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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
EPA-SAB-RSAC-92-022
July 28, 1992
Honorable William K. Reilly
Administrator
U.S. Environmental Protection Agency
401 M St. S.W.
Washington, D.C. 20460
OFFICE OF
THE ADMINISTRATOR
Subject: Review of FY 1994 Strategic Research Issues
Dear Mr. Reilly:
The Research Strategies Advisory Committee of EPA's Science Advisory
Board (SAB) met on February 28, 1992, to review 14 of 39 FY 1994 strategic
research issues for Research and Development activities within the Agency.
This review was held to provide the Agency with insights on the scientific
quality and responsiveness of the new format for Agency research proposals.
The Subcommittee attempted to provide a critical look at specific activities
outlined in each submission. To achieve this goal, representatives
were selected from each of the various committees of the SAB. These
individuals provided a broad spectrum of scientific expertise from
which to draw the conclusions found in this report.
The Committee notes that this document is the Agency's first attempt to
tie research programs to broad issues and that the attempt is laudatory, despite
specific criticisms offered at the meeting and/or listed below. This approach to
research planning offers hope for increased productivity, relevance and scientific
quality in the future. This orientation of research toward issues and greater
integration of divergent research efforts (by relating activities to issues) will
result in an improved, more effective overall strategic and a more
comprehensible research program. This will result in benefits to the Agency, the
country and the environment.
The Committee is also pleased to note that there is considerable
evidence of the influence of both the Future Risk (EPA-SAB-EC-88-044) and in
particular, the Reducing Risk (EPA-SAR-Ef!-qQ-021^ reports in the draft
Printed on Recycled Paper
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documents—however, we regret to note that budgetary recommendations of the
Viiturp Risk report have not been adopted in practice. And, while the concept of
relative risk ranking is used in a number of instances, the document does not
elaborate on the significance of relative risk, i.e., how relative risk should be
related to research efforts, and how to improve the relative risk ranking efforts
themselves. For example, the text of the review documents is not a sufficient
definition of the concept of "Ecological Risk" even though the Committee is
aware of the extensive effort being made to address this issue (cf., the Risk
Assessment Forum's work and the SAB's Ecological Processes and Effects
Committee's (EPEC's) review thereof). Thus, the subject is open to ambiguity
that obscures the rationale provided for research that is driven by ecological
concerns. We trust that this situation will be addressed and clarified in future
years.
Committee members also voiced numerous concerns about
abandoning discipline-based tracking of activities and resources, The
members felt strongly that dual accountability would add additional
insights into the program and urge the Agency to crosswalk activities
and associated resources into formats by issue and office (media and discipline).
In conclusion, the Committee is pleased with the overall approach which
ORD is taking in planning its research activities. Linking environmental R&D
with broad issues enhances the Agency's ability to undertake responsive efforts
and develop sound regulatory decisions. Still, the brevity of most of the
documents preclude an in-depth assessment. In most cases, it was not possible
to couple stated goal3 of the planned research with the related financial
commit mem..
The Committee thanks you for the opportunity to again participate in this
review and looks forward to your response to the recommendations contained in
the report.
c - — . -7 2L
Mr. Aivin AJm, Chairman
Research Strategies Advisory Committee
C.
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NOTICE
This report has been written as a part of the activities of the Science Advisory
Board, a public advisory group providing extramural scientific information and
&dviM ca "ha Ainirc&r.rabitr ant ctijerr afEritls ef Ihe EDTHr-ancu&atat Proiectisn
Agency. The Beard zs jzn&zorei -rcv>ie ;e_1 3ncec. expsrt 3ee;nt of
scientific matters related to pr&bleaia facing the Agency. This report has not been
reviewed for approval by the Agency and, hence, the contents of this rep on da not
necessarily represent the views and policies of the Environmental Protection
Agency, nor of other agencies in the Executive Branch of the Federal government,
tjut ir-es ajettwi
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ABSTRACT
The Office of Research and Development has implemented a new issue
based planning' system for environmental research. This approach to R&D
planning holds promise for research programs. Each of the 14 "issue strategy"
documents (Nonpoint Source Pollution, Indoor Air Pollution, Health Risk
Assessment Methods, Environmental Education and Outreach, Anticipatory
Research, Exploratory Grants and Centers, Drinking Water Pollutants and
Disinfectants, Terrestrial Systems, Habitat/Biodiversity, Wetlands,
Environmental Monitoring and Assessment Program (EMAP), Global Warming
Environmental Releases of Biotechnology Products, and Bioremediation)
provided a brief description of the topic, future activities in the area,
and high/low resource scenarios- The Committee views the process as
an excellent start for future planning cycles.
key words: issue strategy, planning, research
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RESEARCH ISSUE STRATEGIES REVIEW
RESEARCH STRATEGIES ADVISORY COMMITTEE
SCIENCE ADVISORY BOARD
CHAIRMAN
Mr. Alvin Aim, Science Applications International Corp., McLean, VA.
MEMBERS AND CONSULTANTS
Dr. Donald Bo-each*. University cf Maryland, Cambridge. MD.
Dr. Richard Bull, Washington State University.Pulkaaa, WA.
Mr. Richard Conway, Union Carbide Corporation, South Charleston, W. Va.
Dr. Paul Deialer, Retired, Shell Oil, Houston, TX.
Dr. Rolf Hartimg, University of Michigan, Ann Arbor, MI.
Dr. Morton Lippmann, New York University, Tuxedo, N.Y.
Dr. Dean Premo, White Water Associates, Amasa, MI.
SCIENCE APYISORY BOARD STAJET
Mr. Randall Bond, Designated Federal Official, Research Strategies Advisory
Committee, Science Advisojy Board, U.S. Environmental Protection
Agency
Ms. Janice Jones, Staff Secretary, Research Strategies Advisory
Committee, Science Advisory Board, U S. EnvironmentaJ Protection
Agency
Dr. Donald G. Barnes, Director, Science Advisory Board, U.S. Environmental
Protection Agency
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TABLE OP CONTENTS
1.0 EXECUTIVE SUMMARY 1
20 ZNTKODUCTtON 2
2.1 Background , ................ 2
2 2 Charge and General Purpose 3
2.3 General Comments oil Strategy Documents . 3
3.0 HEALTH RELATED ISSUES 6
3.1 Nonpoint Sources 6
3.2 Indoor Air . „ 6
3.3 Health Risk Assessment Methods 7
3.4 Environmental Education and Outreach 7
3.5 Anticipatory Research 8
3.6 Exploratory Grants and Centers..... 8
4.0 ECOLOGICALLY RELATED ISSUES 10
4.1 Terrestrial Systems 10
4.2 Hahitat/Biadiversity ..... , 11
43 Wetlands 12
+.4 EMAP 13
4.5 Global W&rraijig 13
4.6 Environmental Released of Biotechnology Products 14
4.7 Bioremediatian , ....... 15
APPENDIX -- Drinking' Water Pollutants and Disinfectant
By-Products
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1.0 EXECUTIVE SUMMARY
On February 28, 1992, the U.S. Environmental Protection Agency's
Science Advisory Board's (SAB) Research Strategies Advisory Committee met to
review a subset of EPA's Research Issue Strategies developed by the Office of
Research and Development for FY 1994. This report offers detailed comments
on the documents, which varied in length from one to three pages and included:
~ Nonpoint Source Pollution
~ Indoor Air Pollution
~ Health Risk Assessment Method
~ Environmental Education & Outreach
~ Anticipatory Research
~ Exploratory Grants and Centers
~ Drinking Water Pollutants and Disinfectants
~ Terrestrial Systems
~ Habitat/Biodiversity
~ Wetlands
~ Environmental Monitoring & Assessment Program
~ Global Warming
~ Environmental Releases of Biotechnology Products
~ Bioremediation
In general, the Committee was pleased with the approach which
ORD is taking in planning its research activities. Linking environmental
R&D with broad issues enhances the Agency's ability to undertake
responsive efforts and develop sound regulatory decisions. Still, the
brevity of most of the documents preclude an in-depth assessment. In
most cases, it was not possible to couple stated goals of the planned
research with the related financial commitment. Additionally, the
panelists voiced numerous concerns about abandoning discipline-based
tracking of activities and resources. The members felt strongly that
dual accountability would add additional insights into the program.
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2.0 INTRODUCTION
2.1 Background
The Research Strategies Advisory Committee (RSAC) of the Science
Advisory Board (SAB) was asked to review the FY 1994 Strategic Research
Issues proposed by EPA's Office of Research and Development (ORD). RSAC
was provided with 39 ORD strategy issue statements (1-3 pages long), describing
strategies for addressing each of the specific environmental problems. The
RSAC members chose to examine thoroughly a subset of 14 issues, which were
divided, between two workgroups of panelists. Workgroup A (moderated by M.
Lippmann, with RSAC members R. Hartung, P. Deisler, and R. Bull) considered
seven issues:
Nonpoint Source Pollution
Indoor Air Pollution
Health Risk Assessment Methods
Environmental Education and Outreach
Anticipatory Research
Exploratory Grants and Centers
Drinking Water Pollutants and Disinfectants
Workgroup B (moderated by D. Premo, with RSAC members J. Neuhold, D.
Boesch, and R. Conway) considered seven different issues:
Terrestrial Systems
Habitat/Biodiversity
Wetlands
Environmental Monitoring and Assessment Program (EMAP)
Global Warming
Environmental Releases of Biotechnology Products
Bioremediation
Many review comments were conveyed verbally to the Agency during a
meeting held on February 28, 1992. This SAB report integrates and presents
the comments of the two Workgroups. Section 2.0 provides the charge to the
SAB for this review, and the Committee's general response. Section 3.0 contains
the detailed response of the Committee to the health-oriented strategic issues,
while Section 4.0 contains the detailed responses to the ecologically-oriented
issues. The Appendix contains Dr. Bull's more specific comments on general
issues and concerns about researching Drinking Water and the Ground Water
issues.
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2.2 Charge and General Response
The charge to the Research Strategies Advisory Committee was to
evaluate the strategic research issue descriptions according to:
~ The adequacy of the strategic direction provided for each
proposal.
~ The relationship between short- and long-term efforts.
~ The integration of such efforts with similar activities
elsewhere, both within and outside of the EPA.
The Committee notes that this document is the Agency's first attempt to
tie research programs to broad issues and that the attempt is laudatory, despite
various specific criticisms offered at the meeting and/or listed below. This
approach to research planning offers hope for increased productivity, relevance
and scientific quality in the future. This orientation of research toward issues
and greater integration of divergent research efforts (by relating activities to
issues) will result in an improved, more effective overall strategic and a more
comprehensible research program. This will result in benefits to the Agency, the
country and the environment.
The Committee is also pleased to note that there is considerable evidence
of the influence of both the Future Risk and in particular, the Reducing
Risk reports in the draft documents—although budgetary
recommendations of the Future Risk report have not been adopted in
practice. And, while the concept of relative risk ranking is used in a
number of instances, the document does not elaborate on the
significance of relative risk, i.e., how relative risk should be related to
research efforts, and how to improve the relative risk ranking efforts
themselves. For example, the strategy text in the ecology sections
does not sufficiently define the concept of "Ecological Risk" even
though the Committee is aware of the extensive effort being made to
address this issue (cf.t the Risk Assessment Forum's work and the
SAB's Ecological Processes and Effects Committee's (EPEC's) review
thereof). Still, the subject is open to ambiguity that obscures the
rationale provided for research that is driven by ecological concerns.
We trust that this situation will be addressed and clarified in future
years.
2.3 General Comments of the Strategy Documents
SPECIFIC CHARGE #1: Adequacy of strategic direction
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As noted above, this is a good first step in a new approach to
research management. However, as expected, there are many places for
improvement. For example, it would be appropriate to develop an
introductory synopsis of the overall strategic plan for ORD efforts,
thereby providing a setting and background for understanding each
individual issue and identifying its place in the overall strategy.
In general, the issue statements do not provide consistent and adequate
bases for research direction. While some of the strategies were adequately
developed, others lacked a clear sense of direction (See details below.). The
Committee trusts that greater uniformity and improved overall quality will
result as the Agency becomes more experienced with this improved approach to
research planning.
The Committee recommends development of more meaningful
levels of effort associated with the issue statements. In this regard,
an indication of total projected levels effort and distribution among
various disciplines would elicit more useful comments from the SAB at
early stages of planning. One such device which was extremely useful
was included in the issue statements. This section gave a sense of
priority by describing. ascenarios"which presented what would be done
if more funds were available and, conversely, what would be cut if
funds were curtailed. This approach was especially useful in
discussing the exploratory grants and center programs.
SPECIFIC CHARGE #2: Balance between short- and long-term efforts
In most instances little information was provided specifically relating
short- and long-term efforts. The focus was essentially on the totality of the
program and its associated effort for the next several years. In most instances,
graphics projecting expenditures gave an indication of the rate (and distribution)
of expenditure of effort contemplated, although programmatic relationships were
not often specifically addressed.
SPECIFIC CHARGE #3: Integration of research efforts
In some cases mention was made of programs within EPA that are related
to programs of other agencies. However, the extent and mechanism of
integration between EPA and other such organizations could not be easily
determined from the descriptions provided. Within the Agency, programs
dealing with similar or related matters were rarely noted. Furthermore, there
was no obvious effort at integration across (within) the Agency even
though there appeared to be many opportunities for such integration.
For example, possible relationships between different ecological
research programs and the Environmental Monitoring and Assessment
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Program (EMAP) could have been described, but were not. The
Committee urges that such analysis be a component of future
strategies.
Also, there is good reason not to abandon tracking research programs
according to media as those relate better to disciplines (skills) and
regulatory considerations. Ideally, a dual categorization by issues-and
media would be more effective than either alone.
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3.0 HEALTH RELATED STRATEGIC ISSUES
3.1 Nonpoint Sources
The Committee feels that this issue strategy provides a good overview and
adequately reflects EPA's role in the larger national effort to address a critical
environmental issue. While inter and intragency cooperation/
coordinators are evident, it is clear that current national efforts
concentrate on selected problem areas such as midwestern agriculture.
Therefore, the Committee points out that a truly national effort to
adequately address this problem will require considerably more
funding.
3.2 Indoor Air
This issue was addressed as three sub-issues by the Committee: indoor
air, radon, and electromagnetic fields.
With regard to indoor air, emphasis is placed on those indoor pollutant
sources and exposures that cause neurotoxicity, irritation and other non-cancer
health effects (with a focus on organic vapors, their combinations, and
bioaerosols). Other indoor pollutants with potentially significant health effects
are, therefore, judged to be less critically important (e. g., environmental tobacco
smoke especially respiratory effects in children, asbestos and its fibrous
substitutes, and combustion effluents from nonvented sources). The
Committee recommends that related carcinogenic effects will not be
consciously ignored during these investigations, and also recommends
that bioaerosols and organic vapors warrant more research; (cf., the
production of volatile by-products and the production of irritating
compounds possibly aldehydes and aerosols by alternate methods of
drinking water disinfection).
There is also some concern about whether productive clinical research on
individual organic vapors would be feasible, or whether the areas of emphasis
selected were really the most important in terms of reducing the risks of indoor
pollutant exposures. However, it is a consensus that projected funding levels
will not permit appropriate levels of research for more than one or two pollutant
classes.
With regard to radon, the Committee feels that the focus on
mitigation research is appropriate and the program is on track. The
inclusion of EMF however, was questioned since some of the exposures
of greatest concern occur outdoors, though possible interactions of
other agents and EMF cannot be ignored in any setting.
Coordination of research efforts in each of these areas seems to have been
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established with DOE. With regard to indoor air in particular, lines of
communication within EPA and between EPA and NIOSH, DOE, CPSC, and
HUD, seem to be adequate to avoid duplicative efforts. This is particularly
important since some aspects of the strategy seem to focus on areas outside of, or
only marginally related to, EPA's mission and fall into NIOSH and OSHA areas
of responsibility ( e.g., the issue of sick building syndrome).
3.3 Health Risk Assessment Methods
Strategic direction of this ambitious and important initiative is sound,
but the pace of research and funding levels are not commensurate with needs
and opportunities. Improved risk assessment methods could facilitate the
identification of critical research needs and thereby improve the research
planning process. Increased levels of activity in this area could also save time
and money for ORD in the long run by providing a sounder basis for each
successive budget plan.
The Committee gained the impression that the strategy is directed at
individual chemical risks and comparisons between those risks that are
manifested through similar mechanisms. While useful and possibly more
tractable, this approach should be supplemented by other efforts to compare
risks of different types (that is, human health risks—or loss of well being risks—
risks as they might be caused by ecological effects risks vs. other direct human
health effects risks).
Integration activities described in this issue strategy seem to be generally
adequate, and the balance between short- and long-term investigations appears
to be generally sound. However, some effort needs to be expended on the more
difficult issues mentioned in the previous paragraph if EPA is to
generate adequate solutions in the future.
3.4 Environmental Education and Outreach
The RSAC panel found this issue difficult to review. It does not
address research needs, and its education activities are largely focused
at the K-12 level where the panel members have little background or
experience. ORD should more closely coordinate with the Agency's
Office of Environmental Education to consider the needs and prospects
for research on effective means of addressing environmental
educational requirements for students at the K-12 level. Also, the
Committee regrets that the program fails to address critical needs for
graduate and post-graduate training in the environmental engineering,
science, and health disciplines. The people trained in programs
formerly supported by EPA and its predecessor agencies are aging, and
not being replaced by younger professionals with comparable training
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and up-to-date skills. One exception is the program to train under
represented minorities. However, this program cannot, by itself, meet
the critical needs of the environmental research community.
The environmental education and outreach programs at EPA
headquarters, laboratories, and regional offices appear to be well integrated.
Still, it is clear that a greater degree of integration is needed with NSF
programs and with the recently initiated efforts of NIEHS in this area.
3.5 Anticipatory Research
The strategic goals and directions of this new program appear to be
generally appropriate and are certainly promising. Still, there are several
aspects of these efforts which remain unclear at this juncture. For example, at
what level within the organization will it operate?. Will it be utilized to seek out
really new environmental problems, or will it simply develop issues that are
already known within the Agency? The projects mentioned in the issue
statement are all important, but in nearly all cases represent problems that
have been recognized as important for more than 20 years. The Agency needs to
develop some approach to identifying problems that are truly unknown at this
time. The SAB has provided ideas along this line in Future Risk . The
issue of environmental equity mentioned here appears to be a somewhat
separate activity. It is therefore unclear how fully or how well this
sub-issue can be integrated into the program as a whole.
3.6 Exploratory Grants and Centers
The strategy statements of the "Problem and Strategic Research Goals"
are adequate. However, the rest of the issue Paper beats an ignominious retreat
from the needs and responsibilities of the Agency.
The nature of the discrepancy between the needs and goals, on the one
hand, and the status and directions, on the other, are obvious. The Committee
asks that the strategy authors and research managers consider the following:
1) The program's original scope of 15% of ORD research has long since
been abandoned.
2) The number of university-based Centers of Excellence has been
reduced from 8 to 4 in the past and current years.
3) The current Administrators goal of raising the exploratory grants
program to $50 M in annual $10 M increments has been put in
abeyance.
4) The stated intention to shift funds from a general solicitation for
investigator-initiated grants to grants on Requests for Applications
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(RFAs) written to meet programmatic research needs will
reduce the viability of the modest program that currently
exists. This breaks faith with the academic community that
wishes to help EPA through a steady sequence of innovative
and anticipatory research, and is therefore incompatible
with the need for training of the next generation of
researchers in university laboratories.
Program-oriented RFAs can and should be undertaken,
and can utilize the peer review capabilities of the review
panels. However, there is likely to be a net decrease in the
long-term technical contribution to environmental decision
making if support for the RFAs are drawn from the meager
pool of funds available for general solicitation.
5} The stated intention to terminate the general solicitation
in health research is poorly considered. It appears to be
based on a misconception of recommendations in Reducing
Risk. The SAB recommendation in that report was to
achieve a balance between research in ecology, health, and
control—not to abandon health. The Committee asks who
will support extramural health effects and human exposure
research focused on EPA needs if not EPA itself. There
are many such needs that the National Institute of
Environmental Health Sciences (NIEHS) programs simply do
not address.
6) The abandonment of an investigator-initiated grant mechanism in
favor of an RFA process is not consistent with the commitment to
anticipatory research described in Section 3.5 of this
report. In many instances, the RFA process could draw on
such a limited portion of the health effects research
community as to almost guarantee projects of poorer
scientific quality.
Consequently, we note that a combination of both approaches to
conducting research is essential for a strong research program.
It is not possible to determine the relationship between short and long-
term efforts in this area absent a long term program description. Integration
within EPA may also be a problem which should be addressed as illustrated in
the effort to turn limited extramural grants program funds over to support
internal program needs. The integration of Centers with other EPA programs
was also not addressed.
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4.0 ECOLOGICALLY RELATED STRATEGIC ISSUES
The members of Workgroup B believe that the strategy statements are
generaljy very good, concise synopses of broad and complicated topics,
and reiterate that the Agency planners are to be commended for these
efforts. The strategies are genierally informative and clarifying.
One overarching recommendation is that the strategies should provide
more explanation of how each strategy is integrated with other programs within
and outside the EPA. It is especially important that the interrelationships
among the Terrestrial, Habitat/Biodiversity, EMAP, and Wetlands strategies be
clarified and that their complementary attributes be described.
4.1 Terrestrial Systems
It is important to include this issue among the 39 top research strategy
issues of ORD. The health of terrestrial ecosystems is important to both
resource use and publicly perceived values. Therefore, an integrated approach to
its management is crucial. Although resource management (especially of
terrestrial ecosystems) has not historically been a part of EPA's mission, the
Terrestrial Systems Issue is very much a matter of renewable natural resource
management. The physical and chemical quality of the environment affects
ecosystem production of resources, thus providing the rationale for the Agency's
entrance into the resource management field. This rationale should be made
explicit in the strategy.
A western watershed is an appropriate choice for one of the
initial pilot studies because good capabilities exist for remote sensing
and a base of ecological information in that region. The Committee
also feels that some terrestrial landscape representation information
in working forests of the upper Midwest is important as one of the
candidate geographical areas.
One of the stated strategic research goals for the Terrestrial Systems
issue is to answer the question, "What are tfie services valued by the public that
terrestrial ecological systems provide?" The Committee feels that this approach
is somewhat contrary to recommendations put forth in thp Reducing
Risk report in which the SAB notes the divergence that can occur
between scientific evaluation and public perception of a given issue.
Therefore, there should be more discussion in the issue strategy of how
these "values" will be determined and used. How does the value of
ecological resources and services to future generations fit into the
strategy? The Agency should explicitly acknowledge that certain sets
of values will cause basic conflicts in resource management and that
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resource use and terrestrial system impacts are interrelated.
It is critical to articulate the EPA role in the process of resource
management. Will one of the Agency's functions be to provide ecological
information and management technology to resource managers in other
agencies? It should be made clear that all land managing agencies will be
included in this process and interagency cooperation will be important.
4.2 Habitat/Biodiversity
This is a critical topic to include in the Agency's list of issues
and the Subgroup generally favors the research approach outlined in the
document. It would be helpful in the problem definition section to
describe why biodiversity is important and how habitat is important to
maintaining biodiversity. In fact, a working definition of biodiversity
and habitat would be appropriate at the outset. During the public
meeting with the SAB, the Agency made several clarifications that
could be included as part of the written strategy statement. These
clarifications included a discussion of the uses of "greenness
measures" from remote sensing imagery as a surrogate measure of
habitats and invertebrate organisms as the indicator taxa for
biodiversity. In this instance, however, the term "greenness" is
confusing. The section does not adequately explain "how green is
green" nor the relationship of "greenness" to diversity.
There are several issues that should be more fully considered in the
strategic planning process. For example, direct human impacts on biodiversity
(e.g., suburban sprawl, highways, uncontrolled land use patterns, etc.) affect
plant and animal populations even though quality and quantity of habitat are
unaltered. The strategy statement should explain whether its focus will be
individual species or species assemblages; e.g., guilds. The Committee
recommends the latter. In addition, the many cases of habitat boundaries where
the integrating of species assemblages yields relatively higher
biodiversity are an additional challenge. While the written strategy
mentions "habitat of greatest value" regarding comparative risk
assessment, there is no discussion of how such values will be
determined.
At the February 28 meeting, the Agency indicated that the topic of
geographic scale would be a primary research question and would be examined
early in the research program. This aspect should be addressed explicitly in the
document.
The "mitigation" aspect of this research strategy should be more fully
developed. Specifically, as more habitat and biodiversity losses are identified as
existing problems, it becomes more important to consider strategically (in the
research planning context) just how mitigation of these problems areas will be
accomplished. Therefore, RSAC recommends that the Agency consider
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moving : forward with these mitigation ^aspects "prior to, or * concurrent
with, the more systematic assessment component of the' research
strategy.
The -statement should clearly identify whether the focus of the
research is
on all components of the biota or more specifically on the rare forms.
More importantly, policy research into what can be done by EPA now in
light of present scientific knowledge should be undertaken.
*> . Finally, the Committee notes that answers to a fifth policy question are
required in order establish research priorities within this issue strategy; i.e.,
"Which species and habitat types can we effectively manage for now and which
need additional basic or applied research to effect appropriate management?"
The balance between basic research and applied research must be maintained.
Applied research provides technology that can address some immediate needs of
the Agency for mitigation of existing problems and also identifies existing data
deficiencies that must to be addressed by basic research. The required balance
must ensure that concentrating on those habitats and species that are currently
most at risk does not totally divert our attention from those components of the
biota that are not perceived to be at immediate risk. Basic research directed at
such resources should help the country manage and maintain them without
costly restoration or mitigation activities. Key information about habitat
requirements for assemblages of organisms will form a basis for efficient and
economical management for biodiversity.
4.3 Wetlands
The Wetlands issue is clearly significant, and progress toward
achieving the research goals will provide important practical
information. The Agency is in a unique position to assume the lead in
using the landscape approach in wetland function, health, and
management. Consequently, the landscape level of investigation, should
be emphasized in the strategy statement.
The linkages between the wetlands issue and EMAP, Habitat/
Biodiversity, and even Terrestrial Systems should be addressed in the strategy.
It is important that the integration and transfer of information between the
research programs occur throughout the work, but especially in the early stages
of the investigations.
Reference to some important wetland research is also missing from the
strategy. For example, significant work on the cleansing function of wetlands
has been contributed by the Kadlec brothers at the University of
Michigan; John Kadlec in Canada, Utah, and Idaho, and by Howard Odum
and his students in Florida, the Corps of Engineers and many other
university based ecologists. In addition, an important body of
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information on wetland construction exists as a result of 60 years of
wetland construction by the U.S. Fish and Wildlife Service.
The Committee supports research emphasis on seasonally or
periodically wet systems. This commendable proactive approach and
should include overlooked systems such as playa basins, deserts, vernal
ponds, and irrigated agricultural wetlands.
The Committee is concerned that the use of the phrase "categorizing
wetlands" in the document could to be misunderstood as a reference to
wetland delineation. It should be made abundantly clear that wetland
categorization relates to functions and values (such as an important
resource for drinking water), and not to the determination of wetland
boundaries.
4.4 Environmental Monitoring and Assessment Program
(EMAP)
The Committee agrees that EMAP is important for a holistic view
of the environment and for the basic change of Agency strategies for
environmental protection through long-term monitoring. The strategic
direction is sound, except that additional emphasis should be directed
toward providing interim results early in the effort. This near-term
payoff will help ensure the long-term support necessary for EMAP's
success. Because of its size, EMAP is a potential "lightning rod" for
criticism from inside and outside the Agency. A series of EMAP
symposia held at scientific meetings (e.g., ESA, SETAC, AAAS)
displaying short-term results may be important to address potential
criticism in a proactive way.
EMAP is a monitoring program that provides other programs with data
including feedback on ecological condition. In the issue strategy, however, the
distinction between monitoring and research is not made clear. In addition,
some consideration of EMAP as an integral program within the agency would be
helpful in the issue strategy. What is its current and anticipated relationship to
programs and offices with the Agency?
4.5 Global Warming
The Committee recommends that the EPA clarify the strategy
statement as to how it integrates with the international and national
global warming research efforts. There are overlaps between the
Agency's agenda and the agendas of other federal agencies (e.g., NASA's
global atmospheric program), and these should be outlined. It is not
clear whether EPA's research topics were selected because of high
priority relative to the existing programs or because they matched EPA
expertise. Therefore, it is especially important to address how the
global warming strategy relates to other research within the Agency.
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There are programs within the EPA, particularly in the area of effects
on natural systems (e.g., terrestrial systems, habitat/biodiversity,
wetlands, and EMAP), that could contribute to the global warming
strategy if properly integrated. A discussion of such integration would
improve the strategy statement.
The research topics addressed by the Agency require long-term
commitments because they are complex problems. Although
comprehensive answers to research questions cannot be expected for a
number of years, it is reasonable to expect interim "deliverables." A
more fully developed strategy document should identify the short-term
objectives of the program and the interim milestones.
Five major scientific topics are identified in the strategy
document, and a number of associated questions are presented. In order
to adequately evaluate the strategy, a brief description of how the
Agency will address these questions is needed. For example, under the
topic "Atmospheric Chemistry," the Agency indicates that one of the
program's tasks will be to calculate Global Warming Potentials (
GWPs). Since GWPs have already been calculated, it is not clear why
this is an important task within the research strategy. If the Agency
expects to improve the existing estimates for GWPs, it should state
this in the document and provide the associated rationale.
There are two key components missing from the atmospheric chemistry
program: aerosols and CFCs (and other halogenated compounds). The radiative
effects of aerosols are thought to be comparable to, but opposite from, the
present effects of C02. It would be a serious oversight to exclude them from the
research strategy. The direct radiative forcing due to CFCs and related com-
pounds is similar in magnitude to methane, but more importantly, their atmo-
spheric lifetimes can be an order of magnitude greater. Even if CFC emissions
are completely eliminated today, the compounds already released will reside in
the atmosphere for centuries. An additional complication is that although CFC
substitutes like HFC-134a have an ozone depletion potential of zero, some have
appreciable global warming potentials.
Finally, it is not always clear in the text of the issue strategy whether
carbon dioxide or gases other than C02 are the intended focus for the research
effort.
4.6 Environmental Releases of Biotechnology Products
The Committee questions the importance of this issue relative to the other
38 issues presented to the SAB. If this research is aimed at a proactive
positioning of the Agency to address unperceived or unlikely environmental
effects of products of biotechnology, this should be made clearer in the issue
strategy.
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The strategy calls for development of bioassay techniques that measure
the diversity of community structure and function and identify the sensitive
trophic interactions that are measures of ecosystem health. The strategy
statement should be clarified to distinguish this activity from terrestrial habitat
and EMAP activities.
4.7 Bioremediation
The Bioremediation Issue Strategy covers the topic well and addresses the
major points made by the SAB Environmental Engineering Committee in a
recent review of the subject. Successful remediation of chemical releases will
require effective and timely technology transfer to the private sector,
and this component of the issue strategy may require additional
emphasis.
The problem of materials handling also merits a special research
emphasis. For example, how can a contaminated substrate be brought into
contact with the bioremediation product, while simultaneously maintaining
proper physical/chemical conditions that will promote bioremediation.
The issue of mass transport relates more to providing contact between
added microorganisms, nutrients, co-metabolites, and the contaminant.
The "Process Research" component of the issue strategy indicates a focus
limited to identification of microorganisms that degrade contaminants. This
emphasis seems inconsistent with the broader goals of process research in
general.
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APPENDIX
Detailed comments of Dr. Richard Bull on:
DRINKING WATER POLLUTANTS AND DISINFECTANTS
1. The Congressionally mandated evaluation of 25 pollutants every three years
is not an issue that can be rationally planned as a research program.
Consequently, it should be separated from the drinking water disinfectant issue.
2. The responsibility for producing safe drinking water lies largely in the public
sector. Recently, the Agency has mandated the use of disinfectants through the
Surface Water Treatment Rule. Consequently, the responsibility for resolving
problems with disinfection falls clearly with the Agency.
3. The Agency has no basis for determining the impact of an MCL for any
disinfectant by-products on the health risks associated with drinking water. A
single restrictive MCL can necessitate large investments of public funds into
alternate methods of water treatment that may generate a completely different
set of by-products or potentially compromise protection against waterborne
infectious disease. The data base does not exist for the rational evaluation of the
alternatives to chlorine.
4. The drinking water disinfectant and disinfectant by-product issue is a very
complex problem requiring a much higher level of resources than indicated in
the strategy if it is to be resolved by the end of this century.
5. The FY93 resources indicated in these documents for health effects research
are much greater (i.e. 2-3 times) than the Drinking Water Committee was led to
believe in its recent review of the Health Research Laboratory's program in
December of 1991.
6. It is extremely important that the disinfectant problem be considered one of
competing risks. All disinfectants lead to the formation of by-products, but the
problems are more complex than implied in the strategy. The toxic and/or
carcinogenic by-products are not only chlorinated organics. They include
inorganic ions of considerable concern such as chlorate, chlorite and bromate.
Additionally, brominated organics are produced by either chlorination or
ozonation in waters containing trace amounts of bromide ion. Based on the
limited data that is available, the cancer risk associated with chlorination,
chloramination or ozonation differs marginally, all approaching a 10"3 additional
lifetime risk as calculated by the linearized multistage model. In waters
containing bromide (a fairly common occurrence), bromate formation from
ozonation could present a more serious hazard, but field data are quite sparse.
Some evidence suggests that the formation of brominated organics could be
exacerbated by the removal of organic carbon. This is because bromination
occurs preferentially to chlorination. There is little knowledge of the toxic
properties of by-products of disinfectants other than chlorine. Additionally, it is
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important that alterations in drinking water disinfection practice do not
significantly increase the risks from waterborne infectious disease.
7. The impact of alternate forms of disinfection on other ORD initiatives (e.g.
indoor air, risk assessment methods) has apparently been considered only on the
most superficial level.
8. The trend lines in the budget reflect a naive understanding of the need for a
highly interactive research program in this area. Efforts to identify critical by-
products, to determine the efficacy of alternative disinfectant treatments, to
collect the data that are needed to estimate the impacts on public health and to
develop the appropriate risk assessment methodologies for measuring
comparative risks make sense only with in a highly coordinated, iterative
process. The budget lines provided imply a sequential process that does not
logically lead to a solution of the problem.
It has been traditional in this area that as information is developed about by-
products that will limit the use of a treatment option, new treatments or
combinations of treatments will be explored by the drinking water industry that
will create new problems for research.
9. It is extremely important that the Agency develop an epidemiological
capability to address problems in drinking water. This is particularly important
for confirming that risks from waterborne infectious disease are not increased by
alterations in water treatment practice.
Epidemiological investigations of chemical hazards should also be conducted, but
in a much more deliberate manner. These studies should be focused on
differentiating between the effects caused by use of different disinfectants and
the modification of risks that may be contributed by other water quality
characteristics (e.g. TOC, pH, other water treatments). Efforts should not be
directed at individual by-products since it will not be clear what the major by-
products are for non-chlorine alternatives for some time in the distant future.
10. The strategy does not provide a clear concept of how this issue is to be
managed. The limited resource base" indicates a need for a strong mechanism of
prioritization that insures that the limited resources remain focused on the
problem and do not get bogged down in expensive fishing expeditions.
Toxicological studies should be directed towards identifying an^ characterizing
the toxicological properties of major byproducts. Prior data suggests that
carcinogenic and reproductive/teratologic effects are the most critical effects.
One by-product (dichloroacetate) appears to be a neurotoxin, but heptatoxicity
and cancer appear to occur at lower doses. Microbiological risks must also be
studied in focused way. Research should focus on those organisms that are most
likely to increase in incidence as effectiveness of disinfection decreases. Thus
work would not be directed at those organisms not susceptible to disinfection at
all (e.g. Cryptosporidium), but on those that are marginally controlled by
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disinfection (e.g. Giardia)
11. ORD does not seem to recognize the very substantial trade-offs there are
between human health and ecological concerns this issue raises. It is very
important that the coordinator of this program keep in contact with the
regulated community, which is also primarily in the public sector.
GROUND WATER ISSUE STRATEGY
1. It is very difficult to defend this issue on a risk basis except perhaps as a
microbiological problem. Ground water pollution contributes a very small
component to nationally weighted health risks in drinking water compared to
chemicals introduced in treatment and distribution of the water. This has to be
true in the context of indoor air pollution as well.
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