A REPORT
CRITIQUE
OF THE
BIOLOGICAL AND CLIMATE EFFECTS RESEARCH
(BACER)
EFFECTS OF STRATOSPHERIC MODIFICATION
BY AN
AD HOC STUDY GROUP
TO THE
ECOLOGY ADVISORY COMMITTEE
AND THE
ENVIRONMENTAL HEALTH ADVISORY COMMITTEE
SCIENCE ADVISORY BOARD
U.S. ENVIRONMENTAL PROTECTION AGENCY
JULY 20, 1977

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EPA NOTICE
This report has been written as a part of the activities of
the Agency Science Advisory Board, a public advisory group
providing extramural scientific information to the Administrator
and other officials of the Environmental Protection Agency. The
Board is structured to provide a balanced expert assessment of
scientific matters related to problems facing the Agency. This
report has not been reviewed for approval by the Agency and hence
its contents do not represent the views and policies of the
Environmental Protection Agency, nor does mention of trade names
or commercial products constitute endorsement or recommendation
for use.

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UNIVERSITY OF CALIFORNIA, IRVINE
BERKELEY • DAVIS • IHVINE • LOS ANCELES • RIVERSIDE • SAN DIECO • SAN FRANCISCO
SANTA BARBARA • SANTA CRUZ
CALIFORNIA COLLEGE OF MEDICINE
DEPARTMENT OF COMMUNITY AND
ENVIRONMENTAL MEDICINE
IRVINE, CALIFORNIA 92717
July 20, 1977
Dr. Norton Nelson
Chairman
Environmental Health Advisory Committee
Institute for Environmental Medicine
New York University Medical Center
550 First Avenue
New York, New York 10016
Dr. Gordon H. Orians
Chairman
Ecology Advisory Committee
Institute for Environmental Studies
University of Washington
Seattle, Washington 98105
Dear Doctors Nelson and Orians:
I am pleased to transmit, herewith, the report of the Ad Hoc
Study Group to critique the document, Biological and Climate
Effects Research (BACER)--Effects of Stratospheric Modification.
The Study Group has attempted to address itself to the issues
contained in your letter of charge of March 4, 1977. I believe
it addresses the issues as objectively and comprehensively as
was possible considering the lack of specifics and details
contained in the document.
The Study Group hopes that this report will be helpful. I
would be glad to make myself available to you to clarify any aspect
of this critique.
James H. Sterner, M.D.
Clinical Professor of Occupational
Medicine and Industrial Health Care
ii

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BIOLOGICAL AND CLIMATE EFFECTS RESEARCH
(RACER)
EFFECTS OF STRATOSPHERIC MODIFICATION
AD HOC STUDY GROUP
Dr. James H. Sterner, Chairman
Clinical Professor of Occupational Medicine
College of Medicine
University of California, Irvine
Dr. Sidney W. Benson
Professor
Department of Chemistry
University of Southern California
Dr. John L. Buckley
Whitney Point, New York
*Dr. Keith McCree
Program Manager
Advanced Energy and Resources
Research and Technology
National Science Foundation
Dr. Warren P. Porter
Professor of Zoology
University of Wisconsin, Madison
Dr. Ruth A. Reck
Senior Research Chemist
Research Laboratories
General Motors Corporation
Dr. Richard B. Setlow
Senior Biophysicist
Brookhaven National Laboratory
Dr. Raymond R. Suskind
Director
Department of Environmental Health
University of Cincinnati
* * * * *
Dr. J Frances Allen, Staff Officer, Science Advisory Board
*On leave from College of Agriculture
Texas A§M University, Bryan, Texas
iii

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Preface
A letter of November 19, 1976, (Appendix A) from Dr. Wilson
K. Talley, Assistant Administrator for Research and Development,
to Dr. Emil M. Mrak, Chairman of the Executive Committee of the
Science Advisory Board, points out that EPA has been assigned the
role of lead Agency for the Federal interagency research program
on the biological and climatic effects of stratospheric ozone
reduction. This program is based on multi-year plans developed by
ad hoc interagency Technical Task Groups. His letter requests the
Science Advisory Board to review the long-tern plans and the set
of objectives that have been identified as being critical and hence
studies selected for funding under the short term program--$4 million
during Fiscal Year 1977.
In response to this request the Board's Executive Committee at
its meeting January 4-5, 1977, assigned the responsibility for
critiquing this material jointly to the Ecology Advisory Committee
and the Environmental Health Advisory Committee.
In response to this assignment the Chairman of the Ecology
Advisory Canmittee and the Chairman of the Environmental Health
Advisory Committee established an Ad Hoc Study Group to evaluate
the document, Biological and Climate Effects Research (BACER)--
Effects of Stratospheric Modification" In a letter of March 4,
1977, (Appendix B) Dr. Orians, Chairman of the Ecology Advisory
Committee, and Dr. Nelson, Chaiiman of the Environmental Health
Advisory Committee, addressed to Dr. James H. Sterner, Chairman
of the Ad Hoc Study Group, directed the Ad Hoc Study Group to
critique the material in two contexts, as follows:
... whether major errors of omission
or commission can be seen in the
short-tern program, whose tasks have
been selected primarily to reduce
ranges of uncertainties or to identify
potential problem areas where knowledge
presently is virtually non-existent.
... assuming approval of the long-term
program, a more measured assessment of
its adequacy to provide the infomiation
required of regulatory decision-makers,
the lack of which currently makes it
difficult to meaningfully forecast the
impacts of stratospheric ozone depletion,
is needed.
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The Ad Hoc Study Group's report will be presented to the Ecology
Advisory Committee and to the Environmental Health Advisory Committee
for appropriate action.
The Study Group held its first meeting April 6 and 7, 1977.
Presentations were made by Mr. George Wirth, Chairman of the
Chlorofluorocarbon Work Group, Office of Toxic Substances, and
by Dr. Herbert Wiser, Director of the BACER Program. (See Appendix
C for list of attendees.) The Study Group held a working session
on May 19, 1977, to consider the draft critique and preparation of
the final report.
This report will include general conments on the overall
program plans and then consider in more detail the sections of
the document.
v

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TABLE OF CONTENTS
Page
Preface	iv
I. INTRODUCTION		1
II. COMMENTARY ON OVERALL PROGRAM		2
III. COMMENTS ON INDIVIDUAL SECTIONS		4
A.	Climate Change and Monitoring of UV		4
B.	Biological (Non-Human) Research 		7
1.	Terrestrial Plants 		7
2.	Aquatic and Terrestrial Animals	10
C.	Human Health Effects Research	14
D.	Special Instrumentation	18
E.	Program Management	19
F.	Training	20
IV. APPENDICES
A.	Letter of November 19, 1976, from Dr. Wilson K. Talley
to Dr. Emil Mrak
B.	Letter of March 4, 1977, from Dr. Gordon H. Orians and
Dr. Norton Nelson to Dr. James H. Sterner
C.	Names of Attendees at the April 6-7, 1977
meeting of the Ad Hoc Study Group
D.	Reference Materials and Resources
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I. INTRODUCTION
Depletion of ozone in the stratosphere is a future and long-
range problem. Neither the research nor the commitment to it can
be a short range one as it has been up to now. The general nature
of the problem has been known since 1971. Since then the uncer-
tainties in the physical and chemical parameters have been reduced
appreciably, but the uncertainties in the biological ones are still
uncomfortably large. We need long-range and up-dated predictions
for regulatory purposes. To make good predictions we need not only
research over a number of years but a viable basic research effort
to identify new parameters for consideration or new procedures to
solve old problems and for the early identification of unsuspected
new ones.
It is important to emphasize that no one group is wise enough
to foresee the future uncertainties and possibilities related to
ozone depletion. What is needed is continuous surveillance of the
problem by knowledgeable photobiologists and climatologists, not
only deliberately but indirectly via basic research; for example,
four years ago no one would have suspected that visible light
would ameliorate the effects of UV radiation on people. Now as a
result of experiments of human cells in culture this amelioration
is recognized as a good possibility.
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II. COMMENTARY ON OVERALL PROGRAM
The Study Group is concerned that the Agency, in the process
of program development, may have failed to utilize to the extent
desirable the talent and knowledge of photobiologists and other
scientists actively working in the field of biological and climate
effects research. For example, within the Federal Government,
there are competent scientists in the Department of Interior,
U.S. Fish and Wildlife Service who are well equipped to conduct
or oversee extramural research on non-human biological effects
especially related to wild birds, mammals, and aquatic organisms.
Yet there is no evidence that they were involved in planning the
RACER Program. Furthermore, the Rosters of the Interagency Task
Groups consist almost entirely of Government representatives, and
consequently failed to include much of the best scientific exper-
tise on the subject. Although the Task Groups may have called on
outside consultants for advice, it appears to the Study Group that
this advice was not adequately followed in laying out the written
program. While the Study Group recognizes the potential self-
interests inherent in participation in planning by the relatively
small comnunity of scientists working in the area of photobiology,
such potential self-interest also exists for the Roster members
in so far as they represent agencies that use funds for inhouse
research. It seems probable that seme individuals could be found
who are not likely to be recipients of funds under the program,
but who are deeply knowledgeable and whose wisdom of insight would
strengthen the program planning. Finally, while the Study Group
recognizes the need to include scientist-administrators on the
Task Groups so as to assure adequate commitment of their agencies
to participation in the program, it also believes that working
scientists active in the research area within the agencies would
make valuable contributions to the program plan.
The Study Group commends the RACER Staff on the design of the
research plan for FY 1977 and 1978. There are few, if any, tasks
the Study Group believes should be eliminated. The document and
briefing provided to the Study Group described the aspirations of
EPA, but are insufficient to permit the Study Group to judge the
likelihood that the research objectives will be achieved. Several
comments are directed to this point: specifically the comments on
importance of exposure sources in biological experiments, exposure
estimation in epidemiological studies, and exposure estimation in
field studies. The Study Group would need approximately an order-
of-magnitude more data to evaluate critically the individual objec-
tives and to see if these objectives can be accomplished within
three years. (Some of the objectives [Section III-C] obviously
cannot be accomplished within this time.)
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The Study Group is much concerned that there is so little
attention devoted to climatic change--(but recognizes that this
work may be included in NQAA's studies). Climatic change may
well have the most far-reaching effects of stratospheric change--
some efforts toward predicting changes in biological productivity,
attendant upon shifting temperature, are essential. Even small
changes in productivity could substantially alter the food supply
of the world. In a world already unable to adequately feed itself,
lessened productivity could be catastrophic, whereas increased
productivity could be an enormous boon.
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III. COMMENTS ON INDIVIDUAL SECTIONS
A. Climate Change and Monitoring of UV
Attention is called to the Objectives listed on page 4 of
the FY 1978 Interagency Budget Request.
Objective 1: 'Develop understanding of changes
of global mean and variance of
climate variables (the statistical
description of UV, visible and
infrared radiation, temperature,
precipitation and winds near the
surface of the earth) resulting
or related to changes in the
stratosphere."
Current information is not adequate for statistically
relating stratospheric and tropospheric data. There-
fore, such correlation does not merit a top-priority
goal. Since there is currently no understanding of
the mechanism involved, effort in this area would not
be productive at the present time. There is little
scientific basis for correlating one parameter with 1,2/
another, since in general circulation modeling studies
drastically different stratospheric changes appear
with amazingly similar tropospheric changes. On the
other hand, it is much more important to look for mathe-
matical instabilities, if any, which might relate strato-
spheric and tropospheric changes.
Objective 2: "Develop understanding of changes
of regional climate variables (UV
and visible radiation intensities,
temperature, precipitation and
winds) with changes in global-
mean changes."
Understanding changes in regional climate is important
mainly to the extent that the changes can be related
to global changes. The relationship of global to
regional changes merits emphasis.
1/ Syukuro Manabe and Richard T. Wetherald, "The Effects of Doubling
the COo Concentration on the Climate of a General Circulation
Model, J. Atmos. Sci. 32: 3-15 (1975).
2/ Richard T. Wetherald and Syukuro Manabe, "The Effects of Changing
the Solar Constant on the Climate of a General Circulation Model,"
J. Atmos. Sci. 32: 2044-2059 (1975).
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Objective 3: "Monitor ultraviolet (principally UF-B)
radiation spectroradiometrically with
narrow band resolution over a range from
280 to 320 nm in several locations of
different latitudes in the world."
This objective should have been 290 - 350 nm with a band
pass of 5 to 10 ran because a) there is not sufficient
energy < 290 nm to make it worth measuring and b) smaller
band passes are not needed either for biological experiments,
or for reconstructing the sun's spectrum at the earth's
surface.
Objective 4: "Monitor ultraviolet (principally UV-B)
radiation by single observation of
erythemally weighted radiation, repeated
at half hour intervals during daylight
hours, at principal experimental locations.
(This includes calibration, instruments,
observations, data recording and reduction,
analysis and publication of results.)"
It is important that this Objective be carried out in
locations similar to the one used for Objective 3 and
at locations used in epidemiological surveys.
Objective 5: "Develop missing elements between the
National Stratospheric Research Plan
results and BACER."
Climate changes due to the chlorofluorocarbons (CFC) may
arise either from a direct heating in the troposphere by
the greenhouse effect or from an indirect mechanism which
relates stratospheric ozone changes with tropospheric CFC
concentrations. The impact of CFC's on the earth's
climate system must be approached as a global problem but
details relating to man's activities and the assessment
of consequences must be related to local and regional
changes. Combined with any direct effects of CFC's are
the related changes in the humidity and hydrological cycle
which can aggravate the impact on agriculture such as
changes in local precipitation.
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For FY 1978 and beyond it is noted that the climate study-
objectives do not include the following, listed in priority.
1.	Introduction of the direct effect of chlorofluorocarbons in
the available general circulation models of the atmosphere (while
these are highly simplified and imperfect models, they are still
the best available means of estimating the climatic consequences).
Determination of the changes in the hydrological cycle and the
regional impact on agriculture; and the feedback and initial
effects of oceans, surface albedo, clouds, and aerosols would
produce useful information.
2.	Development of a statistical model to describe the present
global atmosphere and its recent history using available terres-
trial and satellite data so that short-term statistical fluctu-
ations would be resolved from longer trends. Using the available
general circulation models to determine the relative climatic
importance of different observed and predicted parameter changes
and determining at what latitudes and in what regions climatic
impacts are/will be greatest would be of value.
3.	Looking for triggering mechanisms (instabilities) relating
stratospheric changes with tropospheric climate changes.
4.	Determining how global parameter changes can affect regional
and local climate.
Adopting accelerated programs along the lines of (1) and (2) is
necessary.
Whereas it is desirable to continue to compute the climatic
consequences of changes in the major radiation absorbing atmospheric
constituents it would also be highly beneficial to add the lesser
effects brought about by the addition of chlorofluorocarbons and
airborne particles (aerosols). This scientific information would
lend support to regulatory decisions long before any climatic effect
is observed. Much of the fundamental data to be used in general
circulation models is now in existence and it is only necessary for
those who use the advanced circulation models to be encouraged
(through funding) to add these minor constituents and to report their
results in the open scientific literature where the information can
be scrutinized by the scientific community. This probably will not
be done without a formal request.
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B. Biological (Non-Human) Research
1. Terrestrial Plants
So far as is known, plants do not get cancer, but they
probably do get damaged by ultraviolet radiation. In the
field the damage may be analogous to sunburn in humans.
Thus the objective of the plant sciences section of the
BACER program is to find out whether or not plants get
"sunburned," and if so, at what rate, and how much greater
this rate might be if the national flux of UV radiation
were to be increased by a few percent.
By analogy with sunburn in humans, where protective
mechanisms such as increase in pigments or skin thickness
plays an important role, it seems likely that plants will
have several defense mechanisms, and that some plants will
be more affected than others. Very little is known at
present about the mechanisms of either the damage or the
defense against it.
The public reaction to a slight increase in the rate of
"sunburning" of plants is likely to be negligible in comparison
with the reactions of an increase in the incidence of cancer in
humans, however slight. The economic implications are unknown,
because the pathology of the subject is still in its infancy.
Until the pathology is much further developed (and this will 3/
take "more than a few years," according to the N.A.S. Committee),
it will be difficult to assess the economic impact of a slight
increase in the rate of damage by solar UV.
As an exploratory program to establish a pathology of UV
in plants, the BACER program appears to be well designed. It. .
follows closely the suggestions made by the N.A.S. Committee.—
In the three years of proposed funding, it is unlikely to
develop beyond the exploratory phase, i.e., it should be possible,
by the end of that period, to produce a list of typical symptoms
(if any) and to suggest some reasons for them.
A critical need exists for close collaboration between
physicists and engineers who design equipment and biologists
who design experiments. The program director should maintain
this collaboration at all costs. He should ensure that
biological experiments in which control of the physical instru-
mentation is not of sufficiently high standard are eliminated
from the program.
3/ Halocarbons: Environmental Effects of Chlorofluoromethane Release,
Nat. Acad. Sci., Washington, D.C. 1976, p. 15.
4/ Ibid, p. 25.
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In reference to specific objectives on page 5 of the FY 1978
Interagency Budget Request, the following points should be noted.
Objective 1: "Determine amounts (dose and dose-
rate) of UV-B radiation reaching
plant parts (e.g., leaves, meristems,
reproductive organs) through plant
canopies."
The feasibility of doing this with plant canopies is
questioned.
Objective 2: "Determine the potential for effects
of UV-B on soil and leaf bacteria
(decomposers and remineralizers) and
consequent effects on plants."
The Study Group concluded that this objective is
unrealistic since UV radiation does not penetrate
the surface of the soil.
Objective 3: "Determine whole plant response to UV-B
radiation by selected agricultural and
natural plants (i.e., effects on photo-
synthesis, productivity, yield, repro-
ductive capacity, nitrogen fixation
ability, etc.) as functions of stage of
development, dose, dose-rate, and wave
length with attention to possible
synergisms."
The Group concluded that the determination of whole
plant responses is important, but it is unrealistic
to do this with monochromatic radiation in the time
available. The experiments should be done with
polychromatic radiation, using solar simulators.
Objective 4: "Determine simple predictors at the
molecular, cellular and tissue levels
(e.g., cuticle thickness, pigmentation
and repair capacity, organelle changes,
etc.) for whole plant sensitivity so
as to allow generalization to other
plants not feasibly studied."
The development of simple predictors is very important
and this experiment is a good one.
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Objective 5: "Determine effects of UV-B on
competitive interactions between
different plant species and
between plant hosts and pathogens/
pests."
The Study Group questions that this objective can
be attained in three years.
Objective 6: "Supplement existing studies on
temperature, precipitation, and
wind on plants."
Objective 7: "Conduct modeling studies of effects
on yield of climatic changes (UV-B
temperature, precipitation, wind)."
Objectives 5, 6, and 7 should receive less emphasis
as indicated by the budget figures presented.
It is not clear that Objective 7 can be achieved
with any reliable predictability.
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2. Aquatic and Terrestrial Animals
a. Effects of Increased UV Due
to Stratospheric Modification
The effects on natural populations of animals of changes in
UV-B radiation due to stratosphere manipulation is uncertain
because there are no dose response curves for possible biological
effects, no knowledge of how much additional UV-B radiation repair
mechanisms can withstand, no way to predict genetic adaptability
of organisms, and no good present model of climate effects of
stratosphere manipulation or of climate effects on population
dynamics. However, substantial damage caused by gradual increase
in UV-B radiation seems unlikely because of 1) animal pigments,
e.g., melanin, which are very efficient light absorbers, 2) repair
mechanisms and 3) potential genetic adaptation. There is a major
gap in our knowledge of the capacity for genetic change by popula-
tions of animals to accommodate increased UV-B radiation. It
seems likely that if there are effects on animals of changes in
UV-B or climate, it will be in highly inbred strains of domestic
animals and in human populations where there has been little
environmentally related genetic selection.
The Study Group feels that much of the proposed BACER budget
for animal research has much too high a priority. Findings for
each BACER proposal objective in "Animals Including Insects"
are listed below.
Objective 1: "Survey literature for potential
detrimental effects of UV-B on
animals other than those already
identified as susceptible."
The literature survey done in the Climatic Impact
Assessment Program (CIAP) monographs seems exhaustive
already. Another such survey does not seem justified.
Objective 2: "Determine the extent of potential
losses among farm animals resulting
from increased UV-B (cancer eye in
herefords, pink eye exacerbation in
cattle and sheep, sunburn in swine,
etc.)."
Implementation of BACER proposals concerning domestic
animals is questionable, since exposure problems could
be handled in the short-term at least for intensively
managed animals by such means as providing shade in the
form of covered open shelters or trees. In the longer-
term hybridizing breeds with those containing more pig-
ment would result not only in more photoprotection, but
also in better productivity as well, since much of
animal husbandry has not yet taken advantage of hybrid
vigor as have plant breeders.
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Objective 3: "Determine the potential effects
on birds' eyes (photokeratitis)
which may interfere with competi-
tive ability and hence survival."
How will such experiments be done? The possible effects
of photokeratitis in wild birds does not at present seem
a likely possibility, since thresholds for rabbits,
monkeys, and man as established by Pitts and Tredici, 1971,1/
(1) show a threshold value at 280 nm two orders-of-magnitude
higher than the integrated solar energy available during the
day at 290-295 nm in midsummer at the latitude of the Canal
Zone. Furthermore, since short wave ultraviolet is diffuse,
a laterally oriented eye of a bird would usually be inte-
grating ultraviolet over only the upper half of the hemis-
phere it "sees," thereby reducing the energy incident on
the eye to one half that measured by a surface oriented
parallel to the ground.
Objective 4: "Determine effects of UV-B on physiology
and behavior (e.g., development, pollina-
tion capacity, pheromone response, navi-
gation ability, etc.) of beneficial and
non-beneficial insects exposed to solar
radiation."
It does not seem likely that insects will be affected
substantially by increased UV radiation, since they
are shielded from it during development. They are
heavily pigmented, and with more ultraviolet they
might be able to navigate even better. Not only is
there no evidence that this is an important effect,
but theoretically a 10% change in UV-B is unimportant
in insect behavior.
The following comments refer to the Objectives listed under Aquatic
Organisms on pages 7-8 of the FY 1978 Interagency Budget Request.
Objective 1: "Determine the responses to UV-B of
the basic food organisms, phytoplankton
and zooplankton (i.e., effects on photo-
synthesis, productivity, nitrogen fixing
ability, survival, etc.) as functions of
dose, dose-rate, and wavelength."
The Study Group finds this objective to be the most potentially
informative of all the proposed animal experiments.
5/ D.C. Pitts and T.J. Tredici, "The Effects of Ultraviolet on the Eye,"
Am. Int. Hyg. Assoc., J., 32: 235-246 (1971).
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Objective 2: "Determine the effects of UV-B on
survival and development of eggs
and larvae of commercially important
species as functions of dose, dose-
rate, and wavelength."
Unless solar simulators are also used in carrying out
the research specified in Objectives 1 and 2, the
objectives will not be achieved.
Objective 3: "Determine simple predictors for the
responses of phytoplankton, zooplankton,
and eggs and larvae of commercially
important species to allow generaliza-
tion to organisms not feasibly studied."
This objective does not appear to be feasible, since
genetic responses are unknown. Even if this should
be feasible, it would take many years to achieve.
Objective 4: 'Determine effects of UV-B on competitive
interactions between different phyto-
planlcton, zooplankton and larval species
with attention to detrimental community
structure shifts."
This cannot be achieved in two years, if ever.
Objective 5: "Determine the potential effects of
enhanced UV-B on the capacity of
fresh water ecosystems to purify
contaminated water."
It does not seem likely that UV-B will have a substantial
impact here given the capacity for genetic shift in
microorganisms.
Objective 6: "Incorporate UV-B effects into models of
ecosystem interactions, where feasible,
to develop a generalized assessment of
the impact of climatic change."
Since the information needed to achieve Objective 6 will
require many years to accumulate, the Study Group finds
that this objective merits only a low priority.
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Objective 7: "Determine penetration of narrow
wavebands of UV-B into various
natural waters with attention to
absorption and scattering by biota.
Correlate UV-B penetration with
existing data on visible light
penetration through biota-containing
waters to allow generalization to
global waters.
Does the National Oceanic and Atmospheric Administration
know that it is to correlate its data with those data
obtained from Objectives One through Six?
b. Climate Effects of Stratosphere Modification
It is apparent that there is a major research gap in coupling
macroclimate-microclimate-animal thermal and mass balances. Such
coupling is needed for predictability of climate effects on activity
patterns, e.g., timing of pollination and predation timing, and for
assessing the effects on food and water requirements for maintenance,
growth, and reproduction of key food (chain) animals.
It is observed that in the short-term no provisions have been
made in BACER to explore mechanisms for reducing exposure of long-
lived domestic animals, e.g., shade or shelter or modified breeding
programs to introduce more pigment into sensitive breeds. In the
long-teim, no evidence is presented that two important areas of
research will be explored. These areas include:
... supporting genetic research directed
toward predicting rates of phenotypic
change in wild populations of animals.
... supporting research into climate effects
on animal thermal and mass balances that would
affect activity patterns and food and water
requirements, thereby affecting population
dynamics and community ecology.
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C. Human Health Effects Research
The acquisition of critical data about health effects is a major
function of a program designed to document regulatory action. It must
be understood, however, that the state of the science is such that
most of the objectives in the health effects area cannot be attained
in a period of two years. It is anticipated that important research
efforts will be started and yield seme significant information in that
period; new methods and instrumentation may be designed and tested but
one cannot anticipate major solutions to be forthcoming in the currently
allotted time. This is particularly true in the most critical areas--
for example, the study of health effects in defined populations through
prospective epidemiological studies. If these are properly designed
they will require up to 10 years to yield this desired information, but
they must be started now.
The objectives as they are now stated may, only with careful
interpretations and explanations, cover the important gaps in know-
ledge and research. Such interpretations and indicated directions
would make than acceptable.
Epidemiologic studies (see pages 15 and 16), it is agreed, should
receive the highest priority. It must be understood, however, that
two types (referred to in Objectives 1 and 2) are needed:
1)	retrospective studies for which data from the already
existing sources may be both incomplete and of limited
accuracy,
2)	prospective studies which may provide a rich yield of
good infoimation if the protocols are properly designed
and carried out.
These efforts require not only skill of epidemiologists but require
the expertise of clinical investigators with knowledge and experience
in the field of human organ system reactions to UV-B in a variety of
settings. This knowledge includes genetic, cultural, and environmental
factors that influence UVR action on skin and an understanding of the
cutaneous and ocular patterns of reactions. Scholars of cutaneous and
ophthalmologic biology are the types of investigators needed here. In
the epidemiologic and clinical study programs, the assessment of frequency
and severity of neoplastic reactions such as epidermal cancer, actinic
precancerous changes as well as melanoma should be underscored. Consider-
able emphasis should be given to the non-neoplastic reactions as described
under Objective 3.
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The following comments relate to specific objectives.
Objective 1: "Obtain improved epidemiological
data to enable a more precise
estimate of the potential increase
in melanoma and non-melanoma skin
cancer resulting from ozone
reduction/increased UV-B."
o The present experimental design utilizes only two
southern cities. Neither of these cities is included
in the non-melanoma data of the Third National Cancer
Survey (TNCS). Hence, most of the epidemiological
data to be collected will be from regions of lower
ultraviolet flux and lower cancer incidence. It is
doubtful whether the data will give appropriate infor-
mation for improving the calculation on the change in
skin cancer with ultraviolet radiation nor will it
give information about the increase in incidence as a
function of time.
o No data will be obtained from areas within the State
of Texas. TNCS obtained data from Dallas and a survey
from the M. D. Anderson Hospital obtained data from
many other localities within the State. Thus, there
has been a good beginning in Texas but the beginning
is not followed up.
o There has been no provision for using dosimeters on
people. Hence, there will be no clear-cut way of
estimating how much, if any, of the latitude depen-
dence of skin cancer is a result of ultraviolet
levels and how much is a result of life style para-
meters. Unless such data are obtained we are no
better off than using the data obtained in CIAP.
0 There is no provision for measuring the spectral
irradiances in the cities used in the survey,
although there is provision for making measure-
ments with the Robertson-Berger meters. However,
these meters do not necessarily measure the proper
spectral distribution and it would be futile to do
extensive epidemiological work without an equiva-
lent amount of effort going into the spectral
properties of sunlight in the areas studied.
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0 All of the epidemiological surveying and analysis
does not have to be done by the National Cancer
Institute. EPA should be able to grant monies to
non-federal academic units for this purpose with-
out going through the National Cancer Institute
(NCI). In the past, surveys other than NCI's
within the United States and elsewhere have
supplied information that has been of great use
in analyzing both melanoma and non-melanoma
problems.
Objective 2: "For the identification of the most
susceptible subpopulation, determine
from follow-up studies the influence
of other factors on skin cancer
induction (e.g., life style, occu-
pation, skin type [complexion and/or
experimentally determined erythema
response] ethnicity, etc.). Also,
determine the extent of recurrence
and subsequent cases, cause of death
(more susceptible to other types of
cancer? less susceptible?) etc."
Refer to page 14 for comment on this objective.
Objective 3: "Examine the potential impact of
increased UV-B on aspects of human
health other than skin cancer,
especially eyes."
It is not clear whether these analyses will be on
new data or on existing data. If on new data,
how will the data be obtained? If on existing
data, what are they?
Such studies require inclusion of a thorough evaluation
of non-neoplastic reactions such as photosensitivity
reactions of the skin and eye including phototoxic as
well as photoallergic reactions. These are now common-
place reactions to one or more chemical agents found in
occupational exposures, in drugs, cosmetics, toilet
goods, household materials, foods, etc. Some of these
have action spectra in UV-B and/or UV-A ranges. Such
studies may also provide a model for detecting human
effects using UVR exposure of short duration.
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In the epidemiological and clinical study programs,
determination of the changes in frequency and severity
of non-neoplastic reactions associated with moderate
and long-term exposure and/or genetic considerations
is essential. These include premature aging, pigment
damage, solar elastosis and degeneration, actinic
cheilitis, poikiloderma, skin wrinkling, scarring,
and atrophy. To this list of nonneoplastic reactions
which require assessment are the disease states that
increase vulnerability to UV-B and/or UV-A: solar
urticaria, polymorphous light eruption, lupus erythe-
matosus, poikiloderma of Civatte, the genetically
determined problem associated with faulty DNA repair--
xeroderma pigmentosum--and many others.
Objective 4: "Obtain information at the molecular,
cellular and tissue levels, regarding
the mechanisms of induction of skin
cancer, skin damage (aging) and eye
damage by solar UV, as functions of
dose, dose rate, and wavelength, with
attention to synergisms with other
factors (wavelength, temperature)
The thrust of research about mechanisms of UV-B damage
on cells and tissues is covered in Objective 4. It is
urgent that the synergistic or enhancing influence of
chemical agents be carefully examined in man. The
common source of agents listed above are important
since new materials with potential for photochemical
injury are introduced with some frequency. A more
important reason for studying combined chemical-UVR
effects in man and experimental animals is the energy
crisis that will result in the more extensive use of
fossil fuels: coal, shale oil products, liquid and
gaseous fuels frcm coal that may involve effluences
containing polynucleararomatic compounds (PNA's) and
other photosensitizing compounds. Many PNA's have
phototoxic properties.
Finally, in order to provide critical information
regarding dose-response relationships through
epidemiological studies, it will be necessary to
design and develop a simple and inexpensive UV-B/
UV-A exposure badge (Section III D, Special Instru-
mentation) .
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D. Special Instrumentation
Since it is technically very difficult to simulate a small increase
in the natural flux of UV radiation, it is essential to have close
collaboration between the engineers and physicists who design the equip-
ment and the biologists who design the experiments. The absence of
this close collaboration in the past has led to a great deal of poor
quality research in this field. The fact that such collaboration is
built into the BACER program augurs well for the scientific quality of
the expected results.
The program director should maintain this collaboration at all costs.
He should ensure that biological experiments in which control of the
physical instrumentation is not of sufficiently high standard are
eliminated from the program. A vigorous program of development of new
instruments and standards should be maintained throughout the program.
There is a great need for adequate solar simulators for both
laboratory and field experiments. There is also a strong need for
the design and development of simple and inexpensive UV-A/UV-B
badge type dosimeters that can be used to determine the effects of
differences in the actual exposure conditions for human subjects.
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E. Program Management
The elements of Program Management seem appropriate to the
proposed broad frame of the FY 1978 BACER plan. It is assumed
that this will be revised in accordance with the scope of the
program that is adopted.
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F. Training
Although the Study Group has been informed that the training
aspect of BACER is unacceptable for funding, the Group wishes to
make two points. Organizing workshops to be held in association
(coincident or contiguous) with several national scientific meet-
ings could be most rewarding. The use of research grants rather
than traineeships to train new investigators will work only to
the extent universities participate in research carried out in
BACER.
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APPENDIX A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O C 20460
NOV 1$ 19/6
OFFICE OF
RESEARCH ANO DEVELOPMENT
Dr. Emil M. Mrak
Chancellor Emeritus
University House
University of California
Davis, California 95616
Dear Emil:
As you may recall, there was a brief discussion, during the October 14
meeting of the SAB Executive Committee, of planned research into the effects
caused by a reduction in stratospheric ozone. EPA has been assigned the
role of lead Agency for the short-term (through Fiscal Year 1977) Federal
interagency research program on the biological and climatic effects of
stratospheric ozone reduction. This program, which is being funded at $4 million
during Fiscal Year 1977, is based on multi-year plans developed by ad hoc
interagency Technical Task Groups.
Transmitted with this letter for your review are these long-term plans,
along with the detailed set of objectives which we have identified as being
most critical and hence studies selected for funding under the short-term
program. I would like to request that the Science Advisory Board critique
this material in wo contexts, as follows:
•	First, we need to know as soon as possible whether major errors of
omission or commission can be seen in the short-term program, whose
tasks have been selected primarily to reduce ranges of uncertainties
or to identify potential problem areas where knowledge presently is
virtually non-existent.
•	Second, assuming approval of the long-term program, we need a more
measured assessment of its adequacy to provide the information required
of regulatory decision-makers, the lack of which currently makes it
difficult to meaningfully forecast the impacts of stratospheric
ozone depletion.
Dr. Herbert L. Wiser, Principal Physical Science Advisor in my office,
will be the source of any information which you may need to conduct this review.
Sincerely
ey
Assi	_ rator
for Research and Development

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APPENDIX B
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
%PRa^	WASHINGTON, D C 20460
March 4, 1977
OFFICE OF THE
ADMINISTRATOR
Dr. James H. Sterner
Chairman
Ad Hoc Study Group on Effects
of Stratospheric Modification
College of Medicine
University of California, Irvine
Irvine, California 92717
Dear Dr. Sterner:
The Environmental Protection Agency has been assigned the role of
lead agency for the short-terni (Fiscal Year 1977) Federal interagency
research program on the biological and climate effects of stratospheric
ozone reduction. This program, which is being funded at $4 million
during Fiscal Year 1977, is based on multi-year plans developed by ad
hoc interagency Technical Task Groups.
In response to an Agency request for Science Advisory Board
review, the Executive Committee at its January 4-5, 1977, meeting
assigned the critique of the document, Biological and Climate Effects
Research (BACER)--Effects of Stratospheric Modification jointly to
the Ecology Advisory Committee and the Environmental Health Advisory
Committee. This document includes long-term plans and the set of
objectives that have been identified as being most critical, and
hence studies selected for funding under the short-term program.
It is requested that the Ad Hoc Study Group critique this material
in two contexts, as follows:
First, whether major errors of omission or
commission can be seen in the short-term
program, whose tasks have been selected
primarily to reduce ranges of uncertainties
or to identify potential problem areas where
knowledge presently is virtually non-existent.

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Second, assuming approval of the long-term
program, a more measured assessment of its
adequacy to provide the information required
of regulatory decision-makers, the lack of
which currently makes it difficult to meaning-
fully forecast the impacts of stratospheric
ozone depletion, is needed.
The M Hoc Group's report will be presented to the Ecology
Advisory Conmittee and to the Environmental Health Advisory
Committee for appropriate actions. In view of the involvement
of these Committees it is urged that the Ad Hoc Study Group
complete its report by May 20, 1977, to assure a timely response
to the Agency's request.
Sincerely

Gordon H. Orians
Chairman
Ecology Advisory Committee
NOx cuii ncisuit
Chairman
Environmental Health
Advisory Committee

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APPENDIX C
ECOLOGY ADVISORY COMMITTEE--ENVIRONMENTAL HEALTH ADVISORY COMMITTEE
AD HOC STUDY GROUP ON BIOLOGICAL AND CLIMATE EFFECTS RESEARCH (BACER)--
EFFECTS OF STRATOSPHERIC MODIFICATION
Attendees April 6-7, 1977 Meeting
BACER STAFF
Dr. E. C. DeFabo
Dr. James R. Hibbs
Mr. Charles Plost
Dr. Louis J. Schoen
Mr. Neal J. Whitney
Dr. Herbert Wiser
OFFICE OF TOXIC SUBSTANCES
Mr. George F. Wirth
SCIENCE ADVISORY BOARD STAFF
Dr. J Frances Allen
Mrs. Beth Bemis
Dr. Joel Fisher
Dr. Alphonse Forziati
Mrs. Ilene Stein

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EP1.2
BACER
US EPA
A Report
Critique Of The Biologi-
cal And Climate Effects
Research (Bacer) Effects,
Of Stratospheric
Modification
EP1. 2
BACER
LIBRARY
U 3 lavtomoMalal Pretention Agaoef
Corvatlis Environmental Reseafch Lab
200 S W 35th Street

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APPENDIX D
Reference Materials and Resources
1.	Department of Health, Education and Welfare, Food and Drug
Administration; Environmental Protection Agency; Consumer
Product Safety Commission. Fully Halogenated Chlorofluro-
alkanes. Proposed Prohibitions and Nature of CPSC Action.
Federal Register, Vol. 42, No. 93, May 13, 1977.
2.	FY 76-77 (Financial) Commitments--RACER Program.
3.	H.R. 783. January 4, 1977. A Bill to authorize and direct
establishment of a coordinated National program relating to
climate and for other purposes.
4.	Interagency Task Force on Inadvertent Modification of the
Stratosphere Other than Flurocarbons. Report, March 1976.
Potential Modifiers of the Stratosphere Other than Fluro-
carbons .
5.	National Academy of Sciences Report, 1976. Halocarbons:
Effects on Stratospheric Ozone.
6.	National Academy of Sciences, 1976. Halocarbons:
Environmental Effects of Chlorofluromethane Release.
7.	National Academy of Sciences Report, September 1976.
Ozone and Other Photochemical Oxidants.
8.	Biometry and Epidemiology Contract Review Committee,
National Cancer Institute (extramural reviewers for NCI
research on BACER).
9.	Biological and Climate Effects Research--Policy Group Roster.
10. Biological and Climate Effects Research--Technical Task Group
Roster.

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