NACEPT
Shaping the Nation's Environmental Policy
National Advisory Council for
Environmental Policy and Technology Comments on
EPA's 2007 Report on the Environment: Highlights of National Trends
January 26, 2008
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Table of Contents
I. Introduction 1
II. Overarching Recommendations 3
III. Policy Benefits and Implications of the EPA Report on the Environment 4
IV. Comments on Specific Chapters 6
V. Editorial Comments, Suggestions, and Clarifications 10
Appendix A: NACEPT Report on the Environment Workgroup Members 15
Appendix B: NACEPT Charge 17
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I. INTRODUCTION
Responding to a charge from EPA to conduct a peer review of EPA 's 2007 Report on the
Environment: Highlights of National Trends, NACEPT established a workgroup to
review the Highlights Document critically, to respond to the particular questions in the
Charge, to suggest changes that could help the document achieve its objectives, and to
provide a series of editorial comments designed to improve the clarity of the presentation.
In addition, the workgroup has proposed some changes in the overall process in order to
enhance the effectiveness of future EPA Reports on the Environment.
NACEPT was asked to answer three questions,
1. Does the Highlights Document accurately represent the scientific content of the
Technical Document? Are key areas over- or under-represented? Would someone
familiar with both documents come to the same conclusions regarding human health and
the state of the nation's environment?
2. The Highlights Document distills the information found in the Technical Document. Is
the Highlights Document scientifically accurate? What conclusions would one come to
regarding human health and the state of the nation's environment?
3. Is the information in the Highlights Document presented in a way that is
understandable to the target audience? Are the structure and length of the Highlights
Document appropriate for its content and the target audience? How could the
presentation be improved?
In response to the first question in the charge, NACEPT concludes that the Highlights
Document accurately represents the scientific content of the Technical Document (also
known as the Science Report). Key areas seem equally represented in both documents,
recognizing the relative brevity of the Highlights document. Someone familiar with both
documents would likely draw the same conclusions from reading the text of each.
However, NACEPT also notes, reflecting a series of draft comments that have emerged
from the parallel review of the full Report by the EPA Science Advisory Board, that there
are shortcomings in the full Report with regard to the ability to chart environmental
changes and to report and track trends. This is especially evident in the Chapters on
Land, Human Health, and Ecosystems, but prevails throughout the Report. The effect in
the Highlights Document, which must reflect in a briefer format the full Report, is to give
the appearance either that no significant changes are taking place in the United States or
that EPA is unaware of them, neither of which is true.
In response to the second question in the charge, NACEPT concludes that the Highlights
Document accurately portrays the Technical Document's scientific content. However,
the Highlights Document does not successfully communicate the ecological connectivity
among the various chapters. Due to the absence of such connections, a reader is likely to
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conclude that there are changes in human health and in the state of the nation's
environment, but be unable to ascertain trends or cause and effect relationships.
In response to the third question, the information in the Highlights Document is presented
in a way that should be understandable to the target audience. The structure and length
are appropriate. Some features such as the use of color and the graphs are particularly
effective. NACEPT does have suggestions to improve the ability of the Highlights
Document to meet its goal to "inform the audience about important environmental issues,
make the information meaningful to them, and provide a means for the audience to access
more in-depth information."
For example, the information presented needs to draw some conclusions rather than
leaving the audience to ask "So what?" Even given the absence of trend data, EPA
should be able to comment on what it does know.
The information presented should be as relevant to the reader as possible. For example,
the public is likely to be interested in how their region or locale is faring compared to the
rest of the country. Links to more local data may help them answer this question and
spur further questions or beneficial action. In addition, some issues of current wide-
spread interest such as autism and obesity are not discussed and their absence is
noticeable.
Several of the improvements suggested above are intended to take greater advantage of
electronic tools, especially links, and the wide availability of on-line data. The
Highlights Document itself should provide more explanation about how to find links and
access data. That implies also that careful attention must be given to the imminent design
and launch of the web-based Report in order to help achieve these goals.
The audience should be empowered to do something to help improve the environmental
trends or conditions. EPA is losing a wonderful opportunity if it does not include some
basic information in each section about environmental stewardship by each citizen. A
link to an appropriate section of the EPA website might be a start in achieving this type
of benefit.
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II. OVERARCHING RECOMMENDATIONS
The Report on the Environment (ROE) Highlights Document (HD) needs to be
strengthened in four very important ways:
1. CONCLUSIONS: The information presented needs to lead to some conclusions.
The document contains few insights into the relationship between cause and
effect. The report would benefit from conclusions at the end of each chapter and
at the end of the document. Absent interpretation, even the well informed public
will have little clue as to what the information is really saying about the condition
of the environment, and whether it's getting better, worse, or staying the same.
Absent conclusions, the Highlights Document leaves the impression that no
significant changes are taking place in the nation, or that EPA is unaware of them.
It is frustrating for the taxpaying public to read again and again that data are
unavailable or inadequate. EPA needs to take a stronger stand in this ROE,
including postulating about causal relationships, trends, and reporting more about
what it does know, rather than dwelling so much on what it does not know.
2. EMPOWERMENT: There needs to be more on what the reader can do. A
primary purpose for issuing the Highlights Document is to provide a more
general, less scientific public with information about the country's environmental
conditions and trends. This audience (the "well informed public") is generally not
scientists but policymakers, politicians, agency staff, environmental activists,
teachers, and concerned citizens. They will want to know what they can do to
protect the environment, given the problems we currently face. EPA would miss
an important opportunity to further the cause of environmental stewardship if it
did not provide at least some basic information in each section or at the end of the
document about how all citizens can be better stewards. The Highlights Document
also should recognize the many, many entities that work to address environmental
issues (federal, tribal, state, local, private, NGO, etc.) that offer both additional
scientific information and opportunities for stewardship. EPA should address this
shortcoming of the report by developing links to appropriate sections of its web
site to further inform the reader about what they can do to take action. A link to a
stewardship page of EPA's website would be a start in the right direction.
3. RELEVANCE: Of necessity, the information presented in this report is
generalized on a nationwide level. The informed public, however, will want to
know how their region or locale is faring compared to the rest of the country. This
can be satisfied by inserts in the text highlighting examples of environmental
conditions from around the country, regardless of whether those conditions
indicate improvements or further degradation. At the very least, the HD could
have links for regional/local information. In addition, some current high-visibility
issues were conspicuously absent from the document: autism, asthma, light
pollution, and childhood obesity (although EPA would need to be very clear how
environmental conditions are linked to childhood obesity). This report would
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appear to be out of touch with the concerns of the general public if it didn't at
least mention these issues.
4. GOING ELECTRONIC: The Highlights Document should explain a bit more
about the electronic version and how it not only can (and will) be updated more
frequently but can also be used to drill down from the national to regional and
state and local levels of information (where they exist).
Finally, the Highlights Document could help the Agency make continued progress toward
decisions leading to sustainability for the nation by using "Sustainability" as an
overarching theme. NACEPT believes that theme is particularly relevant to the Land and
Water Chapters and should be applicable to the entire report. A sustainability theme
could be highlighted for each chapter (side bar or text box) and used to coalesce the entire
report around an important message. It is recognized that major structural changes in the
Highlights Document would be impractical for this edition of the report; however,
NACEPT encourages this thematic approach as a key organizing element for the next
version of the Report on the Environment. For this edition, EPA could reference its
recent work on environmental stewardship that can be helpful in working towards
sustainability.
III. POLICY BENEFITS AND IMPLICATIONS OF THE EPA REPORT ON THE
ENVIRONMENT
Understanding the condition of the nation's environment and measuring changes in its
status over time should be an essential component of a well-conceived and managed
environmental protection system. The steps taken so far to develop, focus, and improve
the EPA Report on the Environment are commendable. The 2007 version presents a
higher standard than did the first version which provided an admirable foundation. Yet,
there is more to be done. NACEPT strongly encourages the continuation of the ROE
process. Two important reasons for this belief, among others, are that a regularly
produced scientifically valid assessment of the environment of the country is an
invaluable tool for assessing the performance of the Agency and for planning for the most
effective use of resources in improving performance. Moreover, such an assessment
provides an exceptionally powerful communication tool to convey to the American
public both environmental successes and information about environmental areas where
more work needs to be done.
That being said, NACEPT strongly urges that EPA keep some points in mind as the ROE
initiative expands in the future.
• For maximum effectiveness, as a management tool and a communication medium,
the ROE must not be seen, by the Agency or by the public, as a public relations
document where favorable results are highlighted and areas of less progress are
obscured. All areas must receive equal attention, both successes and challenges.
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• The set of indicators must be stable, that is, the same indicators should appear
each time the ROE appears in order to allow meaningful evaluation of progress.
Certainly, during the current initial stages of the process some change can be
expected and new issues will surface for the first time in future editions, but
consistency should be achieved as much as possible and as soon as possible. In
the future, changes may be desirable as conditions change and the technical
ability to monitor environmental variables change, but modification of the set of
indicators should be gradual and methodical in order to avoid the perception that
the ROE process is being manipulated.
* As much as possible, the ROE process should be seen as separate from EPA
regulatory and reporting activities, in part because data generated from other
federal agencies are important components of the Report. While EPA planning
should be informed by the trends identified in the ROE, EPA should avoid steps
or actions that could result in a perception that the ROE process can be
compromised to benefit the Agency. This means that the ROE preparation should
be the direct responsibility of EPA offices not directly participating in regulation
and enforcement. Perception, whether or not based on fact, can be an important
factor in the long-term acceptance of the environmental data developed and
presented.
* Because federal environmental priorities are most often established on a nation-
wide basis, a national assessment and national trends are critical for the ROE.
NACEPT recognizes that is the direction that the ROE has taken and supports that
decision. However, individual responses to the document, whether by industry or
individuals, are more likely to focus on environmental conditions more local to
any individual who is motivated to rpgpnnH through r.Vmngp Availability of
regional data to an interested public must be seen as a critical part of the ROE
process as it moves ahead. In this case, the concept of "regional" should be seen
as different from EPA Regional borders; it should focus on ecological regions or
watersheds or other pertinent environmental areas.
• Significant attention should continue to be given to selecting scientifically valid
indicators and, whenever possible, describing cause-and-effect relationships.
Yet, at the same time, there must be due consideration to the question of what
aspects of the environment are most important and need to be measured and
monitored. The nation would benefit from thoughtful reflection on the question
of what we would like to possess in the future of our environment, and making
certain that we have developed the capability to monitor its aspects. Perhaps the
monitoring and data accumulation of today, even though scientifically valid, does
not provide the complete set of information or the type of information that the
nation would like to see. However, raising the question could be a significant
benefit of the ROE process.
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On-line access and more regular update of environmental data bases and trend
information may eventually have the greatest impact of any part of the entire ROE
process. NACEPT strongly urges that the online version of the report be designed
and evaluated to ensure easy access and search capabilities. Moreover, the
electronic report should anticipate and encourage greater use by more
sophisticated readers.
IV. COMMENTS ON SPECIFIC CHAPTERS OF THE HP
A. AIR
Compared to water, air quality monitoring has a very robust data set, yet the data, when
summarized pollutant-by-pollutant, fails to answer the basic question, "Is the air safe to
breathe?" This is what the reader will want to know. It would also be helpful to provide
some information about the overall relative risk of various air pollutants and the
connections between public health and air quality where they are known or suspected to
exist (e.g. asthma).
This chapter could be improved with some fairly simple modifications, such as:
* Regional differences could be acknowledged by highlighting areas of the country
that exhibit the most problematic air quality (e.g., ozone non-attainment areas,
high particulate matter); some kind of color coding for the ambient air parameters
would be helpful in sorting this out;
• The chapter should recognize that only a limited number of parameters are
systematically monitored in the US, and the synergistic impacts of multiple air
pollutants are not well understood;
• Ozone: The ozone graphic was very difficult to read and to understand. It needs
to be rethought. Are the averages for all ozone measurements in the nation
averaged together? Are they the average of the highest value at all stations? The
graph appears not to match the text about the ozone layer or stratospheric ozone,
but rather total ozone levels. The text addresses the thickness of the ozone layer
and the graph measures percent change in total ozone levels over time, a
confusing use of terms. The graph heading might better read: "Stratospheric
ozone began seriously declining in 1979-1993. Since 1993 the ozone layer has
improved but is still below naturally occurring levels."
* Indoor Air: It is unclear if the radon increase in homes is simply because of more
testing, especially in areas where high radon levels are suspected, or because there
is more radon entering and being concentrated in homes. The HD should provide
some explanation for the increase.
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Finally, some conclusions ought to be made with respect to whether air quality is
improving. And, given the prominence of the climate change issue in the
everyday media, more attention to global air pollution issues would help put the
nationwide picture into a larger perspective; this would be particularly helpful for
mercury and greenhouse gas emissions.
B. WATER
In general, the chapter on water is well written and is appropriate for a general audience.
Where technical terms are used, they are clearly explained. However, the absence of
time-series data in many areas (for example, benthic community conditions in wadeable
streams and in estuarine waters, or nitrate concentrations in shallow groundwater) is
frustrating. There is no real "story" without a sense of change-over-time. This may be
an unavoidable matter of data gaps, data standards that are set too high, or lack of
statistical confidence in the data, but the water chapter suffers from the logical conclusion
of a reader that there is no real message. If regional data are available in some areas that
are "suggestive" of national trends, more of that could be integrated into the HD - as in
the Chesapeake Bay example on p. 14. However, it is important that a reader not be led
to conclude that regional trends represent the state of water quality nationwide.
The water section contains frequent statements that no national data are available. This is
perplexing, and may raise suspicions on the part of the reader who has been led to believe
that water resources is a particularly important topic but now sees there is very little
information on it. Readers are likely to view chronic under-reporting or incomplete data
sets as evidence that EPA does not place a high value on water resources. NACEPT
suggests that a helpful follow-on activity to the Highlights Document and to the overall
ROE activity would be the compilation of the most important data gaps, along with
suggestions for a process that the Agency - joining with others - can pursue to fill those
gaps. As stated on p. 16 of the HD, in the context of recreational waters, "Improved data
collection could lead to suitable indicators in several areas." Where available, EPA
should consider the data from TMDL activities and volunteer monitoring. At a
minimum, EPA should acknowledge that such data exists.
The document does not provide information on the condition of the nation's extensive
aquifers, yet the continued drawdown of many of them is a very important environmental
trend in the nation. Especially with the trend towards higher rates of biofuels and ethanol
production, concerns have arisen regarding impacts of increased fertilizer use and
irrigation of crops. Like land utilization, the public is consuming water faster than the
rate of population growth and much of the increase in water demand is attributable to
lawn watering and crop production. The sustainability theme could be easily introduced
in this chapter around the issue of groundwater depletion. If unchecked, water-dependent
development and farming failures seem likely in several parts of the country over the
generation ahead. Especially given the 2007 water crisis in Georgia, if this issue isn't
highlighted, people may well look back and ask "Where was the EPA?" This is a topic
where regional information could be used to suggest the seriousness of the issue for the
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nation. For example, in parts of Texas, Oklahoma, and Kansas, the Ogallala Aquifer that
underlies much of the US Great Plains has already dropped by more than 100 feet and
wells are going dry on thousands of farms.
C. LAND
Overall, the chosen information in the HD is consistent with the scientific information in
the Technical Document, but the chapter suffers from lack of information and
conclusions about land use and land use trends. The lack of consistent, long-term, reliable
data, particularly in the land use and land cover sections, is underemphasized in the
discussions. Although this is prominently mentioned, a lay reader may not fully
understand the consequences of this revelation.
The chapter on land use offers an opportunity for linkage with sustainability and
stewardship themes, which this Administration articulates, as well as some linkages
between water consumption/water quality and land use. However, the report fails to
bring forward the most significant sustainability issues such as, in the chemicals section,
the tripling of nutrient fertilizers in the last 40 years. Likewise, the connection between
the tripling of fertilizer use and water pollution is lost and should be enunciated (e.g.
rising nutrients leading to major eutrophication problems in the Gulf of Mexico,
Chesapeake Bay, Long Island Sound, and other water bodies). Nutrients related to
agriculture, lawn fertilizers and sewage discharge are the number one problem in our
coastal waters and have been for the past 30 years.
The importance of land is very understated at the beginning of the chapter. The regional
breakdown is interesting but artificial. It would be more helpful if the importance of land
was conveyed in relation to the highly diverse ecosystems (or ecoregions) across the
nation. The examples given appear to be from only one or two reports. There are
sources of information generated by local, regional and state governments and by
organizations such as The Nature Conservancy, for example, that could be very helpful in
probing these more local/regional issues. With some additional analysis, which EPA
should undertake, these could be more significant than the data upon which this report
relies, and would point out threats or improvements to some of the most significant land
systems in the US. This would also assist citizen-readers in assessing how to choose their
efforts to be most effective, particularly at the local/regional level, where most land use
decisions are made.
The conclusion on p. 20 should be highlighted and brought to the beginning of the
chapter: "Between 1982 and 2002, the amount of developed land in the US increased at
nearly twice the rate of the population [growth]." This is an incredibly alarming statistic
that speaks volumes about a prevalent problem: sprawl and the lack of adoption of smart
growth principles and policies in the US. The impacts of continued sprawl relate to
habitat destruction, energy use, deteriorating air and water quality, and human health.
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D. HUMAN HEALTH
The EPA mission "to protect human health and the environment" provides ample
rationale for a chapter on human health. However, because this document is designed to
highlight a Report on the Environment, it would seem that the focus of this chapter
should be on those facets of the environment that have potential to impact human health,
and the connections between the two should be emphasized.
While this relationship is discussed in the Chapter (p. 24 "national-level health and
exposure indicators cannot be used to demonstrate a cause-and-effect relationship
between exposure to an environmental contaminant and an adverse health effect"; p. 25
"such tracking can help identify possible environmental factors that contribute to the
diseases or conditions that are the leading causes of death in the United States"; p. 26
"These indicators provide important insights on disease patterns, but cannot be used
alone to understand the role of environmental exposures"), all of the statements are
equivocal. The ROE instead should strive to be more direct about what EPA and the CDC
do know about linkages between environmental conditions and human health.
Based on the examples provided in the health section of the HD, in most cases readers
would conclude that the health of the nation is improving. If the purpose of such a
conclusion is to encourage the reader to conclude that therefore the nation's environment
is also generally improving, that would be counter to the statement above that such
indicators cannot be used to assess impacts of environmental exposure. In fact, other
factors such as improved disease diagnosis and health care may be responsible for
improved public health. Thus, improvements in public health may not necessarily mean
that the environment is improving.
This leads to the question that has been asked before in this NACEPT review: "What is
the story?" Is the story that while changes can be seen in nationwide health data, the data
available do not allow any conclusions to be drawn about relationships to exposures, or is
it something else? Whatever the point of this chapter is, it should be stated more clearly
so that readers are not led to erroneous conclusions.
A logical question from a reader may be why does EPA consider exposure to hazardous
chemicals a problem if health trends cannot be related to changes in environmental
exposure? While such a question clearly understates the complexity of the issue, further
discussion in the document about this point would be very valuable in helping the public
understand this aspect of the EPA mission and the critical link between environmental
quality and public health.
In the Key Points section on p. 26, a few classes of diseases are specifically mentioned.
NACEPT suggests that because of the current media interest it would be useful to
mention autism in children, as well as the increasing problems of childhood and adult
obesity to the extent an argument can be made that the state of the environment may be a
contributing factor to these public health issues.
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E. ECOLOGICAL CONDITION
The chapter on ecological condition is a good Ecology 101 overview with understandable
definitions and descriptions. It presents a clear format and is to the point. The language
is appropriate for a general audience, although perhaps at a slightly lower level than
necessary. The chapter meets the peer review charge by informing the reader about the
importance of environmental issues, making the information meaningful to them and
providing a means for the audiences to access more in-depth information. The message
is conveyed with good graphs, attractive color illustrations and an appropriate balance
and spacing of text and graphics.
The Key Points section on p. 29-33 provides vignettes of ecological indicators, yet the
question of "why" for many of them emerges repeatedly. For example, on p. 29 the last
paragraph on Key Points states that "much of the information about patterns of ecological
systems is more than a decade old, limiting the ability to track recent trends."
This leads to the question why? Why doesn't EPA continue to monitor ecological
condition? Why hasn't EPA sought to obtain and report on data gathered by others?
Why doesn't EPA value ecological condition enough to measure it? The same is true on
p. 30-33. Here again, the last paragraph of the key points contains embarrassingly
repetitive admissions of incomplete and/or inconclusive data. A long explanation is not
needed for any of these, but a sentence or two would be helpful.
Examples of what EPA does know about certain ecosystems that have been the focus of
strategic initiatives (Great Lakes, habitats of endangered species, Chesapeake Bay, Gulf
of Mexico, National Estuaries Program, Okefenokee Swamp, some of our national parks
with unique ecosystems) would also illustrate a higher level of commitment to ecological
resources. Such examples also could serve as success stories to inspire readers to protect
their local or regional ecosystems of concern.
V. EDITORIAL COMMENTS. SUGGESTIONS. AND CLARIFICATIONS
AIR
• p. 5: The overall sum of the toxic pollutants direction is good. Are there some
pollutant emissions that are going in the wrong direction?
* p. 5: Second column, top line - Did EPA identify these 188 air toxics or did
Congress (in the 1990 Clean Air Act Amendments)? It would be helpful for the
chart to indicate how many sites (big difference between 4 and 400).
• p. 6: Are there any large areas where the water has become more acidic?
* p. 6: Second column, last sentence - Should this sentence identify at least a
couple of substances that impair visibility? In the Key Points, last line, isn't
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opacity a measure used in cities? EPA should strive to transmit to the reader that
it fully understands the data and is ready to act on it.
p. 7: Regarding the mixing of the pollutants worldwide; to what extent do foreign
sources contribute to ozone levels in North America? Are there any worldwide
trends that are affecting US air quality?
p. 8: The Key Points do not (but should) differentiate between global and
domestic - the concentrations referenced are global and should say so every time -
and given the use of global concentration as the measure, global emissions should
be referenced after domestic emissions trends.
Need to highlight when we are addressing emissions and when we are addressing
ambient conditions. Consider clearer headings for both.
WATER
* p. 11: Second column, second line - Should it say "more tolerant" rather than
"tolerant"? In Key Points, first column, first paragraph, last sentence, the
description may not make sense to a reader. "Wadeable streams" is a difficult
term for the public to understand, especially as defined. "Wadeable" sounds like
shallow enough to sample without a boat. In the top of the next column (and on
p. 13), it is not clear what "the extent" means (it appears to have a particular
meaning, but it's not provided to the reader).
* p. 11: It is very difficult to see if waters are getting better or worse. Need a
bottom line "score" or "code" for chemical, biological, and physical conditions.
• p. 11: Graph uses different terms from those used under Key Points.
• p. 11: "National indicators are not available for many key stressors". What is
known?
* p. 11: Second Key Point - Is EPA saying that there is more water now than in the
30's and 40's? Isn't water a finite resource? Or is it the reference to useable or
potable water? The statement needs to be revised to make it clear what is
intended.
* p. 12: First column, first paragraph, second sentence - Does this mean that global
or US groundwater has 30 times the volume as global fresh surface water? In
Key Points, first paragraph, the second sentence really leaves the reader hanging -
so nearly 50% of all shallow wells tested for concentrations above the human
health benchmark? By how much? In the third paragraph, this sounds incomplete
at best - don't lots of states and groundwater authorities have information about
the water quality of deep aquifers?
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p. 12: Overall, it is hard to believe that these are the only messages that can be
gleaned from ground water data sources.
p. 12: Confusing statement: "47 of 83 pesticides". What about the other 36
pesticides for which guidelines exist?
p. 12: First Key Point - If 1% of wells had levels above the human health
benchmark, is that good or bad? Where were the wells and how many users did
they affect?
p. 12: Last Key Point - "Such events are not easily captured in measures" is
confusing. Perhaps it can be termed "not measurable" or "cannot be measured
easily" instead.
p. 13: In the main text and Key Points, "extent" is used several times - it is not
clear exactly what that means here - the data source appears to be one person (T.
E. Dahl). If possible, it would be advisable to link an agency or organization to
that single source.
p. 13: How good are the acreage data? At one time there were some significant
questions regarding the accuracy of these estimates.
p. 13: Last sentence in the second paragraph: "Gains can occur"- seems a little
redundant after saying ..."cause of wetland loss" therefore additional elaboration
is suggested.
p. 13: It would be good to know why the trend in wetland acreage is changing for
the better.
p. 14: How representative of all coastal areas are those sampled? Also, is the
70% figure inconsistent with the "wadeable streams" data on page 11? It seems
counter intuitive that the benthic communities in the streams are in such poor
shape and those in the estuaries are in such good shape. At a minimum, the
seeming inconsistency should be explained.
p. 14: At the bottom of the left-side column on Key Points, in talking about the
Gulf of Mexico "dead zone," it states that "substantial areas of hypoxia.. .remain."
This language may unintentionally give the impression that hypoxia was a major
problem in the past, it's improving, but some substantial parts remain. However,
isn't hypoxia a worsening problem in the Gulf rather than the "remainder" of a
largely resolved problem?
p. 14: While there are no national indicators for the condition of coral reefs, this
is another problem area where regional data could be used to indicate its potential
seriousness. For example, Florida's coral reefs are already in serious decline.
Recently both Elkhorn and Staghorn Caribbean coral were added to the list of
threatened species under the Endangered Species Act. Both species have declined
by 97 percent since the late 1970s.
p. 16: Recreational Waters: This is the weakest topic, yet one in which the public
may have great interest. Stating that EPA just can't possibly discuss beach water
conditions is hard to fathom. EPA talks about beach water quality all the time,
issues reports, gives grants, partners with states and NGOs, etc. If it really is true
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that EPA can't discuss such conditions in a scientifically defensible manner, the
ROE should at least reference the information that does exist and where the reader
can find that information. There may be value in a discussion of how EPA must
use data that is not as scientifically valid as desired in order to make rapid
decisions, if this is the reason for lack of data in this case. Could state data be
used in a suggestive way to illustrate the mixed picture or even to give a sense of
the overall direction of change over the past generation?
* p. 16, p. 17: In Key Points, first and second paragraphs, the last sentence's
disclaimer about how all EPA's work failed to focus on the most important
(known) areas makes EPA sound problematic or misguided. Is EPA going to
survey those areas next year? Is there any information/data EPA could use here?
Further explanation in this area would be very helpful.
HUMAN HEALTH
• p. 17: Should the report draw on FDA or USD A data to "round out" the picture?
Also, people will want to know "is our nation's seafood safe to eat?" This page
does not answer that important question. Consumable Fish and Shellfish: Should
there be a "key point" related to the rapid growth and impacts of aquaculture?
• p. 22: First column, second paragraph: Isn't volume or mass proportional to
toxicity sometimes? Maybe EPA could just insert "necessarily" between "not"
and "proportional".
* p. 23: In the Key Points first paragraph and chart, is it intended that the reader
should conclude that it is likely that at 20% of all Superfund sites people are
exposed to contamination above health-based standards?
* p. 25, 26, and 27: Health status Key Points: The rosy picture that's painted in the
opening statement, that overall health is improving, isn't really supported by the
information and data that follow.
• p. 25: Suggest changing "health" to "lifespan" in the opening bold-faced
statement under Key Points (Of course, lifespan can be greatly influenced by
medical advancements and may not be a function of environmental
improvements. This should be more clearly explained). Likely both lifespan and
health should be cited. As an example, the incidence certain cancers is decreasing
and survival rates are increasing - which speaks both to health and lifespan.
• p. 25: Mortality needs to be defined for the public.
* p. 25: In the chart, is the horizontal set of dates the dates in which people are born
and their life expectancy as of that date? Do life expectancies change over time
(after people are born)?
ECOLOGICAL CONDITION
* p. 29: In column 1, first paragraph, "extent" is used here, too, with no definition.
In the second column, first full paragraph, EPA may want to edit the first sentence
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so it doesn't sound like EPA believes climate change is all natural (it doesn't say
that, but some will read it that way). In Key Points, fragmentation is used as the
sole barometer of the forest's health - Are there any other indicators (or studies
looking at disease, etc.)? Why are forests picked as the sole example, rather than
looking at wetlands or prairies or some other system, as well?
p. 29: The Pine Beetle infestation in the West is a major pattern in forest
ecological conditions and is creating fragmentation, increased fuel loading, and a
change in the forest type. Perhaps this should be noted in this section or perhaps
in the Diversity section.
p. 29: Key Points, first paragraph, provide an example after ..."development
patterns".
p. 30: Line 6 of the first paragraph of Key Points, an example of some of the
native fish loss would be beneficial.
p. 30: Last paragraph on Biological Diversity, date of the lamprey introduction
and reasons why sweeping changes occurred in the food web should be added.
p. 30: In Key Points, first column, second paragraph, is the document talking
about native bird populations, including increases and decreases, or just total
numbers of all birds? EPA should reference the work that the Department of
Interior does on endangered species (rather than saying that EPA doesn't have
consistent national indicators for any other types of animals).
p. 31: The chart is hard to read - maybe easier if it is redone to compare north to
north across the time periods, and then look to south to south across the time
periods - now, the reader has to jump back and forth to see how each region did.
p. 32: In Key Points, lots of readers will focus on the first paragraph. Are the
trends noted here global or US only?
p. 33: In Key Points, is ozone pollution an example of bioaccumulation? If so it
should be explained. Most people don't picture ozone accumulating inside a plant
or causing problems when an animal eats it - should the fish tissue paragraph also
note that humans may be impacted?
p. 34: The last sentence of the first paragraph in the section titled "About the
Indicators" should start out "A subset of these", by adding the word "of.
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APPENDIX A: NACEPT Report on the Environment Workgroup Members
Workgroup Members
Jeff Crane
Executive Director
Colorado Watershed Assembly
Carolyn Green
Vice-President
Health, Environment and Safety
Regulatory Affairs
Sunoco, Inc.
Stan Laskowski
Lecturer/Advisor
Master of Environmental Studies Program
University of Pennsylvania
Arleen O'Donnell (*Co-Chair)
Board of Directors
Massachusetts Environmental Trust
Bob Olson
Senior Fellow
Institute for Alternative Futures
Bradley Smith
Dean
Huxley College of the Environment
Western Washington University
Victoria Tschinkel
Executive Committee Member
1000 Friends of Florida
Dan Watts (*Co-Chair)
Executive Director
York Center for Environmental
Engineering & Science
New Jersey Institute of Technology
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Workgroup Members from the Science Advisory Board (SAB)
George Lambert
Associate Professor of Pediatrics
Director, Center for Childhood Neurotoxicology
Robert Wood Johnson Medical School-UMDNJ
Robert Twiss
Professor of Environmental Planning Emeritus
University of California-Berkeley
NACEPT Chair
John Howard
Partner
Vinson & Elkins, LLP
NACEPT Designated Federal Officer
Sonia Altieri
Office of Cooperative Environmental Management (OCEM)
U.S. Environmental Protection Agency
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APPENDIX B: NACEPT CHARGE
Peer Review Charge for EPA's 2007 Report on the Environment: Highlights of
Conditions and Trends
The U.S. Environmental Protection Agency (EPA) has asked independent peer reviewers
to critically review EPA 's 2007 Report on the Environment Highlights of Conditions and
Trends (Highlights Document or HD). Reviewers are asked to evaluate if the HD is an
appropriate distillation of EPA 's 2007 Report on the Environment Technical Document
(Technical Document or TD) and if the HD is presented effectively for the target
audience.
The purpose of the Highlights Document is to present national status and trends in the
environment and human health in a clear, engaging manner to a public audience of
"civic-minded individuals." The HD should inform the audience about important
environmental issues, make the information meaningful to them, and provide a means for
the audience to access more in-depth information.
The Agency's approach to these issues was informed by the overall purpose of the Report
on the Environment (ROE), the nature of the TD as its source document, and by feedback
on an earlier publication, the Draft Report on the Environment Public Document 2003
(PD03).
Using the guidance in Section 1 and the more detailed background information in
Section 2 (pp. 2-5), please address the three peer review charge questions. Please
become familiar with the HD's scope and layout so you can adequately address charge
question 2.
Section 1: Charge Questions and Review Materials
The draft Highlights Document is being reviewed for content in the following important
areas:
* Scientific accuracy and alignment with the Technical Document. •
* Presentation to the target audience.
The following materials are provided:
Review Document
* Draft Highlights Document
Background Materials
• ROE07 Technical Document.
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* Attachment A to the Charge: ROE07 Indicator Definition and Criteria.*
• Attachment B to the Charge: ROE07 Questions and Supporting Indicators.
The first charge question is directed to SAB reviewers who are also reviewing the
Technical Document. Questions 2 and 3 are to be answered by all reviewers.
Considering the background information provided in Section 2 below, please read the
review document and respond to the following questions:
SAB reviewers:
1. Does the Highlights Document accurately represent the scientific content of the
Technical Document? Are key areas over- or under-represented? Would someone
familiar with both documents come to the same conclusions regarding human health and
the state of the nation's environment?
All reviewers:
2. The Highlights Document distills the information found in the Technical Document. Is
the Highlights Document scientifically accurate? What conclusions would one come to
regarding human health and the state of the nation's environment?
3. Is the information in the Highlights Document presented in a way that is
understandable to the target audience? Are the structure and length of the Highlights
Document appropriate for its content and the target audience? How could the
presentation be improved?
Section 2: Background
Purpose of EPA's 2007 Report on the Environment
EP'A's Report on the Environment 2007 (ROE07) consists of three products:
1. A Technical Document written for environmental professionals. This document
forms the scientific basis of all three products.
2. A Highlights Document written for civic-minded individuals.
3. An electronic Report on the Environment that facilitates access to the data and
their sources.
The purpose of ROE07 is to answer questions that the Agency believes best reflect its
mission to protect human health and the environment. To the extent possible, this is
accomplished using a suite of indicators that have been subjected to rigorous peer review.
The ROE07 summarizes and communicates what is known and not known about the
current status and trends in the condition of air, water, land, human health, and ecological
systems in the nation. EPA intends to use this information to inform its strategic
planning and decision-making.
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A fundamental premise of the ROE is that it uses only peer-reviewed indicators to answer
the questions. Though many other environmental data sources, publications, and site-
specific research projects are available, the ROE intentionally uses only indicators that
rely on physical, chemical, and biological measurements to monitor trends in condition
over time.
Further, the 2007 ROE focuses on national-level indicators. National indicators address
ROE questions at national as opposed to regional or local scales and thus provide a broad
and relatively coarse picture of condition.
ROE Review
In 2003, EPA released its first ROE, the Draft Report on the Environment 2003
(DROE03), which consisted of a Public Document (PD03) and a Technical Document.
Both documents were reviewed by EPA's Science Advisory Board and national "dialog
sessions" were held in six cities to receive comments on the report's utility and to obtain
feedback on how to improve future reports. EPA then developed the updated Technical
Document and Highlights Document currently under review.
The indicators in the 2007 ROE Technical Document were reviewed by external
scientists in 2005 and the entire draft TD will be reviewed by EPA's Science Advisory
Board. In addition, drafts of the 2007 ROE Highlights Document were reviewed by EPA
and by other federal agencies. The HD has incorporated the results of these reviews to
create the present document.
Development of the ROE07 Technical Document
Questions. A series of 23 important questions concerning trends in the condition of the
environment and human health have been developed and form the structural basis of the
report. The questions focus not only on EPA's current regulatory and program activities,
but also on issues clearly related to EPA's mission to protect human health and the
environment. The questions should be answered as fully as possible if EPA is to be
adequately informed about important environmental trends. However, it is recognized
that the questions cannot be answered completely based on the available data.
Indicators. The questions are answered using indicators that meet an explicit definition
and a set of criteria (see Attachment A). These indicators come from a number of
sources, including the DROE03, EPA, other federal agencies, and non-profit
organizations. All proposed indicators were screened for their ability to pass a peer
review based on the indicator definition and criteria. Based on the peer reviewer
recommendations, some indicators were dropped from further consideration and others
were revised for inclusion in the Technical Document. The final set of indicators is listed
in Attachment B.
Other Elements of the TD. The questions and their associated indicators are presented in
five main chapters of the TD; Air, Water, Land, Human Health, and Ecological
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Condition. The text for each question describes the scope of the question, presents the
indicators used to answer the question, and summarizes the "answer" that the available
indicators provide to the question, along with limitations and gaps (i.e., where no
indicators meeting the criteria are currently are available to answer important aspects of
the question). The TD also includes an introduction and several appendices.
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Development of the Highlights Document
In developing the HD, EPA has benefited from feedback from several groups, including
EPA's Science Advisory Board, the National Advisory Council for Environmental Policy
and Technology, the Local Government Advisory Committee, and a series of national
dialog sessions in 2003 and 2004.
Audience
The target audience for the 2007 Highlights Document is "civic-minded individuals,"
which is a subset of the population that has some interest and knowledge of the
environment and is likely to seek environmental information. Civic-minded individuals
include members of civic or community groups, members of environmental groups,
parents, students, educators, and local decision-makers. In addition, there are secondary
audiences for the HD who are not environmental or health professionals, but are likely to
use the HD rather than the TD for professional purposes. Examples of these audiences
include the media, policymakers, industry, and real estate professionals.
This target audience is deliberately narrower than the PD03 target audience of the
"educated layperson." This change was made in response to feedback which encouraged
EPA to design the HD for a more tailored audience and to make the HD considerably
shorter than the PD03. By targeting the civic-minded individual, the HD is likely to
appeal to the individuals it is most likely to reach, rather than a broad general public
audience, most of whom have limited interest in the material. In other words, the HD is
targeted to those who will read it, rather than those who will not. If the HD targeted a
broader audience, the informed readers would need to wade through long explanations of
basic concepts before reaching the information they seek, and assume that the HD is not
for them.
Purpose
EPA received comments from multiple venues indicating that the HD would be more
effective if its purpose was defined more precisely. Reviewers suggested that without
certain revisions in the Highlights Document, EPA would miss an opportunity to engage
and educate Americans on the state of the environment. Based on this feedback and
considering the needs of the target audience, EPA proposed three purposes for the
Highlights Document:
1. Describe the highlights in conditions and trends in the environment and human
health.
2. Inform the audience about important environmental issues and make the
information meaningful to them.
3. Provide a means for the audience to delve deeper into environmental indicators
and information.
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The first purpose is central to the ROE as a whole and includes the key point, as does the
TD, that EPA's ability to describe conditions and trends in many areas is limited by
incomplete information. The second purpose for the HD is to inform the public about
important environmental issues and increase the level of environmental literacy. The
third purpose is to provide a means for the audience to learn more about indicators and
environmental and health issues. Given the goal of creating a shorter HD, the document
could not provide details about any single topic. However, it should whet readers'
appetites and direct them to more detailed information in the 2007 TD and the e-ROE.
Length
The PD03 was 160 pages long. Groups and individuals commenting on the PD03 clearly
recommended that the next version be much shorter. The ROE07 TD presents indicators
to address the 23 questions and is organized into five chapters (see Attachment B). The
HD is similarly organized, with one exception. The Outdoor Air question of the TD was
divided into three parts in the HD (Outdoor Air, Acid Rain and Regional Haze, and
Ozone Depletion) because in the TD this question includes more than 25 indicators. To
keep the HD brief, each topic is allocated a single page.
Content
Each page provides background information and summarizes the status and trends based
on the available indicators, while also acknowledging indicator gaps and limitations.
Each page also includes a graphic to illustrate one of the indicators.
A basic premise of the ROE07 HD was that its scientific content would be derived
entirely from the Technical Document. In order to distill the large quantity of
information in the TD into a short HD, EPA highlighted indicators for each topic using
several criteria:
* Scientific importance,
* Importance to civic-minded individuals,*
* Degree to which the indicator contributes to answering the ROE question,* •
* Degree to which there are significant changes in trends in recent years, and* •
* New indicator.
This information is shown in bulleted form on each topic page.
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ATTACHMENTS A AND B OF THE CHARGE TO NACEPT
ATTACHMENT A: ROE07 INDICATOR DEFINITION AND CRITERIA
Indicator Definition
A numerical value derived from actual measurements of a pressure, ambient condition,
exposure, or human health or ecological condition over a specified geographic domain,
whose trends over time represent or draw attention to underlying trends in the condition
of the environment. Indicators and their underlying data must meet criteria (see box
below) for data quality, comparability, representativeness, and adequate coverage in time
and space. Note that indicators rely on an underlying database or set of databases, but the
databases themselves are not indicators.
Indicator Criteria
1) The indicator makes an important contribution to answering a question for the ROE.
(In this context, "important" means that the indicator answers a substantial portion of
and/or a critical part of the question.)
2) The indicator is objective. It is developed and presented in an accurate, clear,
complete, and unbiased manner.
3) The underlying data are characterized by sound collection methodologies, data
management systems that protect their integrity, and quality assurance procedures.
4) Data are available to describe changes or trends, and the latest available data are
timely.
5) The data are comparable across time and space, and representative of the target
population. Trends depicted in this indicator accurately represent the underlying
trends in the target population.
6) The indicator is transparent and reproducible. The specific data used and the specific
assumptions, analytic methods, and statistical procedures employed are clearly stated.
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ATTACHMENT B: ROE07 QUESTIONS AND SUPPORTING INDICATORS
Air
Outdoor Air
What are the trends in outdoor air quality and their effects on human health and the
environment?
Carbon Monoxide Emissions; Ambient Concentrations of Carbon Monoxide; Lead
Emissions;
Ambient Concentrations of Lead; Nitrogen Oxides Emissions; Ambient Concentrations
of Nitrogen Dioxide; Volatile Organic Compound Emissions; Ambient Concentrations of
Ozone; Ozone Injury to Forest Plants; Particulate Matter Emissions; Ambient
Concentrations of Particulate Matter (PM); Sulfur Dioxide Emissions; Percent of Days
with Air Quality Index Values > 100 ; Mercury Emissions; Air Toxics Emissions;
Ambient Concentrations of Benzene; Ozone and PM Concentrations for U.S. Counties in
the U.S./Mexico Border Region; Ambient Concentrations of Manganese Compounds in
EPA Region 5
Acid Rain and Regional Haze
What are the trends in outdoor air quality and their effects on human health and the
environment?
Nitrogen Oxides Emissions; Regional Haze; Sulfur Dioxide Emissions; Acid Deposition;
Lake and Stream Acidity; Particulate Matter Emissions
Ozone Depletion
What are the trends in outdoor air quality and their effects on human health and the
environment?
Concentrations of Ozone-Depleting Substances; Ozone Levels over North America
Greenhouse Gases
What are the trends in greenhouse gas emissions and concentrations?
U.S. Greenhouse Gas Emissions; Atmospheric Concentrations of Greenhouse Gases
Indoor Air
What are the trends in indoor air quality and their effects on human health?
U.S. Homes Above EPA's Radon Action Levels; Blood Cotinine Level
Water
Fresh Surface Waters
What are the trends in extent and condition of fresh surface waters and their effects on
human health and the environment?
High and Low Stream Flows; Streambed Stability in Wadeable Streams; Nitrogen and
Phosphorus in Wadeable Streams; Nitrogen and Phosphorus in Streams in Agricultural
Watersheds; Nitrogen and Phosphorus Discharge from Large Rivers; Pesticides in
Streams in Agricultural Watersheds; Benthic Macroinvertebrates in Wadeable Streams;
Lake and Stream Acidity
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Ground Water
What are the trends in extent and condition of ground water and their effects on human
health and the environment?
Nitrate and Pesticides in Ground Water in Agricultural Watersheds
Wetlands
What are the trends in extent and condition of wetlands and their effects on human health
and the environment?
Wetland Extent, Change, and Sources of Change
Coastal Waters
What are the trends in extent and condition of coastal waters and their effects on human
health and the environment?
Coastal Water Quality; Coastal Sediment Quality; Coastal Benthic Communities;
Submerged Aquatic Vegetation in Chesapeake Bay; Hypoxia in the Gulf of Mexico and
Long Island Sound; Harmful Algal Blooms along the Western Florida Coastline; Coastal
Fish Tissue Contaminants; Wetland Extent, Change, and Sources of Change
Drinking Water
What are the trends in the quality of drinking water and their effects on human health?
Population Served by Community Water Systems with No Reported Violations of
Health-Based Standards
Recreational Waters
What are the trends in the condition of recreational waters and their effects on human
health and the environment?
There are currently no national indicators available for this topic.
Consumable Fish and Shellfish
What are the trends in the condition of consumable fish and shellfish and their effects on
human health?
Coastal Fish Tissue Contaminants; Contaminants in Lake Fish Tissue
Land
Land Cover
What are the trends in land cover and their effects on human health and the
environment?
Land Cover; Land Cover in the Puget Sound/Georgia Basin; Forest Extent and Type
Land Use
What are the trends in land use and their effects on human health and the environment?
Land Use; Urbanization and Population Change
Wastes and the Environment
What are the trends in wastes and their effects on human health and the environment?
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Quantity of Municipal Solid Waste Generated and Managed; Quantity of RCRA
Hazardous Waste Generated and Managed
Chemicals Applied and Released to Land
What are the trends in chemicals used on the land and their effects on human health and
the environment?
Fertilizer Applied for Agricultural Purposes; Toxic Chemicals in Production-Related
Wastes Released, Treated, Recycled, or Recovered for Energy Use; Pesticide Residues in
Food; Reported Pesticide Incidents
Contaminated Land
What are the trends in contaminated land and their effects on human health and the
environment?
High-Priority Cleanup Sites with No Human Contact to Contamination In Excess of
Health-Based Standards; High-Priority Cleanup Sites Where Contaminated Ground
Water Is Not Continuing to Spread Above Levels of Concern
Human Health
Health Status
What are the trends in human health status in the United States?
General Mortality; Life Expectancy at Birth; Infant Mortality
Diseases and Health Conditions
What are the trends in human disease and conditions for which environmental pollutants
may be a risk factor, including across population subgroups and geographic regions?
Cancer Incidence; Cardiovascular Disease Prevalence and Mortality; Chronic Obstructive
Pulmonary Disease Prevalence and Mortality; Asthma Prevalence; Infectious Diseases
Associated with Environmental Exposures or Conditions; Childhood Cancer Incidence;
Birth Defects Rates and Mortality; Low Birthweight; Preterm Delivery
Exposure to Environmental Contaminants
What are the trends in human exposure to environmental contaminants including across
population subgroups and geographic regions?
Blood Lead Level; Blood Mercury Level; Blood Cadmium Level; Blood Cotinine Level;
Blood Persistent Organic Pollutants (POPs) Level; Urinary Pesticide Level; Urinary
Phthalate Level
Ecological Condition
Patterns in Ecological Systems
What are the trends in the extent and distribution of the nation's ecological systems?
Forest Extent and Type; Forest Fragmentation; Ecological Connectivity in EPA Region
4; Relative Ecological Condition of Undeveloped Land in EPA Region 5; Land Cover;
Land Use; Urbanization and Population Change; Wetland Extent, Change, and Sources of
Change; Land Cover in the Puget Sound Basin
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Biological Diversity
What are the trends in the diversity and biological balance of the nation's ecological
systems?
Bird Populations; Fish Faunal Intactness; Non-Indigenous Estuarine Species in Pacific
Northwest; Coastal Benthic Communities; Harmful Algal Bloom Outbreaks along the
Western Florida Coastline; Submerged Aquatic Vegetation in Chesapeake Bay; Benthic
Macroinvertebrates in Wadeable Streams
Ecological Processes
What are the trends in the ecological processes that sustain the nation's ecological
systems?
Carbon Storage in Forests; Ecological Connectivity in EPA Region 4
Physical and Chemical Attributes of Ecological Systems
What are the trends in the critical physical and chemical attributes and processes of the
nation's ecological systems?
U.S. and Global Mean Temperature and Precipitation; Sea Surface Temperature; Sea
Level; High and Low Stream Flows; Lake and Stream Acidity; Nitrogen and Phosphorus
Discharge from Large Rivers; Nitrogen and Phosphorus in Streams in Agricultural
Watersheds; Nitrogen and Phosphorus in Wadeable Streams; Streambed Stability in
Wadeable Streams; Hypoxia in the Gulf of Mexico and Long Island Sound
Ecological Exposure to Contaminants
What are the trends in biomeasures of exposure to common environmental pollutants in
plants and animals?
Coastal Fish Tissue Contaminants; Contaminants in Lake Fish Tissue; Ozone Injury to
Forest Plants
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Shaping ih« Nation's EnvKortmerial Policy
National Advisory Council for Environmental Policy and Technology
January 28, 2008
Administrator Stephen L. Johnson
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Re: NACEPT Comments on EPA's 2007Report on the Environment:
Highlights of National Trends
Dear Administrator Johnson:
On behalf of the National Advisory Council for Environmental Policy and Technology, I am
pleased to forward to you the Council's comments on EPA's draft 2007 Report on the
Environment: Highlights of National Trends (ROE/HD).
The Council commends EPA for preparing the Report and working to improve it. Better
understanding of our nation's environmental conditions and effectively communicating that
information to the public is essential to making sound policy and fostering the environmental
stewardship necessary to implement it. NACEPT strongly encourages the agency to continue
this work.
The Council concludes that the Highlights Document accurately represents the scientific content
of the Report on the Environment's Science Report. However, we have several concerns, and
offer recommendations to address those concerns, regarding the agency's ability to chart
environmental changes and to report and track trends.
In the attached comments, the Council suggests ways to strengthen the Report, including:
• Maintain the integrity of the Report. The Report should be as independent as possible of
EPA regulatory activities, and it should not be used as a public relations tool to highlight
favorable results or obscure problems.
* Select scientifically valid indicators that address the most important environmental
issues, describe in the Report the cause-and-effect relationships to inform those
indicators, and maintain the same set of indicators across Reports to allow meaningful
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evaluation by the agency and the public. New issues will necessitate the addition of new
indicators but should not detract from the continuity of the historical indicators.
• Highlight regional examples of environmental conditions and trends and provide
available regional data.
• Draw some conclusions from the data presented (within each chapter and at the Report's
end) to give the agency and the public some sense of whether conditions are getting
better, worse, or staying the same.
• Provide information (or links) for how individuals can be better stewards in addressing
problems the Report identifies.
• Ensure on-line access to and more frequent updates of the Report's data and trends, and
inform hard-copy readers about the electronic version and the opportunities to drill down
to other levels of data.
We also are attaching public comments we received regarding several groups' request that EPA
address light pollution. We appreciate you giving us the opportunity to comment on this critical
document, and we stand ready to provide any additional input or answer any questions about our
comments.
Sincerely,
/Signed/
John L. Howard, Jr.
Chair
cc: Arleen O'Donnell, Working Group Co-Chair
Dan Watts, Working Group Co-Chair
Marcus Peacock, Deputy Administrator
Charles Ingebretson, Chief of Staff
Ray Spears, Deputy Chief of Staff
Molly O'Neill, Assistant Administrator for Environmental Information and Chief
Information Officer
Mike Flynn, Director, Office of Information Analysis and Access, OEI
Vanessa Vu, Director, Science Advisory Board
Rafael DeLeon, Director, Office of Cooperative Environmental Management
Sonia Altieri, NACEPT Designated Federal Officer
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