United States
Environmental Protection
Office of the Admin
Science Advisory Board
Wellington, DC 20460
mber 1
Report of the
Ad Hoc Committee
to Review the
National Acid Precipitation
Assessment Program

                REPORT OF THE
               AD HOC COMMITTEE
                TO REVIEW THE
United States Environmental  Protection  Agency
            Science Advisory Board
            Washington, D.C.  20460
                December 1983

                         TABLE OF CONTENTS



      A.  Policy Expectations For NAPAP  Program 	  4
      B.  Review Committee Procedure   	  5
      C.  Outline Of This Report	5


      A.  How the present interagency  system works   	  6
      B.  Strengths of the present  approach    	  9
      C.  Weaknesses of  the present approach	10
      D.  General findings on the present  NAPAP efforts 	 10



      A.  Management changes--a proposed two-tier approach
            to acid deposition R&D	17
      B.  Revised budgeting procedure	22
      C.  Key areas requiring additional resources	24
      D.  Control technology    	25
      E.  Mitigation strategies	25
      F;  Improving the  quality of  basic science	25


          A -- Roster of the Ad Hoc Committee to Review the
                 National Acid Precipitation Assessment Program	A-l
          B -- Terms of  Reference     	B-l
          C -- Some Pertinent Studies  Related to NAPAP .... 	C-l
          D -- Inter-Agency Task Force on  Acid  Precipitation   	D-l
          E -- NAPAP Budgets FY'82  --  FY'84   	E-l
          F -- Ad Hoc Committee Recommendations on  NAPAP Budget   .  .  .  .F-l

     This report  has  been  written as  part  of  the  activities  of
the Environmental  Protection  Agency's  Congressionally established
Science Advisory Board;  a  public group providing advice on scientific
issues.  The Board is  structured  to provide  a balanced, independent,
expert assessment of  scientific  matters it reviews,  and hence, the
contents of this report do  not necessarily  represent the views and
policies of the Environmental  Protection Agency nor of other agencies
in the Executive Branch of the Federal  government.

    This is the  final  report  of the Ad Hoc Committee to  Review  the
National Acid  Precipitation Assessment Program  (NAPAP).   The Com-
mittee has  met over a  five-month period  to  review the  activities
of this  important  research effort with  special  emphasis  on  scien-
tific quality,  the scope  of  the research  effort,  adequacy of  the
research plan  and  its  relevance to policy  concerns,  and  research

     The Review  Committee  is  acutely  aware   of  the need  both  to
provide  information  to  policy  makers  in  the  short  run,  and  to
accumulate  knowledge over  the  long  term which  will  provide  improved
understanding  of the relationship between emissions and environmental
effects.  The Committee's recommendations are aimed at strengthening
NAPAP's  ability  to meet both of  these  objectives.

     The present NAPAP system has important strengths and weaknesses.
On the one  hand, the  Review Committee was  favorably impressed  with
the progress that  NAPAP has made since its establishment  in  1981,
the manner  in which the interagency process is working  to  coordinate
research projects  in the participating agencies and the  scope of  the
present  research effort.

     On  the other  hand,  the Committee has  found  several  weaknesses
in the  program  which  should  be  repaired.    First,   insufficient
resources are  being provided  to NAPAP  given  the  enormous  breadth
and complexity  of  the  technical  issues   involved.  Moreover,  the
resources are  allocated to the  participating  agencies  in  a  manner
which competes  with  declining  agency research budgets  and  does  not
give part-time  task  group leaders authority over  the  technical
program  for  which  they   are   responsible.    Second,   the   present
decentralized  interagency  management  process  is  not  likely to  be
capable  of  undertaking  several  important  functions:    systematic
integration of research results, management of large scale projects,
and technical  support  for policy formulation.  Third,  insufficient
multi-year, indepth studies of the atmospheric consequences of emis-
sions and ecological effects of acid deposition on lakes and streams,
watersheds, forests,  soils, and  biota are underway to  provide  an
adequate basis  for verifying  "system" models which are needed  to
meet credibly  the  1985   and   1987  NAPAP assessment   milestones.
Substantial additional  resources  will be required over  time  to
answer important technical issues.   Key areas requiring  additional
emphasis are integrated assessments, indepth  studies of aquatic  and
terrestrial effects  and  verification  of  source-receptor  models.
Additional  aspects of the NAPAP program which need strengthening are
mentioned in the body of this  report.

      The  report  also notes some technical areas which  need greater
 emphasis  and  resources.   These include air monitoring,  accelerated
 development of   techniques   for   dry   deposition   monitoring,   more
 precise determination  of  resources  at risk,  and  attention to  the
 relationship  of  acid deposition  to  other air  pollution phenomena.
 The  need  for  additional research  on  mitigation strategies  is  also
 noted as  well as  the need  for  a  greatly expanded program on control
 technologies  to  be  carried  out  by the  Department of Energy  (DOE)
 outside the NAPAP program.

      The  principal  recommendations of the Review  Committee  address
 management changes/  revised budgeting procedures, key areas requiring
 additional resources, and  the  need to improve  the  scope  and quality
 of the  basic  science  effort  underlying  the  entire  NAPAP  effort.
 There  should  also be  greater  cooperation with   foreign  countries
 facing the acid deposition  problem.

      The  recommended management  changes  involve the  addition  of  a
 full-time Director  of  Assessment  who  would  be an Assistant  Admin-
 istrator  or Deputy Assistant Administrator of  EPA. This individual
 would be  the  EPA  representative  on  the  Joint  Chairs of  the NAPAP
 Interagency Task  Force,  and he or she would be responsible for the
 functions of  (1)   technical  support   for policy  development,   (2)
 integration of  research   results  and   technical  assessment,   (3)
broad research guidance  to  the NAPAP  Research  Coordination Council,
and  (4) the management  of  new, large scale projects.  The  existing
NAPAP interagency process would be maintained  to carry  out the  bulk
of the research effort.

     The  principal   budget   recommendation  concerns  changing   the
manner in which resources are  provided  to agencies participating in
NAPAP.  Any additional  funds allocated above  the FY'84 budget  levels
should be provided  as   "new"  money to  the participating  agencies.
The  Director  of   Research,  task   group  leaders,   and the  proposed
Director  of Assessment  must have  control over  the  NAPAP  approved
research budgets  for which  they are responsible.

     The  Review Group  believes that  it is essential  to  strengthen
and  expand the fundamental  science component of the  NAPAP program.
A standing,  external scientific   advisory  committee  for  NAPAP  is
proposed and  increased  emphasis is recommended  for  publication  of
scientific results  in  the  peer  reviewed  scientific  literature  to
provide a mechanism  for  debate on controversial  issues.  A  funda-
mental research  effort  is  essential  to  clarify many  questions
about the environmental  impact of acid rain.  Therefore,  the basic
research must  be  protected  from the  budgetary  demands  of  more

short-term research  efforts  and larger projects.   To  insure broad
participation by  qualified  scientists, an  external  research grant
program, open  primarily  to  industry  and  universities,   should be
established as a matter of  high priority with  an  anticipated  funding
level of $10 million per year  in new funds.

II.  Introduction

     This is the  final report of the  EPA  Science Advisory  Board's
Ad Hoc Committee to Review the National  Acid Precipitation  Assessment
Program (NAPAP).   The  Committee  was established on  August 17,  1983
at the request of  the  Secretary of  Agriculture John  Block, Environ-
mental Protection  Agency  Administrator   William  Ruckelshaus   and
National Oceanic  and  Atmospheric  Administration Administrator  John
Byrne.  The  membership  of  the  Review Committee  is  presented  in
Appendix A.

     The charge of the Committee was "^to review  and  evaluate the tech-
nical quality of  the national  program  and  suggest  future  research".
The review included  an examination  of  the  plans and objectives  of
the program,  program  implementation,   and  how  well  the   planned
program will pursue  key scientific  questions relevant to decision
making.  The complete  terms  of  reference  are included in Appendix

     There have been  several  recent technical reviews pertinent to
the NAPAP  program.   In  addition  to  the  peer  reviews   undertaken
semi-annually by  the  NAPAP  program,  pertinent  studies  have  been
undertaken by  the National  Academy   of  Sciences,  the   Office  of
Science and Technology Policy, the  Office of Technology  Assessment
of the Congress,  the  Electric  Power Research Institute,   J'ason,  and'
Working Groups  under the US-Canada Memorandum  of  Intent.    A  list
of these studies  is  included in Appendix C.

     The present   review  differs  substantially  from  these prior
efforts.  This Committee saw as its principal task to conduct  a "top-
down" review  of  the  research management  of  the  NAPAP program.
Thus, the  Committee's  principal  objective  was  not  to review NAPAP
on an  individual  project  basis  (a task  which  is  satisfactorily
carried out by the  NAPAP  peer  review process) but to   assess  the
adequacy of  NAPAP  plans  and  programs  for  producing   scientific
knowledge to  improve  the  scientific   basis  for  decision   making.
Most of the  Committee's  recommendations   are  directed toward  this
end.  The reason  for adopting this  posture is the  recognition  that
the fundamental purpose  of the NAPAP research program should be to
provide scientific information needed  to make more  informed  regula-

 tory  decisions  and to accumulate scientific information which  will
 reduce  technical uncertainty  over time*   The present  Committee  rep-
 resents  the  first  systematic  external  review of  the adequacy  of the
 NAPAP program and  its plans for  meeting policy concerns.

      A.  Policy Expectations  for the	NAPAP  Program

      The Review Committee  is  strongly  aware of the sharp tension
 which exists between  policy expectations  and the prospects  for  de-
 livering scientific answers with adequate confidence.   On   the   one
 hand, the  decision maker  confronts a  serious  public  issue which
 requires political  resolution.   In  this  circumstance/ it is  under-
 standable that the  decision maker will seek to establish a  research
 program which will  be responsive to short-term policy concerns  and
 which will  yield  results that will permit  more  informed decisions
 to be  made  on  a  cost-effective basis.   On  the other  hand,   the
 scientific community  is  mindful of  the  great   complexity  of   the
 acid  deposition  problem and  the need  for  a  longer-term  research
 program which  will   provide  reliable  scientific  knowledge.    No
 matter how large the  commitment  of  resources to  acid  rain research,
 some information is beyond the  reach  of .  scientists on a time scale
 which matches the needs of policy makers.

     There are  several  reasons  for this  judgment.   First,  some  of
 the key  scientific  questions,   e.g.,  effects  on  soils,   forests,
biological species, watersheds, and  materials and structures, require
 very long periods of time to document. Second, the physical, chemical,
 meteorological, and biological phenomena  involved in acid deposition
 are remarkably  complex; many  years  of   scientific  study  will  be
 required to  understand  the phenomena  adequately, especially  if  one
 requires verification of models  and laboratory prediction by field
 study.  Third, the resources  and time required  to design and develop
 improved control measures and to appreciate the  response of ecosys-
 tems to  change  are also  considerable.   Finally,  there is growing
 realization that acid deposition is just  one of  a class of  interre-
 lated problems, e.g., ozone, trace  metals,  carbon dioxide,  visibil-
 ity, solid  waste  disposal,  and water quality,   that  society  must
 confront over the long term if the  quality of the global environment
 is to be preserved and enhanced.

     Accordingly, the Review Committee takes the  posj-tj^gn tha^t_£on^
 tinuing investment in a long-term research  program is required  re-
 gardless of the^gglj^cydecisions which ajre  taken  or are not take^n
 during this decade.  The  Committee's   recommendations  are  designed
 to improve  the  long-term  effectiveness   of the  research  program.
 Policy makers should  clearly understand  that  a   sustained  program,

requiring resources  substantially  in excess  of  current levels, is
the only course of action which will produce  information of practi-
cal value in  the  short-run and which  will also generate knowledge
in the long-run that will provide a comprehensive basis for dealing
with the problem of acid deposition.

     B.  Rev^ew^Committee Procedure

     The Ad Hoc Review  Committee held  five meetings for a total of
nine days.  The Committee  reviewed  past studies on acid deposition
(see Appendix C), and met  with  representatives of the Joint Chairs
(Department of  Agriculture,  Environmental  Protection  Agency   and
National Oceanic and Atmospheric Administration) of the Interagency
Task Force on Acid Precipitation.  Extensive  briefings were provided
to the Committee  by  the NAPAP program  office staff and by each of
the ten  NAPAP Task  Groups.   In  addition,  the  Committee  met  the
Chairman and the review panel leaders of the  two NAPAP peer reviews
which have been held.  The Committee also benefitted from a briefing
on the  research  activity  of  Electric Power  Research  Institute
(EPRI) and  this   organization's  views  of   the NAPAP  program,  the
need for expanded research,  and the prospects for  improved control
technologie s.

     Throughout the  Review Committee's  deliberations,  all  of  the
agencies and individuals involved in the NAPAP program were extremely
cooperative.  The  Committee is  greatful  for  this  cooperation  and
wishes to thank  especially Dr.  Chris  Bernabo,  Executive Director
of the NAPAP  program,  for his  efforts in  arranging constructive
meetings with  all  of  the  participants  in the  NAPAP  program.

     C.  Outline of this Report

     The body  of  this  report  consists of   three  major  sections.
Section III consists of  a  description of how  the  present interagehcy
NAPAP system  works  and discusses  its  strengths  and  weaknesses.
Section IV  is  devoted to discussion of some  outstanding technical
issues in the NAPAP program which the Review  Committee believes  are
not receiving adequate  attention.   The  changes  recommended by  the
Committee to the NAPAP program are  presented  in  Section V separated
into the areas of management changes, revised budgeting procedures,
key areas requiring  expanded resources, control technology,  miti-
gation strategies and improving the  quality of NAPAP1s basic science
component.  An Executive Summary of the  Committee's conclusions  and
recommendations is provided in Section  I of  the  report.

III. Description of the Present NAPAP Program

     A.  How the present interagency system works

     The NAPAP program is run by an Interagency  Task  Force  composed
of twelve  agencies.   These include the  Departments of  Agriculture
(DOA), Commerce  (DOC),   Energy  (DOE),  Health  and  Human   Services
(HHS), Interior  (DOI),  State  (DOS),  and  the Council  on  Environ-
mental Quality  (CEQ),  Environmental  Protection  Agency  (EPA),  Na-
tional Aeronautics  and  Space Administration  (NASA),  National  Oce-
anic and Atmospheric Administration  (NOAA),  National Science  Foun-
dation (NSF), and  Tennessee Valley Authority (TVA).   The  business
of the  Task  Force  is  conducted  by  the  "Joint  Chairs"  filled  by
representatives of the heads of three agencies,  DOA,  EPA and   NOAA.
There is an interagency Program Coordination Office,  housed in CEQ,
which manages the  interagency program and provides staff  support.
support.  In addition, there  is  a  legislative requirement  for four
public members and representatives from four national laboratories:
Argonne, Brookhaven, Oak Ridge, and Pacific Northwest.  An organiza-
tional chart of the interagency program  is  included  in  Appendix  D.

     The work of the NAPAP program is carried  out by ten  Task  Groups
each of which  is  chaired by  a representative of  a  "coordinating"
agency.   The  ten  task  groups  and  the  coordinating  agencies  are:

      Task Group                          Coordinating Agency

   A.  Natural Sources                       NOAA

   B.  Man-made Sources                      DOE

   C.  Atmospheric Processes                 NOAA

   D.  Deposition Monitoring                 DOI

   E.  Aquatic Effects                       EPA

   F.  Terrestrial Effects                   DOA

   G.  Effects on Materials                  DOI
         and Cultural  Resources

   H.  Control Technologies                  EPA

   I.  Assessment and  Policy Analysis        EPA

   J.  International Activities              DOS

There is  a  Research  Coordination  Council/   composed  of  the task
group leaders  and  agency representatives, which  oversees  the work
of the task  groups and  coordinates  their activities.   The Council
is responsible for developing the NAPAP research  plan and for  prepa-
ring an annual intefagency budget request.

     1.  The present research plan--Participants  in the interagency
process are  responsible  for  developing the objectives and  research
plans of the NAPAP program.  A ten year "National  Acid Precipitation
Assessment Plan" was prepared in 1981 as were supporting  documents
on "Research Goals  and  Objectives"  and "Major Deliverables." These
documents describe  the  results  expected from the research  activity
and how the  outputs of  the  individual task  groups  relate to each
other.  The  1982 NAPAP	Annua1 Re por t  t o t h e President an d  Congr e ss
summarizes the program in some detail and establishes three  important
milestones for integrated assessments  to  be prepared in 1985, 1987,
and 1989.  In general^ the existing NAPAP  research plans adopt rele-
vant objectives and define the  important	research issues involved  in
the origins  and effects  of acid deposition.

     2.  Management of the research activities--The process of esta-
blishing research  objectives and  plans is carried out by  an  inter-
agency process.  The  work plans  of  the  individual  task groups are
determined through  a  negotiating process  between the coordinating
interagency  process  and  the  participating  agencies.   Thus,  the
NAPAP program  is   technically  decent r a1i z e d,   with  the   research
effort determined  by  compromising  what  the  Research Coordination
Council views  as  important  and  what  each   participating  agency
views as important.  This situation results in part from legitimate
concerns of  the various  participating agencies about those aspects
of the  acid  deposition  problem that  are most  closely  related to
their agency's  mission,   about  their  own research  priorities  and
the need  to  maintain  their  in-house  research   organization.   In
part, the decentralization  results  from  the  method  of  funding the
NAPAP program, discussed below.

     In principle,  the   technical direction  for  the  NAPAP program
comes from the Joint  Chairs and  the  task group   leaders meeting at
the Research Coordination Council.  It is  important to realize that
none of these  individuals devotes  full  time  to  the  NAPAP effort.
However, there is  an  Executive  Director  who  is  full  time and has
a staff of four individuals.

     3.  Technical review process—The  NAPAP  program  has  built   a
high quality system of independent peer  review.   There  is an open
annual meeting at  which  all of  the  projects undertaken  by NAPAP

are reviewed  by a panel  which is  organized  according to the  task
groups.  To  date,  three  program  peer reviews have  been  held:   in
Fredericksburg, VA in  September 1982;  Raleigh, NC  in  February  1983;
and Boston,  MA  in  August 1983.  They  not  only provide a technical
review of  all  ongoing   projects   but,  equally   important,   these
meetings are  an opportunity  for  informal  communication  among  the
scientific researchers in the  NAPAP program.

     The Review Committee believes  that these periodic technical
reviews are of  great value and should  be continued.   An important
question about  the periodic peer reviews is the manner in which  the
recommendations of the review  panels  should be implemented.  There
is a need to  strengthen the process for	following  up  the recommenda-
tions^of the  peer review  panels and assuring that  meritorious  sugges-
tions are addressed  and  actually  adopted.   The present interagency
structure does  not  possess  sufficient  authority  over  the  agency
programs to enforce  many  of  the  reasonable recommendations made by
the peer review panels.

     4.  The  funding mechanism--At  present, the budget for NAPAP  is
established by  OMB  review of  a joint interagency submission.   The
interagency submission is constructed  from requests  from the parti-
cipating agencies through the task groups and  the Research Coordina-
tion Council.  When OMB approves a  budget level and  associated pr<^~
gram, the agencies are required to  carry out the program within  their
existing agency research  resources.

     The consequences  of  this practice  are  far  reaching  and very
detrimental to  high  quality  research  on acid   deposition.    The
reason is simple:   each  agency is  effectively funding,  out  of  its
research base,  an  interagency research  program  over  which  it  has
only partial  control and  interest.   At a  time  when the  research
base of most  of the participating  agencies is  eroding,  the NAPAP
program is  viewed  to  be a  not  entirely  welcome  competition  for
resources which address   other  research and development  issues  of
importance to the agencies.   The  inevitable result  is that  (a)  the
agencies seek  to  substitute  work  and research  performers,  i.e.,
their in-house  laboratories,   which are  not   central to  key  acid
deposition research or of the  highest  quality, and (b) the agencies
are reluctant (EPA is  an  exception) to propose or accept pertinent
new work for fear that it  further erodes their base  research program.
The outcome is that the NAPAP  research proram is far  less effective
and less flexible than it should be to achieve its goals.

     A serious consequence of  this^  founding method	is  that the  task
group le a de r s effectively do not have  authority over  the regeajrgh
program that they ajre_ex£ected to direct.  Several task groups have

projects funded  by  several agencies, e.g.,  in  FY'83 Task Group  D,
Deposition Monitoring,  had  its  $4  million  budget  split  between
four separate agencies.   The  fact is that  the  research program  of
each task  group  is  limited  by  what  the  individual  agencies  are
willing to  do  and  willing to support.   This  means that the  task
group leaders  and the  Interagency  Task  Force  have little  ability
to select  work   or  change direction when it would  be  in the  best
interest of the overall research effort.  Such authority is essential
to maintain quality control.

     Thu_s_/ __ the present  funding and budgetary  control procedure  is
a fundamental flaw  in  the  NAPAP program.   It  should be  revised  to
provide (a)  "new" research funds to  the participating agencies  so
that the NAPAP program is not seen  as  competing  with existing agency
research needs,  and  (b )  authority for  the  task  group leaders  to
carry out  the  research  program  approved by the   Interagency  Task
Force through  its Joint  Chairs  to  permit  the  best research to  be
undertaken by the most  qualified research performer.

      In sum, while the  existing joint  submission  of an  interagency
budget with OMB review is an excellent way to formulate  an integrated
program which  involves  diverse  scientific  disciplines  and  agency
interests, the present manner by which the budget support is provided
effectively removes authority from  the task  group  leaders,  who are
responsible for  the research  program, and impairs  the  effectiveness
of the overall research  effort.

                   ££ _ the  present _ approach
     The NAPAP  program has been  in existence  for  over two  years.
The progress  which  has been  made during  that  time  is  good.   Such
progress is  not easy, and  the  NAPAP program  is  respected both  by
this Review  Committee  and by  much of  the  external  scientific  commu-
nity .

     The interagency  process  which has been established  to  manage
NAPAP has  many  advantages.   In  particular,  an effective  forum has
been established to coordinate the  views  and research  activities  of
the various  agencies.  Such coordination  is  absolutely essential  to
the success  of  the  program,  which  must integrate diverse  research
results which are sponsored by many different agencies.   The  Review
Committee believes that the interagency process is particuj^arJLy_aj:>--
proprj.ate for the research activity of NAPAP,  especially an activity
composed of  relatively small  projects.  The  process  is less satisfac-
tory for the functions of  integrating research  results,  assessment,
and technical analysis to  support  policy formulation and for the
design and execution of larger-scale, multi-year  projects.

     C.  Weaknesses	o£_the	present  approach

     The NAPAP research program has made commendable progress  during
its relatively brief  existence,  but there are some important  weak-
nesses.  Repairing these  weaknesses will  lead to  a  more effective
research program over the long-term.

     Perhaps the central weakness of the NAPAP  program  is that  there
is no  single  technical individual  in  charge  of  the  entire  effort
with both the responsibility and the authority to execute and  inte-
grate the program.  It  is  noteworthy that neither the Joint  Chairs
nor the task group leaders  devote full  time to  their NAPAP responsi-
bility or  view  NAPAP  as  their principal  job.  The  lack  of  NAPAP
management control  over funds  has  been  discussed  above.   Such a
decentralized, interagency program  is  not  likely to be capable of_
undertaking major projects which require  disciplined attention to
schedule and  costs.  Nor  is  the  present  structure  likely  to  be
capable of  integrating  diverse research  results  in  a manner  which
addresses/ in  a   timely fashion,  the   short-term  concerns  of the
policy maker.  The problem is aggravated by the inordinate expecta-
tions of policy  makers as  well  as the  lack  of  "new money" at a
time when larger projects, e.g., survey of resources at'risk,  moni-
toring, large-scale experiments, are being proposed.

     The pressure to undertake large,  more short-term projects at a
time when  agency  research budgets  are  shrinking results  in both
inadequate attention to basic science  in the program and a tendency
to favor in-house laboratories at the  expense  of the broader  s c i e n -
tific community in industry and especially universities.  Moreover,
the effort to stretch  inadequate  resources to  cover the  vast  array
of acid  deposition problems  has   resulted  in  projects  that are
underfunded and too  short in  duration.  A research  program  which
is characterized by  such  sub-critical  projects  cannot be expected
to attract the highest quality technical people.

     D. General findings on the present NAPAP efforts

     The judgments of the  Review Committee about the present  NAPAP
effort largely  follow  from  the  strengths and  weaknesses  of the
NAPAP program mentioned above.  Some of the salient findings  of the
Review Committee follow:

     (1) The assessment milestones  of  the NAPAP plan in 1985,  1987
         and 1989 are unlikely to be met in a  satisfactory way.
         Given the  level   of   resources  provided,  the  complexity

    of the   acid  deposition  problem and  the  need  for  indepth
    systematic field  study,   the  present  NAPAP  milestones  as
    summarized, for  example,  in  the  1982  NAPAP Annual  Report
    are too ambitious.
( 2 )  Insufficient attention is b^ng given to the verification
                                                emissions to
    deposition ) _ and to the development and verification of big-
    logical effects models.   Since these  models  are key  to the
    evaluation of trends in acid deposition and proposed control
    strategies,  inadequate  attention  to  veritif ication  is most
    serious.   A principal  reason,  which  leads the  Committee to
    believe that  adequate  assessments  will  not  be  available
    in 1985  and 1987,  is the  absence  of  a   field  measurement
    program which  would  need  to be  in  place  now  if  verified
    models were  to be available  in 1987.   Also,  field confirma-
    tion will take  considerably  more  time than has  been allot-

( 3 )  Insufficient attention is being devoted to the integratj.on
    of the research results of the various task groups into an
    overall assessment .   At present, relatively little intellect-
    ual effort  is   underway  to  combine   research  results  in  a
    manner that  will lead to  understanding  at a  higher level of
    aggregation  than  individual  projects.  Up  to  the  present,
    Task Group I (Assessment and Policy Analysis)  has spent most
    of its effort in assembling research material rather than in
    ^.2ilL2 research  which  builds  on  the  results  of  the   other
    task groups.  This  circumstance  is an  inevitable  result of
    the NAPAP interagency process.    Intellectual  leadership is
    required here.

( 4 )  The NAPAP program is devoting _ too little attention to inter-
    national cooperation on acid deposition research.  The Review
    Committee believes that more  could  be learned by additional
    international cooperation, especially  with  Canada, England,
    Germany,  Sweden, Norway and  Japan.   Other nations have done
    more research than has the United States (US) on some subjects,
    e.g., Sweden has  an  extensive  liming  program, and  Norway
    and Germany have been  studying  the effects of  acid  rain on
    forests for  many years.   Moreover,  if understanding of acid
    deposition is  to be   considered   satisfactory,  the  models
    should be transportable  to  other  areas  and  still  provide
    reliable predictions with  appropriate  change  of input  data.
    The proposed US  program on  acid  deposition   is  quite   self-
    contained.  It  is not planned as a  cooperative effort with
    various European  countries,  even  though  acid  deposition

    problems seem especially severe there.  Our research program
    for 1985 does  not explicitly consider  this  or the European
    response to  it.   In some  crucial  aspects  of the  ecological
    impact problem this is especially regrettable.  Thus, German
    and central  European   forests  have  been  subjected  to  even
    greater stresses  from  sulfur  oxides and  other atmospheric
    pollutants than have our  own.   Understanding the relationship
    of this pollution to widespread forest damage in those coun-
    tries would  seem to be  critical  to  understanding what may
    be or become  at risk  here to unmanaged soils  and forests.

(5)  The status of atmospheric  modelling remains primitive.
    Present models for  acid  deposition  are  forced to  use rather
    rough parameterizations  because   of   insufficient  knowledge
    of relevant  atmospheric   chemistry,   dry  deposition,  cloud
    physics, upward  transport   out  of  the  mixing layer,  etc.
    Therefore £  B.£i££i  confidence  in  the  detailed predictions
    of models is not yet warranted.  Rather,  a  record of success-
    ful testing and  evaluation of various  extensive  data  bases
    on air  and  precipitation  chemistry  taken  simultaneously
    over several  years  would  be  needed to  "verify"  a  model.
    Except perhaps  for  sulfate  and  nitrate   in  precipitation,
    however, such data  bases  are  not yet  available.   Although
    very general  features  and  trends  for  acid  in precipitation
    should be  reasonably  described, particular  source-receptor
    correlations for emission changes  are  much more questionable.
    Models should play  a  more crucial  role  both  in  the  design
    of experiments  and  in  data  analysis.   Support   is  needed
    for such developments and  for incorporation of deeper under-
    standing of  extended  data  bases  as  they  become  available.
    But, in the absence of such,  the  use of present models with
    the intent  of quickly offering detailed answers  for near-term
    policy decisions is  risky.
( 6 )  Control technology is a central component of the acid deposi-
    tion problem and is currently not included ±n the NAPAP pro-
           The Federal funding  level  for development and demon-
    stration of new control technology  should  be increased sub-
    stantially to complement on-going industry commitments.  The
    development of new and improved, retrof itable , emission con-
    trol technologies followed  by successful  pilot-  and demon-
    stration-scale testing, is  of key  importance  in the poten-
    tial long-term mitigation of acid deposition.

         A number  of  improved  control  technologies  to  reduce
    source emissions are under  development at  various scales of
    operation.  All  have  incremental  associated  capital  and

operating costs which must be compared to the present  scales
of development  and  accumulated  operating  experience.  The
urgent need  for a  technically  sound basis  to  evaluate the
benefits and  costs of  these  control  options  and tightened
regulations requires  an  accelerated  national  program   of
development and  demonstration  over  at  least the  next five

     These developmental processes  include  (a)  physical and
chemical coal  beneficiation  (cleaning)  prior  to  use,  (b)
combined S02  and  NOX  removal,  either though furnace sofbent
injection (limestone,  dolomite,  etc.)  in  conjunction with
staged combustion  or  though  development  of  improved flue
gas cleanup  (scrubbing)  processes/  (c)  modification of pul-
verized coal  furnaces  to   fluidized  bed  combustion  having
much lower  S(>2  and NOX  emission   characteristics,  and  (d)
intensive coal  cleanup  through conversion to clean synthetic
petroleum or  solid fuels.  In  addition,  increased  research
emphasis should  also  be  placed  on  the  impacts  of   these
retrofitable  processes  on  water  quality,   and  the  quantity
and the quality of  solid waste produced.

     Because  control  technology  is  integrally  related   to
combustion system  design and  because  of   the  magnitude   of
the required  R&D  effort,   the  Review  Committee  recommends
that the  federal  focus for  this  national program  be  the
DOE and  that  it be planned and  implemented in  conjunction
with the private   sector.   EPA  should maintain its current
support role  in technology development,  thus   avoiding con-
flict of  interest  while maintaining  a  strong  information
base for regulatory decision making.

     A major  Federal program  (several  tens of millions  of
dollars per   year)  for  development   and   demonstration   is
needed in addition  to basic research  support for  longer-term
fundamental studies.    These  studies  include   the  general
areas of coal clean up, combustion control, post-combustion
monitoring, effluent  identification,  and  novel  techniques
for cleanup.

     Both furnace  sorbent injection and fluidized bed conver-
sion are two promising process developments which particularly
require expanded development and demonstration  efforts. This
will resolve  remaining  engineering uncertainties  and will
provide confidence  on  commercial   application  to  both  new
and existing  combustion sources by the  end of  this decade.

        The importance of this expanded  emission control develop-
    ment and demonstration  program is  underscored by  the  fact
    that approximately  40%  of  the total  cost  of  a  coal-fired
    power plant today  is  related  to environmental control.  The
    results of  the  proposed  program will  support  accelerated
    resolution of this  perceived  conflict between  coal  and the
    environment, while  avoiding unnecessarily  expensive and in-
    efficient solutions  which  freeze   control  technologies  in
    today's plants*

(7)  Mitigation--The  subject of mitigation is not adequately
    treated in the current program.  Scientific feasibility^
    studies of mitigation strategies prior to possible field
    implementation should be developed.   Mitigation programs
    for aquatic/ terrestrial and materials effects  may be carried
    out in the future.  Before extensive experimental mitigation
    studies,  such as   lake,   liming,  are  undertaken,  intensive
    baseline  data collection  is required.   The  appropriate task
    groups should support  such  data  collection  to  study  the
    feasibility of  mitigation to  their  corresponding  effects.
    Research  additions  to  the  aquatic  and  terrestrial  task
    groups should be  made to  fully  utilize data  obtained  from
    foreign and  domestic  liming   programs  currently  underway.

(8)  Basic science is of great importance to the NAPAP effort
    and is receiving too little attention.  To understand the
    impact of any environmental  change  requires  information on
    the magnitude of  the  change  itself,  the resources  at  risk
    and the resiliency  of these  resources.  All  three  of these
    areas have  components of  applied and  basic  science  that are
    poorly addressed by the NAPAP.   Previous  statements in this
    document  have discussed how to improve  the applied assessments
    program of   the  NAPAP.    However,   assessments  depend  upon
    our basic understanding  of  how acidic  deposition  interacts
    with the  receiving  systems-aquatic  ecosystems,  terrestrial
    ecosystems  and materials.  If  the   fundamental  knowledge is
    lacking,  the assessments will  be weak, improperly formulated
    and counter productive.   To insure  that  current assessments
    will be  reasonable  and   that  future  assessments  will  be
    better, the basic  science component  of the  NAPAP  must  be
    strengthened.  Specifically:

         1.  The basic science program  should be a stable, long-
    term component of  the  NAPAP.  Since  progress in basic science
    is  achieved over longer  time scales  than are assessment acti-
    vities, the management  of the NAPAP  should  be  structured

    so that the  basic science  program will  be protected  from
    interruptions in funding and  from  the more immediate concerns
    of the assessment activities.

         2.  The Federal Interagency Task Force should be involved
    in the basic  science  activity.   Since  our  understanding of
    the interaction of acidic deposition  with receiving systems
    requires the  involvement of most  scientific  disciplines,
    strong interaction among federal  agencies   is  required  to
    have a  balanced research effort.   Each  task   group  should
    have a  full  time  individual,  with  control   of  financial
    resources,, who  works  with  other task group leaders and the
    Director of Research to ensure such an  approach is successful.
    Once the  general  goals  and resource  availabilities  have
    been established,  the task  group  leaders   should rely  on
    universities to manage and  to perform the research.

         3.  The basic science  research program managed  by the
    North Carolina  State  University  (NCSU)  Acid   Precipitation
    program should be  expanded  and emulated.   This program has
    received high reviews  for both the quality of its management
    and its basic  research.  It has  been  the  only  program of
    the NAPAP to bring in  new scientists in a coordinated manner
    to address basic  questions   regarding acid  deposition.   If
    future advances  are to  be  made  in our  basic   understanding
    of the  impacts   of  acid deposition,  programs  such  as  the
    NCSU must be continued on a  long-term basis.

         The expanded basic science program will  improve knowledge
    of the basic  processes  and  mechanisms  occurring  in natural
    ecosystems and  accordingly   will  strenthen  the  ability  to
    assess the impacts of  future environmental changes.

(9)  Scientificcommunication should be strengthened.   The  NAPAP
    peer review panels have noted that  NAPAP  project  investigators
    were not always cognizant of available research results, and
    that there is not adequate  communication between task groups
    on subjects which are necessarily  related.   The single most
    important mechanism to  assure  both  credibility and  use of
    research results is publication in  peer reviewed scientific
    journals.   The Review  Committee	strongly urges  that the com-
    munications among the  tas^kgroug grolect investigators be
    strengthened	and that all  investigators _be encouraged to
    publish  their	results  in  thg peer reviewed scientific

     In addition to these general conclusions of the Review Committee,
there are several more specific  technical issues deserving attention
that emerged  during  the  Committee's  deliberations.   These  issues
are discussed in the next section.

IV.  Some Outstanding Technical Issues in the NAPAP Program

     Listed below are  several technical questions which  the Committee
believes require greater emphasis  within  the NAPAP program.  In many
cases these issues have  not  received  adequate attention because of
the limitation on the  resources  which  have been devoted  to the NAPAP
program.  In certain  cases,  the  gap exists because the NAPAP program
organization and research plan  is compartmentalized.   A summary of
the budget of  the  NAPAP program  is  included in Appendix  E.   The
Committee recommends that the Joint Chairs charge the NAPAP program
to evaluate the status of each of the technical issues mentioned be -
low and to recommend steps to repair existing deficiencies .

   (1)  The resources  at risk need to  be  better  defined by detailed
       geographical surveys;  emphasis  should be  placed  on  lake
       watersheds and forests.

   (2)  High quality,  long-term (20 years needed) study of the in situ
       biological response of  fish,   forests,  and  soils  are  of
       major importance to the  program.
   ( 3 )  Studies _ o n_a_ c_^d _ deposition induced chemical effects on lakes
       and streams, coupled with watershed and soil response, _ are
       urgently needed on an ecosystem basis.

   (4)  Expanded air monitoring is required  for  model verification;
       this is a major gap in the program.

   ( 5 )  Accurate methods for dry deposition monitoring in the field
       must be _ developed before establishing a monitoring network.

   (6)  The present NAPAP effort on man-made sources must be strength-
       ened, especially  quality  control  on  the  source  inventory.

   (7)  Significant attention should be  devoted  to the relationship
       of acid deposition phenomena and effects to other atmospher-
       ic pollutants ,  e.g., ozone, trace metals.

   ( 8 )  Additional laboratory and field experiments are needed to
       elucidate the mechanisms of the chemical transformations
       which occur in the  atmosphere; more  work on cloud processes
       is also desirable.

   (9)   Basic  studies  of  the
        damage by corrosion from acidic substances should be initi-
        aled." There  have  been  few   significant  studies  on  the
        influence of  acid  rain  on  the  mechanical  properties  of
        materials.   There are  no  quantitative data  on  the  effects
        of pH and  composition  of  acid rain  or  fog, and  time and
        temperature of exposure under  conditions  of  stress, strain
        and alternating  stresses.   The  least  studied  of  these
        phenomena is  corrosionf at igue  of  materials  in acid  rain
        environments.  Corrosion-fatigue will  occur even  in environ-
        ments in which  stress-corrosion  cracking  does  not occur.

   (10) Adequate baseline data should be gathered for the assessment
        of the  effects   of  possible  mitigation   strategies,  e.g.,
        lake liming.

     The preceding list,  in conjunction  with  the  general   findings
presented in Section III D, summarizes the major gaps and deficiencies
that the Ad Hoc  Review Committee found in the NAPAP program.  Most of
these gaps and deficiencies can be removed by management attention,
additional resources, and time.

V .  Recommended Changes to  the NAP AP Program

    In this  section  the main  recomendations  of  the  Ad Hoc Review
Committee are presented.

     A .  Maj^gejaejit changes - A proposed  two-tier approach  to  acid
         d e p o si tip n_R^D

     The limitations of the  present decentralized management  approach
of the NAPAP  Program  have been discussed in  Section III C.   These
limitations include  (a)  the absence of  a single technical manager
with both the responsibility  and  authority to carry out a  research
program of high scientific quality which is  responsive  to key policy
issues and the  schedule for  their  resolution,  (b)  an  organization
which does not have sufficient  technical  and  administrative support
to undertake  larger  projects  and applied  studies,  and (c)  lack of
authority and  intellectual  leadership  to  address   the demanding
technical issues of integration of research  results and  quantitative
assessment of alternative  courses of  action  for dealing with  acid
deposition.  The Review  Committee believes  that  strengthening  the
management and organization of  the NAPAP  program is  an  essential
prerequisite for _ realizing  major  improvement  in  the  acid deposition
research effort.

      In  principle, the Review Committee favors a management structure
 for  an applied R&D program in which a  single  technical  individual  is
 in charge  and where  the  program is  located primarily in a  single
 agency.  Such an  R&D  organization  is  most  likely to yield  effective
 research results.

      The Ad Hoc Review Committee  does  not believe that it is feasible
 to adopt/  at  the present time,  a  centralized lead agency approach
 for  the  NAPAP program for two reasons.   First, the acid deposition
 problem  involves  the   direct  and  legitimate  interest  of  too many
 agencies to permit  a  single agency to acquire  full  control of the
 program.   Second,  the  NAPAP  interagency   approach   is   basically
 functioning well,  and it would  be a mistake  to  undertake a major
 reorganization which would almost certainly interfere with a research
 process  that  is  gaining strength.  Indeed the  Review  Committee  is
 eager to  see  steps  taken to  strengthen  the  interagency process.

      In  sum,  any  management  structure   proposed  for  NAPAP  must
balance  a  centralized and decentralized approach.   Thus,  no ideal
 solution to the  management  organization is  likely  to exist.  The
 Review Committee  has  arrived at  a proposed two-tier approach which
 it believes strikes  an appropriate balance  and, most  importantly,
provides the opportunity for a much more effective and high quality
research program.

     The essential feature of the two-tier approach recommended by
 the  Review Committee  is that certain  functions be removed  from the
task group structure  and assigned to  a new,  full-time,  high-leve1
technical manager housed in EPA.  These  functions are:

     1.  Technical support to policy  development.

     2.  Integration and Program  Assessment (presently Task Group I).

     3.  Broad research guidance to the NAPAP Research  Coordination

     4.  Management of large  scale  projects and  research studies
         which require  project  management  and  administrative   or
         technical support.

This new position would be  at  the  level  of Assistant  Administrator
 (AA)  or  Deputy  Assistant Administrator  (DAA)  within  EPA, and the
individual would  be   the  EPA   Administrator's  representative   at
meetings of the   Joint  Chairs.  The  title  of this  new  full-time

position should be  something such as Director of Assessment of  the
NAPAP Program.  The  relationship of the Joint Chairs to the Inter-
agency Task  Force would  remain unchanged,  although  the  full-time
EPA Director  of  Assessment  would  act  as  convenor  of  the  Joint
Chairs.  In  addition,  this new EPA AA  or  DAA would be  responsible
for the  performance  of  work by EPA  under the  sponsorship  of  the
task groups.   The EPA manager  would also be able to  draw  on  EPA
administrative resources and external technical  support  contractors
to carry out the functions of (2) program integration  and assessment
and (4)  project  management.    A proposed NAPAP organization chart
is attached.

     There are  several advantages  to the proposed  new management
structure.   With  regard  to the  assessment  tier  the  advantages  are
f_ir_st, a  single  individual  would  be  responsible  for  many  of  the
technical aspects of the  NAPAP program.  This person  would be in  a
position to  implement larger scale  projects,  for  example, the design
and operation  of  deposition monitoring  networks,  which are likely
to be a  progressively  greater part  of  the NAPAP program.  Second,
the critical  function  of program  integration and assessment would
be strengthened and  would receive  the  greater emphasis which this
function deserves.  Third, a mechanism would be created for  providing
short-term technical  support to policy makers.   This  function  is
very badly needed at  a  time when  many different  policy  proposals
are being put  forward.  But,  the  function of short-term  technical
support to policy deliberations must not be  permitted  to  interfere
with the on-going research program; the proposed two-tier arrangement
avoids this  danger.   Fourth,  the  strengthened  assessment activity
will permit  improved  research planning  and  resource  management in
the NAPAP  program.   It  is  anticipated that  the  new  Director   of
Assessment will be in a better  position  to  provide  research guidance
to the  Research  Coordination  Council   because  of  the additional
intellectual effort that will be devoted to  integration  of existing
research results and to assessments.

     Fundamental research should also benefit from the  proposed  two-
tier approach.  First, the on-going,  largely  effective,  interagency
process for  undertaking  research  would remain  in place.  To some
extent the separation  of  the assessment function  from  the research
activity should improve  the ability  of the  program  to direct  its
efforts toward addressing key research questions without the distrac-
tions of entering  into short-run  policy debates  or  attempting  to
manage larger projects on an  interagency basis.  Second, the proposed
separation should provide some degree of protection for the research
budget from  the  growing  demands to  fund large  scale, more applied
projects such as monitoring  networks or resource  surveys.  In sum,

                                   Interagency Task  Force
                                       Joint  Chairs-^
                                   (Executive Secretary)2
                                                                         Advisory Committee
                                                                         National Laboratory
  Assistant  Administrator
  Deputy Assistant  Administrator
                                                        Research Coordination  Council  (RCC)

                                                            (Director of  Research)
Technical Support &
Policy Development
Integration & Program
(Formerly Task Group
Research Guidance to
through Joint Chairs
 Management of Large
 Scale Projects
 Responsible for EPA
 Performance on Task
 a. External
 b. Contractors ft other
    contract performers
Task Groups-*
                                                                    i  u  H  n  i
     Convenor of Joint Chair Meetings
2Executive Secretary—CEQ member liaison to policy makers
3Task Group I (Integration and Program Assessment) to DAA EPA; Task Group H to DOE;
   new Task Group K on Mitigation to DOI

the Review  Committee  anticipates  that  the  proposed  management
structure will  strengthen  the  ability  the  NAPAP  research program
to address fundamental scientific issues relating to acid deposition
without the distraction of short-run policy response.  The proposed
management structure is _ intended to facilitate the existing inter-
              _f^o r c a r r yi ng o u t research wjl t h gr e a t e r _e_mp_h a s i s on
long-term _ fundamental work .

     The proposed management structure has some disadvantages which
should also  be  considered.   First,  there will  be  some  who argue
that locating the proposed new Director  of  Assessment in EPA gives
rise to an apparent  "conflict  of interest" since  this agency has a
bias toward  regulation which  will  influence  its evaluation of acid
deposition issues.  The Review Committee believes  that it is essen-
tial for the Director of Assessment to be housed in  a single agency
to assure that  there  is  adequate support to perform the designated
functions.   The selection of EPA seems most logical  to the Committee,
although arguments can be  advanced both for and against the choice
of another agency.

     The second disadvantage of the proposed management structure is
that it may be  viewed by  some as downgrading the interagency process
or the research  focus  of  the  present NAPAP  effort.  As discussed
above, this  is not the intent of the proposal.  The  main reason for
the two-tier approach  is to provide  a  structure  for carrying out
functions, especially integration and project  management, which can-
not ef f ectively b e carried out by a  decentralized, interagency organ-
nization.  The Review  Committee  affirms its support  for the inter-
agency process to  carry  out  the  research program  and believes that
the present  arrangement will lead to a  strengthened  scientific base
over the long-term.

     The Review  Committee  also  recommends  the establishment  of a
technical advisory committee  for the NAPAP program.   Such  an advisory
committee can be  of  great benefit  to  the program.  The  advisory
committee can provide top-down technical advice to the Joint Chairs
concerning the effectiveness of the research program. The committee
should also  have  a  special responsibility to assure that the level
of resources provided  for  fundamental  research  is adequate to the
long-term objectives of  the  research program.   Most importantly,
the advisory committee  would  function  as  an important communications
link between the   scientific  community  and  the  national  program.
This communications function would serve  to strengthen the scientific
program and  to  assure both  that  the   concerns  of  the  scientific
community were heard by the NAPAP programs and that  the purposes of
the NAPAP program were better  understood by the broader scientific

community.  The  advisory  committee would be  of value to the NAPAP
program managers  and  would increase the credibility  of the program
in the scientific community.

     B .  Revised budgeting procedure

     In Section  III.A.4,  the present  method  of  funding  the NAPAP
program was described.  From this  discussion^ it  is evident that
2La.l2£_£llaJlSe.f	should be made in the manner by which acid deposition
research budgets are provided.  If  these  changes are  not  put into
place the  result will be that  (1)  the participating agencies will
progressively refuse  to  undertake NAPAP work because it displaces
significant research  activities which  they  view as more central to
their agency's mission and/or (2)  the agencies will continue to label
work and research performers  as  "acid  deposition related"  in order
to protect their base research activities or in-house  laboratories.
Continuation of  the  present  practice  of  funding  NAPAP  research
out of (declining) agency research budgets will lead to bad research.
The present mechanism for  funding NAPAP research  from agency research
budgets undercuts the Administration's  stated  interest in supporting
research on acid deposition.

     A second important adverse consequence  of  the budgetingsystem
is that task  group leaders  do  not have  effective  control  of the
funds required to carry out their approved research programs.  This
is because the task group projects are placed  into the budgets of
several agencies after a  negotiation process over  which projects and
performers will be  supported.   A  task  group leader cannot change a
project or  select  a  different  research  performer  without  the
agreement of  the agency,  which   frequently  is  reluctant  to shift
resources away from projects that serve agency  interests.

     A major revision of these budgeting procedures	is required.
The revision must be based on three premises:

     (1)  Substantial additional resources will  be required to
         support acid  deposition   research  over  the  next  several

     (2)  The acid deposition research budget must be  provided
         as "new" money to the participating agency and not from
         the existing, declining research programs of these agencies.

     (3)  The task group leaders and the new proposed  Director
         of Assessment in EPA must have control over  the NAPAP
         approved budgets for which they are responsible.  They
         should be  dedicated full time to their functions.

     The revisions required to achieve these objectives can be made
by strengthening the existing interagency budgeting process through
OMB.  At present, OMB reviews an interagencybudget request submitted
by the  Joint Chairs.   The  problem  with  the existing  approach  is
that OMB does  not fund the research by  adding resources  to agency
budgets but  rather  directs that  the NAPAP program be  carried out
within existing  agency  budget levels.  The Review Committee recom-
mends that,  following OMB review  of^the interagency KAPAP budget
submission^  OMB add  the approved  funding levels to agency budgets
in the final passback to the agency.  In this passback the funds
added to the agency  budgets must  be  earmarked for exclug^ve^u^e by
t h e_N A P AP_p_£02£a.S •   Tne  expenditure  of the  funds should be under
the authority of the task group leaders and the Director  of Assess-
ment, subject  to approval  by  the  Research  Coordination Council
and/or the  Joint Chairs.   These  changes   would  assure  that  more
effective research would be  undertaken  with greater  flexibility  to
pursue emerging  ideas  and to  attract the  most  qualified research

     The FY'84 NAPAP budget level is  $21'million.	The_Review Commit-
tee believes that any additions above this  level  must be  provided ag
^new" mone%  j^nto the participating agency budget  and  not  from the
e.xi.fstijig	research base of the participating agencies.

     It is difficult to specify  precisely the level to  which the
NAPAP research  program  may   need to  grow.   However,   the  Review
Committee is certain that  substantial additional  resources will  be
required, over a  period of time,   to answer the important technical
questions.   It  is of   fundamental importance  that   Administration
officials recognize and accept that the research program will require
a long-term  commitment  and that  erratic  increases  or decreases  in
the allocated budget be avoided.   Accordingly, the Review Committee
favors a  slow  but  sustained  growth  of  the  NAPAP  research effort
rather than  a crash  expansion.

     The Committee is especially  £oncerned  that large projects
(estimated total cost in excess of $f> million not^be^undertaken un-
til the following sj^x^tepsare taken.  These include:

     (1) Preparation of  a  written research plan describing what  is
         to be done, why  it  should  be  done, and  how  it will  be

     (2) Independent technical  peer  review of the   research plan.
         Preparation of  an adequate  research plan  will  typically
         require significant resources.

      (3)  Description  of  how  the  project  will be  managed.

      (4)  Preparation  of  an   estimated  cost  and time  schedule  to
          complete  the project.

      (5)  Designation of a single  technical individual who is reponsi-
          ble  for the  project.

      (6)  Provision  made  for  analysis and dissemination of  results.

      The  Review Committee expects that over time the NAPAP program
could grow  to a level  of approximately $100  million  per year  for
several years.  However/ it  will  take  some time before  the NAPAP
program can effectively  employ  such a resource level.  The Commit-
tee's recommendations  for the  FY'85 NAPAP budget  level  have been
transmitted separately by letters dated October  21 and November  16,
1983  to the Joint Chairs  (See Appendix F).

      The manner  in which such  a  resource  level  should  best  be
deployed depends,  in  part, upon the research activities  undertaken
by industry,  states, and  foreign  governments.  The Committee encou-
rages the NAPAP program  to continue  to coordinate its research acti-
vities with these entities and with  EPRI and to cooperate on parti-
cular projects and programs where appropriate.

     C.  Key  areas requiring  additional resources

     The Review Committee has stressed in this report its view that
the acid deposition research  program is underfunded relative to  the
complexity of the scientific  issues  which  should be addressed.  In
this section,  the Committee wishes to draw attention to certain  key
areas which require additional resources  and greater emphasis in  the
programs.   These key areas are:

   1.  Integrated Assessments;

   2.  In-depth studies  (requiring perhaps 5 to 10 years  of field
       measurements )	of aquatic	and  terrestrial effects	particular-
       ly  soils,	forests and watersheds;

   3.  Verification of	source^regegtgr models, including  ambient
       (ground and  elevated)  air  quality,  event wet  deposition,
       and dry deposition monitoring.

      D.  Control technology

      As discussed  in  Section  III.D,  little  attention  has  been
devoted to control technology within the NAPAP program.   Yet controls
are essential to coping with acid deposition.

     The process  of  developing new  control  technologies  for  coal
cleaning, combustion, and  clean-up  should be central to the design
of combustion  systems  and requires analysis  of trade-offs between
capital costs, fuel type,  etc.  The development of a control technol-
ogy within a  combustion system requires  substantial R&D (hundreds
of millions of dollars)  at  the required scale (hundreds of megawatts)
and substantial time  to yield reliable test data on cost and perfor-
mance.  For these reasons,  the Review Committee believes  that advanc-
ed control technology development  should be primarily a DOE responsi-
bi11y.  The Review Group recommends that DOE be  given the task, out-
side of the NAPAP program, to	formulate a  comprehensive and aggres-
sive program, in cooperation with industry, for  advanced^control
technology development.  NAPAP's  role  in  control technology should
be limited to  awareness of  developments  in  the  technology  and in
the trade-offs  possible;   the  NAPAP  program  should  not  undertake
control technology hardware programs.   The responsibility for devel-
oping cost-effective control technologies should be assigned to DOE.

     E. M i t i ga t i o n s t rat e g i e s

     The Review Committee  believes  that before  embarking on large-
scale liming or other mitigation programs,  it is essential to study
the effects that  such actions have on  ecosystems.   To  prepare for
assessing the  consequences  of  possible   mitigation   programs,   a
substantial amount of  research is  needed (including field experi-
ments) by appropriate task groups.

     F.  Improving the quality of the basic	science

     The Review  Committee  is concerned  that  insufficient emphasis
is being given  to maintaining the quality  of the long-term funda-
mental research, which must be an  important component of any nation-
al effort on acid deposition. In particular,  the Committee believes
that insufficient  attention  is  being  given to   supporting research
of a fundamental nature which is relevant to the  long-term objectives
of the  NAPAP  program but  which  is  not  narrowly directed to task
group needs.   Such  research is of  major  long-term  benefit  to the
NAPAP program because it stimulates  new ideas  that test  the mainline
NAPAP research  approach.   Research of  this type, which is largely
performed in  universities,  should  be  supported  through  a  peer

reviewed grants program.  The Review Group recommends that a grants
program of approximately $10 million per year be established within
the NAPAP  program  with  an  initial level  of $5 million  in  FY'85.

     The Acid Precipitation  Act of 1980  included  an authorization
of $5 million per year to NOAA to fill gaps  in the NAPAP.  The Com-
mittee recommends that this  money  be  appropriated* in FY'85 through
the existing  authorization/  which  has   never  been  appropriated.
The money  should be  used to fill important  basic  science needs of
NAPAP.  The  allocation  of  these  funds  should be  managed  by the
Director of Research for the Research Coordination Council.

     The Committee recommends that in FY'86  and beyond the authori-
zation be increased to $10 million per year.

                             APPENDIX A
                       SCIENCE ADVISORY BOARD
Dr. John Deutch, Chairman
Dean of Science
Massachusetts Institute of
Building 6, Room 123
77 Massachusetts Avenue
Cambridge, Massachusetts   02139
Dr. Terry F. Yosie, Executive Secretary
Staff Director
Science Advisory Board (A-101)
Environmental Protection Agency
401 M Street, SW
Washington, D.C.    20460
Dr. Richard Balzhiser
Senior Vice-President for
  Research and Development
Electric Power Research Institute
Room 1-296
3412 Hillview Avenue
Palo Alto, California   94303
   Dr. James N. Galloway
   Department of Environmental
   Clark Hall
   University of Virginia
   Charlottesville , Virginia   22903
Dr. George Hidy
General Manager
Environmental Research and
2625 Towngate Road
Westlake Village, CA   91361
   Dr. William Klemperer
   Department of Chemistry
   12 Oxford
   Harvard University
   Cambridge, Massachusetts
Dr. Gene E. Likens
Institute of Ecosystems Studies
The New York Botanical Garden
Gary Arboretum, Box AB
Millbrook, New York   12545

Dr. Stanford S. Penner
Energy Center  (B-010)
University of California at
  San Diego
La Jolla, California   92093

Dr. Malvin Ruderman
Department of Physics
Columbia University
New York, New York   10027
   Dr. Michael Oppenheimer
   Environmental Defense Fund
   444 Park Avenue South
   New York, New York   10016
   Dr. Herman Postma
   Oak Ridge National Laboratory
   P.O. Box X
   Oak Ridge, Tennessee    37831
                           A - 1

                             APPENDIX B
                         Terms of Reference
            for the Ad Hoc Committee to Review the National
               Acid Precipitation Assessment Program

     The Administrator of EPA, NOAA  and the Secretary of Agriculture
have requested that an external  group  of  scientific experts review
the National  Acid  Precipitation   Assessment  Program  (NAPAP)  to
assess its initial progress and  future plans  and to make recommen-
dations on how  the effectiveness of  the  program  can  be  improved.
The review  panel  is  requested  to  complete  its  deliberations and
report by 30 December 1983.

PURPOSE - To review and evaluate the technical quality and progress
          of the  National  Program   and   suggest   future  research.

CHARGE  - Evaluate  the  strengths   and weaknesses of  the  program,
          particularly the ability  of  the planned effort to answer
          the scientific questions most pertinent to policy develop-
          ment.  The review will cover an examination of:
                  and Ob jectives ;   Are the objectives  of the program
            clear, complete, and appropriate given the overall purpose
            of the research program?  Are the objectives realistic?
            Are the  plans  responsive  to  the objectives?   Are the
            resource allocations across  and within major  research
            areas adequate, excessive, inadequate?  Do the schedules
            for results seem reasonable?   Is there reasonable proba-
            bility of  success  in  meeting  program  objectives?  Are
            there any overlaps, duplication,  or gaps  in the plans?
            Is there an appropriate balance between basic and applied
            research efforts?

          • Implementation ;  How well does  the management structure
            and process for planning and  implementing  work?  Are the
            projects being  performed  and  the  various  individual
            agency efforts well coordinated?  Do the  projects
            address the  program's   objectives?   How  well   are the
            agencies working  together?   Are  national  objectives,
            not just agency mission requirements, being met?

          * Applications ;   Will the  planned  program  address the
            critical scientific questions most relevant to decision
            making?  Do the plans and projects demonstrate progress
            toward usable assessments  of the problem and  possible
            solutions?  Are the proposed  assessments well conceived?
            Will the information generated be useful  and of lasting
            scientific and policy-making value?
                               B - 1

       PROCEDURE -  The Committee will pursue its inquiry through discussion
                    with Federal officials reponsible for the research
                    program/ researchers in the program (both in govern-
                    ment and non-government laboratories) and external
                    experts.  Attention will be given to the relevance of
                    the program's current and planned activities to the
                    urgent needs for better scientific information to
                    develop sound policies.

RECOMMENDATIONS  -  The report of the ad hoc review panel may address any
                    aspects of the research program.  However, particular
                    emphasis should be given to:

                    - identifying possible future research in scientific
                      areas most relevant to policy concerns

                    - suggesting ways of improving the program and its

                    - recommending how to ensure the outputs of the program
                      are most effectively communicated and utilized

                    - indicating ways to strengthen the scientific quality
                      of the program

                    - suggesting changes in the level and direction of
                      effort in pertinent areas.
                                      B - 2

                             APPENDIX C

Some Pertinent Studj^eg Rejj_ted to NAPAP

1.  NAPAP, National  Acid Precipitation  Assessment Plan,  June  1982

2.  NAPAP Annual Report, 1982

3.  Report  of  the  First  Annual  Review  Meeting  of  the  NAPAP,
    Fredericksburg, VA, September 1982

4.  Report on the Effects  Research  Review Meeting  of the  NAPAP,
    Raleigh,  NC, February 1983

5.  Report on Atmospheric Review Meeting  of  the  NAPAP
    Boston, MA, August 1983

6.  Office of Technology Assessment  Report,  July 1982

7.  National   Academy  of  Sciences  Study   a)  1981  b)Calvert  1983

8.  Jason Report

9.  EPRI RSD  plan

10. Working  Groups  under  US/Canada  Memorandum  of  Intent,  1983

11. Office  of  Science  and  Technology  Policy  Report,  Executive
    Office of the President
                            C - 1

                                             INTERAGENCY TASK FORCE ON ACID PRECIPITATION
                                                        Interagency Task Force
                        Program Coordination
Joint Chairs
Director of Research




Depos it ion

Kf £«;






nologi es

ments and



                                                         Coordinating Agencies

                             APPENDIX E
                      NAPAP BUDGETS  ($000 BA)
Task Group

A.  Natural Sources

B.  Man-made Sources

C.  Atmospheric Processes

D.  Deposition Monitoring

E.  Aquatic Impacts

F.  Terrestrial Impacts

G.  Effects on Materials

H.  Control Technologies

I.  Assessment and Policy

J.  International
                               E - 1

                           APPENDIX F

                       WASHINGTON, D.C. 20460

                             NGN I 6 1983

                                                                OFFICE OF
                                                            THE ADMINISTRATOR
Mr. William D. Ruckelshaus
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460

Mr. John R. Block
The Secretary of Agriculture
Administrative Building, Room 200A
12th Street & Jefferson Drive, S.W.
Washington, D.C.  20250

Ms. Nancy Maloley
Council on Environmental Quality
722 Jackson Place, N.W.
Washington, D.C.  20250

Mr. John V. Byrne
National Oceanic and Atmospheric Administration
Herbert C. Hoover Building
14th Street & Constitution Avenue, N.W.
Washington, D.C.  20230

     This letter conveys an interim report from your Ad Hoc Committee to
review the National Acid Precipitation Assessment Program (NAPAP) con-
cerning our judgments on the FY 85 interagency budget submission.  The
principal purpose of the review committee is to evaluate the technical
progress of the NAPAP program and to make recommendations for change
that will strengthen this vital national research program.  Our final
report, due to you before December 30, 1983, will address the progress
of the NAPAP program in detail.  This letter reponds to a request to
comment on the proposed FY 85 NAPAP budget at a time appropriate for
budget cycle consideration.

     Throughout the Ad Hoc Committee deliberations we have been impressed
with the complexity of the scientific and technical questions which must
be answered in order to respond in a cost/effective manner to the acid
deposition problem.  The required technical program demands a sustained
research effort which addresses both policy concerns and fundamental
scientific issues.  This research effort undoubtably deserves, in light
of the potential environmental effects and the economic costs of control,
much larger research budgets during the coming years.  However many of
the key scientific questions, e.g., long term biological and ecological
effects, will require many years of research to answer, in part because
of the time scale of natural processes; accelerated funding cannot in
                              F  -  1

 all cases  lead  to  better  answers  sooner.  Thus,  it is of paramount
 importance to establish a research program which is of  the highest
 technical  quality  and  recognized  to  require  sustained support.  It is
 essential  to  avoid the oscillation in  research support  which all  too
 frequently affects programs  that  command momentary political attention.

     We have  reviewed  the FY 85 budget from  this  viewpoint.  The  NAPAP
 interagency process has requested $82.027 million at level III and
 $35.247 million at level  II  for FY 85  compared to $27.468 million in
 FY  84.  We believe that the  program  should receive, at  most, a 100%
 increase in FY  85  to a level of about  55 million.  Earlier we have
 advised Ms. Maloley and Mr.  Aim as to  the extreme importance of
 providing  any increment above the FY 84 NAPAP level as  "new" fenced
 money in the  agency passback in order to avoid eroding  the existing
 research base of the participating agencies  and  to assure that the
 best technical  talent  is  applied  to the unique problems of the NAPAP
 program.   A copy of this  letter is attached  for your consideration.

     The $55  million FY 85 budget which we advise evidently will  require
 a choice among  the several NAPAP  proposed research projects which the
 interagency task force recommended as "essential" or "highly desirable"
within their  level III increment.  Our committee has not done the work
necessary  to  reach precise judgments on which of  the proposed projects
should be  deferred.  However the  Committee wishes to note some projects
which it believes would be especially valuable to include in any  increment
above level I.  These projects are:

   Task Group B: (1) third party  verification of the man-made sources
                     emission inventory;

   Task Group C: (2) ambient air  quality monitoring (similar in scope
                     to the past  SURE project);

                 (3) provision for participation in a large scale
                     atmospheric field study (this could be either
                     the proposed EPRI MATEX experiment, the DOE
                     non-linear experiment or the EPA source receptor

                 (4) increased attention to laboratory  studies which
                     bear an atmospheric chemistry;

   Task Group D: (5) augmentation of the wet deposition network;

                 (6) accelerated development of  new reliable methods
                     for measuring dry deposition;
                                 F - 2

   Task Group E: (7) expansion and continuation of the survey of lake
                     water quality and fish resources including water-
                     shed parameters;

                 (8) intensive ecosystem monitoring;

                 (9) scientific feasibility studies of mitigation
                     strategies prior to field implementation; and

  Task Group F: (10) quantification of significant changes in soil
                     and forest productivity and stability due to
                     acid deposition and other potentially damaging

     In addition, the Committee believes that advanced control technologies
are of great importance to the acid deposition problem; this issue will
be addressed in detail in our final report.

     In the Committee's review it became apparent that the NAPAP program
increasingly will be proposing larger projects of longer duration.  For
these projects (estimated total cost greater than $5 million) it is
especially important that a process be established to assure five steps
have been taken before project approval:

     (1) Preparation of a written research plan describing what is to
         be done, why it should be done, and how it will be done.

     (2) Independent technical peer review of the research plan

     (3) Description of the management of the project

     (4) Preparation of an estimated cost and time schedule to
         complete the project

     (5) Designation of a single technical individual who is responsible
         for the project at each stage of development.

     Finally, the Committee notes its concern that the perceived need
to obtain basic data and answer near term policy concerns is outweighing
increased attention to more fundamental scientific inquiry bearing on broader
questions involving the mechanisms of pollutant transport, environmental
damage, long term biological effects, and new control concepts.  Since acid
                                F - 3

deposition is only one example of the long term environmental problems (C02,
trace metals, ozone etc.) we will face, it is short sighted not to make
some considerable investment on the most basic scientific questions which
arise.  The proposed FY 85 NAPAP budget conspicuously omits such an initiative.
The Committee recommends that as much as $5M of the FY 85 program be devoted
to unsolicited grants to study these scientific questions.
                             Sincerely yours
                          Professor John Deutch
                        Chairman Ad Hoc Committee
                             to Review NAPAP
cc: Mr. Aim, EPA
    Mr. Khedouri, OMB
                              F - 4

                                    APPENDIX  F

5 r«W7. 8
       ^^                        WASHINGTON. D.C.  20460.
                                    October  21, 1983
                                                                          OFFICE OF
                                                                      THE ADMINISTRATOR
      Ms.  Nancy Maloley
      Council on Environmental  Quality
      722  Jackson Place,  NW
      Washington, D.C.    20006

      Mr.  Alvin L. Aim
      Deputy Administrator
      Environmental Protection  Agency
      401  M Street, SW
      Washington, D.C.    20460

      Dear Ms. Maloley and Mr.  Aim:

           You have requested interim reports from the Ad Hoc Conmittee to Review
      the  National Acidic Precipitation Assessment Program (NAPAP) concerning the
      FY'85 budget.   We will provide you our reconmendations with regard to level
      and  distribution  of resources for the working groups after our next meeting
      on November 10 and 11. However, we believe it is useful to draw your attention
      to a more fundamental issue which applies to any level of incremental research
      support provided to the NAPAP programs.  This issue concerns the past practice
      of effectively funding the NAPAP research effort from the participating Agency's
      base R&D program.

           It is our unamious opinion that any increment to the NAPAP research
      effort must be provided by "new" money in the agency passback, fenced for use
      by the respective Task Group Leaders to support the NAPAP approved program.
      Our  reasons for this opinion will be fully discussed in our final report.  In
      sum  we -believe that continuation of the past practice has the adverse impacts
      of (a) eroding the base Agency R&D program which addresses issues of importance
      to the participating agencies other than acid deposition; (b) inevitably leading
      to Agency substitution of work and of research performance that are not
      optimally suited to address key research acid deposition issues; (c) effectively
      limiting the flexibility  of the Task Group Leaders to allocate funds to projects
      that have the highest potential for producing research of importance to the
      program; and (d) creates  an impression in the technical community that the
      Administration is not serious about the acid rain research program.

           We recommend to you  in the strongest possible terms to urge the
      Office of Management and  Budget to provide any increment in the FY 85 NAPAP
      program in the participating Agency passback as a final increment to the Agency
                                        F - 5

budget.  This will assume both a more effective and higher quality  research
program that will move this Nation to resolve the substantial scientific
uncertainties over the long>fcerm.
                           1  \          A
cc:  Mr. Willian Ruckelshaus
     Mr. John Block
     Mr. John Byrne
     Dr. Courtney Riordan
     Dr. Orville Bentley
     Dr. Lester Machta
     Dr. Chris Bernabo
     Dr. Terry F. Yosie
inperely you
                                        John Deuten") Chairman
                                        Ad Hoc Committee to Review
                                          the National Acidic
                                          Precipitation Assessment
                                  F - 6