UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON D.C. 20460
OFFICE OF THE ADMINISTRATOR
SCIENCE ADVISORY BOARD
May 12, 2008
EPA-SAB-08-008
The Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
Subject: Comments on EPA's Research Budget for Fiscal Year 2009: A Report
of the Environmental Protection Agency (EPA) Science Advisory Board
(SAB)
Dear Administrator Johnson:
The EPA Science Advisory Board (SAB) has evaluated the Environmental Protection
Agency's Fiscal Year 2009 research budget. This year, the SAB separated its review of the
upcoming year's research budget from its review of EPA's long-term strategic research
directions (i.e., research to be conducted over the next 5 to 10 years). The SAB and the Assistant
Administrator for Research and Development agreed to this approach for two reasons. The first
was to enable the SAB to handle its annual review of the research budget in a more focused and
efficient way than in the past. The second was to allow the SAB to begin to engage with EPA
scientists in an ongoing process aimed at developing periodic feedback on EPA's future research
vision. The SAB believes that this approach has led to a more effective and appropriately
thorough evaluation of EPA's annual research budgets within the context of how it will allow the
Agency to move forward with the vision embedded in its long-term research vision. The SAB's
overarching findings on the FY 2009 research budget are in this letter, and additional details are
in the enclosure to this letter.
The Mission of the Environmental Protection Agency is ".. .to protect human health and
the environment." In order to do that the Agency must pursue two kinds of research:
1. Research that directly supports the Agency's ability to better and more efficiently operate
its ongoing programs;
2. Research that generates the knowledge to help the Agency and the Nation prepare to deal
with future and emerging environmental problems.
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Environmental problems are growing steadily more complex and challenging. Thus, in
both these contexts, the research that EPA must conduct is becoming more complex and
demanding. However, despite the growing research challenge, overall levels of research support
across the Agency's Office of Research and Development (ORD) have fallen, in the aggregate,
by about $90 million1 (a drop of 14.2% computed as FY 2008 dollars) since 2004. If one
excludes research related to Homeland Security the total decrease is $97.1 million (a drop of
16.2%). Changes in individual research and development programs (in Millions of Dollars and
percent) are shown in Figure 1.
Change in percent
Clean air
Drinking water
Water quality
Land
Computational toxicology
Endocrine disrupter diameicals
Fellowships
Global Change
Homeland Security
Human health and ecosystems
Human health risk assessment
Pesticides and toxics
Sustainability
Hanotechnology
TOTAL
Change in millons
of 2008 dollars
$7.1
$2.0
$7.0
$3.4
$9.7
Figure 1: Percent change (left) and dollar change (in millions ~ right) in EPA ORD budget between
2004 enacted levels and the 2009 President's Budget in constant 2008 dollars. This plot excludes
earmarks, which have declined in recent years.
EPA's scientific staff has done a remarkably good job sustaining as strong a research
program as they have in the face of an ever more challenging funding environment. Several
programs, such as nano-technology and computational toxicology have experienced modest
growth in the dollars they receive. However, where there has been growth it has generally come
at the expense of other programs such as extramural research and research to monitor the status
of the nation's ecosystems.
Despite the best efforts of the Agency's scientific staff, with the research budget so tight,
more and more of the research effort has shifted to supporting the short-term needs (e.g., data
generation and methods development) of existing regulatory programs. This is important, but
not sufficient to meet the nation's future needs. When proposals are made for activities that are
1 Budget data are from EPA ORD. Adjustment to constant dollars has been done with the NASA Gross Domestic
Product Deflator /Inflation Calculator available at http://cost.jsc.nasa.gov/inflateGDP.html (computed on a 2004
resource total that does not reflect Congressional earmarks of approximately $55 M).
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more forward looking, but which do not fit under current narrow regulatory mandates, we
understand that management often declines to pursue such requests because of tight budgets.
The effect of this "eating our seed corn" is that EPA is under-investing in research on a
wide range of emerging science needed to understand and manage current environmental
problems and those that are likely to be recognized in the future. As a consequence we run a
considerable risk that we will not be able to address these problems adequately in the future. We
also run the risk of incurring much larger future costs because we do not understand the subtle
intricacies of these risks and hence could blunder into difficulties, such as inappropriate
regulatory responses, from which it may be much more expensive to recover than if we
understood what we were facing ahead of time.
The SAB offers two
examples of this, but there are
more. Climate change is going to
result in dramatic impacts on
ecosystems. Yet, since 2004
EPA's research budgets for both
climate change and for
characterizing the state of the
Nation's ecosystems have
undergone dramatic reductions
(Figure 2). While Congress
restored some resources in the
climate change budget in FY 2008,
the President's budget for 2009
proposes to continue the
downward trend.
22
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17
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16
ol
120
110
•§ ioo
s
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70
60
Ecosystems
04 05 06 07 OB 09
Fiscal year
04 05 06 07 OB 09
Fiscal year
Figure 2: Time trends, in 2008 constant dollars, of research
budgets for climate change and for ecosystems.
One of the best ways to
better identify and develop an
understanding of future and
emerging environmental problems
is to enlist the talents of America's
broader research community,
including both university faculty
and inventive young doctoral
students. However, since 2004,
support for both the Science to
Achieve Results (STAR) program
of extramural research, and the
more focused program of STAR
Graduate Fellowships, have
undergone reductions of roughly
35% (Figure 3).
80
o 70
04 05 06 07 OB 09
Fiscal year
04 05 06 07 OB 09
Fiscal year
Figure 3: Time trends, in 2008 constant dollars, of research
budgets for STAR extramural research and STAR Fellowships.
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The SAB is also concerned that ORD may be developing tools that get handed off to
others who, because of their own tightening budgets, do not have the resources to use them. We
are also concerned that, in an area related to research and data collection funded by the State and
Tribal Assistance Grants (STAG) appropriation, support for air monitoring is being reduced and
in the future will require a 40% match by state agencies. There is reason to believe that this
could result in a substantial loss of critical air monitoring data.
It is sometimes argued that deficits in EPA budgets for research and data collection are
made up by environmentally related expenditures being made in other Federal agencies.
However, in at least some cases we know this is not the case. For example, USGS water quality
monitoring, assessments, and research have all been decreasing over the past decade and are
proposed for very significant additional decreases in the FY2009 budget. Under the President's
budget the USGS water budget will fall from $221-million enacted in 2008, to a proposed level
in 2009 of $203-million. The number of locations where the USGS collects long-term data on
nutrients, pesticides, metals, and major ions has decreased by more than 50% since the early
1990's. Also, the number of USGS research scientists working on water quality issues such as
nutrient enrichment or emerging contaminants has steadily decreased at rates of 5% per year for
at least a decade.
In order to develop a better understanding of the overall adequacy of the Nation's
environmental research and data collection, we urge you to work with others in the Executive
Branch and with the Congress to initiate an integrated assessment of environmental research and
monitoring investments across the entire Federal system. For example, many of the water
quality data that are collected in the U.S. are collected by the US Geological Survey.
Over the next few years, the Science Advisory Board will continue to review and offer
comments on the year-to-year changes in the Agency's R&D budget. However, because we
believe that a strategic focus on the Agency's research needs is so essential, we have also
embarked on a process to develop and offer strategic guidance to the Agency on research needs.
The Office of Research and Development has been extremely helpful in supporting this effort.
ORD now plans its long-range view of EPA's research around sixteen specific areas.
The focus on these sixteen research areas is important. However, if EPA is to be prepared to
address future needs, the Agency's research program will have to adopt a more integrated view,
one that recognizes the inherent complexities and interconnections among human and ecological
systems, gives greater consideration to feedbacks, and focuses on the relevant scales of each
issue. In this context, it is clear that if the Agency is to truly protect the environment, it must
undertake a larger, more adequately funded, program of research that goes beyond its immediate
regulatory needs and address the broad array of environmental problems facing the nation.
Several changes are needed to address pressing environmental problems that do not fall neatly
within existing regulatory mandates. Today these needs are only addressed within the Agency's
research plans in fragmentary ways. In its research programs, we believe EPA should:
1) broaden the interpretation of "land preservation" to include systems analysis
pertaining to future land-use decision making and managing the consequences of
complex issues such as bio-fuels, urban-sprawl, green-field development, and the
pressures of unconstrained coastal development;
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2) expand the focus on the environmental consequences of new technologies to include
a broader consideration of the life-cycle of new products and their globalization;
3) in light of changing socio-economic pressures and the growing stresses that will result
from climate change (reduced snow pack, more intermittent precipitation and stream
flows, more frequent drought, etc.), expand the analysis of water infrastructures,
supply, demand and quality;
4) expand and strengthen work on multi-pollutant health impacts and environmental
control;
5) reinvigorate and modernize research on sensitive human and ecological populations;
6) improve the science foundation needed to respond to unexpected and emerging
problems and environmental disasters;
7) expand policy relevant research on developing, testing and evaluating new and
innovative alternatives to conventional command and control regulation;
8) dramatically improve the integration of economics and the decision and behavioral
sciences into research and policy development across the Agency; and
9) continue to work on improving the effective communication of research results to
potential users both inside and outside the Agency.
The SAB recognizes that research can only successfully provide the science to respond to
the nation's needs if senior leadership in the Agency and the Congress work to provide the
resources needed to pursue a research program that fully supports EPA's mission of protecting
human health and the environment, now and in the years to come. The SAB looks forward to
working with ORD as this effort proceeds.
Sincerely,
/Signed/
Dr. M. Granger Morgan, Chair
EPA Science Advisory Board
Enclosure
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NOTICE
This report has been written as part of the activities of the EPA Science Advisory Board (SAB),
a public advisory group providing extramural scientific information and advice to the
Administrator and other officials of the Environmental Protection Agency. The SAB 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 of commercial products constitute a recommendation for use.
Reports of the SAB are posted on the EPA website at http://www.epa.gov/sab.
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U.S. Environmental Protection Agency
Science Advisory Board
CHAIR
Dr. M. Granger Morgan, Lord Chair Professor in Engineering; Professor and Department Head,
Department of Engineering and Public Policy, Carnegie Mellon University, Pittsburgh, PA
SAB MEMBERS
Dr. Thomas Burke, Professor and Co-Director Risk Sciences and Public Policy Institute, Bloomberg
School of Public Health The Johns Hopkins University, Baltimore, MD
Dr. James Bus, Director of External Technology, Toxicology and Environmental Research and
Consulting, The Dow Chemical Company, Midland, MI
Dr. Deborah Cory-Slechta, J. Lowell Orbison Distinguished Alumni Professor of Environmental
Medicine, Department of Environmental Medicine, School of Medicine and Dentistry, University of
Rochester, Rochester, NY
Dr. Virginia Dale, Corporate Fellow, Environmental Sciences Division, Oak Ridge National Laboratory,
Oak Ridge, TN
Dr. Kenneth Dickson, Professor, Institute of Applied Sciences, University of North Texas,
Denton, TX
Dr. David Dzombak, Professor, Department of Civil and Environmental Engineering, Carnegie Mellon
University, Pittsburgh, PA
Dr. Baruch Fischhoff, Howard Heinz University Professor, Department of Social and Decision Sciences,
Department of Engineering and Public Policy, Carnegie Mellon University, Pittsburgh, PA
Dr. James Galloway, Professor, Department of Environmental Sciences, University of Virginia,
Charlottesville, VA
Dr. James K. Hammitt, Professor of Economics and Decision Sciences, Harvard Center for Risk
Analysis, Harvard University, Boston, MA
Dr. Rogene Henderson, Scientist Emeritus, Lovelace Respiratory Research Institute, Albuquerque, NM
Dr. James H. Johnson, Professor and Dean, College of Engineering, Architecture & Computer Sciences,
Howard University, Washington, DC
Dr. Bernd Kahn, Professor Emeritus and Director, Environmental Resources Center, School of Nuclear
Engineering and Health Physics, Georgia Institute of Technology, Atlanta, GA
Dr. Agnes Kane, Professor and Chair, Department of Pathology and Laboratory Medicine, Brown
University, Providence, RI
Dr. Meryl Karol, Professor Emerita, Graduate School of Public Health, University of Pittsburgh,
Pittsburgh, PA
11
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Dr. Catherine Kling, Professor, Department of Economics, Iowa State University, Ames, IA
Dr. George Lambert, Associate Professor of Pediatrics, Director, Center for Childhood
Neurotoxicology, Robert Wood Johnson Medical School-UMDNJ, Belle Mead, NJ
Dr. Jill Lipoti, Director, Division of Environmental Safety and Health, New Jersey Department of
Environmental Protection, Trenton, NJ
Dr. Michael J. McFarland, Associate Professor, Department of Civil and Environmental Engineering,
Utah State University, Logan, UT
Dr. Judith L. Meyer, Distinguished Research Professor Emeritus, Institute of Ecology, University of
Georgia, Lopez Island, WA
Dr. Jana Milford, Associate Professor, Department of Mechanical Engineering, University of Colorado,
Boulder, CO
Dr. Rebecca Parkin, Professor and Associate Dean, Environmental and Occupational Health, School of
Public Health and Health Services, The George Washington University Medical Center, Washington, DC
Mr. David Rejeski, Director, Foresight and Governance Project, Woodrow Wilson International Center
for Scholars, Washington, DC
Dr. Stephen M. Roberts, Professor, Department of Physiological Sciences, Director, Center for
Environmental and Human Toxicology, University of Florida, Gainesville, FL
Dr. Joan B. Rose, Professor and Homer Nowlin Chair for Water Research, Department of Fisheries and
Wildlife, Michigan State University
Dr. James Sanders, Director, Skidaway Institute of Oceanography, Savannah, GA
Dr. Jerald Schnoor, Allen S. Henry Chair Professor, Department of Civil and Environmental
Engineering, Co-Director, Center for Global and Regional Environmental Research, University of Iowa,
Iowa City, IA
Dr. Kathleen Segerson, Professor, Department of Economics, University of Connecticut, Storrs, CT
Dr. Kristin Shrader-Frechette, O'Neil Professor of Philosophy, Department of Biological Sciences and
Philosophy Department, University of Notre Dame, Notre Dame, IN
Dr. Kerry Smith, W.P. Carey Professor of Economics, Dept. of Economics, Carey Scl of Business,
Arizona State University, Tempe, AZ
Dr. Deborah Swackhamer, Interim Director and Professor, Institute on the Environment, University of
Minnesota, St. Paul, MN
Dr. Thomas L. Theis, Director, Institute for Environmental Science and Policy, University of Illinois at
Chicago, Chicago, IL
in
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Dr. Valerie Thomas, Anderson Interface Associate Professor, School of Industrial and Systems
Engineering, Georgia Institute of Technology, Atlanta, GA
Dr. Barton H. (Buzz) Thompson, Jr., Robert E. Paradise Professor of Natural Resources Law at the
Stanford Law School and Director, Woods Institute for the Environment Director, Stanford University,
Stanford, CA
Dr. Robert Twiss, Professor Emeritus, University of California-Berkeley, Ross, CA
Dr. Lauren Zeise, Chief, Reproductive and Cancer Hazard Assessment Branch, Office of Environmental
Health Hazard Assessment, California Environmental Protection Agency, Oakland, CA
LIAISONS
Dr. Steven Heeringa, (FIFRA SAP), Research Scientist and Director, Statistical Design Group,
Institute for Social Research (ISR), University of Michigan, Ann Arbor, MI
Dr. Melanie Marty, (CHPAC Chair), Chief, Air Toxicology and Epidemiology Branch, Office
of Environmental Health Hazard Assessment, California EPA, Oakland, CA
Dr. Henry Anderson, (CHPAC Alternate), Chief Medical Officer, Division of Public Health,
Wisconsin Division of Public Health, Madison, WI
SCIENCE ADVISORY BOARD STAFF
Mr. Thomas Miller, Designated Federal Officer, 1200 Pennsylvania Avenue, NW
1400F, Washington, DC, 20460, Phone: 202-343-9982, Fax: 202-233-0643, (miller.tom@epa.gov)
IV
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ENCLOSURE
THE SCIENCE ADVISORY BOARD'S PROGRAM-SPECIFIC
COMMENTS ON THE FY 2009 US EPA RESEARCH BUDGET
1. Human Health Research "Cluster"
The areas discussed in the "Human Health Research" cluster include the specific research
areas of Human Health, Computational Toxicology, Endocrine Disrupters, Safe Pesticides/Safe
Products, and Human Health Risk Assessment2. These comments apply to all those areas
collectively except those portions of the Endocrine Disrupters research area and of the Safe
Pesticides/Safe Products areas that focus on ecosystems research issues. The latter are not
included in these comments.
The Human Health area is proposed for a net 6% reduction in budgeted funding for FY
2009. The resulting proposed funding will likely be insufficient to effectively evaluate and
implement the monumental changes in biological sciences that the Agency faces in the years
ahead. The rapid emergence of toxicogenomic and computational sciences is significantly
impacting not only the expectations of how the Agency will test environmental contaminants for
health and environmental effects, but also how it will translate these test results to quantitatively
predict human health risks for informing policy decisions. The SAB recommends strongly that
resources for the Human Health Research program be increased, not decreased, in order to meet
the above expectations.
In addition, due to progress in reducing environmental levels of many individual
contaminant compounds, the SAB believes that future health evaluations conducted by EPA will
need to address the scientifically more challenging problem of cumulative health risks associated
with "environmentally relevant" exposures to complex mixtures of chemicals. Significant
questions remain about how these "environmentally relevant" mixture exposures may interact
with other endogenous or exogenous chemical exposures, disease and/or physiologic states,
and/or other factors (e.g., age, gender, etc.).
Implementation of research to address these challenges will require access to
significantly expanded and changed expertise and technology resources both inside and outside
of EPA. Meeting the expected needs will also require that the new skill sets be highly
integrated. At a minimum these needed skills will include: molecular biology, computational
modeling, information technology, database management and maintenance, exposure modeling,
human biomonitoring, clinical and molecular epidemiology, and risk evaluation and
communication. Increased resources are needed to be directed to build rapidly Agency capacity
in these areas.
2 The long-range view of the components included within these research areas are addressed in the "Compilation of
EPA ORD Research Program Descriptions," October 2, 2007 - see pages 2 through 29 (SAB, 2007).
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The complexity and rapid change of these emerging sciences also demands that the
Agency collaborate with, and engage in stable partnerships with, other federal agencies, the
external academic and private scientific communities, and other societal stakeholders. Given
current resources levels it is not reasonable to expect that EPA to be entirely self-sufficient in the
implementation of the complex testing and risk evaluation paradigm needed now and for the
future. Thus, EPA must be able to make expanded and longer-term extramural funding
commitments that are not vulnerable to year-to-year fluctuations associated with current shorter-
term funding strategies. Extramural research resources will be critical to developing the needed
research tools and technologies into Agency research strategies, as well as to assure adequate
opportunities for regular stakeholder dialogues and scientific oversight of EPA's strategic
science direction.
2. Ecosystems, Water, and Security Research "Cluster"
Overarching Comments on Ecosystems, Water and Security Research
The areas discussed in this "Ecosystems, Water, and Security Research" cluster include
the specific research areas of Drinking Water, Homeland Security, Water Quality, and
Ecosystems Protection Research3.
Given the highly constrained budget environment, EPA ORD's research priorities and
available funding choices in this area are for the most part in alignment with the long-term vision
for EPA research in this area. Funding choices have been made in a thoughtful way. However,
resources for research in all these programs, especially ecosystems, are entirely insufficient to
address all the critical water issues that need to be addressed - EPA is only funded at a level that
allows the research to address the "tips of the icebergs" for these issues. EPA water research
programs are reduced to the "bone," and thus the ability to protect the environment and position
the U.S. to address coming environmental threats is extremely compromised.
This part of the research program's emphasis is almost entirely focused on today's needs.
EPA must devote some effort, and resources, to research that develops the knowledge base upon
which the nation's emerging environmental problems can be anticipated.
The STAR research grants program has been a major part of EPA's approach to
addressing the nation's future science needs. Reductions in EPA's STAR grants program
significantly limit EPA's ability to support research to help it to understand future emerging
issues.
After years of significant budget cuts, especially for Ecosystems Research, and the
overall budget erosion in general, these programs are running "lean and mean." Thus, even
small investment increases would have a substantial impact in allowing EPA to conduct
important needed research that can not now be done. Those who implement ORD's research
planning process have been exceptionally nimble in their planning of this research program,
3 The long-range view of the components included within these research areas are addressed in the "Compilation of
EPA ORD Research Program Descriptions," October 2, 2007 - see pages 30 through 50 (SAB, 2007).
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especially given the shrinking resources experienced by ORD. EPA ORD must continue to be
adaptive and flexible as it plans for the future in this research program.
Those who manage these research programs are commended for excellence and creativity
in leveraging unique outside partners (e.g. Ecosystems researchers have been working with The
National Geographic Society on mapping ecosystem services). Further, with limited resources
available for traditional partnerships, sharing data and study results with EPA's academic and
federal partners, through use of a virtual, collaborative platform (the NSF concept of a
"collaboratory") is a useful paradigm to pursue. Some EPA research programs are exploring this
practice, known as "open-source-science," and the practice is encouraged by the SAB.
It is imperative to keep the climate change stressor explicit in EPA's research. Some
programs (e.g., the water quality program) do not appear to be addressing how climate may be
impacting storm waters and quality of ambient waters.
Education and outreach are crucial issues that need to be addressed by EPA's water and
security research program.
Drinking Water
The budget for drinking water is decreased by $3.5M from the FY 2008 enacted level.
This was attributed to completion of specific disinfection byproducts (DBF) work and
implementation of the arsenic rule making. A number of important issues in drinking water
seem to need more attention. For example:
a) For arsenic research, a demonstration program for small communities on
arsenic control in drinking water. ORD phased out this work as
implementation occurred. Additional questions remain to be answered for
arsenic to improve the implementation of that rule.
b) For DBFs, a four laboratory study looking at non-cancer effects was completed
and is about to be published. Further research is being phased out. However,
only nine DBFs are regulated (albeit as surrogates for DBFs as a class). There
are more than one hundred DBFs already identified for which explicit health
research data do not exist.
c) New contaminants are being considered for regulatory attention through the
Contaminant Candidate Listing (CCL) process. Listing is a cyclical process
and it will be a major need as EPA goes forward. The SAB is concerned that
not enough research is being directed toward new contaminant issues in water
to adequately address the current CCL or future listing needs.
d) About $1M was appropriated by Congress for research on geological carbon
sequestration and its potential effect on drinking water in FY 2008, but this was
removed from the budget for FY 2009. The Drinking Water program is
working with CDC and the EPA air program to begin to address this issue. In
addition, the Drinking Water research program will issue some STAR grants in
2008. However, without further funding and continued research in FY 2009
the potential longer term gains from this investment will not be sustained.
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e) The Total Coliform Rule revision is on a fast track and is due out by the end of
the summer of 2008. This rule may be expanded to be a broader distribution
system rule. There clearly are not enough resources being invested in this
important area considering the infrastructure improvement needs that are
suggested by the hundreds of local orders that are issued to drinking water
system users to boil water for certain periods of time to reduce the threat of
waterborne diseases. Biofilms will be a big area for research as will
monitoring the distribution system. A component organism for this issue,
Legionella, is now proposed for the Contaminant Candidate List (number 3)
and this will need to be addressed.-
f) Drinking Water research priorities have been driven by statutory needs, and the
agency can only do emerging issues at the fringe of its program. Issues not
able to be addressed include: nanomaterials in drinking water, applications in
terms of distribution systems, and technology associated nano-based water
treatment research.
g) The drinking water research program will have to leverage work in Homeland
Security regarding biosensors and microbial risk assessment. Drinking water is
likely one of the most important exposure routes for microbial pathogens.
Decreased funding in this area has the potential to directly influence the health
of millions of citizens.
Homeland Security
Homeland Security research programs continue to expand in FY 2009. Programs
underway or under development respond to Presidential Directives intended to ensure that
comprehensive surveillance, monitoring, and decontamination techniques are available for the
environment.
As detection and sensor techniques continue to mature, research is expanding into
detection and treatment of possible future events that could occur in indoor and outdoor areas.
EPA's focus on anthrax builds on existing research programs that deal with chemical, biological
and radiological agents. However, it is not clear that there is a science-based or risk-based
argument for addressing only anthrax without consideration of other biological agents of
concern. Considerable challenges still remain in the areas of risk communication and
particularly with surveillance and decontamination issues arising from potential wide-scale
events.
One of the Homeland Security activities in the Land Preservation area addresses training
of volunteers to serve in a Response Support Corps or as part if an Incident Management Team.
The agency estimates that it will need between 3,000 and 3,500 members to respond to five
concurrent incidents of national significance. The FY 2009 budget provides funds to train 700 of
these individuals. However, research has shown that only 50% of volunteers can be relied upon
to respond to incidents, so the number of volunteers to be trained should be at least doubled,
even without taking into account normal attrition. The agency should pursue social science
research to identify the barriers to volunteer participation in incidents.
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Water Quality
The resources for water quality increased from FY 2004 through 2008 from $45 million
to $55.6 million and from FY 2008 to the FY 2009 President's Budget to about $56 million.
Though seemingly substantial, this increase largely reflects resources directed at infrastructure
research and "administrative" costs associated with ORD staff. The Water Quality research
program faces difficulty because of the large number and diversity of issues that need to be
studied and the lack of extramural funds to support the research program. The Agency has had
to slow activities across the research program because of the resource availability, and while no
project is being eliminated, many will be delayed. Thus, research on storm waters, Consolidated
Animal Feeding Operations, Total Maximum Daily Loads, the effects of nanotechnology on
water quality, how climate change may affect water quality, how water quantity may be affected
by water consumption, and pharmaceuticals in surface water all are receiving less resources than
are necessary to answer the many major uncertainties that the SAB sees in the Water Quality
area. There are additional demands in at least one of the long term goal areas on scientific staff
time that comes from responding to an ongoing lawsuit dealing with recreational waters and
microbial standards for recreational waters.
Ecological Research
As we have noted in past years, the long-term erosion of funding for EPA's ecological
research is of great concern to the SAB. Funding has decreased from $102 million in 1995 to
about $66 million in 2009, a decrease of nearly 36% in nominal dollars. Because ecosystem
goods and services provide the natural infrastructure supporting the health and well-being of our
society, it is essential for EPA to conduct a robust ecological research program targeted at
understanding how stressors affect ecological services.
EPA has reconfigured its ecosystems research program to focus on ecological services.
The SAB commends EPA for being creative in developing and initiating a strategic research
program focused on ecological services. The SAB commends EPA for developing partnerships
and being innovative in exploring "open source science" approaches to catalyze further research
on ecological services. However, the levels of funding to be allocated for the important areas of
decision support systems development, research on the relationships of ecological services to
human wellbeing, education of the public about the importance of ecological services, and
implementation of research on valuation approaches are entirely insufficient. These components
of the ecological research program are critical to improvement of environmental decision-
making in the Agency. We encourage increased funding for EPA's Ecological Services
Research Program, especially in the area of the STAR grants program. Because the Ecosystem
program is embarking on a new direction with considerable potential, it is moving into an area of
science that is still in its infancy. This is precisely when the Agency needs to engage as many
minds as possible to help develop the science. STAR funds would be well spent to further the
development of this program, resulting in a more robust end product. In addition, resources must
be available to ensure that EPA can hire and retain the highest level of professionals in the
diverse areas of expertise that make up the analysis of ecosystem services. In some cases, this
may involve the acquisition of specialized consultants when specific expertise is needed that is
not available within the agency.
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While ecosystems are valuable for the services they provide they also have intrinsic value
in their own right. The tight budget means that broader questions of the overall health of the
nation's ecosystems, and how stressors such as climate change, may affect that health in the
future, are now largely being ignored by the Agency's research programs.
3. Economics and Sustainability "Cluster"
Economics and Decision Sciences
The areas discussed in this "Economics and Sustainability Research" cluster include the
specific research areas of Economics and Decision Sciences and Sustainability4.
Economics and Decision Sciences research has been shifted from ORD into EPA's
National Center for Environmental Economics (NCEE),where it is now focused almost
exclusively on economics. The extramural research budget is no longer included in the Science
and Technology (S&T) appropriation for ORD. The budget has declined sharply from more than
$2M several years ago to $1.1M in FY2007 to approximately $600,000 in Fiscal Year 2008. This
remaining budget is likely to be directed toward issues of evaluating ecosystem services,
including definition, evaluation, and valuation, and perhaps toward issues of valuing reductions
in mortality risk, though the levels to be invested in specific areas are not certain.
EPA's level of research investment in economic, decision, and behavioral sciences
appears grossly inadequate to support its mission, i.e., to protect human health and the
environment by developing regulations and other policies to alter behavior of individuals, firms,
and other organizations. Economic, decision, and behavioral sciences that clarify how these
agents respond to alternative policies, and how policies can be designed to be more effective and
less burdensome, should be a central component of EPA research. EPA's past research in this
area has led to major advances in policy with benefits that appear to dwarf the Agency's
cumulative expenditures on this research. For example, EPA research on economic-incentive
regulatory mechanisms has contributed to shifting tradable permits and similar mechanisms from
politically unacceptable to a preferred choice, sharply reducing the cost of achieving
environmental quality. Similarly, EPA research on methods to estimate the monetary value of
reductions in health risk provide a basis for showing that regulations for fine particulate matter,
despite being among the most expensive, are well-worth their cost.
Sustainability
The EPA's Sustainability research strategy attempts to disperse the Sustainability
paradigm throughout EPA's programmatic areas. This research program emerged during a
transitory period from the Pollution Prevention (P2) program. The program's current focus is on
the development of meaningful metrics and indicators, support tools such as Life Cycle Analysis
(LCA), and research on innovative technologies.
4 The long-range view of the components included within these research areas are addressed in the "Compilation of
EPA ORD Research Program Descriptions," October 2, 2007 - see pages 51 through 64 (SAB, 2007).
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One measure of the effectiveness of the strategy might be the extent to which other
programs influence, and in turn are influenced by, the sustainability approach. Indeed, several
(perhaps as many as 11) Agency programs have clear connections to sustainability. Thus it is
somewhat puzzling that among all of ORD's research programs, funding for the sustainability,
and its predecessor program pollution prevention, has declined the most (60%) over the past five
years. The SAB is concerned that within a few years the program will face elimination through
funding attrition.
It is ironic that at a time when environmental problems are increasingly regional or even
global in scope, and characterized by a high degree of complexity, that the kinds of metrics and
tools envisioned within the sustainability program have not been applied within the agency and
spread to other agencies in a more systemic way. Clearly LCA methodologies are powerful
ways to weigh options among competing or alternative decisions that society must make.
A new opportunity has been presented to the Agency through the new Energy
Independence and Security Act of 2007, which calls for the EPA to lead the assessment of the
environmental consequences of biofuels development in the US. Although this is but one of the
many critical areas which will have major environmental impacts, it may present a key
opportunity to demonstrate the value of applying the LCA approach. For the agency' s
sustainability metrics and support tools, this might at last propel the sustainability strategy to a
greater level of recognition, thus funding of this effort is encouraged.
4. Clean Air and Global Change Research "Cluster"
The areas discussed in this "Clean Air and Global Change Research" cluster include the
specific research areas of Global Change and Clean Air Research5.
Global Change
EPA'S Global Change research program is assessment-oriented and focuses upon
understanding the effects of global change on air and water quality. EPA'S program is a part of
the integrated Climate Change Science Program (CCSP) that is carried out by many U.S.
agencies. The EPA research program is reduced by over $3 Million in the FY 2009 budget to
just over $16 Million. The EPA Global Change Research Program performs well considering its
declining funding and relatively small, though focused and important role, in the overall Federal
program on climate change.
In general, the SAB believes that the Agency needs to report their strategic objectives for
global change in terms of overall greenhouse gas emission reductions in addition to energy
intensity (efficiency) goals (million metric tons of carbon equivalent [MMTCE] of emissions
from a growing baseline).
The Intergovernmental Panel on Climate Change (IPCC) 4th Assessment, a consensus
report of the world's scientific community, has shown that dramatic emission reductions (-80%)
5 The long-range view of the components included within these research areas are addressed in the "Compilation of
EPA ORD Research Program Descriptions," October 2, 2007 - see pages 65 through 75 (SAB, 2007).
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will be needed by 2050, and emission reductions must begin soon. States are leading the way in
these planning efforts, and for EPA to be relevant in the future, research is needed on the most
effective strategies to reach these reduction goals. Thus, EPA should adopt some consistent
emission reduction objectives identified by IPCC to inform and to better define their research
portfolio.
Clean Air (formerly NAAQS and Air Toxics)
The Air Program of EPA's Office of Research and Development (ORD) is commended
for providing high-quality scientific information to support EPA's development of National
Ambient Air Quality Standards (NAAQS) for criteria air pollutants and for moving the Agency
toward of a multi-pollutant approach to the regulation of air pollutants. ORD's Air Research
Program has expanded the scope and value of its research results through leveraging the research
done by other Federal agencies such as the National Institute of Environmental Health Sciences
(NIEHS) and publicly- and privately-funded organizations such as the Health Effects Institute
(HEI). It is essential that this core research program be maintained or expanded in real research
dollars to continue this successful effort.
In a related area, the EPA FY 2009 Annual Performance Plan and Congressional
Justification budget figures indicate that the President's Budget for Healthier Outdoor Air
continues to decrease funding for State and Tribal Assistance Grants (STAG) for routine air
monitoring [such as particulate matter (PM)]. In addition, there is a requirement for 40% in
matching funds for states involved. Such data are greatly needed for risk assessments and
strategic goal assessments. There is a very limited ability for states and tribes to increase their
budgets to accommodate this 40% match. Thus, the change in this part of STAG will mean a
loss of monitoring capability which EPA needs in order to assess nationwide trends. Once these
programs are eliminated at the state level, they will be difficult to resume. Restoration of full
funding of these STAG grants is important to prevent the cascading effect of federal cuts leading
to state cuts, leading to irreparable loss of monitoring capability.
Likewise, the reduction in the President's FY 2009 proposed budget for Reducing
Greenhouse Gas [GHG] Intensity has cut funding for the clean car program, the GHG Registry
Rule, and Energy Star by more than $9 M. These changes seem counterintuitive given the crisis
affecting our environment from climate change and the relative cost effectiveness of these
programs.
Indoor air is an unfunded ORD responsibility. While some of the air research, such as
the near road research, can lead to indoor air mitigation in buildings housing sensitive
populations such as schools, this is not a focus of the EPA's research program. Providing
funding for indoor air research can be another avenue to address asthma issues.
Responsibility for mercury research may be moved into the air program, but it has
extremely limited funding. Yet the concern for climate change has led to voluntary energy
conservation efforts which include an increasing demand for compact fluorescent lights (CFL).
These CFLs contain mercury which can be released inadvertently into homes if broken, or into
waste facilities when discarded. The impact of this nationwide trend where CFLs are widely
available through nearly all low cost or other retail outlets, coupled with consumer education
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programs to encourage their use for energy conservation, needs to be coupled with research on
the impact on human health in indoor air as well as the impact with regard to the mercury
materials balance. Life cycle analysis of these new trends is a cross-cutting issue which needs to
be included in the research budget.
5. Technology "Cluster"
The areas discussed in this "Technology Research" cluster include the specific research
areas of Land Preservation and Restoration, Nanotechnology, and Global Earth Observation
System of Systems/Advanced Monitoring Initiative research6. Many of the research areas within
the EPA ORD program seek partnerships with other government agencies and some non-
governmental organizations. This leveraging mechanism is important to the success of EPA's
mission because of the difficult budget constraints that are associated with the EPA research
program. Nowhere in the program is this more necessary and appropriate than in the technology
area where the private sector often benefits directly from EPA's research and development
activities (e.g., see the SAB comments on technology verification below).
Land Preservation & Restoration
EPA's Land Preservation and Restoration research continues to focus on cleanup of
contaminated sites, control of releases to land, and control of leaking underground tanks. In
deciding on its program focus, ORD has worked in cooperation with other EPA offices and some
organizations outside the Agency to assess key research needs. The Office of Solid Waste and
Emergency Response (OSWER) relies upon this research in order to meet its objectives in
EPA's land pollution prevention and cleanup programs under the Resource Conservation and
Recovery Act (RCRA) and the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA). Many land preservation and restoration research needs remain. Given
the limited resources available, ORD's leveraging and identification of information gaps and
cross-cutting multiple program opportunities appears to make good use of the funds available to
address high priority problems.
An area from which nearly all EPA financial support has been withdrawn is technology
evaluation and verification. This should be reconsidered. The function of the EPA
Environmental Technology Verification (ETV) and the Superfund Innovative Technology
Evaluation (SITE) programs are essential to moving technology to commercialization and have
involved substantial leveraging of limited EPA funds. From the evaluations conducted by the
National Advisory Council for Environmental Policy and Technology (NACEPT, 2006;
NACEPT, 2007) Environmental Technology Subcommittee, it is clear that (a) the ETV program
has been very effective in moving environmental technologies forward in the marketplace, and
(b) the EPA support for the verifications - amounting to 50 - 66% of the cost on average - is
important for program vitality. The financial support of EPA for technology verification is
critical for many environmental technology firms which typically are small operations. There is
discussion and documentation of these findings in the May 2006 report of the subcommittee
entitled "EPA Technology Programs and Intra-Agency Coordination." Technology verification
6 The long-range view of the components included within these research areas are addressed in the "Compilation of
EPA ORD Research Program Descriptions," October 2, 2007 - see pages 76 through 92 (SAB, 2007).
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is discussed further in the May 2007 report of the subcommittee entitled "EPA Technology
Programs: Engaging in the Marketplace." In both reports, the subcommittee recommended the
expansion and support of the Agency's programs for technology verification as a core function
within EPA. It was the view of the subcommittee that EPA's technology verification activity has
had significant positive impact on environmental technology development and advancement, and
that there is much more impact that this activity could have. The SAB believes that it is
important to maintain the unique ability of EPA to help advance environmental technologies to
commercialization through technology evaluation and verification and targeted development.
Related to environmental technology development, the EPA SBIR budget, already
modest, is slated for significant reduction. The EPA has used small business innovative research
(SBIR) RFPs (Request for Proposals) to target particular areas of technology development need,
and has been effective in stimulating technology development as documented by the NACEPT
subcommittee noted previously. The SBIR budget reduction should be reconsidered.
As in other research areas, an activity that has been lost due to budget constraints is the
connection with the academic community largely via programs such as STAR. Academic
research is an effective way to leverage EPA research in important areas. ORD should consider
opportunities for developing critical relationships to build flexible research capacity in key areas.
While the current and planned ORD land preservation and restoration research activities
pertaining to RCRA and CERCLA are well linked to specific regulatory needs under that
legislation, it is clear that large-scale, important land preservation and restoration challenges
facing the nation are largely unaddressed by ORD efforts. This is understandable considering
budget constraints and the focus on immediate mission that the budget constraints impose.
Nevertheless, the Board recommends that ORD seek to broaden the interpretation of "land
preservation" to include systems analysis pertaining to future land-use decision making and
managing the consequences of bio-fuels, urban sprawl, green-field development, and the
pressures of unconstrained coastal development.
Nanotechnol ogy
The ORD program on nanomaterials has been formulated strategically, considering EPA
needs and with an eye towards leveraging and potential needs for future regulatory decisions.
This program involves many external groups. EPA held three rounds of carefully targeted
extramural research competitions on the environmental implications of nanotechnology. EPA
has given careful attention to building on areas of internal expertise such as fate and transport,
ecological assessment, and small particle inhalation. The program integrates activities at the
international, national and cross-agency levels. If more funding became available, the
recommendation would be to expand investment in the current focus areas. An important,
unaddressed challenge is the implication of mixtures and environmental transformations of
nanomaterials and other contaminants.
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Global Earth Observation System of Systems (GEOSS) and the Advanced Monitoring Initiative
(AMI)
GEOSS effectively leverages opportunities with other agencies, using high quality data
sets to serve EPA needs. Some of the additional benefits of GEOSS are that it develops a
technologically collaborative culture, creates an understanding of the need to plan for such
collaboration, and, that done right, it will work itself out of business. The current $5M funding
supports 34 projects, which together are well balanced in meeting program needs across the
EPA. However, after completion of the demonstration stage, the SAB recommends focusing on
a smaller number of high impact projects such as monitoring the temporal and spatial changes in
water quality within the Chesapeake Bay or the Mississippi River.
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REFERENCES
NACEPT (2006) "EPA Technology Programs and Intra-Agency Coordination." National
Advisory Committee on Environmental Policy and Technology, May 2006.
NACEPT (2007) "EPA Technology Programs: Engaging in the Marketplace." National
Advisory Committee on Environmental Policy and Technology, May 2007.
Quereshi, K., R.R.M. Gershon, M.F. Sherman, T. Straub, E. Gebbie, M. McCollum, MJ. Erwin,
and S.S. Morse. "Health Care Workers' Ability and Willingness to Report to Duty
During Catastrophic Disasters." J. of Urban Health: Bulleting of the New York Academy
of Medicine, doi:10.1093/jurban/jti086. Oxford Univ. Press.
SAB (2007) "Compilation of EPA ORD Research Program Descriptions," - compiled by US
EPA Science Advisory Board Staff Office, October 2, 2007 from individual descriptions
provided by EPA ORD National Program Directors from EPA's Office of Research and
Development in support of the October 3-5, 2007 Science Advisory Board meeting
(See on the SAB Website at:
http://yosemite.epa.gov/sab/sabproduct.nsf/04D4C3B698482D32852573680068A363/$F
ile/compilati on_of_epa_ord_res_prog_descrip.pdf).
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ABBREVIATIONS
AMI
CAFO
CCL
CCSP
CDC
CFL
CERCLA
DBF
DW
EPA
ETV
FY
GEOSS
GHG
HEI
IPCC
LCA
MMTCE
NACEPT
NAAQS
NCEE
NIEHS
ORD
OSWER
PM
PP or P2
RCRA
RFP
SAB
STAG
STAR
SBIR
SITE
U.S.
USGS
Advanced Monitoring Initiative
Consolidated Animal Feeding Operations
Contaminant Candidate List
Climate Change Control Program
Centers for Disease Control
Compact Fluorescent Lights
Comprehensive Environmental Response Compliance and Liability Act
Disinfectants, Disinfection Byproducts
Drinking Water
U.S. Environmental Protection Agency
Environmental Technology Verification
Fiscal Year
Global Earth Observation System of Systems
Greenhouse Gasses
Health Effects Institute
Intergovernmental Panel on Climate Change
Life Cycle Analysis
Million Metric Tons of Carbon Equivalents
National Advisory Council on Environmental Policy and Technology
National Ambient Air Quality Standards
National Center for Environmental Economics
National Institute for Environmental Health Sciences
US EPA Office of Research and Development
Office of Solid Waste and Emergency Response
Particulate Matter
Pollution Prevention
Resource Conservation and Recovery Act
Request for Proposals
Science Advisory Board
State and Tribal Assistance Grants
Science to Achieve Results
Small Business and Innovative Research
Superfund Innovative Technology Evaluation Program
United States
US Geological Survey
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