing witness noted:
It seems clear that the process is systematically struc-
tured. What is not clear is whether that process func-
tions or simply exists on paper. It is not clear whether
that process suffices to protect environmental concerns.
We saw no guarantee that an identified environmental
problem must be dealt with, that a mitigation strategy
must be adopted, and so forth. It is not clear to us
that this process necessarily identifies the needed envi-
ronmental research related to a given technology or if it
does identify it, that it proceeds to accomplish it, or if it
accomplishes it, that it integrates the results into actions in
future decisions.
(Richard Pratt, Pennsylvania Sierra Club)
In addition to specific issues regarding the design
and operation of the project review and assess-
ment process, a major finding of the Section 11
analysis was that the public as represented in the
workshops and the Hearing does not appear to
understand, and therefore lacks confidence in
DOE's systems for treating environmental issues.
13
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The concerns about the adequacy of DOE's
"attention to environmental protection and energy
conservation" in its RD&D programs which
resulted from the 1979 Section 11 program can be
grouped into six major areas. These are:
A. Nonnuclear energy RD&D priorities;
B. Purpose of nonnuclear RD&D;
C. Project review process;
D. Evaluation criteria for technology develop-
ment;
E. Resolution of environmental issues at the
national, regional, and local levels; and
F. Public participation in nonnuclear RD&D.
MAJOR FINDINGS AND
RECOMMENDATIONS
A. Nonnuclear Energy RD&D Priorities
FINDING: DOE's priorities for technology
development are not based on comparative
evaluation of alternative technologies.
Past DOE procedures for RD&D decision-
making have not led to comprehensive analysis,
comparative evaluation, and prioritization of
potential alternatives for meeting energy needs.
Instead, the knowledge gained from research on
engineering performance or environmental prob-
lems is used in specific project decisions, with
review and comparison focused on narrow selec-
tions of engineering alternatives. For example, past
procedures only required or fostered comparisons
within various program areas (e.g., oil shale pro-
cessing) rather than assessing the value of several
supply alternatives versus reduction of demand
through energy conservation measures.
At the Hearing and in all of the workshops there
was an overriding consensus that smaller scale
appropriate technologies using renewable resources
have not been given adequate evaluation and atten-
tion when RD&D priorities are set. Criticism of the
priority-setting process included opinions that:
the process does not take into consideration alterna-
tive small-scale technologies when it evaluates a par-
ticular major system technology. In other words, it does
not consider other ways to obtain the energy which is
proposed for production by the technology under con-
sideration
and:
if technological alternatives are not reviewed, then
energy conservation possibilities will not be addressed,
nor will appropriate technologies or other alternatives
be addressed which might produce more economically
the same amount of energy as the large-scale tech-
nologies being considered.
(Susan Tachau, National Center for Appropriate
Technology)
Participants described in detail their belief in the
potential lower costs and environmental advan-
tages of such alternatives as solar energy, recycling
and conservation as compared to the technologies
DOE is now emphasizing. They felt there, is an
urgent need to find better methods to balance
RD&D efforts and to make that balancing process
known to the interested public. Several recent
studies contain support for these opinions, empha-
sizing the crucial importance of conservation and
renewable resources to our energy future.*
If DOE's priority-setting processes are to be
widely accepted as giving adequate attention to
energy conservation methods and environmental
protection, they should be justified in terms of
explicit comparisons of a broad range of alter-
natives. DOE should demonstrate that it has
thoroughly considered production and conserva-
tion, intensive and appropriate technologies, and
both large-scale centralized and small-scale decen-
tralized technologies. Further, it should be clear
that research priorities were established on the
basis of these comparisons.
There are two specific aspects of DOE's plan-
ning and priority-setting in which the adequacy of
attention to energy conservation and environmen-
tal protection could be improved. The first area
concerns the extent to which energy conservation
was considered in past energy demand forecasting,
and the second concerns an alternative approach
for comparing RD&D opportunities, one which is
based on energy "end use."
* Landsberg, Hans, H. et al., Energy, the Next Twenty Years,
1979; Stobaugh, Robert, and Daniel Yergin, Energy Future,
1979.
14
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The dynamic nature of energy supply and demand
within the past several years has forced a
mode of policymaking which may overemphasize
the economic consequences of supply shortages.
Contributing to this approach have been
overestimates of energy demand which have been
derived from past economic performance. The
forecasting models do not realistically reflect the
consumer response to unprecedented disruptions in
energy supply or major changes in energy pricing.
The econometric models are valuable tools, but
they do not have the flexibility necessary to reflect
the continuous response of social and economic
structures. This is especially relevant in the area of
conservation, where recent energy consumption
patterns have demonstrated that they can shift
dramatically as a result of supply and price
changes.
A further problem is the fact that models have
not included the potential impact of the capacity of
the economy to turn over or replace the capital
stock. Newer technologies tend to be more energy
efficient than the technologies they replace. By the
year 2000, the Nation is likely to replace 35 percent
of existing commercial buildings, 60 percent of exist-
ing industrial boilers, and virtually all remaining
energy-using devices.*
The usefulness of formal models, derived from
historic data, decreases significantly as uncertainty
about assumptions and variables increases. Recent
questions about the validity of the relationship
between energy use and economic activity, and the
inability to accurately predict energy prices and
resultant consumer behavior, tend to undermine
any planning system that relies exclusively on tradi-
tional econometric demand predictions.
Formal models can help uncover counter-intuitive
results and thus promote deeper understanding...The
dilemma of formal models, however, is that the scien-
tific aura surrounding them encourages those who use
the results of models to expect much more. And a model
incorrectly used can do more harm than good. **
The priority-setting process could be improved if
it included a comparison of technologies based
on the ultimate "end use" of the energy produced.
* Based on Statistics from the Bureau of Economic Analysis, U.S.
Department of Commerce, prepared by TRW Energy Systems
Group for DOE, Office of Conservation and Solar Energy.
**Stobaugh, Robert & Daniel Yergin, Eds., Energy Future,
"Appendix: Limits to Models," p. 262.
Under this analytic framework each fuel source
and technology would be compared as to its capacity
to fulfill a specific energy need in the most efficient
and environmentally beneficial manner. As one
witness expressed this:
the principle is that the 'end use' for which energy is
required should determine, as much as possible, the
resource and form of the energy to be employed for that
use. The choice should be based on considerations of
conservation or, in other words, of energy economy.
This means that preference should always be shown for
forms of energy that, while remaining compatible with
the 'end use' to which they are put, are as direct as possi-
ble, involve as little capital-intensive technology as possible,
and come, as much as possible, from renewable sources.
(Susan Tachau, National Center for Appropriate
Technology)
For example, in residential heating, rather than
just replacing heating oil with synthetically derived
oil, other alternatives such as passive solar heating,
wood burning, and increased energy efficiency
through the use of insulation and double-glazed
windows should be considered.
RECOMMENDATIONS: DOE research
priorities should reflect systematic and
explicit comparisons of production and con-
servation alternatives.
The comparisons should help establish prior-
ities on the basis of energy efficiency and
environmental attributes.
Methods of analysis, such as energy "end
use," should supplement econometric models
which tend to underrate the effects of energy
conservation.
B. Purpose of DOE Nonnuclear RD&D
FINDING: The major barrier to commercial
use of an energy technology is uncertainty—
uncertainty about environmental perfor-
mance, engineering performance, and process
costs.
Uncertainty about technical, environmental, and
economic feasibility are the principal barriers to
the adoption of new energy technologies. The DOE
15
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RD&D program has operated under the assump-
tion that a technology demonstration is the way to
reduce this uncertainty, and that a successfully
operating prototype with wide-scale dissemination
of information on its characteristics would lead to
commercialization, given appropriate market con-
ditions. Under this assumption, the primary pur-
pose of research and development is the opera-
tional demonstration unit. DOE's past RD&D
management system seems to have been built on
this concept, that technologies can best be
developed through an orderly progression of
demonstration projects of ever-increasing size.
Another approach to RD&D would be specifically
directed toward identifying and solving problems
associated with technology development. As one
witness said:
whole agency...whose mission it is to build and secon-
darily to do the best it can with the consequences... You
need a more balanced situation, where you are setting
your energy priorities and your environmental priorities
at the same time and how can we optimize both of these—
rather than looking for the best energy technologies and
then later worrying about how to handle the environment..
(Richard Pratt, Pennsylvania Sierra Club)
Another witness observed:
I think the need has to be stressed for experimental
facilities which test not only the technological capabil-
ity, but also the environmental issues.... There's also a
need to emphasize decisionmaking systems which focus
on incremental and adaptive decisionmaking to the
greatest extent possible, rather than go/no-go decisions,
so that we can reflect, as we move through various steps,
the findings of environmental research, assessment, or
monitoring.
(Alan Hirsch, Fish and Wildlife Service)
The most intractible problem with technology develop-
ment programs is the single-purpose momentum they
generate to carry each new technology into full commer-
cial application. Unfortunately, DOE's management
system does everything possible to reinforce rather than
correct this fault. It is hardware-oriented; it is not
geared to problem-solving.
(Kevin Markey, Friends of the Earth)
Reviewing research programs in terms of the
problems they are trying to solve — that is, the bar-
riers they are trying to eliminate — means that
research would not be justified solely in terms of
proving engineering feasibility, but in terms of pro-
viding the solutions to problems impeding the
development of the industry. If data on engineer-
ing performance are critically lacking, this may
indicate a need for demonstration; but the problem-
solving approach may anticipate and resolve
development issues, such as the generation of car-
cinogenic wastes, that may not be relevant in the
present design stage. The problem-solving approach
would make explicit the research required to pro-
duce information needed for engineering and
environmental protection evaluations.
Many workshop participants and hearing wit-
nesses observed that technical and environmental
research should be more closely linked and that
DOE efforts in both areas should be designed to
provide the greatest amount of data to be used in
decisionmaking. One witness stated:
The development of new strategies or
technologies to produce or conserve energy in-
volves several major activities: basic technical
research; research on environmental, social, legal,
or institutional barriers; testing and demonstration
of the technology; and finally, commercial opera-
tion and marketing of the technology. Government
involvement is more appropriate in some of these
activities than others given the constraints, incen-
tives, and capabilities within the private sector.
Moreover, the private sector is unlikely to conduct
research into environmental effects of energy
technologies, thus this area is particularly appro-
priate for government involvement. But DOE's
RD&D program seems to be heavily oriented
toward rapid commercialization of technologies
rather than toward thoroughly testing and exam-
ining all aspects of their application, including
environmental effects. DOE's research goal should
be directed toward providing data on technical
readiness, cost, and environmental risks. As stated
in a recent study:
The market cannot be expected to provide the right
amount or kinds of basic scientific research or informa-
tion gathering, but can ordinarily move ideas from the
lab to the marketplace at about the right rate. We think
it is important, therefore, that government policies con-
centrate on encouraging programs that enhance basic
knowledge and provide a wide range of competing tech-
nological concepts that can be evaluated and, when
warranted, picked up and applied by the private sector.*
What you need is a system which is a little more balanced
between branches that are building things and branches
that are considering alternatives, rather than having a
* Landsberg, Hans; H. et al., Energy, the Next Twenty Years,
1979, p. 50.
16
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RECOMMENDATION: DOE program and
project plans should be based on an evalua-
tion of the barriers preventing the develop-
ment of energy technologies such as the
availability of effective environmental control
technologies. Research should be specifically
directed toward overcoming these barriers.
C. Project Review Process
FINDING: In the past, high cost, large-scale
individual projects appeared to receive a
disproportionate share of senior DOE
management attention. Substantial research
programs such as conservation that involve
numerous small projects have not received
senior Department-wide review.
Many witnesses felt that DOE lacks a project
review process that is sufficiently broad-based and
systematic, and that this has resulted in a bias toward
large technologies. This bias has caused the majority
of DOE's smaller, appropriate technologies to
appear to languish in their development, even
though their supporters feel that they may be more
cost-effective and their environmental impacts may
be less severe.
There are approximately 300 nuclear and non-
nuclear DOE-sponsored technology RD&D proj-
ects now underway. During their development, all
technology RD&D projects progress through
various stages including basic research, pilot,
demonstration, and commercialization. At each
stage, projects are reviewed, and a decision is made
to move them forward or to hold back further
development because of technical, environmental,
or economic problems. The level and type of
review a project receives at these key decision
points depends on whether it is designated a "Major
System Acquisition" (MSA), "major project" or
"project."
Several criteria are supposed to be used in
designating MSAs. These are: national urgency,
dollar value (government investment in excess of
$50 million in the technology development stage or
$200 million over the life of the project), and
recommendations by the Assistant Secretaries or
the Director of Energy Research.* To date, cost
has apparently been the major criterion used in
determining MSAs. Criteria for designation of a
"major project" include total estimated cost,
importance to program objectives, size and
complexity, visibility, degree of DOE control
required, clarity/stability, and recommendations
by one of the DOE Assistant Secretaries or Director
of Energy Research.** All others are classified as
"projects."
In the past, the process that guided DOE project-
level review (the PPMS) was directed primarily
toward Major System Acquisitions. MSAs were
formally reviewed at key decision points in their
development by DOE senior management includ-
ing the Under Secretary and Assistant Secretaries
(the Energy Systems Acquisition Advisory Board)
and considerable documentation was required.
Major projects and other projects were reviewed
by the Program Office and the responsible Assis-
tant Secretary or Director of Energy Research.
Specific requirements for these projects were not
clear within PPMS; with the newly proposed Project
Management System, management review require-
ments covering MSAs are to be expanded to include
all major projects.
Focusing senior management attention on a few
large projects has several implications. Since
periodic consideration of MSAs has been required
of senior DOE officials, many participants in
workshops and hearings felt that large technologies
seem to acquire considerable support and momen-
tum as they proceed through the various develop-
ment stages and it appears that few are held back,
even those with adverse environmental impacts.
Participants felt that if top DOE management
reviewed a wider range of technologies during the
various development stages, small, environmentally
benign technologies would receive more DOE
emphasis. One witness contended that:
The complex procedures which were established by DOE
to guide technology expenditures, the PPMS, appear to
fail to provide for adequate evaluation of alternative
actions on programs....By the time that DOE staff has
committed large amounts of time and financial resources to
the particular project...it is almost too late to adequately
address alternatives in an EIS.
(Merilyn Reeves, League of Women Voters of
Maryland)
* Department of Energy, Major System Acquisitions. (Order
5700.1). September 11, 1978.
** Department of Energy, Project Management Study
(DESM 79-1).
17
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Another implication of the DOE project review
system's focus on Major System Acquisitions is that
not all projects with potentially severe environmental
impacts receive comprehensive senior management
review. The cost of a project does not necessarily
reflect severity of its potential environmental
impacts. For instance, under PPMS, no oil shale
projects were designated as MSAs, however, some oil
shale technologies were specifically noted in the
Environmental Readiness Document as having a
high likelihood of severe environmental impacts.
The purpose of management review is to assure the
quality of projects and programs through examina-
tion of technical capabilities, project engineering
and environmental plans, cost estimates, and
other factors. With the emphasis that has been
placed on a few individual projects by past DOE
management systems, senior management atten-
tion has been diverted from broader reviews, which
could include these major projects and those pro-
grams which are composed of many small projects
such as energy conservation. Major projects which
involve significant costs must, of course, receive
substantial scrutiny. However, alternative manage-
ment systems can be used to assure that all major
expenditures receive appropriate review—whether
they are associated with a single facility or with
program areas. If the review process is expanded to
include both major projects and major programs,
it could generate the information needed for cross-
technology comparisons.
RECOMMENDATIONS: DOE should
develop a balanced and comprehensive man-
agement review process that includes such
programs as energy conservation.
The potential severity of environmental impact
should be included as a factor in selecting
projects for senior management review.
D. Evaluation Criteria for
Technology Development
FINDING: It is unclear what formal envi-
ronmental criteria, if any, DOE uses as a basis
for its policy and project management deci-
sions.
To date, DOE appears to have used three
specific criteria in evaluating environmental
concerns:
• Comparisons of pollutant emissions 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.
These criteria are generally included in a number
of DOE documents that assess potential environ-
mental effects of specific technologies. However, it
is not clear if these criteria are used consistently or
how these factors have affected DOE decisions.
Workshop participants and Hearing witnesses
suspected that environmental criteria, even though
they may exist, are not given sufficient weight in
decisionmaking. As one Hearing witness commented:
Absence of explicit criteria gives the appearance, if not
the reality, that decisions are arbitrary.
(Mark McClellan, Pennsylvania Citizen's Advisory
Council)
Another stated that:
The process of evaluating competitive technologies
requires explicit criteria which should include risk evalua-
tion, potential for environmental degradation,
aesthetics and social concerns, and one aspect so often
overlooked—the worldwide consequences of developing
a technology. The obvious criteria include impacts on
air, land, water and the biosphere. The changes brought
about in these resources must then be evaluated in terms
of how they affect man. In this analysis, it is not only
direct health effects that are of importance, but also the
impact on those values that are often impossible to
quantify, but are so important, such as the aesthetic
impacts of changes and the recreational values of
the environment.
(Gordon MacDonald, The MITRE Corporation)
The use of explicit criteria, applied consistently
to different technologies, would ensure that the
environmental problems associated with individual
projects could be evaluated on a common basis.
However, under PPMS, the project review system
was designed to provide a framework only for
approval or disapproval of individual projects; it
did not permit environmental criteria to be used to
advocate those technologies which are most
environmentally preferable.
18
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Some of the hearing witnesses commented on the
scientific uncertainty in environmental impact
assessment. These scientists pointed out that there
are important limitations in the present capability
of state-of-the-art methodologies to precisely define
the environmental or public health impacts of pro-
posed technologies. Nevertheless, they concluded
that consistent and systematic comparisons can be
made that will demonstrate the relative environ-
mental advantages of energy technology alternatives.
Just as importantly, these methods can indicate
where judgments cannot be made regarding the
environmental differences between technologies.
Witnesses agreed that environmental evaluations
are needed for a number of impacts—a "single
figure of merit" for environmental or public health
concerns is inappropriate. Although it is very dif-
ficult to develop quantitative measures for each
area of environmental or health impact, it impossible
to develop assessment methodologies that allow
some technology comparisons. In the area of
public or environmental health, for example, emis-
sions of classes of pollutants can be compared. In
addition, cancer risk assessments can be made
from the results of chemical analysis or biological
testing.
RECOMMENDATIONS: DOE should develop
explicit environmental criteria for use in for-
mulating energy policy and evaluating
technology development, and submit those
criteria for public and peer review.
The criteria should be quantitative whenever
possible in order to facilitate cross-technology
comparisons. To support this quantification,
standard assessment procedures (protocols)
should be prescribed to ensure uniform
results. The criteria should include the follow-
ing areas:
• Impacts on public and occupational health and
safety;
• Impacts on ecosystems;
• Resources (land and water) required for
technology production;
• Socioeconomic impacts (e.g., the social and
economic dislocations caused when a "boom
town" grows up near a plant site in a previously
rural area);
• Global impacts (e.g., carbon dioxide buildup in
the atmosphere causing a "greenhouse effect,"
acid rain); and
• Net energy analysis (e.g., comparisons made
between energy produced by burning or
decomposing urban waste and the amount of
energy required to produce new products such
as paper which are lost to recycling when used
to produce energy).
E. Resolution of Environmental Issues
at the National, Regional, and
Local Levels
FINDING-Resolution of Environmental Issues:
DOE does not designate responsibility for
resolving various levels of environmental con-
cerns asssociated with energy technology
development.
The types of environmental concerns associated
with a technology range from site-specific impacts
of particular projects to national and global con-
cerns such as basic health effects of pollutants or
carbon dioxide build-up in the atmosphere. Deci-
sions on the environmental acceptability of a
technology require environmental research and
analysis covering the whole range of impacts.
The development of an energy technology from
its early research stage through its commercializa-
tion stage usually requires that associated environ-
mental concerns be addressed at three levels:
• Site-specific concerns — Including environ-
mental questions associated with the construc-
tion of an energy facility, such as site-specific
pollution impacts (e.g., ground water contam-
ination), resource requirements (e.g., water or
land), and socio-economic impacts (e.g., boom
town effects).
• Regional or cumulative concerns — Including
site-specific pollution or resource requirements
affecting areas beyond the immediate vicinity
of a facility, such as water rights questions.
Problems may also result from cumulative effects
of several facilities located in a given region.
• National concerns — Including health effects,
global effects of widespread implementation of
a technology, and the development of appro-
priate environmental control technologies.
19
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For the environmental concerns associated with
a technology to be addressed adequately, potential
environmental problems at all three levels should
be clearly identified and treated in a timely manner.
At present, the DOE management process does
not ensure that regional and local concerns are
identified or that responsibility for analysis of
regional and site-specific effects is clearly defined.
This means, for example, that a national research
program designed to develop generic information
on water requirements of synthetic fuels may appear
totally unresponsive to local concerns for stream
flow depletion by water use at individually proposed
pilot plants. As one witness said:
DOE has spent millions studying the Geysers. We're
practically an annuity for the National Labs. But our
local government still doesn't have the basic envi-
ronmental and economic information we need in the
form we can use. We tend to think it might be because
no one ever came to us and asked us.
(Mary Jadiker, Lake County, California, Planning
Commission)
Further, although extensive environmental impact
statements may be prepared for specific projects,
their formal role in the project review process has
not been clarified.
Unless DOE recognizes the importance of deal-
ing separately with interests at the local, regional,
and national level, it will continue to appear
unresponsive. Although an environmental issue
may cut across all levels, its resolution may best be
undertaken by the level that is affected. DOE's
credibility would be significantly enhanced if the
local level is actively involved in identifying and
dealing with these issues.
RECOMMENDATIONS: DOE should clearly
assign organizational research responsibility
for resolving issues at local, regional, and
national levels. Further, DOE should provide
management attention to ensure progress in
resolving issues at each level.
DOE's management should allocate resources
for research on local, regional, and national
environmental problems and encourage effective
information exchange.
FINDING-Resolution of Environmental Issues:
DOE does not have a mechanism for system-
atically coordinating plans for RD&D proj-
ects with appropriate State and local agencies.
The role of State and local agencies in DOE deci-
sions concerning RD&D projects has not been
clearly defined. Although these agencies have
responsibility for permitting and enforcing various
regulations, DOE has not institutionalized a pro-
cedure for involving them in early project decisions,
such as siting. This can lead to serious conflicts
and delays later in the process. The views of many
local officials were summarized as follows by one
Hearing witness:
We're the ones who see, hear, smell, pay for, or benefit
from your 'go* decisions. Obviously, we feel those
ultimate decisions must be made at the local level.
(Mary Jadiker, Lake County, California, Planning
Commission)
Failure to resolve local concerns can create enor-
mous barriers to RD&D projects. For example,
DOE is planning to construct a $140 million 50 Mw
geothermal demonstration plant in the Valles
Caldera of New Mexico. This is the largest geother-
mal demonstration plant DOE has under contract.
Only 50 percent of the funds for the plant are,
however, federally sponsored, with the balance
coming from the Union Oil Corporation and the
Public Service Company of New Mexico. DOE had
expected to start construction of the plant in the
spring of 1980 on a small section of privately owned
land called the Baca Ranch and to start, in 1982,
a 3-year demonstration of the plant. However,
plans for construction of the plant are being
delayed because of several factors, including the
unacceptability of the draft Environmental Impact
Statement. Specifically, the draft EIS has been
criticized by local Indian tribes because of its lack
of analyses of both the adverse effects on Indian
religious practices and mitigating measures to off-
set these effects. For the final EIS, DOE has
prepared a specific section on Indian issues. That
section has been circulated for comment to affected
tribes.
In contrast to this experience, by providing a
process which coordinates activities of all relevant
agencies, the time and resources of all those con-
cerned can be concentrated on generating the data
needed to make the necessary critical environmen-
tal decisions. For example, in an effort to involve
and coordinate participation of agencies in a coopera-
tive scheduling procedure, the State of Colorado
has established a "Joint Review Process."*
* State of Colorado, Department of Natural Resources, Project
Status Report on the Joint Review Process. November 1979.
20
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Developed by the Department of Natural Resources
with support from DOE, it is designed to
streamline the process of review and approval of
projects and the granting of permits. It provides a
"one-window" coordination forum regarding
regulations, evaluation criteria, and public involve-
ment. One agency at each governmental level is
designated as the lead agency for its level, and
represents the interests of its sister Federal, State,
or local agencies at project review sessions.
The Joint Review process was designated to
bring an organized and rational approach to the
review and decisionmaking procedures necessary
for development of major energy resources. This
voluntary intergovernmental review procedure
coordinates local, State, and Federal regulatory
reviews and provides the public with additional
opportunities to become involved in all phases of
project planning and review.
According to the State of Colorado, the advan-
tages of this are two-fold: first, the decisionmaking
timeframe can be cut by 40 percent by timely and
precise scheduling of all permitting and regulatory
procedures. Second, public involvement begins
early in the process with public information and
outreach followed by opportunities for expression
of concerns, discussions of issues, and incorporation
of responsible criticism. This allows for meaningful
public participation 2 years ahead of mandated
public hearings. As stated by its supporters, the
process "provides adversaries with the same data,
and keeps them talking" while promoting government
"by cooperation and compromise."
RECOMMENDATION: DOE should
encourage the involvement of State and local
agencies in the resolution of environmental
issues associated with projects affecting their
jurisdictions. Joint review processes can both
expedite and improve environmental review.
F. Public Participation in Nonnuclear RD&D
FINDING-Public Participation: DOE does
not provide effective opportunities for public
participation in decisions regarding non-
nuclear RD&D.
DOE, particularly the Assistant Secretary for
Environment, has taken measures to increase the
attention paid to public participation. In spite of
these recent steps, one of the major themes to
emerge from the workshops and National Hearing
was that public involvement in DOE's management
and decisionmaking systems has been woefully in-
adequate. Participants expressed a deep sense of
frustration based on their perception that DOE
officials do not feel accountable to the public for
their decisions.
DOE procedures do not systematically involve
the public, except as mandated by the National
Environmental Policy Act (NEPA) process. The
public is not given an opportunity to review or
comment on the documents associated with DOE's
internal environmental assessments. Since the
NEPA process is not initiated until a later stage of
technology development, these internal documents
provide the only environmental information for
early decisions. As a result, the public is hindered
in its participation in these decisions. Participants
in the workshops and Hearing noted that this
often results in delays when the construction of
facilities is proposed. They emphasized that in-
viting public involvement earlier in the process
would facilitate identification of issues and the
resolution of conflicts, thus expediting the process.
As one participant summarized this problem:
The purpose of effective citizen action is not to subvert
[Government's] responsibilities, but to make sure they
are honored. Government and industry have experts,
but citizen organizations often have their own expertise
to contribute to environmental decisionmaking. More-
over, although environmental decisionmaking must be
based on the best available scientific and technological
information, value judgments and social decisions are
ultimately required. And these social decisions must
reflect the public will, for the environment belongs to
the public, not just to the experts in a particular deci-
sion. When risks must be measured against benefits, or
when economic and environmental values must be
weighed and balanced, the public has the right and the
obligation to make its views known. Mediating dif-
ferences between citizens and Government early in the
planning process can prevent confrontation at a later
date, and can also prevent subsequent distrust of the
Government on the part of the citizenry.
(Edith Chase, League of Women Voters)
Participants stressed the need for an "advocate"
within DOE to increase opportunities for meaning-
ful public participation at appropriate points in the
nonnuclear RD&D decisionmaking process. They
felt that most DOE officials concentrate on the
scientific aspects of projects and do not view public
21
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participation as a high priority. Establishment of
an advocate for public participation within the
Department would demonstrate a commitment to
institutionalizing a program of public participa-
tion. One witness outlined the role of a Public Par-
ticipation Advisor, based on a similar position in
the State of California, that could serve as a model.
This advisor:
"initiates and monitors aggressive outreach
programs;
ensures opportunities for full and adequate
participation by all interested groups and the
public at large;
advises groups and the public as to effective
ways of participating in the Department's pro-
cesses; and
reviews, monitors, and assists in implementing
public participation plans and activities in all
DOE offices."
(Michael Paparian, California Sierra Club)
In DOE, this Advisor should report directly to the
Secretary, as do the public affairs and Congres-
sional liaison advisors, and would be responsible
for ensuring adequate public participation oppor-
tunities. In general, the position would differ from
existing organizational entities in its access to
the Secretary and in its role as advocate of public
participation in decisionmaking.
Another mechanism that could be used to ensure
that public participation opportunities are institu-
tionalized within DOE is the recently published
Citizen Participation Manual. This document pro-
vides guidance on planning, implementing, and
assessing public awareness and participation pro-
grams. DOE senior officials should strongly support
implementation of the Manual, and the Public
Participation Advisor, if appointed, should be
charged with monitoring its application.
RECOMMENDATIONS: DOE should sys-
tematically involve the public in a timely and
meaningful manner in consideration of the
environmental aspects of policy development,
program planning, and project management.
Senior management attention should be com-
mitted to institutionalizing public participation
activities.
FINDING-Public Participation: Existing
public participation mechanisms do not ensure
balanced representation of views, or representa-
tion of a broad spectrum of individuals and
organizations.
The Federal Advisory Committee Act (Public
Law 92-463) states that legislation to establish an
advisory committee shall "require the membership
of the committee to be fairly balanced in terms of
points of view represented" (Section 5[b][2]).
Many members of the public believed that this
philosophy should also apply to other public
involvement activities, and that DOE should
encourage participation by as many interested groups
and individuals as is feasible in workshops, Hearings,
and other events. NEPA requirements for public
involvement (Section 1506.6) also support the
concept of participation by all interested parties.
Some participants stated that DOE does not
design its public participation activities to
encourage broad representation of diverse views.
Some believed that well-funded public-interest
organizations, industry, and recognized profes-
sionals in scientific fields tend to be over-
represented. A recent study by Common Cause
investigated the membership balance of 14 DOE
Advisory Committees that existed during 1977 and
1978. The study found that
industry was represented on DOE Advisory Committees
6 times as often as public, intergovernmental, or education
representatives. If the Consumer Affairs and Energy
Extension Service Advisory Committees...are not
included, the ratio of industry to public representatives
on the other twelve is 15:1.*
Further, workshop participants asserted that
DOE review panel membership was too narrowly
composed. Many members of the public are well
acquainted with the technical and environmental
aspects of proposed projects, and participants felt
that representatives of this informed public should
be included on review panels in addition to profes-
sional scientists to ensure that environmental con-
cerns have been identified and adequately addressed.
Open for Business Only?, A Common Cause Study of the
Department of Energy, February 1979, page 18.
22
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There are often complaints from Federal offi-
cials that there are opportunities for. public
participation but' that interest and attendance are
poor. DOE should have an independent third party
review of the extent to which interested groups
attended DOE-sponsored events, and the reasons
for nonattendance.
In order to assure that groups which are not well
funded do not have difficulty participating in the
public programs offered, DOE should make funding
available. When necessary, there should be reim-
bursement for travel and per diem expenses to
enable witnesses to testify at hearings, participants
to attend workshops and conferences, and local
project-related commissions and boards to sponsor
forums and disseminate information.
Finally, much frustration was expressed
throughout the Hearing and workshops about the
fact that it is extremely difficult to locate the
appropriate source or the individual who can pro-
vide information because the data are scattered
throughout DOE offices. By establishing a toll-free
telephone number with a good information back-
up system, DOE could provide an easily accessible
central source through which the public could
request and obtain materials, and "get answers
to questions."
RECOMMENDATION: DOE should im-
prove its efforts to provide the public with the
information necessary to understand and effec-
tively comment on environmental issues
related to energy development.
RECOMMENDATION: DOE should actively
support efforts to assure a broader represen-
tation of public views in its nonnuclear RD&D
decisionmaking processes.
FINDING-Public Participation: The amount
and quality of information DOE makes
available to the public is inadequate.
Information is crucial to responsible, meaningful
public participation. Workshop participants and
hearing witnesses cited a number of shortcomings
in DOE's public information activities. Partici-
pants alleged that important internal documents
such as Environmental Development Plans and
Environmental Readiness Documents are not
systematically disseminated, and that documents
that are supposed to be available upon request are
difficult, if not impossible, to obtain. They said the
materials that are distributed are frequently highly
technical and laden with bureaucratic jargon.
What is needed are summaries of all major decision
documents, written clearly, concisely, and in
language that can be understood by the 'lay'
public.
Another summary document requested by several
participants was an annual review of all DOE-
supported technologies, explaining briefly each
technology and its development status, its potential
for meeting energy needs, its energy efficiency
and economy, and any possible drawbacks and
constraints to its use.
FINDING-Public Participation: The Envi-
ronmental Advisory Committee (EAC) has
not been integrated into DOE decision-
making.
The EAC was established to provide advice and
recommendations to the Secretary, through the
Assistant Secretary for the Environment, on
policies that affect the environment and the safety
of the general public. However, after four quarterly
meetings, the EAC has not yet developed a clear
vision of its role. Neither the Department nor the
Committee has well-defined expectations of the
other.
There is a strong feeling among EAC members
that they are "information receivers" rather than
"advice givers." Effective, regular methods for the
EAC to communicate its views to the Secretary or
other senior department officials have not been
developed; the EAC rarely finds itself talking
directly to policymakers, but talks primarily to
support staff. Consequently, its members believe
that the EAC has little impact on policy.
An active, assertive role and structure for a DOE
advisory group can be seen in the functioning of
the DOE Energy Research Advisory Board (ERAB).
The purpose of the Board is to provide DOE top
management with long term guidance on overall
research and development, and to serve as a link
between the technical community and DOE. The
23
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seemingly successful integration and implementa-
tion of ERAB's recommendations are based on:
• the structure of the advisory process — a
contract-like procedure for becoming involved
in an issue through the use of agreed-upon
"terms of reference" entered into with the
requesting program office;
• the commitment of top DOE management to
respond to their findings;
• the nature and stature of its membership —
primarily top business, industry, and research-
oriented university officials who historically
have had an "ear" at DOE.
In order to strengthen the EAC, it is necessary to
tie its functions more directly to decisionmaking.
This can be done by establishing a number of issue-
and program-oriented task forces (supplemented
by nonmember talent) to study and provide
recommendations on specific environmental con-
cerns. Regular meetings of the EAC should be set
up with the Secretary, the Assistant Secretary for
Environment, and other policy officials in atten-
dance, to provide the forum EAC needs for its
recommendations.
The Office of Environment has recognized the
problems experienced by the EAC and commis-
sioned a study of the Committee's first year of
operation. This is an indication of the Office of
Environment's interest in enhancing the effec-
tiveness of this Committee, and may lead to
improvements in many of the areas discussed
above.
RECOMMENDATION: DOE should clarify
the role of the Environmental Advisory Com-
mittee and link its functions more directly to
Departmental decisionmaking activities.
24
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APPENDICES
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APPENDIX A
REGIONAL WORKSHOP SUMMARIES
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 RD&D deci-
sionmaking process, and to encourage participants
to begin preparing testimony for the October Na-
tional Hearing. Specifically, the goals of the
workshops were to:
• Present an overview of the research, develop-
ment, 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 decisionmaking 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 presentations of
information and opportunities for discussion. The
morning session focused on the formal DOE non-
nuclear RD&D planning and review process for
Major System Acquisitions (especially the Program
and Project Management System),* and the after-
noon 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 partici-
pants prior to the workshop.**
* This System is described in Chapter II of this report.
** Environmental Protection Agency, The Federal Nonnuclear
Research and Development Act (Public Law 93-577), Section 11,
Environmental Evaluation, EPA 600/9-79-020, June 1979.
Environmental Protection Agency, Issue Paper on Urban Waste
and Cogeneration Technologies, July 12, 1979.
Environmental Protection Agency, Issue Paper on Oil Shale
Technologies, July 18, 1979.
Environmental Protection Agency, Issue Paper on Coal
Liquefaction (Solvent Refined Coal) Coal Gasification (Oasifiers
in Industry) Technologies, July 31, 1979.
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 questions 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 technologies?
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?
The groups were not expected to reach a consensus,
although there was a surprising agreement on many
questions.
Each work group chose a spokesperson to present
its comments to the entire workshop. The partici-
pants 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 Hearing 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.
27
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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 assess-
ment process and on two specific technologies,
urban waste utilization and cogeneration.
Invitations to participate in the workshop were
sent to 250 individuals, and fifty-five active par-
ticipants and several Government and other
observers attended the workshop. The group was
composed of representatives of industry (29%),
environmental groups (21%), State and local
governments (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's discussion of the
Program and Project Management System, skep-
ticism was expressed about the extent to which the
actual decisionmaking 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 ensure
that a comprehensive management review did occur
and that environmental concerns would be con-
sidered at appropriate points. In particular, separa-
tion of technology development and environmental
research into two "tracks" covered by separate
plans (Technology Program Plan and Environmental
Development Plan) and managed by separate offices
(Program Office and Office of the Environment) was
viewed as having both positive and negative aspects
from the environmental perspective.
cost, poor coordination of environmental and tech-
nology research efforts, and, ultimately, a lack of
attention to environmental issues in planning and
at key decision points.
Participants questioned whether the Energy
Systems Acquisition Advisory Board had specific
criteria governing its deliberations, review of
documents, and recommendations about the readi-
ness of a technology to move forward to a further
phase of development. There was a general agree-
ment that such criteria should exist, particularly
for evaluation of the Environmental Readiness
Document, and should be made public. Among the
environmental criteria suggested were traditional
environmental concerns (effects on water, air,
land, wildlife, vegetation) and the broader eco-
nomic, 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 per-
formed as early as is feasible in the process, before
major capital investments have been made in a
technology. Several participants questioned
whether there is a point beyond which it is virtually
impossible to halt the development of a tech-
nology, regardless of the findings of environmental
research.
Finally, several participants expressed the view
that this process reflects DOE's overemphasis 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 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.
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 (Environ-
mental 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
Public Participation in the Process
Work group reports indicated general consensus
that public involvement in the Program and Project
Management System was inadequate. Representa-
tives of environmental groups, public interest
groups, and industry stated that they did not have
adequate information 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 opportunity
28
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to participate, primarily through review of Envi-
ronmental Assessments and Environmental Impact
Statements, it is too late for their opinions to affect
many important decisions.
Two factors were presented as crucial for achiev-
ing 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 fre-
quently 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 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 Acquisition Advisory
Board. Some suggested that the public should be
represented on the Board; others felt that an out-
side public review board should be established.
This public review board should actually meet and
discuss issues, not just review written materials and
submit 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 potential
effect of public participation was to slow down the
process. 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 efforts 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 programs in
the United States and were 2 of 16 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.
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 pro-
grams, and that smaller scale, appropriate
technology projects were not adequately encouraged.
In the same vein, some participants felt that DOE
should put more effort into promoting conserva-
tion in addition to supporting energy production.
In the area of urban waste utilization, one group
felt that DOE should concentrate on recycling and
bioconversion rather than combustion technol-
ogies. 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 men-
tioned recycling as an important program. Partici-
pants emphasized that successful recycling efforts
29
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could not depend on volunteers. In almost all
volunteer projects, 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 compre-
hensive 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 responsibil-
ities for making participation successful. For the
two technologies studied as well as the whole project
review process, participants felt that the public
should be more specifically informed in order to
fully participate.
DENVER WORKSHOP SUMMARY
The second regional Section 11 workshop was
held in Denver, Colorado on July 18, 1979, at the
Environmental Protection Agency Region VIII 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.
Forty-six people attended the workshop, repre-
senting 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, participants
discussed 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 community 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 con-
cerns and felt strongly that State and local officials
should be included much earlier in the planning
process.
As in the Atlanta workshop, timing was an
important issue in this discussion. Many par-
ticipants felt that environmental 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 technological research should go hand-in-hand.
Participants also felt that monitoring and updating
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 more interaction
was needed between environmental and technological
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
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a formal system incorporating a uniform accoun-
tability 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
conservation and solar technologies. Several par-
ticipants recommended better coordination between
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 standardized and made public.
Public Participation in the Process
There was general agreement among the work
groups that public participation in the process was
inadequate. One of the major recommendations
formulated by the groups was earlier, more mean-
ingful involvement of State and local governments,
industry, and interested organizations. Par-
ticipants 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. Active involve-
ment in a steering role of those who could be
affected by a project would encourage a com-
munity's sense of ownership of a project and the
building of cooperative working relationships.
Participants also noted that improvements were
needed in DOE's information dissemination pro-
cedures. They felt that internal environmental
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 participation is to be effective
and meaningful, some participants felt that better
public education 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 Acquisi-
tion Advisory Board, holding regional conferences
to discuss policy questions, and establishing
regular community boards for site-specific ques-
tions. Participants stressed that effective public
participation 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 activities. Another
participant recommended that U.S. Senators and
Representatives should sponsor attendance of peo-
ple from their districts or States at meetings such as
the October National Hearing.
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 process 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 focused specifically
on oil shale, and discussed 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 initia-
tives would have on oil shale research and develop-
ment 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 includ-
ing the human as well as the! natural environment.
Thus, in addition to traditional concerns, they said
that oil shale environmental 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 environ-
mental research.
The participants said that they did not have
enough information to judge whether DOE's envi-
ronmental 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.
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Finally, participants repeated their recommenda-
tion 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 DOE's information dissemination
procedures had been inadequate in oil shale
development. 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 docu-
ments be prepared and that these summaries con-
tain 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 involve-
ment be incorporated into any new groups and pro-
cesses developed in response to President Carter's
July energy message. Participants were concerned
that the President's emphasis on oil shale develop-
ment could have highly detrimental effects if environ-
mental issues were not examined comprehensively
and with sensitivity to local concerns.
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 Region IX
Office. This workshop focused on the DOE non-
nuclear RD&D planning and assessment process
and on research and development 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%), rele-
vant Federal agencies such as the Bureau of Land
Management and U.S. Geological Survey (16%),
research laboratories and universities (13.5%),
environmental groups (8%), and other organizations
and areas of expertise (14%).
The DOE Environmental Planning and
Assessment Process
The initial reaction of most participants to the
Program and Project Management System during
the morning session was that it is irrelevant to their
experience, since it applies only to projects that
receive very substantial DOE support. Their expe-
rience 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 assign-
ing technologies to the process. These criteria could
include breadth of applicability, nationwide poten-
tial, 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 sug-
gested that there should be an initial assessment for
each geographical area in which a project is being
considered to establish baseline data and to deter-
mine 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.
There was general agreement that a broad range
of potential impacts should be considered, in-
cluding traditional elements, social and economic
costs and benefits, land use compatibility,
qualitative changes in the resource brought about
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by development or occurring naturally, conserva-
tion 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 deci-
sions, 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 plan-
ning and research so that local concerns could be
brought into the decisionmaking 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 con-
cern to those affected by a project. One participant
summed up this discussion by saying that "DOE
answers questions no one asks and then does not
have information on issues of considerable local
concern."
Many participants criticized the timing of
environmental research. They felt that research to
develop the technology proceeds ahead of environ-
mental research. They felt that these two areas
should be more closely coordinated and that DOE
should be supporting more research and demon-
stration 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 echoed other workshops'
conclusions that better information dissemination
was needed and documents should be made more
readily available for public review. A number of
participants had attempted to obtain internal DOE
environmental documents in the past without suc-
cess. 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 comments. One group recommended
that DOE establish a Public Advisors Office which
would have responsibility for disseminating infor-
mation and answering questions. This office
should undertake an aggressive outreach effort to a
wide audience, including industry, State and local
government, environmentalists, and technical ex-
perts. The group suggested 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 questions.
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 information.
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 partic-
ipants said that an understandable document sum-
marizing technologies and projects would be very
useful. These suggestions grew out of a need ex-
pressed 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 after-
noon technology discussion on geothermal energy
because California's hydrothermal resources
account for over 70 percent of the electrical energy
potentially recoverable from such reservoirs in the
U.S. The largest geothermal 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 work-
shop participants had been actively involved in The
Geysers project, through industry, local govern-
ment, or citizens' action groups. They had discussed
many of the environmental issues surrounding geo-
thermal development in the past, and many con-
flicts had, over time, been resolved. One partici-
pant from industry and one community represen-
tative presented a brief overview of their experience
with this project and perspectives on it.
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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 environ-
mental research is needed. 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 geother-
mal 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 infor-
mation do not exist.
A major issue raised by many participants was
that DOE does not ask local officials and the com-
munity 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 opposed to publicly-supported
projects; and about the extent of DOE's respon-
sibility for site-specific studies in addition to
generic research on a technology's environmental
effects.
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 nonnuclear RD&D planning
and assessment process and on two specific
technologies—coal liquefaction and coal gasification.
Invitations to participate in the workshop were
sent to 125 individuals; forty-five people attended
the workshop; representing industry (24%), envi-
ronmental groups (18%), public interest groups
(16%), State and local government (11%), univer-
sities and research organizations (11%), and labor
(4%). Also participating in the workshop were
several private citizens who have been actively
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
An initial question many participants asked dur-
ing the morning session 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 having an impact on decisions or if the informa-
tion contained in the various documents is actually
ignored. They also wondered if the process was
now irrelevant because of President Carter's
proposed energy initiatives for "fast tracking"
synthetic fuels.
A 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 nonrenewable technologies? They
also questioned how energy conservation fits in
and whether it is a factor in this process. Some par-
ticipants 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 par-
ticipants was that the process deals only with very
large projects. They were critical that the Office of
Environment does not have the same formal input
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for smaller projects with possible serious environ-
mental effects as for larger projects although
similar documentation is produced.
Several work groups said they felt that specific
criteria were needed for Energy Systems Acquisi-
tion 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 suggested that environmental
factors be used to form a "threshold," or
minimum standard particularly 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 con-
sideration 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, participants
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 par-
ticipants felt that these site-specific issues were not
receiving adequate attention or satisfactory resolu-
tion. Several groups felt that Environmental
Impact Statement 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 com-
munication among various levels 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 impor-
tance 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; compila-
tion 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.
Participants felt that the timing of public input is
important and that review of Environmental Impact
Statements is too late. They felt that earlier
discussion of issues in public forums was needed to
encourage communication, rather than presenta-
tion 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 com-
mittees should then be formed for siting decisions
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 even-
ing meetings to facilitate participation by working
people.
Several groups requested that the public be given
an opportunity to review Environmental Develop-
ment Plans and Project Environmental Plans, to
ensure that all appropriate environmental 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, coal liquefac-
tion and coal gasification. These two technologies
were chosen for discussion by this group because of
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the potential development of a coal synthetic
industry in the region. Within DOE, a Commer-
cialization Task Force Study recommended coal
liquefaction and gasification as candidate commer-
cialization technologies, and three gasification
projects and two liquefaction projects were
designated "major systems" within the Program
and Project Management System. 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 Manage-
ment 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 sup-
port for the program. Participants noted that many
decisions appear to have been made without any
regard for the formal process. One participant
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 environ-
mental 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 required more attention. Some par-
ticipants thought that DOE simply had too much
confidence that it knows the answers to environ-
mental 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 deci-
sions. Other criteria that participants felt should be
considered in examination of coal synthetic fuels
were net energy and net cost, including 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 tracking" will
have on synthetic fuels research. They worried that
environmental research may be cut short, and that
opportunities for public participation in the pro-
cess 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 in these areas has been
inadequate. Desire for a more open process was
expressed by many groups, but a basic question was
raised: does DOE really want public participation?
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. Par-
ticipants 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 deci-
sionmakers 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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APPENDIX B
NATIONAL HEARING SUMMARY
The Section 11 National Hearing was held in
Washington, D.C., on October 3, 4, and 5, 1979.
The Hearing panels included the Department of
Energy Assistant Secretary for Environment,
representatives from the Environmental Protection
Agency and the Council on Environmental Quality,
and members of congressional staff, environ-
mental groups, State governments, and industry.
Thirty-five people presented testimony, and an
additional participant subsequently submitted writ-
ten testimony. Participants represented a broad
spectrum of interests, including industry, environ-
mental organizations, public interest groups,
universities and research laboratories, State and
local government, and the general public. Many of
the participants had attended one or more of the
regional workshops held earlier this year.
Prior to the Hearing, witnesses were sent
materials discussing the focus of this year's Section
11 activities and the major issues that emerged
from the workshops.* Most of the witnesses
addressed one or more of these issues in their
testimony. This appendix summarizes comments
from the National Hearing on seven key issues and
on other topics of interest to particular witnesses.
A full transcript of the Hearing has also been
published.
1. Nonnuclear Research Priorities
Many Hearing witnesses were concerned that
DOE's current nonnuclear RD&D policy appears
to favor large-scale, centralized technologies based
on nonrenewable resources. They felt that smaller-
scale, decentralized, appropriate technologies are
not given the attention or support they merit.
Several participants described in detail the poten-
tial lower cost and environmental advantages of
alternatives such as solar energy, recycling, and
conservation when these approaches are compared
with the large projects DOE now emphasizes.
Many witnesses felt that there is an urgent need for
DOE to balance its RD&D efforts better if the
nation's energy requirements are to be met, in both
the immediate and the long-range future.
* Environmental Protection Agency, Background Document for
National Hearings. EPA 600/9-79-033. September 1979.
It did not appear to witnesses that, in setting
policy and RD&D priorities, DOE planners system-
atically evaluate and compare all proposed and
available technologies to determine which ones
offer the greatest potential for meeting our energy
needs most economically and with the least
environmental risk. Instead, DOE
is hardware-oriented; it is not geared to problem solv-
ing. There is no meaningful competition among
technologies within each resource category. There is no
real competition among resources in developing national
energy plans or determining budgetary priorities.
(Kevin Markey, Friends of the Earth)
Witnesses felt that such comparisons of both
production and conservation options are essential
to the development of a rational, comprehensive
energy policy.
In discussing the importance of performing such
assessments, one witness stressed that
in evaluating technologies from an environmental
standpoint, it is crucial to compare the new technology
with that which it replaces or augments, as well as with
other new competing technologies.
(Gordon MacDonald, The MITRE Corporation)
2. Objectives of DOE Research, Development,
and Demonstration
In one workshop, considerable time was spent
discussing the role of DOE as an RD&D agency,
and this question was examined further by several
Hearing witnesses. Witnesses said that DOE's
research goals were not clearly articulated. The
RD&D program seems to be heavily oriented
toward rapid commercialization of technologies
rather than toward thoroughly testing and examin-
ing all aspects of their application. One witness
outlined how this aspect of RD&D could be improved:
What you need is a system which is a little more
balanced between branches that are building things and
branches that are considering alternatives, rather than
having a whole agency...whose mission it is to build and
secondarily to do the best it can with the consequences....
You need a more balanced situation, where you are set-
ting your energy priorities and your environmental
priorities at the same time and then you look at those on
the same footings and try to ask, how can we optimize
both of these—rather than looking for the best energy
technologies and then later worrying about how to
handle the environment.
(Richard Pratt, Pennsylvania Sierra Club)
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Both this witness and other participants felt that
technical and environmental research should be
more closely linked and that DOE efforts in both
areas should be designed to provide the greatest
amount of data to be used in decisionmaking.
Another witness reinforced this idea:
I think the need has to be stressed for experimental
facilities which test not only the technological capability,
but also the environmental issues....There's also a need
to emphasize decisionmaking systems which focus on
incremental and adaptive decisionmaking to the greatest
extent possible, rather than go/no-go decisions, so that
we can reflect, as we move through various steps, the
findings of environmental research, assessment, or
monitoring.
(Allan Hirsch, U.S. Fish and Wildlife Service)
3. Project Management and Review
Witnesses felt that DOE's project management
system, which requires top-level review only of
projects involving major Federal investment, was
also a problem. Projects that do not require large
outlays of capital are managed at lower levels and
therefore may never have their potential benefits
seriously considered by DOE policymakers. Wit-
nesses believed that this lack of attention to smaller
projects reinforces a bias toward high-technology
solutions to energy problems. Therefore, although
witnesses recognized that not all projects could be
monitored regularly by top officials, they felt that
cost should not be the primary criterion for selecting
projects for senior management review.
The uniqueness of environmental or health considera-
tions, and potentiality of a system should also be
examined.
(Chester Richmond, Oak Ridge National Laboratory)
Further, witnesses felt that this top management
review should not be limited to determining
whether a technology is technically feasible, the
cost is acceptable, and the environmental effects
are manageable; it should also include comparison
with alternative technology options, i.e., it should
review all feasible options. Criticism of the review
process included the opinion that
the PPMS review process does not take into considera-
tion alternative small-scale technologies when it
evaluates a particular major system technology. In other
words, it does not consider other ways to obtain the
energy which is proposed for production by the
technology under consideration.
(Susan Tachau, National Center for Appropriate
Technology)
The witness added the consideration that
if technological alternatives are not reviewed, then
energy conservation possibilities will not be addressed,
nor will appropriate technologies or other alternatives
be addressed which might produce the same amount of
energy more economically than the large-scale
technologies being considered.
(Susan Tachau, National Center for Appropriate
Technology)
Another witness contended that
The complex procedures which were established by
DOE to guide technology expenditures, the PPMS,
appear to fail to provide for adequate evaluation of alter-
native actions on programs...By the time the DOE staff
has committed large amounts of time and financial
resources to a particular project... it is almost too late to
address alternatives adequately in an EIS.
(Merilyn Reeves, League of Women Voters of
Maryland)
To ensure that alternatives are adequately con-
sidered in policymaking and project management,
several Hearing witnesses suggested that tech-
nologies be compared according to the efficiency
of their "end use"—that each fuel source and tech-
nology be compared with others that can be used to
meet a given energy need or "end use," such as
residential heating or transportation. As described
by one hearing witness,
The principle is that the "end use" for which energy is
required should determine, as much as possible, the source
and form of the energy to be employed for that use. The
choice should be based on consideration of conservation
or, in other words, of energy economy. This means that
preference should always be shown for forms of energy
that, while remaining compatible with the "end use" to
which they are put, are as direct as possible, involve as
little capital-intensive technology as possible, and come,
as much as possible, from renewable sources.
(Susan Tachau, National Center for Appropriate
Technology)
Another witness cited a recent report by the
Carnegie-Mellon Institute of Research, "The Least
Cost Energy Strategy," which discusses a new way
of looking at interfuel competition—an approach
called "energy services"
The premise is that an "energy service" is what people
require: people want a warm house; they, in effect, are
neutral as to whether this comes from gas heat, electricity,
and so forth.
(Benjamin Schlesinger, American Gas Association)
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4. Criteria for Assessing Technologies
Several Hearing witnesses expressed concern that
environmental criteria do not appear to have
significant influence in DOE technology develop-
ment decisions. Others felt that once the decision is
made to invest in a technology, it is virtually
impossible to halt or even slow its progress, even
if serious environmental questions remain un,an-
swered. Therefore, many witnesses supported the
development and establishment of explicit environ-
mental criteria which would be applied consistently
to all technology projects at key decision points.
Further, they felt that these criteria should be
explained to the public and that the results of the
application of the criteria to each decision should
be disclosed. As one Hearing witness commented
Absence of explicit criteria gives the appearance, if not
the reality, that decisions are arbitrary.
(Mark McClellan, Pennsylvania Citizens Advisory
Council)
Witnesses felt that in addition to cost and net
energy analysis, the criteria should address a broad
range of environmental issues; should apply to the
potential local, regional, and global effects of a
technology project; and should include considera-
tion of the entire fuel cycle. Ideally these criteria
should be measurable and observable. In discuss-
ing the broad range of applicable criteria, one
scientist stated that
The process of evaluating competitive technologies
requires explicit criteria, which should include risk evalua-
tion, potential for environmental degradation,
aesthetics and social concerns, and the aspect so often
overlooked—the worldwide consequences of developing
a technology....The obvious criteria include impacts on
air, land, water, and the biosphere. The changes
brought about in these resources must then be evaluated
in terms of how they affect man. In this analysis, it is
not only direct health effects that are of importance, but
also the impact on those values that are often impossible
to quantify, but are so important, such as the aesthetic
impacts of changes in the recreational values of the
environment.
(Gordon MacDonald, The MITRE Corporation)
Another scientist noted that in evaluating energy
technologies,
environmental and health considerations cover a span
from site-specific to those that are truly global in nature.
One might look to the acid rain problem as an indication
of growing interest in regional concerns...We must also
include the internal environment of an daergy-
generating facility, which brings us into the iniportant
area of worker protection, health, and safety.
(Chester Richmond, Oak Ridge National Laboratory)
Regarding this last concern, a representative from
the National Institute on Occupational Safety and
Health said that
the issue of occupational safety and health has generally
been given relatively low priority and visibility in the
development of new energy technologies.
(Kenneth Bridbord, National Institute for Occupational
Safety and Health)
He felt that these concerns should be among the
earliest issues to be discussed, studied, and resolved
before large-scale commitment to a technology is
made,
because occupational safety and health issues are
largely independent of siting, occupational safety and
health assessments should really precede overall
environmental assessment.
(Kenneth Bridbord, National Institute for Occupational
Safety and Health)
Several witnesses discussed potential approaches
to the application of environmental criteria. One
described two models that could be used to inte-
grate environmental factors into technology
decisionmaking.
The first model is to have a periodic review to identify
and avoid potential 'show stoppers'...things that would
stop the technology dead and which unless overcome
would make continuation unwise. It is my impression
that this is the motivating element of the current DOE
process. But a second model is to have an interactive
process in which environmental and energy conservation
factors are influential in steering the technology
development along one path as opposed to another
path.
(Larry Moss, National Coal Policy Project)
Another witness had a slightly different perspective
on the role of environmental criteria in the review
process.
The review process is only useful and accomplishing its
objectives if it can result in a negative decision. This
does not appear to be the case within the Department of
Energy today. Once a project enters the funding pipeline
for basic research, it appears to be a foregone conclu-
sion that it will proceed unmolested through the key
decision points in the PPMS to commercialization.
(Mark McClellan, Pennsylvania Citizens Advisory
Council)
The process should be modified to include
thresholds or
environmental conditions which must be met during
each development phase. Any deficiencies or unaccep-
table environmental problems should be a condition for
temporarily halting and in severe cases canceling a proj-
ect. In the case of the project that does not meet the
39
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threshold, the DOE Under Secretary should have the
discretion to allow the project to proceed...but only to
the next phase, and under conditional approval which
would stipulate that specified environmental concerns
must be resolved in a specified time period, or the proj-
ect will be placed on permanent hold at that phase. No
technology should ever be approved for commercializa-
tion unless all thresholds are satisfactorily met.
(Mark McClellan, Pennsylvania Citizens Advisory
Council)
Environmental issues are currently examined in
Environmental Readiness Documents (ERDs). One
witness discussed shortcomings, primarily a lack of
thoroughness, in the way the ERD deals with these
issues.
ERDs should address five areas: the current state of
knowledge about the health, safety, and environmental
impacts that would be created by deployment of the
technology; available control technologies; the current
and proposed regulations which will affect commer-
cialization; the areas of environmental concern for
which information is inadequate and further research is
required; and the likelihood of significant delay in
attaining program objectives because of environmental
concerns. The ERDs tend to present data unsystemat-
ically and to emphasize qualitative rather than quan-
titative analysis. Most ERDs treat the current state of
knowledge about environmental concerns insufficiently.
They omit definitions of the origin and size of the envi-
ronmental concerns ....ERDs now merely list a pot-
pourri of research needs and their dollar value. They
should make some effort to prioritize these needs....
Environmental issues are now identified haphazardly. A
more logical approach, used in many of the analyses at
Brookhaven, would go through, the entire fuel cycles of
each of the technologies and identify possible environ-
mental conflicts.
(Samuel Morris for Leonard Hamilton, Brookhaven
National Laboratory)
Finally, a witness discussed the importance of
developing and applying environmental criteria
early in the process
lived near planned projects, were not given a clear
role in the DOE decisionmaking process.
Most of the assessment of the environmental impact
is...done on the national level. Most of the serious envi-
ronmental effects of the new large-scale technologies
will be felt most severely at the regional and local levels
where the energy facilities are actually located. These
effects must be examined closely.
(Susan Tachau, National Center for Appropriate
Technology)
Participants felt that more responsibility for
environmental assessment should be delegated to
these local levels to increase the likelihood that
local concerns, as well as generic technology con-
cerns, would be dealt with at appropriate times.
Local, State, or regional officials have a familiarity
with their own environment that results in a deeper
understanding of the potential range and severity
of impacts a project may cause. This information
must be considered along with generic technical
data in making technology project decisions. In
discussing the importance of continued research at
all levels, another witness recommended that
DOE...should coordinate its funding sources so that
both site-specific...and generic work can be pursued...
Answers to the regional and global concerns most probably
will arise from the generic research conducted as part of
the core programs at various laboratories.
Further,
non-Federal levels of government will become the foci
of decisions on environmental tradeoffs among energy
policy alternatives. Harmony between energy develop-
ment and regional concerns will be largely defined at the
regional level, with the Federal government defining the
boundaries of acceptability, offering incentives for
actions and decisions that are in the national interest, and
helping resolve conflicts that arise between States and
regions whose actions and decisions affect one another.
prior to siting decisions. Today these considerations
usually enter after individual sites have been selected
and are being evaluated and after the battle lines have
been drawn. If we use these criteria early in the process
of identifying candidate sites for demonstration projects
or for full-scale projects, we could ease—if not avoid—
many last-minute confrontations.
(Allan Hirsch, U.S. Fish and Wildlife Service)
Therefore,
DOE should make special efforts to keep State and
especially local officials involved, as projects proceed
through the environmental evaluation process, primarily
through improved information dissemination, assis-
tance to outside groups in preparing EISs, and
establishing local planning and review groups.
(Chester Richmond, Oak Ridge National Laboratory)
5. Appropriate Levels for Treating
Environmental Issues
A concern expressed in each workshop and
repeated at the National Hearing was that agen-
cies at the State and local levels, whose residents
And one witness complained of a present situation.
DOE has spent millions studying the Geysers. We're
practically an annuity for the National Labs. But our
local government still doesn't have the basic environ-
mental and economic information it needs in a form it
can use. We tend to think it might be because no one
40
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ever came to us and asked us. Local government is too
often treated as the object of some anthropological field
trip. Our geographic jurisdiction seems to be considered
as some underdeveloped colonial possession, just right
for exploitation.
(Mary Jadiker, Lake County, California, Planning
Commission)
Many participants stressed that the role of local
and State agencies should not be limited to reviewing
documents or decisions. Instead, these organizations
should be involved in a steering capacity before
final siting decisions are made and then throughout
the life of a project. As one witness stated,
We're the ones who see, hear, smell, pay for, or
benefit from our 'go' decisions. Obviously, we feel those
ultimate decisions must be made at the local level.
(Mary Jadiker, Lake County, California, Planning
Commission)
should be doing so and doing so very early. Early par-
ticipation outside the agency, we believe, is necessary for
the effective management of any program which is ulti-
mately going to impact the public. Now...the public has
its say (only later) and often that is inefficient and leads
to many delays which could have been prevented if this
much broader public impact had begun early.
(Richard Pratt, Pennsylvania Sierra Club)
Little attempt is made to inform the public when
decisions are going to be made and what the options
are. Thus, citizens cannot actively seek involve-
ment at appropriate times. This situation is exacer-
bated by the seemingly constant crisis atmosphere
and organizational flux that surrounds DOE
decisionmaking, which makes it very difficult for
outsiders to discern how and when to attempt to
influence the process. To improve communication
with the public on decisions, one witness suggested
that
6. Public Participation
The clearest theme to emerge from the work-
shops and the National Hearing was that public
involvement in DOE's management and decision-
making systems has been woefully inadequate.
Hearing witnesses expressed a deep sense of
frustration in their efforts to participate in DOE's
decisionmaking process. Through their comments,
they reinforced the four overall criticisms of
DOE's interactions with the public that were made
at the workshops, and they offered some specific
recommendations.
First, the amount and quality of information
available to the public is inadequate. Important
internal documents are not systematically dis-
seminated, and documents that are supposed to be
available upon request are difficult, if not impossi-
ble to obtain. Materials distributed are frequently
highly technical and laden with bureaucratic
jargon.
Second, opportunities for effective public par-
ticipation in the decisionmaking process are inade-
quate. DOE technology management processes do
not systematically involve the public until man-
dated by NEPA requirements. At this point in the
process, many critical decisions have already been
made. The public is never given an opportunity to
affect the choices DOE makes among alternative
technology options. According to one witness,
We can see that DOE is not involving a wider public in
the decisionmaking process, and it is our view that they
we need to put more emphasis not so much on the
formal system of preparing and circulating documents, but
providing opportunities for various segments of the
public who are concerned with these projects—like
government agencies, the industry, environmental
community—to meet in forums where... questions can
be...(asked) and mutual respect can be generated.
(William Rogers, Gulf Mineral Resources Company)
As an example, one witness cited the National
Coal Policy Project, which aimed to reconcile the
views of energy developers and those of environmen-
talists. The approach to reconciliation used in the
project was the "Rule of Reason," an alternative to
adversary-type processes, in which the primary aim
of the parties was to find an accommodative solu-
tion which did not seriously transgress the values of
either party. This witness suggested that DOE
could use this process to help resolve important
long term issues, such as those involved in the
development of synthetic fuels.
The third overall criticism of existing participa-
tion mechanisms was that they appear to favor cer-
tain interests. Advisory committees seem to be
dominated by industry groups, and research review
panels are composed of narrow groups of profes-
sionals with vested interests in pursuing traditional
technology projects. Groups that are not well-
funded have difficulty being involved in the public
programs offered.
Finally, participants felt that the general attitude
of DOE officials is not favorable toward public
participation. Although certain officials in DOE
have a strong personal commitment to public in-
volvement, overall there seems to be too little value
41
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attached to effective citizen input. Even when lip
service is given to citizen activities, little time is
devoted to adequate exchange between top officials
and representatives of public groups. Many DOE
representatives seem to consider members of public
groups as naive amateurs with little of substance to
contribute. One witness countered this attitude:
No management system will work without meaningful
public involvement. It must be clear to the public also
how DOE responds to public... participation. Credibility
of public involvement efforts demands a responsive
Department.
(Kevin Markey, Friends of the Earth)
Witnesses stressed that the implementation of
meaningful measures to encourage public par-
ticipation would, in fact, result in a number of
benefits to DOE: issues would be identified earlier,
conflicts would be resolved more easily, greater
public support would be fostered, and the process
would be expedited. Finally, it would meet the
public's demand and legislative mandates for
greater participation in governmental decision-
making. As one participant summarized,
Public participation should not be viewed as an end
unto itself, rather as a means of achieving goals, and
it should always be clear that it is providing an oppor-
tunity... to participate in the decisionmaking...first you
decide what decisions have to be made, then you decide
when you are going to make those decisions, and then
you decide how it is best to bring in the public to provide
advice at those key points in the decisionmaking process.
(Edith Chase, League of Women Voters)
7. Discussions of Specific Technologies
A number of witnesses discussed the merits or
drawbacks of specific technologies. Individual
witnesses discussed the pros and cons of geothermal
development and synthetic fuels from coal and oil
shale. Others discussed the benefits that would
result from an increased DOE emphasis on recycling,
improved waste management methods, gasohol,
and the increased efficiency of electrical appliances
and equipment.
Most witnesses who discussed specific ap-
proaches focused on conservation, renewable
resources, and appropriate technologies. One
witness stated, regarding conservation, that it
must be an inherent part of our national energy policy
and must be viewed as complementary to energy
research and development and not as an alternative to it.
(Patricia Pelkofer, Group Against Smog and Pollution)
Another pointed out the necessity of conservation.
Conservation has been our only source of new supplies
in the recent past and will be our only source in the near
term. Conservation, along with the use of renewable
sources, should be our major source in the long term.
(Lore Keffer, Group for Recycling in Pennsylvania)
Finally, in discussing the urgency of the need to
place more emphasis on renewable sources of
energy, one witness stressed that the national
energy program must soon see
the beginning of a transition in economic and political
advantage from the fossil and nuclear programs to the
more benign renewable fuel forms. The purpose of this
Hearing is to establish a document for congressional and
executive review. I think it has to be established here
that the people have gone on record as being concerned
about a future that is dominated by dead ends and
disappointments. A self-sustaining renewable fuel
should be priced below the use of our rapidly depleting
reserves by policy. To give the petroleum or synthetic
fuels programs articifical supports and financial benefits
is to work counter to basic principle, and it is to suc-
cumb to political irrelevance and cowardice, to oppose
the inevitable, to delay the day until we must face our
cold and hungry children in the darkness of our own
selfish short-sightedness because we waited too long.
(Scott Crytser, Pennsylvania Gasohol Commission)
42
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REFERENCES
DOE Documents
Department of Energy, Citizen Participation
Manual (Order 1210.1). August 13, 1979.
Department of Energy, Compliance with the
National Environmental Policy Act, Proposed
Guidelines, Federal Register, Volume 44, No. 139,
Wednesday, July 18, 1979
Department of Energy, Designation of Major
Systems (Order 4240.1). February 1, 1979.
Department of Energy, Draft Report of the Energy
Research Advisory Board. Study Group on
Construction/Development Project Management.
October 1979.
Department of Energy, Draft U.S. Conservation
Strategy, Office of Conservation and Solar
Energy. November 2, 1979.
Department of Energy, Environmental Develop-
ment Plans (Order 5420.1). August 1978.
Department of Energy, Intergovernmental Affairs
Council Charter. October 1, 1979.
Department of Energy, Major System Acquisitions
(Order 5700.1). September 11, 1978.
Department of Energy Memorandum, Envi-
ronmental Planning and Review in Relation to
Major Systems Acquisition Projects, Assistant
Secretary Ruth Clusen, December 18, 1978.
Department of Energy Memorandum, Program
and Project Management System for DOE Outlay
Programs. Interim Policy and Guidance. Under
Secretary Dale Myers, May 31, 1978.
Department of Energy, National Energy Plan II,
Environmental Trends and Impacts, May 9, 1979.
Department of Energy, News Release. "Energy
Secretary Establishes Local Government Advisory
Group." R-79-510. November 30, 1979.
Department of Energy, Office of the Assistant
Secretary for Environment, Office of Technology
Impacts Report, April 1979.
Department of Energy, Policy and Program Plan-
ning System (Interim Management Directive 0203).
September 30, 1977.
Department of Energy, Project Management
System Study (DESM 79-1). November 1979.
Department of Energy, Proposed Guidelines for
Compliance with the National Environmental
Policy Act. Federal Register Notice 42136. July 18,
1979.
EPA Documents
Environmental Protection Agency, Background
Document for National Hearings. EPA 600/9-79-
033. September 1979.
Environmental Protection Agency, Issue Paper on
Coal Liquefaction (Solvent Refined Coal) Coal
Gasification (Gasifiers in Industry) Technologies,
July 31, 1979.
Environmental Protection Agency, Issue Paper on
Oil Shale Technologies, July 18, 1979.
Environmental Protection Agency, Issue Paper
on Urban Waste and Cogeneration Technologies,
July 12, 1979.
Environmental Protection Agency, The Federal
Nonnuclear Research and Development Act
(Public Law 93-577), Section 11, Environmental
Evaluation, EPA 600/9-79-020, June 1979.
Other Federal Documents and Legislation
Council on Environmental Quality. National Envi-
ronmental Policy Act, Regulations, Federal Register,
Volume 43, No. 230, Wednesday, November 29,
1978.
Energy Advisors: An Analysis of Federal Advisory
Committees Dealing with Energy, Prepared for the
Subcommittee on Reports, Accounting, and
Management of the Committee on Governmental
Affairs, U.S. Senate, March 1977.
Executive Office of the President, Office of
Management and Budget. Major Systems Acquisi-
tions. Circular A-109. April 5, 1976.
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Federal Advisory Committee Act of 1972 (Public
Law 92-463). March 1972.
Other Materials
Delphi Research Associates, The First Year: An
Assessment, A Report on DOE's Environmental
Advisory Committee, January 1980.
Inside DOE, Biweekly McGraw Hill Publication,
December 7, 1979.
Landsberg, Hans, H., et al., Energy, the Next
Twenty Years, (Sponsored by the Ford Foundation
and Administered by Resources for the Future),
Cambridge Mass.: Ballinger Publishing Company,
1979.
Resolving Environmental Issues in Energy
Development: Roles for the Department of Energy
and its Field Offices. Rand Corporation. January
1979.
Schurr, Sam H., et al., Energy in America's
Future: The Choices Before Us, Johns Hopkins
University Press for Resources for the Future,
1979.
State of Colorado, Department of Natural
Resources, Project Status Report on the Joint
Review Process, November 1979.
Stobaugh, Robert and Daniel Yergin, Eds., Energy
Future, New York: Random House, 1979.
Open for Business Only?, A Common Cause Study
of the Department of Energy, February 1979.
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