March 17, 2000
EPA-SAB-RSAC-00-007
Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Subject: An SAB Report: Review of the FY2001 Presidential Science and Technology Budget
Request for the Environmental Protection Agency
Dear Ms. Browner:
On February 23 and 24, 2000 the Research Strategies Advisory Committee (RSAC) of the
Science Advisory Board (SAB) met to review the Science and Technology component of the FY2001
Presidential Budget Request for the US Environmental Protection Agency (EPA). As in past years this
report was developed by the entire RSAC in a rapid response fashion before the Congressional hearing
on EPA's Science and Technology budget. RSAC's report was approved by SAB's Executive
Committee during a public meeting on March 8, 2000.
The Committee was pleased to see the Agency has continued to make marked improvements in
the budget and planning process. In particular, the committee commends the initiative taken by the
Agency's Office of Research and Development to build upon the Government Performance and Results
Act (GPRA) framework that has been developed for Agency planning and budget development.
Innovations such as developing an inventory of science activities in the Agency, beginning to construct
an Agency-wide science strategy and developing basic principles for how to do it, piloting a series of
multi-year planning processes and developing futures assessments can significantly improve the science
planning and budgeting process if implemented effectively.
Special concerns were the need for additional scientists and engineers to maintain core
competencies and the observation that programs for which EPA has no statutory authority to regulate
(e.g., indoor air and Naturally Occurring Radioactive Material) receive consistently low budget
priorities despite their potentially high impacts on the environment and public health. Also, long-term
research projects are at special risk because they are terminated or truncated due to cost-cutting
imposed to provide the resources needed to respond to high-priority, short-term needs.
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As part of the review process, the RSAC responded to six charge questions:
a. Can the objectives of the research and development program in ORD and the broader
science and technology programs in EPA be achieved at the resource levels requested?
The Presidential budget request levels were similar to the levels requested in the last two years.
The science and technology activities included in the request were selected using a process similar to
that used in the previous year. This involved a priority-setting process that identifies the highest
environmental risks within each environmental goal established in the EPA Strategic Plan and uses the
sound scientific principles of the risk assessment/risk management framework. The RSAC found the
funding request priorities to be consistent with the environmental goals established in the Agency's
Strategic Plan. However, RSAC is concerned about the impacts of the hiring freeze at EPA which
prevents ORD from hiring postdoctoral fellows and other scientists needed by the Agency to provide
continuity in the research program to meet program needs, and to maintain the core competencies
needed to ensure that EPA has the scientific ability to address emerging environmental issues.
RSAC concurs with the Agency's increased science emphasis on endocrine disrupter
chemicals, epidemiology of paniculate matter, cumulative risks/intermittent exposure, drinking water
Candidate Contaminant List (CCL) pollutants, Resource Conservation and Recovery Act (RCRA)
corrective action, global change assessment, ecosystem research and monitoring, and children's
environmental health. Nonetheless, RSAC reiterates its concerns expressed previously relative to the
adequacy of the overall level of the Science and Technology budget to address ever more complex
environmental issues. Although ORD was not able to share with RSAC its own priorities for research
efforts that would have been proposed for the FY2001 budget had its budget ceiling been higher,
drinking water CCL, tropospheric ozone, RCRA corrective action, endocrine disrupters, ecosystem,
and combustion science are examples of project areas from our members' areas of expertise that we
believe need even more resources. Undoubtedly, other research project areas also have great merit for
immediate funding.
b. Does the budget request reflect priorities identified in the EPA and ORD-Strategic
Plans?
As with recent budget requests, ORD and Program Office Science and Technology budgets
have aligned with the priorities for FY2001, with the Agency and ORD strategic plans, and with the
Agency's Government Performance and Results Act (GPRA) goals. However, RSAC concluded that
the budget for several potentially high risk, high uncertainty and/or high cost areas is not adequate,
including: naturally occurring radioactive material (NORM); indoor air quality; and Non-Aqueous
Phase Liquids (NAPL) remediation technologies. Our overall impression is that the budget is
reasonably consistent with the stated priorities of the strategic plans, but we are concerned that some
important research needs are unfulfilled because they are not given priority in the plans or, in some
cases, do not even appear in those plans.
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c. Does the budget request reflect coordination between ORD and the Program Offices?
The Committee was impressed with the progress made in the past year in heightening the level
of interaction between ORD and Program Offices. Evidence of this effort was provided in a variety of
ways. First, the Scientific Inventory explicitly identifies the science activities of many Program Offices.
Second, a high degree of coordination is evidenced by the explicit coupling of ORD's research
portfolio to specific goals of the program office. Finally, there was the explicit acknowledgment by
some of the program offices that research was an important underpinning of many regulatory actions.
The Agency has further improved the coordination between ORD projects and the needs of the
program offices, and we can see that the program office needs are well integrated into the ORD budget
request. There were good indications of communication and responsiveness of ORD efforts to support
program offices needs. There are also excellent examples of ORD and Program office teams working
together on specific issues, such as in the area of paniculate matter. RSAC recommends that the
Agency continue to expand these joint efforts. In addition, for the first time the Agency has developed
an inventory of all of the science activities underway at the Agency. The inventory is a critical tool for
further coordination of science activities across all offices. Without it effective coordination is not
possible.
d. Does the budget request support a reasonable balance in terms of attention to core
research on multimedia capabilities and issues and to media-specific, problem-driven
topics?
The RSAC concludes that the Office of Research and Development budget request is
appropriately balanced between core research (-44%) and problem-driven research (-56%).
However, the reasons for the distribution of projects between these two categories is not always
obvious. As importantly, the Agency needs to focus on maintaining and securing the core competencies
that it will need to address current and unforeseen future environmental impacts. On this point, the
environmental fellowship and postdoctoral programs are important components that improve the vitality
of the EPA work force.
e. Does the budget request balance attention to near-term and to long-term research and
science and technology issues?
It is difficult to assess the proper balance of long-term and short-term science and technology
issues. Nonetheless, RSAC has a continuing concern about the over-emphasis on shorter-term issues.
The Agency needs to move forward with a multi-year planning process or "road map" that lays out the
steps it plans to take to use science to increase its understanding of environmental impacts and ways to
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prevent them. The road map also needs to show how EPA plans to sequence and integrate the steps it
plans to take to reach these science goals and how reaching them will better inform Agency decision-
making. It will be difficult to properly maintain a sustained focus on these longer-term issues with a
yearly budget planning process as opposed to a multi-year budget planning process. An explicit
approach that incorporates the requirements of longer-term research programs within the short-term
budgetary process needs to be developed. We reiterate our recommendation that the Agency
strengthen its strategic planning processes to fund the longer-term research on critical environmental
issues that transcend the year-to-year budget framework. The Committee believes that emerging issues
need to have ongoing stable support, because EPA is the key Agency responsible for aggressively
watching for critical new environmental threats to human health and to ecosystems.
f How can EPA use or improve upon the Government Performance and Results Act
(GPRA) structure to communicate research plans, priorities, research requirements,
and planned outcomes?
The GPRA-goals structure used by the Agency to organize its FY2001 budget request
provides a clear picture of how the research and science programs relate to EPA's overall mission. The
Committee applauds EPA's efforts to use case studies as pilot efforts to map out research program
plans over many years. We look forward to the expansion of these pilots to include more- and
ultimately all- of the Science and Technology (S&T) budget. As the Agency moves to update its
Strategic Plan, RSAC recommends that it move forward with evaluations of research programs by
environmental outcomes rather than outputs. As noted above, RSAC encourages the Agency to build
on the science inventory and strategic principles currently under development and to move to a multi-
year planning process for research that includes annual performance goals and outcomes on the critical
path of activities for achieving each major environmental objective.
We appreciate the opportunity to review and provide advice on the Science and Technology
component of the FY2001 Presidential Budget for EPA. The Research Strategies Advisory
Committee would be pleased to expand on any of the findings in our report, and we look forward to
your response.
Sincerely,
/signed/ /signed/
Dr. Morton Lippmann, Interim Chair Dr. William Randall Seeker, Chair
Science Advisory Board Research Strategies Advisory Committee
Science Advisory Board
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NOTICE
This report has been written as part of the activities of the Science Advisory Board, a public
advisory group providing extramural scientific information and advice to the Administrator and other
officials of the Environmental Protection Agency. The Board is structured to provide 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, the contents of this report do not necessarily
represent the views and policies of the Environmental Protection Agency, nor of other agencies in the
Executive Branch of the Federal government, nor does mention of trade names or commercial products
constitute a recommendation for use.
Distribution and Availability: This Science Advisory Board report is provided to the EPA
Administrator, senior Agency management, appropriate program staff, interested members of the
public, and is posted on the SAB website (www.epa.gov/sab). Information on its availability is also
provided in the SAB's monthly newsletter (Happenings at the Science Advisory Board). Additional
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copies and further information are available from the SAB Staff.
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ABSTRACT
The Research Strategies Advisory Committee (RSAC) of the Science Advisory Board (SAB)
met February 23 and 24, 2000 to review the Science and Technology portion of the FY2001
Presidential Budget Request for the US Environmental Protection Agency. RSAC felt that EPA has
continued to make marked improvements in the budget and planning process. It found the request to
be appropriately prioritized based on the Agency Strategic Plan, but it had reservations about the
adequacy of the overall funding level given the increasing complexity and cost of environmental
problems. Special concerns were the need for additional scientists and engineers to maintain core
competencies and the observation that programs for which EPA has no statutory authority to regulate
(e.g., indoor air and Naturally Occurring Radioactive Material) receive consistently low budget
priorities despite their potentially high impacts on the environment and public health. Progress has been
made to heighten the level of interaction between the Office of Research and Development (ORD) and
Program Offices. RSAC notes that many of the problems confronting the Agency are not solvable by
the "media-specific" driven research. Thus, it is critical that the Agency maintain its core research
program. The balance between long-term and short-term research needs and science and technology
issues seems appropriate (e.g., in recent years, the Agency has initiated numerous long-term research
efforts in the areas of children's health, global climate change, coastal ecosystem health, and dry
deposition monitoring), but there is still no overall explicit approach to incorporate the requirements of
longer-term research programs within the short-term budgetary process. Research on emerging issues
needs to have ongoing, stable support because EPA is the key Agency responsible for aggressively
watching for critical new environmental threats to human health and to ecosystems. The Government
Performance and Results Act (GRPA) goals structure provides an excellent framework for aligning
research priorities with the resources allocated to perform the work. However, RSAC is concerned
that annual performance goals are still focused on specific products (i.e., reports, data collected, etc)
and recommends that the program goals should focus instead on outcomes, and that the annual
performance goals be related to milestones aimed towards achieving the long-term objectives identified
in the Strategic Plan.
Keywords: GPRA, budget, research, strategic planning
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US ENVIRONMENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
RESEARCH STRATEGIES ADVISORY COMMITTEE (RSAC)
CHAIR
Dr. Wm. Randall Seeker, Senior Vice President, GE Energy & Environmental Research Corp., Irvine,
CA
MEMBERS
Dr. William Adams, Director of Environmental Science, Kennecott Utah Copper Corp., Magna, UT
(Did not attend)
Dr. Stephen L. Brown, Director, R2C2 Risks of Radiation and Chemical Compounds, Oakland, CA
Dr. Richard J. Bull, Senior Staff Scientist, Battelle Pacific Northwest National Laboratory, Richland,
WA
Dr. Theo Colborn, Director, Wildlife and Contaminants Program, World Wildlife Fund, Washington,
DC
Dr. Philip K. Hopke, Professor, Clarkson, University, Potsdam, NY
Dr. Alan W. Maki, Environmental Advisor, ExxonMobil Co, USA, Houston, TX
Dr. Genevieve M. Matanoski, Professor, School of Public Health, Johns Hopkins University,
Baltimore, MD (Did not attend).
Dr. Paulette Middleton, Deputy Director, RAND Environmental Science & Policy Center, Boulder,
CO (Did not attend)
Dr. Maria Morandi, Assistant Professor, University of Texas Health Science Center at Houston,
School of Public Health, Houston, TX
Dr. Ishwar Murarka, Chief Scientist and President, ISH Inc., Cupertino, CA
Dr. William H. Smith, Professor of Forest Biology, Yale University, New Haven, CT
SCIENCE ADVISORY BOARD STAFF
Dr. John "Jack" R. Fowle HI, Designated Federal Officer, Environmental Protection Agency, Science
Advisory Board (1400A), 1200 Pennsylvania, Ave, NW, Washington, DC 20460
IV
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Ms. Wanda R. Fields, Management Assistant, US Environmental Protection Agency, Science Advisory
Board (1400A), 1200 Pennsylvania, Ave, NW, Washington, DC 20460
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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1
2. INTRODUCTION 4
2.1 Background and Schedule 4
2.2 Charge to the Committee 4
2.3 Format of this Report 5
3. RESPONSE TO THE CHARGE 6
3.1 Objectives Versus Resource Levels Requested 6
3.2 Budget and Priorities in Strategic Plans 9
3.3 Coordination between ORD and the Program Offices 10
3.4 Balance Core and Problem-driven 12
3.5 Balance Near-term and Long-term 12
3.6 Improvements to GPRA Structure 13
APPENDIX - ACRONYMNS A-l
VI
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1. EXECUTIVE SUMMARY
On February 23 and 24, 2000, the Research Strategies Advisory Committee (RSAC) of the
Science Advisory Board (SAB) reviewed the FY2001 Presidential Budget Request for the US
Environmental Protection Agency (EPA). The Committee was pleased to see that the Agency has
continued to make marked improvements in the budget and planning process. In particular, the
committee commends the initiative taken by the Agency's Office of Research and Development (ORD)
to build upon the Government Performance and Results Act (GPRA) framework that has been
developed for Agency planning and budget development. Innovations such as developing an inventory
of science activities in the Agency, beginning to construct an Agency-wide science strategy and a set of
principles for how to implement it, piloting a series of multi-year planning processes, and developing
ways to conduct futures assessments are actions that can significantly improve the science planning and
budgeting process if implemented effectively.
As part of the review process, the RSAC responded to six charge questions.
a) Can the objectives of the research and development program in ORD and the broader
science and technology programs in EPA be achieved at the resource levels requested?
RSAC found the funding request to be appropriately prioritized based on the Agency Strategic
Plan, but the Committee continues to have reservations about the adequacy of the overall funding level
given the increasing complexity and cost of environmental problems. An influx of new researchers is
required in order to maintain core competencies that ensure continuity in the research, and to be
prepared to address newly emerging issues. This is particularly important given that ORD has a aging
workforce. It is critical that ORD find some way to bring additional scientists on board to ensure that
EPA's current and future science needs are met.
Areas of emphasis highlighted in the FY 2001 plan identify major science and technology issues
that, with some exceptions, reflect the highest environmental priorities identified by the risk
assessment/risk management framework. ORD was not able to share with RSAC its own priorities for
research efforts that would have been proposed for the FY2001 budget had its budget ceiling been
higher. We suspect that numerous research project areas have potential benefits for EPA's regulatory
and guidance programs that would far outweigh the costs of the research and are therefore excellent
candidates for funding. Example project areas from our members' areas of expertise that we believe to
have such favorable benefit/cost characteristics include tropospheric ozone, RCRA Corrective Action,
endocrine disrupters, drinking water Candidate Contaminant List (CCL), combustion research, and
ecological research. Undoubtedly, other research project areas also have great merit for immediate
funding. The RSAC also feels that the Agency needs to more fully integrate the risk assessment
paradigm into the strategic planning process.
b) Does the budget request reflect priorities identified in the EPA and ORD Strategic
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Plans?
In general, the RSAC was able to understand from the information provided about how items in
the budget relate back to the goals and objectives stated in the EPA and ORD strategic plans.
Although RSAC did not always understand how the size of a particular request reflected the priorities
assigned in the plans, there were no obvious inconsistencies.
RSAC suspects that omissions in research activities often relate to the lack of a legislative
authority or executive mandate to pursue the issue at hand. For example, naturally occurring
radioactive materials (NORM) and indoor air are good candidates for high Agency research priorities,
but EPA has no statutory authority to regulate either indoor air or NORM and these issues have
received consistently low budget priorities over the years.
c) Does the budget request reflect coordination between ORD and the Program Offices?
The Committee was impressed with the progress made in the past year in heightening the level
of interaction between ORD and Program Offices. Evidence of this effort was provided in a variety of
ways. First the Science Inventory explicitly identifies the science activities of many Program Offices.
Second, a high degree of coordination is demonstrated by the explicit coupling of ORD's research
portfolio to specific goals of the program office. Finally, there was the explicit acknowledgment by
some of the program offices that research provided an important basis for many regulatory actions.
The Agency has further improved the coordination between ORD projects and the needs of the
program offices, and we can see that the program office needs are well integrated into the ORD budget
request. There were good indications of communication and responsiveness of ORD efforts to support
program offices needs. The Office of Pollution Prevention, Pesticides and Toxic Substances (OPPTS)
and the Office of Air Programs (OAR) presentations provided the strongest evidence of this. In the
latter case, the Agency effort to understand the effects of exposure to PM2 5 and to prevent harm to
human health and the environment is a very good example of how a highly coordinated and synergistic
program has been built between the research and regulatory programs of the Agency.
d) Does the budget request support a reasonable balance in terms of attention to core
research on multimedia capabilities and issues and to media-specific problem-driven
topics?
The FY2001 ORD request allocates approximately 44% and 56% of the budget, respectively,
to core and media-specific research areas, consistent with the National Academy of Sciences (NAS)
past recommendations and with ORD's strategic plan. RSAC is encouraged by the continued efforts of
ORD to improve coordination with the Program Offices so its projects can better meet program needs.
The criteria used for the classification of research activities as "core" or "problem-driven" are not
always obvious and should be clearly stated and applied consistently. It is most important to maintain
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core research capabilities, as many of the problems confronting the Agency are not solvable by the
"media-specific" driven research.
e) Does the budget request balance attention to near-term and to long-term research and
science and technology issues?
The Agency has given thoughtful consideration to both long-term and short-term research
needs and science and technology issues. In recent years, the Agency has initiated numerous long-term
research themes (e.g., children's health, global climate change, coastal ecosystem health, and dry
deposition monitoring). However, there is still no overall explicit approach to incorporate the
requirements of longer-term research programs within the short-term budgetary process. Long-term
research projects are at special risk because they are terminated or truncated due to cost-cutting
imposed to provide the resources needed to respond to high-priority, short-term needs. RSAC notes
that the upcoming change in administration also places long-term research projects at risk. RSAC
urges the establishment of a mechanism to identify and pursue emerging issues because recognition of
such issues often forms the bases for future research and science and technology programs and may aid
in the timely identification of environmental problems before they become major problems with sizable
impacts and remedial costs. The Committee believes that emerging issues need to have ongoing, stable
support because EPA is the key Agency charged to watch aggressively for critical new environmental
threats to human and ecological health.
f) How can EPA use or improve upon the Government Performance and Results Act
(GPRA) structure to communicate research plans, priorities, research requirements,
and planned outcomes?
EPA uses the GRPA goals structure to organize its budgets. This format provides an excellent
framework for showing the alignment of the research priorities with the resources allocated to perform
the work. RSAC is concerned that annual performance goals are still focused on specific products
(reports, data collected, etc.) rather than on the improved understanding of environmental functions and
processes. The Committee recommends that the program goals should focus on outcomes rather than
outputs and that the annual performance goals truly relate to achieving the identified objectives in the
Strategic Plan.
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2. INTRODUCTION
2.1 Background and Schedule
RSAC is made up of members from most of the other standing committees of the SAB. The
Committee has reviewed the Office of Research and Development's (ORD) budget request annually
for more than a decade. This is the second year that all of the Science and Technology components in
Agency Program Offices were reviewed and the third year that a GPRA goal-based budget was
presented. The purpose of the review is to provide the Agency and Congress with advice and insight
on the adequacy of the FY2001 budget request to implement a science program of high quality that is
responsive to the Agency's needs. The Committee was provided with background documents supplied
by the Agency, supplemented by briefings from Agency senior managers during the meeting.
The Science Advisory Board (SAB) review of the proposed Science and Technology budget
for the Environmental Protection Agency is normally an annual event. The timing associated with the
public availability of the budget materials often makes scheduling of a formal review difficult. Reviews
completed by RSAC also require formal public review and approval of the SAB's Executive
Committee. This year, the budget materials were released in early February, with the review materials
made available to the Committee on February 8th. The Committee met on February 23 and 24, 2000,
with formal review and approval by the Executive Committee completed on March 8, 2000.
Generally, the Chair or another Member of the RSAC provides expert testimony to the House
Committee on Science during its annual budget hearings, which are normally scheduled shortly after the
release of the proposed budget. This year's budget hearing will be held on March 23, 2000, with Dr.
Seeker testifying on behalf of RSAC.
2.2 Charge to the Committee
a) Can the objectives of the research and development program in ORD and the broader
science and technology programs in EPA be achieved at the resource levels requested?
b) Does the budget request reflect priorities identified in the EPA and ORD Strategic
Plans?
c) Does the budget request reflect coordination between ORD and the Program Offices?
d) Does the budget request support a reasonable balance in terms of attention to core
research on multimedia capabilities and issues and to media-specific problem-driven
topics?
e) Does the budget request balance attention to near-term and to long-term research and
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science and technology issues?
f) How can EPA use or improve upon the Government Performance and Results Act
(GPRA) structure to communicate research plans, priorities, research requirements,
and planned outcomes?
Responses to these questions, and other issues the Committee wishes to address, are provided
to both the Agency and the Congress.
2.3 Format of this Report
Following the Executive Summary and this Introduction, this report provides specific responses
to the questions in the Charge to the Committee (Chapter 3).
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3. RESPONSE TO THE CHARGE
3.1 Objectives Versus Resource Levels Requested
Charge Question: Provide advice on whether the objectives of the research and
development program in ORD and the broader science and technology programs in EPA
can be achieved at the resource levels requested
The Presidential budget request levels were similar to the levels requested in the last two years.
The science and technology activities in the request were selected similar to last year, involving a
priority-setting process that identifies the highest environmental risks within each environmental goal
established in the EPA Strategic Plan and using the sound scientific principles of the risk assessment/risk
management framework. The RSAC found the funding request priorities to be consistent with the
environmental goals established in the Agency Strategic Plan. However, RSAC is concerned about the
impacts of the hiring freeze at EPA which prevents ORD from hiring postdoctoral fellows and other
scientists needed by the Agency to ensure continuity in the research program, to meet program needs,
and to maintain the core competency needed to ensure EPA has the scientific ability to address
emerging issues.
An influx of new researchers is required to maintain core competencies. This is particularly
important because ORD has an aging workforce. ORD has attempted to solve this problem through its
postdoctoral fellowship program, but the EPA hiring freeze prevents ORD from hiring postdoctoral
fellows this year and for the foreseeable future. It is critical that ORD find some way to bring additional
scientists on board to ensure that EPA's current and future science needs are met.
RSAC was pleased to see that the Agency developed the ORD Strategic Plan for FY 2001 as
an outgrowth of the previous year's effort. We feel it is necessary to emphasize that most of the
programs and problems confronted by the Agency do not lend themselves to short-term answers but
instead are only resolved through multi-year research efforts. Areas of emphasis in the FY 2001 plan
identify major science and technology issues which, with some exceptions, reflect the highest
environmental priorities identified by the risk assessment/risk management framework. ORD was not
able to share with RSAC its own priorities for research efforts that would have been proposed for the
FY2001 budget had its budget ceiling been higher. We suspect that numerous research project areas
have potential benefits for EPA's regulatory and guidance programs that would far outweigh the costs
of the research and are therefore excellent candidates for funding. Below, we list example project
areas from our members' areas of expertise that we believe to have such favorable benefit/cost
characteristics. Undoubtedly, other research project areas also have great merit for immediate funding.
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a) Tropospheric Ozone
Although tropospheric ozone research has been increased slightly in the proposed
budget, the level of support is insufficient to meet Agency needs. There is still a significant lack
of knowledge on the full range of atmospheric processes that lead to ozone formation and
accumulation, and on the relative importance of major precursors (e.g., NOX, hydrocarbons) in
control strategies. There are also significant knowledge gaps in atmospheric chemistry
pathways that are common to both ozone and secondary particle formation; without this
understanding it may be difficult to achieve either PM or ozone compliance with the NAAQS.
Knowledge about the major determinants of exposure to ozone and PM, as well as the health
effects from the combined exposures to these pollutants is also limited. A better understanding
of tropospheric ozone will require more support than is currently being proposed.
b) RCRA Corrective Action
RCRA correction action is an effective regulatory program which has very high
potential for cleaning and restoring our land and water resources. However, a significantly
greater budget needs to be allocated to this initiative in order to assure achieving EPA's GPRA
goal and objectives for corrective action. Integration of technical and engineering experiences
for use by the EPA regions that are implementing the RCRA corrective actions requires
significantly more funding than that currently proposed if we are to restore contaminated sites to
productive use and to reduce health risks to acceptable levels at each site.
c) Endocrine disrupters
It is a concern of the RSAC that in EPA's effort to reach each of its GPRA goals, it
may overlook or not provide for the essential research needed to reach those goals. For
example, under the endocrine disrupter program, five essential effects-related goals were
presented in the budget narrative that, in the long-term, will begin to meet the Agency's mandate
under the 1996 FQPA and amendments to the SDWA. However, the critical research that will
provide the foundation for meeting those goals is not apparent in the budget narrative, is not
clearly defined in any budget line, nor is it reflected in the Agency's 2001 budget request. The
1996 FQPA and amendments to the Safe Drinking water Act (SDWA) directed EPA to:
develop a screening program, using appropriate validated test systems and other
scientifically relevant information, to determine whether certain substances may
have an effect in humans that is similar to an effect produced by a naturally
occurring estrogen, or other such endocrine effects as the Administrator may
designate.
EPA was to design a screening program for chemicals of this nature by August, 1998, which it
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did through the use of the Endocrine Disrupters Screening and Testing Advisory Committee
(EDSTAC). The EDSTAC recommendations included a set of four in vitro and seven in vivo
screens for Tier One screening and a set of three mammalian reproductive and four
multigenerational tests in other taxa for Tier Two testing. EPA was to implement the program
by August, 1999 and report to Congress in August, 2000 on the effectiveness of the program.
The recommended screens and assays required further testing and modification, as well as
standardization, and validation before they could be applied under FQPA or SDWA. Not one
of the screens or tests has been standardized or validated yet and the budget request is
insufficient to support the R&D required for these efforts. It is critical that the screens and tests
be standardized or validated before any testing for endocrine disruption is done to ensure it is
done appropriately.
d) Candidate Contaminant List
The Candidate Contaminant List (CCL) serves as a driver for research under the
SDWA. The briefing material provided a long list of contaminants that are to be regulated in
the next two years. This list serves to identify those contaminants (both microbial and
chemicals) for which research information will be needed. The budget allocated ($48.9M)
appears inadequate to meet the stated objectives for the diverse research (occurrence,
exposure, health effects and remedial action work) that will underpin these major environmental
regulations. The many and varied agents involved demand a diverse set of research activities.
For example, current methods for detection of pathogens such as Cryptosporidium are too
insensitive to meet regulatory goals. Risk assessments for key contaminants and populations
(e.g., arsenic, copper, dichloroacetic acid, microbial pathogens in immunocompromized
individuals) require much more complete information than is currently available. The Agency's
plans to explicitly consider sensitive individuals add significantly to this research burden. In
addition, there are many precedent-setting rules that will have to deal with modes of action not
explicitly addressed in previous regulations in order to properly consider alternative
technologies for remediation. Consequently, the Agency will have to carefully consider its
research priorities to determine what information it will need to meet the most important of its
regulatory goals in this area.
e) Combustion Research
There has been a steady decline in the combustion science research conducted at the
Agency. Combustion remains today the dominant source of power production, transportation,
and waste treatment in today's society. This dominance is likely to continue for many years to
come. Combustion-based sources also generate significant quantities of many types of pollution
including ozone and acid rain precursors, fine particulate matter and air toxics. For this reason,
the Agency must enhance its core competency in combustion science including combustion
chemistry, characterization and monitoring systems, combustion generated pollutants and
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control technologies.
f) Ecological Research
The responsibilities of the EPA extend to the protection of ecological health as well as
human health issues. RSAC is concerned that the level of research funding presently allocated
to ecological research is not adequate to address the numerous risks imposed by chemical,
physical, and biological stressors on varied ecological resources. In the case of ORD, for
example, the Sound Science goal support is decreased for FY 2001. Only global change
research shows a significant increase in support from FY 2000 to FY 2001. Both Integrated
Science for Ecosystem Challenges (ISEC) and the Coastal Monitoring Initiative program are
scheduled for extremely modest increases. Unlike human health concerns, ecological health
issues frequently lack organized, special interest support. As a result the Agency has a special
responsibility to expand efforts to protect ecosystems. Human health is ultimately and intimately
linked to the health of our Nation's ecosystems.
3.2 Budget and Priorities in Strategic Plans
Charge question: How well does the budget request reflect priorities identified in the
EPA and ORD strategic plans?
In general, the RSAC was able to understand from the information provided how items in the
budget relate back to the goals and objectives in the EPA and ORD strategic plans. Although we did
not always understand how the size of a particular request reflected the priorities assigned in the plans,
neither did we find any obvious inconsistencies. In the future, RSAC recommends that the Agency be
more specific relating the budget requests to Agency priorities.
Our overall impression is that the budget is reasonably consistent with the stated priorities of the
strategic plans, but we are concerned that some important research needs may remain unfulfilled
because they are not given priority in the plans or in some cases may not even appear in those plans.
RSAC suspects that these omissions often relate to the lack of a legislative authority or executive
mandate to pursue the issue at hand. If the Agency believes that a particular program proposal may fail
to gather support from either the Executive Branch or the Congress because of such a lack of authority,
then it is less likely to propose that program over others with lower scientific priority but with obvious
authorities or mandates. Even if the program is proposed, the proposed budget may be less than might
be justified by the magnitude of the risks addressed and the degree of uncertainty in those risks. Two
examples of such "orphan risks" are Naturally Occurring Radioactive Materials (NORM) and
hazardous constituents in indoor air.
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Screening-level calculations of the individual and population-wide risks of NORM suggest that
they may well be of the same order of magnitude or higher than the corresponding risks posed by other
materials (e.g., chemical wastes) that are highly regulated by the Agency. These estimates are
accompanied by a great deal of uncertainty. The combination of potentially high risks and high
uncertainty makes NORM a good candidate for Agency research priority, but in fact this area has been
assigned consistently low budgets despite over a decade of attention in the Office of Radiation and
Indoor Air (ORIA) and its predecessor organizations. This situation is exacerbated in the FY2001
budget request because it reduces the ORIA's budget while preserving some protected programs
funded out of that budget. The result is that NORM investigations will be brought to a virtual standstill
at a time when they could benefit from an infusion of support to support EPA's core capacity in this
area..
Similarly, the estimated health risks from hazardous constituents in indoor air are widely judged
by scientists working in this arena to be greater than those posed by emissions from point, area, and
mobile sources, yet research to reduce residual uncertainties or to devise intervention strategies is not
well funded in comparison to the more traditional regulated sources of airborne hazards. EPA has no
statutory authority to regulate either indoor air quality or NORM.
The Agency does have authority, however, to regulate Non-Aqueous Phase Liquids (NAPLs)
that occur in subsurface soils from leaking storage tanks, spills, and improper disposal of wastes.
NAPLs are generally thought to pose significant risks and to require significant resources for
remediation with currently available technologies. However, development of cost-effective methods to
clean up these contaminants has not received a corresponding degree of attention at EPA or elsewhere.
It is not clear from the materials presented to the RSAC why higher priority has not been given to
NAPL remediation technologies. EPA leadership and federal funding would help address this need.
Exploitation of opportunities to leverage EPA funds through partnerships with the owners of
contaminated sites and other responsible parties could also be effective.
3.3 Coordination between ORD and the Program Offices
Charge question: How well does the budget request reflect coordination between ORD
and the Program Offices?
The Committee was impressed with the progress made in the past year in heightening the level
of interaction between ORD and Program Offices. Evidence of this effort was provided in a variety of
ways. First the Inventory explicitly identifies the science activities of many Program Offices. Second, a
high degree of coordination is evidenced by the explicit coupling of ORD's research portfolio to
specific program office goals. Finally, there was the explicit acknowledgment by some of the program
offices that research was an important underpinning of many regulatory actions.
The Science Inventory organized by ORD seems to be a very important catalyst for
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communication between Program Offices and ORD. Moreover, it provides a tool for identifying points
of interaction and synergy between different Program Offices that could be important for advancing the
Agency's regulatory agenda with a more cohesive, multimedia approach. This type of information base
could be a very effective tool for identifying problems that have cross-Program Office interests.
Mistaken actions could well be avoided with an organized and searchable database of this kind. A
strategy needs to be developed explicitly to ensure that the database is used to establish cross-program
interactions.
If the Science Inventory is used as a basis for instituting a multiyear planning process that
develops a road map to guide the Agency by specifying research needs and the sequence of events
leading to specific environmental decisions, it will provide a very effective means for identifying critical
data gaps that might not be apparent to either the Program Offices or to ORD. In this context, it should
also provide a better picture of progress towards particular objectives, a better basis for defending
Agency programs, and a more efficient and useful projection of peer review into the regulatory process.
Without it, effective coordination of science activities underway across the Agency is not possible.
Certain of the Program Office participants in the budget review meeting clearly indicated they
appreciated the contribution of the research program. The OPPTS and Office of Air Program
presentations provided the strongest evidence of this. In the latter case, the PM2 5 problem appears to
be a very good example of how a highly coordinated and synergistic program has been built between
the research and regulatory programs of the Agency.
Other Program Offices appear to view ORD as a source of information, but not necessarily the
place within the Agency that will help them to identify the problems of the future. The Committee's
intent is not to identify this as a negative interaction between the Programs and ORD, but rather to note
that the Programs may not be fully utilizing the capabilities within the Agency. An active mission of
ORD should be aimed at identifying and anticipating the next big environmental problems facing the
Agency. In this regard, the Committee was pleased to see that ORD has assumed a responsibility for
identifying future problems. It is hoped that Program and Regional Offices will support and contribute
to this activity, because they are often closer to the real world problems and are in a good position to
recognize trends that are of potential importance in this regard.
RSAC also feels that the Agency needs to more fully integrate the risk assessment paradigm
into its strategic planning process. Considerable energy and resources were spent during the last 15
years, under the direction of the Risk Assessment Forum, to fully develop and test the risk assessment
paradigm leading to ultimate publication of risk assessment guidelines in the Federal Register. Agency
staff and management should now recognize that they have the most effective and efficient planning and
prioritization tool at their fingertips with these guidelines. The well-known steps of problem formulation,
risk analysis, risk characterization and risk management apply to essentially all of the Agency activities.
RSAC is concerned that many of the new and existing programs within the Agency do not properly
reflect the knowledge that could be gleaned from proper application of risk assessment guidelines.
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Agency staff should be continually refreshed and tutored on the applications of the risk assessment
guidelines. There is not a better tool available to ensure the promotion of high quality science and the
proper allocations of budgetary resources.
The RSAC reinforces its support of the use of the risk assessment and risk management
paradigm to develop priorities for research and regulation designed to protect both human and
ecological health. Resources in all Program Offices are limited and methods that begin with evaluations
of exposure and hazard identification for humans or loss of habitat for ecosystems provide a first cut for
determining which contaminants and/or biological (e.g., exotic organisms) and physical (e.g., habitat
destruction) stressors are likely to be detrimental serve as guides for fuller characterization of the hazard
or stressor for purposes of risk assessment. At the same time there must be sufficient flexibility so that
efforts can be directed at understanding new problems or addressing older problems too complex to
resolve in the past (e.g., meaningful studies of complex environmental mixtures).
3.4 Balance Core and Problem-driven
Charge Question: How well does the budget request support a reasonable balance in
terms of attention to core research on multimedia capabilities and issues and to media-
specific problem-driven topics?
The 2001 ORD budget request allocates approximately 44% and 56% of the research budget
to core and media-specific research areas respectively, consistent with the NAS' past
recommendations and with ORD's Strategic Plan. RSAC is encouraged by the continued efforts of
ORD to improve coordination with the Program Offices so its projects better meet program needs.
This is evident in the budget request. The decision process and criteria that lead to a project being
classified as "core" or "problem-solving" research is still not transparent, so the RSAC cannot fully
evaluate this charge question. The committee recognizes that the resource allocations to the two areas
of research may vary from year to year as budgetary constraints and Agency needs change. However,
the criteria used for the classification of research activities as "core" or "problem-driven" should be
clearly stated and applied consistently. RSAC believes that it is most important to maintain core
research capabilities, as many of the problems confronting the Agency are not solvable by the "media-
specific" driven research. It is critical also that the Agency maintain and improve multimedia core
competencies that will help address these problems and identify emerging and future issues. RSAC
strongly supports the fellowship and exploratory grant programs because they will contribute strongly to
competency development.
3.5 Balance Near-term and Long-term
Charge Question: How well does the budget request balance attention to near-term and
to long-term research issues?
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RSAC concludes that the Agency has given thoughtful consideration to both long-term and
short-term research needs and science and technology issues. Addressing both long- and short-term
issues with comparable efforts is more important than developing specific criteria for a fixed ratio
between the two needs. There are a number of emerging issues that would benefit from longer-term
thinking and planning. Examples include the impacts on ecosystems of genetically modified agricultural
plants, the potential for outbreaks of waterborne drug-resistant pathogens, and the risk management
implications of the ability to identify genetically determined variables in susceptibilities to hazards. We
commend the Agency for working towards a balance, and we offer suggestions for improvement.
While some of the programs emphasized in FY 2001 are longer-term efforts, there is still no
overall explicit approach to incorporate the requirements of longer-term research programs within the
short-term budgetary process. There are several examples of longer term research issues that are
addressed in the current budget request including: global climate change assessments, ecosystem
monitoring and studies on impacts on developmental children's health. It is important that the Agency
strengthen its strategic planning processes to fund and protect the longer-term research on critical
environmental issues that transcend the year-to-year budget framework. Long-term research projects
are at special risk, because they are terminated or truncated due to cost-cutting imposed to provide the
resources needed to respond to high-priority, short-term needs. RSAC notes that the upcoming
change in administration also places long-term research projects at risk. Long-term research requires
multi-year planning and evaluation.
In addition to the need to balance long-term and short-term research, we urge the Agency to
improve its ability to identify and pursue emerging issues. This process should be open and transparent
to stakeholders and be coordinated with other agencies. Emerging issues often form the bases for
future research and science and technology programs. These programs may aid in the identification of
environmental problems before they become major issues with sizable impacts and remedial costs.
These efforts are necessary even for a mission-oriented agency such as EPA. Future environmental
concerns are difficult to anticipate and, as such, may require the assistance of both internal and external
experts. Identification mechanisms, for example, might include the use of workshops, recommendations
and assessments from relevant professional societies, and suggestions of experienced researchers both
within and without the Agency.
The Exploratory Grants Program is a further mechanism to identify emerging issues. RSAC is
very concerned about the decline in funding for this Program. In 1994 support for Exploratory
Research was $22 million dollars. This has dropped to a low of $10 million in FY 2000 and the
request for FY 2001 is that it held at this low level. The Committee believes that emerging issues need
to have ongoing stable support from EPA, because it is the key Agency that can aggressively watch for
critical new threats to human and ecological health. In addition to an adequate funding level, RSAC
recommends that selections for Exploratory Grant proposals be based on the extent to which they
identify novel and important themes that are relevant to EPA's responsibilities.
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3.6 Improvements to GPRA Structure
Charge: Provide advice on how can EPA use or improve upon the Government
Performance and Results Act (GPRA) structure to communicate research plans,
priorities, research requirements, and planned outcomes.
EPA continues to utilize the GRPA goals structure to organize its budgets and is now moving
toward the first evaluation of the completion of the annual performance goals that were set for FY1999.
This format provides an excellent framework for showing the alignment of the research priorities with
the resources allocated to perform the work. RSAC is concerned that annual performance goals are
still focused on specific products (reports, data collected, etc) rather than on the improved
understanding of environmental function and process. RSAC recommends that the program goals
should focus on outcomes rather than outputs. In addition, it is important that the annual performance
goals really relate to the identified objectives in the Strategic Plan. There needs to be a more substantial
effort to identify appropriate milestones that are related to providing the fundamental understanding of
impacts to the environment rather than on specific products.
GPRA requires the matching of the Agency's long-term objectives to EPA's Strategic Plan or
to the ORD Strategic Plan. These Strategic Plans outline research priorities over a time span of 3 to 5
years. Thus, to really utilize the GPRA process, it is important to use multiyear planning to attain the
long-term goals. RSAC applauds the launching of the six pilot multiyear planning efforts. It is essential
to look ahead at where the Agency has decided it wants to be as outlined in the Strategic Plans and to
lay out a multiple year pathway to achieve those objectives. The implications of changes in planned
budgets, new research results, the emergence of other competing priorities, etc. can then be examined
in a well-defined context. However, it is important to recognize that these multiyear plans cannot be
immutable since research will inevitably lead to unexpected results. Thus, periodic reappraisal and
possible revision of the multiyear plans must be an integral part of the process. However, there is no
way to determine if the annual performance goals are on the critical pathway to meeting the strategic
plan goals without a multiyear plan.
We look forward to seeing the results of this multiyear planning process and encourage its
expansion as soon as practical. In the implementation of this process, it is essential to ensure that
planning does not become onerous. Otherwise the planning process can consume too much time and
energy relative to actually performing the research to obtain the needed information.
The ORD GPRA plans must be integrated with the Program Office plans in order to fully meet
the Agency goals. The availability of the Science Inventory provides an essential tool in this planning
process. RSAC looks forward to the report of the Science Policy Council on what processes will be
used to utilize the inventory and other Agency data bases to foster and facilitate the integration based on
the GRPA goals. We hope that in the near-term future, we will see integrated multiyear plans that show
how the various components of the Agency are addressing complicated environmental problems in a
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coordinated and coherent manner and thereby meeting the Agency's long term goals (i.e., road maps).
While the Committee was impressed with the substantive progress made in the past year, it is
important that this momentum continue over the next several years to institutionalize the process. To be
useful, the information in the Science Inventory must be uniformly represented. It was difficult to ignore
the fact that there was generally more specificity provided for projects in the STAR program than for
intramural research.
Another problem for the Committee was that it was frequently not clear how critical a particular
set of performance measures were coupled to specific goals. In part this concern may come from the
fact that we are not privy to the internal deliberations and negotiations that must occur in the
development of a set of prioritized research projects. To compensate for this lack of transparency, the
RSAC suggests that ORD might collaborate with the Program Offices to develop a short description
(1-2 sentences) of why the specific science product is critical to the Agency Goal.
The RSAC believes that ORD has taken an important step forward in establishing a science
activity database. ORD has also developed a database for major products of the Agency that should
be peer reviewed. Noting that EPA has recently established an Office of Environmental Information
(OEI), the RSAC recommends that EPA integrate these two databases into a single Science database
that includes both the Agency's science activities and its science products. A single database consistent
with the GPRA goals offers several advantages to EPA including it will: minimize the effort of Agency
respondents; allow for consistency in criteria used to assess science activities and peer review; allow
cross checking for completion of both products and activities; and provide the user with more complete
information on the Agency activities. An integrated database can be an effective foundation for building
an Agency-wide science strategic plan. Finally, any integrated database developed by EPA should be
a searchable database and web enabled for use by both the Agency and public. To be effective, an
interface needs to be built between the Agency's planning process and its science operations and peer
review/quality control efforts for which the science activities and peer review databases were
developed.
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APPENDIX - ACRONYMNS
CCL Candidate Contaminant List
EDSTAC Endocrine Disrupters Screening and Testing Advisory Committee
EPA US Environmental Protection Agency
FQPA Food Quality Protection Act
FY Fiscal Year
GPRA Government Performance and Results Act
ISEC Integrated Science for Ecosystem Challenges
NAAQS National Ambient Air Quality Standards
NAPL Non-Aqueous Phase Liquids
NAS National Academy of Sciences
NOX Nitrogen Oxides
OEI Office of Environmental Information
OPPTS Office of Pollution Prevention, Pesticides and Toxic Substances
ORD Office of Research and Development
ORIA Office of Radiation and Indoor Air
PM Paniculate Matter
PM2.5 Particulate Matter of 2.5 microns or less
RSAC Research Strategies Advisory Committee
RCRA Resource Conservation and Recovery Act
SAB Science Advisory Board
S&T Science and Technology
SDWA Safe Drinking Water Act
A-l
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United States Science Advisory EPA-SAB-
RSAC-00-007
Protection Agency Washington, DC
AN SAB REPORT: REVIEW
OF THE FY2001
PRESIDENTIAL SCIENCE
AND TECHNOLOGY
BUDGET REQUEST FOR
THE ENVIRONMENTAL
PROTECTION AGENCY
A REVIEW BY THE RESEARCH
STRATEGIES ADVISORY
COMMITTEE (RSAC) OF THE
SCIENCE ADVISORY BOARD
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