UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   WASHINGTON D.C.  20460
                                                               OFFICE OF THE ADMINISTRATOR
                                                                 SCIENCE ADVISORY BOARD
                                     June 8, 2007

EPA-SAB-07-007

Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
       Subject:      Science Advisory Board (SAB) Advisory on the Office of Research and
                    Development's (ORD) Sustainability Research Strategy and the Science
                    and Technology for Sustainability Multi-year Plan
Dear Administrator Johnson:

       At the request of the Office of Research and Development (ORD), the SAB recently
reviewed ORD's Sustainability Research Strategy (Strategy) and the related Science and
Technology for Sustainability Multi-year Plan (Plan).

       The SAB's Environmental Engineering Committee, augmented with other SAB members
for this advisory, strongly endorses the Agency's proposal to establish a research program
focused on Sustainability because the results from such a program will improve the scientific
foundation for a sustainable environment.  Within the context of the current review, the
Committee understood Sustainability to be defined as "a means to create and maintain conditions
under which humans and nature can exist in productive harmony and that permit fulfilling the
social, economic and other requirements of present and future generations of Americans".

       Environmental protection has primarily been achieved through regulations and
enforcement. The Committee applauds the Agency's steady movement towards a systems-based
approach to environmental decision-making that reflects the complexity of the world in which
we live and effectively balances environmental protection and societal interests.

       The Strategy, which emphasizes interdisciplinary approaches to environmental
protection, provides an effective road map for the transition of the ORD's Pollution Prevention
and New Technologies program to the new Science and Technology for Sustainability program.

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The Strategy identifies research that will support risk-based environmental protection decisions
without compromising society's economic or social development goals. The Plan, which
describes the Agency's proposed sustainability research and technical activities, explicitly
supports the Strategy while establishing a scientific framework for generating the environmental
and public health information vital for achieving the Agency's short and long term sustainability
research goals.

       Although the science in the Plan is sound, it is unlikely that the Agency's sustainability
outcomes will be achieved within five-years.  Success in that time frame requires greater
resources, both human and financial.  Obviously, a workforce with experience and expertise
relating to sustainability is necessary. A management structure aligned with a systems-based
approach to environmental decision-making is also vital.  Creative human resource programs can
draw on both expertise within the Agency's current workforce and uniquely trained individuals
from outside the Agency to foster a capable sustainability workforce.  Less than one percent of
the Agency's Science and Technology appropriation is budgeted for the sustainability research
program. Given the Strategy's stated goal of integrating the concept of sustainability throughout
the Agency's science and research programs,  the SAB was concerned by this proposed level of
funding. The  sustainability research program funding level should be commensurate with its
value to Agency decision-making.  As such, a substantially higher budgetary commitment is
critically needed for a viable sustainability research program.

       The Agency is a scientifically credible steward of environmental protection. That
credibility allows the Agency to assume a substantive and visible role in sustainability research.
A number of government agencies, private industry and non-governmental organizations have
already endorsed and adopted environmental  sustainability as a framework for environmental
management. Therefore, the SAB encourages the Agency to use the opportunity that ORD's
sustainability research program provides to promote and coordinate sustainability-based science
and research activities across the federal and private sectors.

       Thank you for the opportunity to provide advice on this important and timely topic. The
SAB applauds the Agency's leadership in advancing the scientific foundation for environmental
sustainability.  The SAB would also like to acknowledge its pleasure in working with a very
dedicated, knowledgeable and responsive ORD  scientists and managers. The SAB looks forward
to receiving your response to this advisory.
                                        Sincerely,
       /Signed/
   /Signed/
Dr. M. Granger Morgan, Chair
EPA Science Advisory Board
Dr. Michael J. McFarland, Chair
Environmental Engineering Committee

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                                     NOTICE

This report has been written as part of the activities of the EPA Science Advisory Board, a
public advisory group providing extramural scientific information and advice to the
Administrator and other officials of the Environmental Protection Agency.  The Board is
structured to provide balanced, expert assessment of scientific matters related to the problems
facing the Agency. This report has not been reviewed for approval by the Agency and,
hence, the contents of this report do not necessarily represent the views and policies of the
Environmental Protection Agency, nor  of other agencies in the Executive Branch of the
Federal government, nor does mention  of trade names or commercial products constitute a
recommendation for use. Reports of the EPA Science Advisory Board are posted on the EPA
website at http://www.epa.gov/sab.

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                     U.S. Environmental Protection Agency
                             Science Advisory Board
     Environmental Engineering Committee Augmented for Sustainability
                                    Advisory
CHAIR
Dr. Michael J. McFarland, Utah State University, Logan, UT

ENVIRONMENTAL ENGINEERING COMMITTEE MEMBERS
Dr. Viney Aneja, North Carolina State University, Raleigh, NC

Dr. David A. Dzombak, Carnegie Mellon University, Pittsburgh, PA

Dr. T. Taylor Eighmy, University of New Hampshire, Durham, NH

Dr. Catherine Koshland, University of California, Berkeley, Berkeley, C A

Dr. Reid Lifset, Yale University, New Haven, CT

Dr. Mark Rood, University of Illinois, Urbana, IL

Dr. John R. Smith, Alcoa Inc., Alcoa Center, PA

OTHER SAB MEMBERS
Dr. Anna Alberini, University of Maryland, College Park, MD
(Environmental Economics Advisory Committee)

Dr. William Mitsch, The Ohio State University, Columbus, OH
(Ecological Processes and Effects Committee)

Mr. David Rejeski, Woodrow Wilson International Center for Scholars, Washington, DC
(Chartered Science Advisory Board)

Dr. Thomas L. Theis, University of Illinois at Chicago, Chicago, IL
(Chartered Science Advisory Board)

Dr. Valerie Thomas, Georgia Institute of Technology, Atlanta, GA
(Chartered Science Advisory Board)
SCIENCE ADVISORY BOARD STAFF
Ms. Kathleen White, Washington, DC

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                               Table of Contents
Summary                                                1

 General Recommendations                                1

 Recommendations on the Sustainability Research Strategy     4

 Recommendations on the Science and Technology for        7
  Sustainability Multi-year Plan


Responses to Charge Questions on the Strategy              11


Responses to Charge Questions on the Plan                  21


Discussion of General Recommendations                   29
                                      in

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                                      Summary

The SAB Environmental Engineering Committee, augmented with other SAB members, was in
unanimous agreement that, together, the Strategy and Plan form an excellent first step in the
Agency's transition from the historical single media or "stovepipe" approach to environmental
protection to a systems approach that continues to focus on and achieve environmental
protection. The Strategy, which basically describes a research framework for addressing the
technical,  social and economic complexity of current and emerging environmental protection
issues, constitutes a new paradigm that explicitly embraces the application of life-cycle
principles in support of short and long-term risk management decisions.  On January 24, 2007,
the White House issued an Executive Order Strengthening Federal Environmental, Energy, and
Transportation Management, that said sustainable, "means to create and maintain conditions,
under which humans and nature can exist in productive harmony, that permit fulfilling the social,
economic, and other requirements of present and future generations of Americans."  This
definition is consistent with the Committee's understanding of sustainability in the context of the
current review.

Accompanying the Strategy is the Agency's sustainability Plan, which describes the specific
research and technical activities proposed by the Agency that will support future sustainability -
focused environmental decision-making.  The Committee fully endorses the Plan as the blueprint
for the Agency to achieve both its short and long term sustainability outcomes.  However, the
Committee also recognizes that ensuring successful sustainability outcomes depends on the
Agency's ability to commit sufficient resources to support the development, dissemination and
application of new environmental monitoring and assessment technology as well as the design
and implementation of suitable  sustainability metrics and indicators. The Committee is
confident that full implementation of the sustainability Plan will generate vital scientific and
technical information that will enable Agency decision-makers to better address both present and
emerging environmental issues.

The Committee strongly supports the Agency's decision to establish a sustainability research
program to address the multifaceted nature of current and emerging environmental problems.
The Committee applauds the Agency's determination to look beyond the media-specific
regulatory model to explore a more integrative approach to environmental protection that is
cognizant of the economic and social impacts of environmental decision-making. Environmental
protection decisions that also support the economic and social well being of future generations is
of paramount importance to Agency decision-makers and the Strategy clearly establishes the
path for achieving that goal.

Similarly, given the expanding technical and social science based information needed to support
sustainability-focused environmental decisions, internal restructuring of the Agency's current
programs is required to manage and direct data collection and processing. To this end, the
Committee acknowledges that the Strategy provides a clear road map for facilitating the
Agency's transition from the Pollution Prevention and New Technology (PPNT) program to the
Technology for Sustainable Outcomes program.

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Of particular importance to achieving broad Agency adoption of the sustainability paradigm is
the creation and deployment of a technical workforce effectively trained in the practical
application of environmental sustainability concepts and methods. The Committee encourages
ORD to work with senior Agency management to establish and reinforce the institutional
changes necessary to foster a greater understanding and appreciation for the economic and
societal benefits of sustainability-centered environmental protection.

The Committee strongly supports the Agency's decision to advance environmental stewardship
and collaborative problem solving to achieve measurable, sustainable outcomes. The Committee
applauds the Agency's progression from pollution control to pollution prevention to
sustainability.

Because of the Agency's international reputation as a scientifically credible steward of
environmental protection, the Committee strongly encourages the Agency to assume a more
substantive and visible role in conducting and disseminating results of sustainability research.
Other government agencies (both national and international), commercial industry and a myriad
of non-governmental organizations and private citizens have endorsed environmental
sustainability.  Moreover, as global recognition of the economic and societal impacts on
environmental decision-making increases, the interdisciplinary approach to solving
environmental issues endorsed by the Strategy and Plan elevates the Agency's environmental
stewardship profile. EPA's scientific capability can be of great value to the sustainability
concepts for environmental management.  By providing a scientific foundation for sustainability
approaches, EPA provides a sound basis for its own sustainability programs and for those of
others.

General Recommendations

1.      The Committee recommends that the Agency better define those terms associated with
       the sustainability strategy and the measurement of sustainability outcomes.

To minimize the confusion and ambiguity for the targeted audience of both the Strategy and the
Plan, the Committee encourages the Agency to define more clearly what is meant by the term
sustainability.  Both documents would benefit from explicit acknowledgement of the competing
definitions of sustainability, thereby providing a context for the Agency's choice among the
various definitions of this term and recognition of alternative views of this  contested and often
nebulous topic.

2.      The Committee supports application of sustainability principles  to address and resolve
       specific, multi-faceted environmental problems.

The Committee acknowledges that the judicious selection of research projects within the Plan
will help to facilitate the diffusion and adoption of the sustainability paradigm both within and
outside the Agency. To ensure a successful Agency transition from the traditional media-specific
"stove pipe" approach to a more integrated systems approach to environmental protection
requires that the sustainability research activities be scientifically compelling and have wide
national visibility.  Moreover, the sustainability research products should strategically integrate

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into the Agency's other 16 multi-year plans and provide the technical focus that guides the
sustainability research activities conducted by other federal agencies.

The Agency should be prepared to undertake some "higher risk - higher payoff projects, i.e.,
projects that because of complexity, data requirements, methodological novelty, and
interdisciplinary focus may be challenging, but would have a large impact if they are indeed
developed successfully.  The project portfolio should also balance targeted Agency needs and
geography. The project portfolio should become the basis for articulating the relationship
between projects and products for the annual performance measures (APM) and annual
performance goals (APG) described in the Plan.

3.      To encourage broad adoption and implementation of sustainability-based approaches to
       environmental protection across the EPA, the Committee strongly urges the Agency to be
       creative and strategic in developing its human resources programs.

If the Agency is serious regarding the development of sustainability-based approaches to
environmental protection, it must actively cultivate the personnel skill sets necessary to achieve
their effective implementation.  Sustainability champions  should be strategically positioned
throughout the Agency to support the diffusion and adoption of sustainability-based approaches
to environmental decision-making.  To ensure that the important societal concerns and aspects of
sustainability are appropriately considered, the Agency should seek to employ individuals with
professional backgrounds that go beyond the physical sciences, engineering and economics.
Stronger social science expertise is  needed in fields such as anthropology for ethnographic
assessments (how individuals, households and communities think, behave and interact with
products, technologies and natural systems), psychology (behavioral economics) and decision
theory.

4.      The Committee encourages  the Agency to enhance the diffusion of environmental
       sustainability principles and practices within and outside the Agency

The Plan correctly points out that, as the value of the ORD sustainability program becomes
recognized, other Agency program  offices will understand the value of sustainability attributes,
goals, and metrics, and become active in seeking out collaborative projects.  This research
program gives the Agency opportunities to define environmental sustainability both internally
and externally and to promote the use of related research products.

To assume a leadership role in promoting the economic and societal benefits of the sustainability
paradigm, a true systems approach will be needed. This means involving personnel from many
different areas including various Agency program offices,  regional offices and other federal
agencies (e.g., Department of Defense, Department of Energy, Department of  Agriculture, etc.),
local environmental groups, private industry and other community stakeholders.

ORD could further solidify its leadership role in promoting sustainability-based environmental
decision-making by developing greater capacity in sustainability research.  This could be
achieved through a combination of: hiring new personnel with training in sustainability research,
establishing incentives for existing  personnel to apply their technical expertise in support of the

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sustainability paradigm, pioneering new models of cooperative research with industry and
development of small groups of sustainability experts within the Agency who could conduct
analyses and other related work.

5.      Support for sustainability is widespread. Both sound science and senior management
       support can further the paradigm.

While not universally accepted as the sole approach to environmental protection, support for
sustainability, as both a goal and a means of approaching decisions, is widespread.  The concept
and practice of sustainability now permeates the Agency and many other institutions. Both a
strong scientific base and the overt support of EPA management can promote wider
implementation of the sustainability paradigm. These activities are mutually enhancing as well.
Sound science provides a basis for support by senior management and senior management can
advocate for the resources with which to further strengthen the science base.

6.      The Committee recommends that the Agency make judicious use of targeted
       collaborations with other federal agencies as well as the private sector.

The Agency's research budget for this Plan is surprisingly small.   There are clear benefits to
seeking opportunities for collaboration with other federal agencies and the private sector to meet
program goals. Of course, there is also a risk that the focus of the research program could
become diluted by demands for time and resources. The key is pursuing the most appropriate
opportunities in terms of a project's level of complexity, probability of success and national
visibility.  If resources allow, sustainability research investments, as a whole, would benefit
from the Agency providing overall leadership and focused coordination to these external entities
because none presently exists.
Recommendations on the Sustainability Research Strategy

The responses to the specific Sustainability Research Strategy Charge Questions are briefly
summarized here. (The letter S denotes that this is a charge question relating to the
Sustainability Research Strategy.)

SI.    Does the SAB  agree with the central premise of the Strategy that sustainability is all
       about decision making and that ORD research support should aim to inform and allow
       decision makers at all levels of government and in the private sector to choose courses of
       action that will lead to achieving sustainable outcomes?

The Committee does not agree with the central premise that sustainability is "all about decision
making" and "aiming to inform." The Sustainability Strategy document is a careful and
thoughtful effort to capture the opportunity to implement an important paradigm shift across
much of the Agency's jurisdiction.

The Strategy will serve as an important companion document to the Plan as the sustainability
paradigm is adopted within the Agency. It will also be important as the Agency works externally

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with other Federal agencies and stakeholders across the nation.  Rather than simply focusing on
decision-making and the use of sustainability-based research to inform decision-makers (albeit
critically important), the Committee offers the following expansive view of the programmatic
needs of the sustainability Strategy:

       1.      Agency-sponsored core research focused on sustainability science is needed.

       2.      Public stakeholders are part of the cultural aspect of responding to and
              implementing sustainability at the local level and should be explicitly
              acknowledged within the Sustainability Strategy.

       3.      The definition of sustainability may benefit from additional interpretation. The
              research portfolio would be more compelling if ORD were more explicit about the
              interdependence of the three pillars of sustainability (environment, social aspects
              and the economy).

       4.      ORD needs to explicitly promote and integrate a life-cycle approach to
              environmental protection decision-making within the Sustainability Strategy that
              goes beyond simply generating information and furnishing it to decision makers.
              The life-cycle approach would support the need for behavioral change and
              outcome measurement over time.

S2.    Does the strategy make a compelling case for ORD  and EPA that Sustainability Research
       is a priority for ORD?

The Committee agreed with the case made in the Strategy that a systems view is needed in order
to address environmental problems and that a sustainability framework encompasses a systems
approach. Allocation of resources, on the other hand, does not indicate that Sustainability
Research is a priority for ORD. The level of Agency resources currently allocated to support
sustainability research is woefully inadequate for a meaningful scientific research program.
Further, if the resources allocated to the Sustainability Research Strategy reflect Agency priority
setting, then sustainability research does not currently appear to be a priority within ORD.

S3.    Does the strategy focus on priority national issues and identify the right research
       questions?

The Strategy is cross-media.  The areas and questions outlined are quite comprehensive, and
expand upon the initial themes. Nevertheless the Committee is concerned that insufficient
attention is devoted to certain issues (such as climate change research), the interface of social
science and economics research with chemical and /biological research, and the difficulty  of
developing a meaningful suite of sustainability metrics.

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S4.    Does the strategy identify the right implementing steps to address research questions and
achieve sustainable outcomes (Advance technology, develop tools and approaches, advance
systems research and disseminate and apply results.)

As the discussion of implementation progresses, the specificity of the Strategy decreases as does
ORD's control over the outcomes.  The Strategy should acknowledge increasing resource
demands tied to coordination with multiple entities. Neither the Strategy nor the Plan specify
how the Agency will identify and pursue future research opportunities, what resources will be
used, or how success might be evaluated.  Finally, it is unclear what happens to the Agency's
focus on pollution prevention. Prevention has been an important part of the EPA message for
over 15 years and one that resonates with the public, NGO community and industry.

S5.    Does the strategy adequately and correctly connect to policy and/or decision-makers
       inside and outside EPA for achieving desired sustainability outcomes?

Policy and decision-making are two different, but related, aspects of the problem. Decision-
making depends on the way policy is implemented and requires that appropriate incentives (i.e.
policy tools) be established. The Strategy focuses on activities, offices, and regions within EPA,
and coordination among these entities. There is limited discussion of connections to and
collaborations with decision-makers and organizations outside of EPA.  The Strategy does
connect to EPA decision-makers by arguing that environmental sustainability research is
important and appropriate for ORD as well as by seeking to negotiate with other EPA program
managers and decision-makers about the content and future of sustainability research at EPA.

S6.    Does the Strategy enable ORD to prioritize its research investments? Does the Strategy
       define an appropriate role for EPA relative to other funding agencies? Does it sufficiently
       encourage other Federal agencies and organizations to relate their sustainability efforts to
       EPA's so as to promote co-funding and/or collaboration where appropriate?

The Strategy document clearly states that it is up to the individual multi-year plans and to the
National Program Directors to identify their priority sustainability research areas and presents
criteria for setting priorities that are consistent with those found in the Strategy.  Moreover, the
Strategy emphasizes that each individual multi-year plan should develop a balanced research
portfolio with a good mix of short-term and long-term projects, known and emerging issues,
projects that are traditionally central to EPA's mission and others that are more on the
boundaries (e.g.  agriculture and energy).

The Committee had mixed reactions to this agenda and the criteria for setting priorities.
Recognizing both the importance to ORD of establishing a scientifically credible presence in
sustainability-based research and the reality of limited budgetary resources, the Committee
recommends a two-pronged approach that (i) pursues core research on sustainability and
sustainability metrics, and (ii) establishes a small number of demonstration projects that would
give ORD high visibility in the sustainability arena.

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S7.    Does the Strategy outline an adequate roadmap for ORD to implement this program (P2
       transition to Sustainable Technology, coordination among NPD and across existing
       multi-year plans, leveraging interagency cooperation, and defining emerging research
       areas?)

The Strategy lists specific projects and programs with a sustainability emphasis or focus in other
agencies. It also identifies other federal agencies with overlapping interests for each of the six
broad research themes, as well as international partners. Despite these lists, however, and EPA's
acute awareness of other nations' focus and recent advances on sustainability matters, the
discussion and the information offered is too cursory to allow the Committee to judge whether
these other agencies have sufficient incentive to establish partnerships with EPA and promote
co-funding and collaborations. However, the Committee supports ORD's roadmap for
implementation of the Sustainability Research Strategy" the roadmap is described in chapter 6 of
the strategy.

S8.    Does the SAB believe that sustainability research is a sufficiently strong concept for
       integrating and coordinating across ORD research programs?

From a science perspective, sustainability is a strong concept that has value in integrating and
coordinating sustainability-based activities across ORD research programs. However, there are
inherent obstacles and historical impediments to such change. The SAB recommends the
Administrator and senior leadership consider a variety of approaches to ensuring the success of
the implementation of this Strategy throughout the Agency's research program.
Recommendations on the Science and Technology for Sustainability Multi-year Plan

The responses to the Multi-Year Plan Charge Questions are briefly summarized here.  (The letter
P denotes that this is a charge question relating to the Multi-Year Plan.)

PI.    Does the organization of the new Sustainability Technology Plan provide a clear logical
       framework for implementing an element of the overall Sustainability Strategy? Does the
       Plan follow appropriately from the Sustainability Research Strategy? Are the research
       issues identified in the Plan consistent with the research questions identified within the
       Sustainability Research Strategy?

The Plan provides a clear and logical framework for implementing an element of the overall Strategy.
Within the context of limited resources, the Plan identifies a set of issues that are consistent with the
Sustainability Research Strategy and current ORD capabilities. The criteria for project selection should
be reviewed to ensure that they are appropriate for identifying those  research activities that will more
effectively support the Strategy.

The Committee is largely satisfied with the content of the Plan through Chapter 4. The
Committee did engage in extensive discussion about Chapter 5, which presents the specifics of
the planned research program. The Committee's comments are included later in this document.

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P2.    For each major research track addressed within the Plan (e.g., Decision Support Tools,
       Education, Technologies, Systems, and Metrics/Indicators), do the Annual Performance
       Goals (APGs) and Annual Performance Measures (APMs) represent a logical progression
       of activities and intended outcomes? Does the Plan identify the specific issues motivating
       the research program?

Within each major research goal related to metrics, tools and technologies, the respective annual
program goals and measures represent a logical progression of activities and intended outcomes.
Nevertheless, it is difficult to determine the overarching objective and specific goals for the
research program proposed.

However, the long-term goals themselves should be re-ordered. A more logical progression is:

    1.  Develop the appropriate metrics

    2.  Develop any decision support tools required for analysis (if possible, the tools should be
       systems-based and linked to metrics).

    3.  Investigate technological options to reach the goal and try to get the technologies in place
       (SBIR grants, performance incentives...).

Recognizing the budgetary constraints and the desire to achieve high profile measures of success,
the Agency might consider selecting one or two key demonstration projects  that are focused on a
real and current sustainability issues.  To the extent practicable, the projects should support
sustainability metrics development, development and application of sustainability decision
support tools and sustainability technology development and demonstration. The actual projects
identified should have a major impact for the municipality, region, or even industry that is
affected with the information gained easily transferred to other entities.

P3.    Does the Plan lay out a balanced program addressing both short-term and longer-term
       research that meets current needs while positioning the Agency to respond to  emerging
       issues?

The Committee is convinced that the most pressing need is for short term successes to gain
further support for the research program. Looking at the longer term, the Committee is
persuaded the program should have the capability to detect emerging problems and inform the
Agency. A prescriptive numerical balance, in dollars, work years, number of projects, or variety
of disciplines is not recommended.

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P4.    Do the long-term goals address the high-priority science, engineering, and technology
       needs of users that will help the Agency meet its strategic goals relating to sustainability?
       Do the long-term goals clearly relate to the research tracks within the Plan framework?
       Do they provide a picture of what the program is trying to achieve? Will the proposed
       research activities lead to progress towards these goals?  Are the goals appropriately
       linked to long-term environmental outcomes?

Addressing the longer term outputs and outcomes of the program is important because ORD
research has historically been focused on shorter term needs.  The Plan explains clearly the
linkages of the annual performance goals to the long-term goals and the long-term goals to the
Strategy.  However, it is not clear whether these long-term goals will significantly advance
sustainable approaches to management and address specific sustainability challenges.  The
weakest part of the Plan is the integration between the long-term goals and long-term
environmental outcomes. The outcomes, while measurable, are not scientifically compelling nor
are they focused on achieving goals through the application of sustainability principles. A
tenuous link between sustainability goals and outcomes leaves the Plan vulnerable to claims that
ORD is retreating to the historical single-media "stove pipe" approach to environmental
protection.

While the development of new, more sustainable technologies is usually best left to the private
sector, the Agency has a critical role to play in certifying and evaluating data and making it
available to the sustainability community. Furthermore, the Agency is encouraged to engage in
research that is specifically  focused on developing incentives for private companies to invest in
and adopt new technologies.

The Plan alludes to but does not explicitly develop the Agency's role in conducting "regular and
continuous assessments of environmental trends".  If indeed the Agency assumes this role, and
makes such assessments available to the public, then it will be performing a valuable service that
can enable decision makers at all levels to respond to both emerging as well as legacy
environmental issues.

P5.    Are the research products supportive of the strategic target as set forth in the Agency's
       Strategic Plan under Objective 5.4?

Objective 5.4 of the Agency's Plan focuses on enhancing society's capacity for sustainability
through science and research. The long-term goals support this strategic target by establishing
sustainability metrics, creating decision-support tools, and developing and applying cutting-edge
technologies to solve environmental problems. However, it is unclear who will be leading the
proposed efforts, how funding will be prioritized, or how the research products will be defined.
Given the lack of detail, it is difficult to assess the nature of the  products or their significance.
With the limited budget projections, it is unlikely that products will have a large impact on
enhancing the science or decision-support of sustainability.

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P6.    Does the scope of work proposed within the Plan complement research being supported
       by other programs inside and outside EPA?

The Committee found that the scope of work appeared to complement research inside the
Agency and perhaps outside the Agency. The Committee urges the Agency to conduct more
extensive investigation and documentation of external research related to the Plan.

P7.    Are there other potential emerging research areas that the Plan should consider?

The long-term goals are sufficiently broad to cover most emerging issues, however, it is unclear
how the Agency will identify, prioritize, and respond to emerging issues on an on-going basis.
The plan should explicitly address this concern since it has both resource and coordination
implications.

P8.    Is the level of resources specified by the Plan sufficient to address the research issues that
       it identifies, allowing ORD to achieve the intended outcomes of the research program? Is
       the Plan's  relative allocation of those resources among the research tracks of the
       sustainability research program appropriate, based on a consideration of scientific and
       programmatic needs?

The level of support specified for the Plan is less than one one-thousandth of the Agency's
overall budget and no more than 1% of the S&T budget. In the Committee's opinion, a
substantially higher commitment is needed to have a serious impact on internal research
priorities,  managerial buy-in, and program visibility  and growth. The level of support allocated
will limit progress and suggests to the Committee that the Agency does not ascribe a high level
of importance to sustainability-based research activities. In the Committee's opinion, the area of
environmental sustainability should become a main thrust of ORD, with allocation and resources
established at a level commensurate with its importance to current and future Agency decisions.

P9.    Does the Plan appropriately address findings and recommendations in evaluations of the
       program and its components?

ORD is clearly interested in working with other parts of the Agency and organizations outside of
the Agency. However, the descriptions of how such collaborations will be developed and
implemented need to be strengthened in the Plan.

Overall, the Plan is too vague when it describes proposed results and outcomes that pertain to
sustainability. Planned efforts to quantitatively describe those planned results and outcomes need
to be expanded in light of future external assessments of the sustainability program.

This Committee's review and the upcoming BOSC review should address the concerns
delineated in the PART evaluation.  Regarding the integration of the elements of the P2NT (now
sustainability)  research program, the Plan provides evidence of substantial efforts at coordination
and integration. The Committee's evaluation of those effects is described in the responses to
other Plan charge  questions.
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             Responses to Charge Questions Relating to the Strategy

SI     Does the SAB agree with the central premise of the Strategy that sustainability is all
       about decision making and that OKD research support should aim to inform and
       allow decision makers at all levels  of government and in the private sector to choose
       courses of action that will lead to achieving sustainable outcomes?

The Sustainability Strategy document is a careful and thoughtful effort to capture the opportunity
to implement an important paradigm shift across much of the agency's jurisdiction and, along
with other Federal partners and stakeholders, the national landscape. The Agency is to be
commended for its work here.

The document will serve as  an important companion document to the Plan as the sustainability
paradigm is adopted internal to the Agency. It will also be important as the Agency works
externally with other Federal agencies and stakeholders across the national landscape.

Many of the comments offered here reflect initial thoughts by the Committee that eventually
resulted in the seven overarching comments being developed during the Committee meeting
(presented in section 4 of this report). Consequently, these comments in response to SI may be
elaborative in nature.

The Committee does not agree with the central premise that sustainability is "all about decision
making" and "aiming to inform." Rather, four additional, expansive views are offered:

First, Agency-sponsored core research focusing on sustainability science is needed. By defining
sustainability as "all about decision making," the Strategy mixes together scientific questions
with assumptions about likely policy directions. Overtly combining sustainability research
activities with possible policy decisions weakens and limits the scientific aspects of the Strategy
to only those environmental issues that can be addressed in the near term.

Development of decision support tools implies a foundation of knowledge about sustainability.
In some areas, there is this foundation: for example, the benefits  of energy efficiency are widely
acknowledged. But, by not  explicitly acknowledging the critical need for conducting research
specifically focused on defining the fundamentals of sustainability  science, the Strategy may not
fully support sustainable outcomes. ORD research support should not just aim to inform decision
makers, but should enable the Agency to establish a systematic and transparent process for
identifying and prioritizing major environmental concerns that can be effectively addressed
through application of sustainability principles.  Sustainability research should provide the
Agency with the scientific tools to deliver maximum value back to stakeholders in terms of a
balance to economic, social  and environmental improvements (the three pillars of sustainability).

It is of critical importance that the Strategy be able to distinguish between two related, yet
distinct functions: clarifying sustainability principles, and implementing sustainability solutions.
The strength of ORD research has traditionally been focused on clarifying and documenting
environmental impacts.  This role for ORD research is commendable and should be expanded to
include clarifying the Agency's current understanding of sustainability principles.  Implementing
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sustainability solutions to a recognized environmental problem will be primarily a policy
decision. After policy decisions are made, ORD research could then appropriately focus on
applied research to implement the policies. For instance, ORD's efforts to "develop a set of
appropriate metrics to gauge society's progress towards sustainability" (ES-page  14) should, in
part, be based on metrics already available (e.g., energy efficiency) and allow greater focus on
current and future policy and regulations. With such existing metrics, then society could proceed
with the task of developing technologies and approaches to achieve these goals.

Second, the public and public stakeholders are clearly part of the cultural aspect of responding to
and implementing sustainability at the local level.

Sustainable decision-making will take place at many levels and across both the public and
private sectors, from individuals to neighborhoods, municipalities and regions, countries and
continents, NGOs and private firms, and consumers and producers. Any plan to inform and
support decision-making on such a scale is a large undertaking involving research on; material
and energy flows, information dissemination, economic incentives and expectations for present
and future payback.  As such, integration of social factors into the science that ORD has
traditionally employed is an essential element of the sustainability paradigm. Typically, major
legislative actions and federal policy are needed that respond to public perception of need. The
sustainability paradigm is of such a nature, a radical departure from past ways of perceiving
humankind's relationship to the environment.

An important premise in the sustainability paradigm is informed decision making for change
agents (e.g., government) and for the practitioners (e.g., the public).  In general, the difficult
component of decision-making is having the needed information.  In this regard, it is important
that the Strategy focus on decision-making and identify "information driven" processes. A
sustainability-focused solution to environmental concerns is effective only if information is
coupled with incentives (or disincentives) that can drive behavioral change (and prevent
backsliding to traditional unsustainable solutions).  The Strategy fails to explicitly acknowledge
the role of the public and other stakeholders besides local,  state and federal government and the
regulated entities. The public should be apprised of and might well be interested in learning
about what technological advances funded by ORD have been adopted by private industry. In
addition, the metrics and indicators developed under the auspices of ORD research program
would serve the interests of the public at large, not just those of government officials and
decision makers.

Third, the definition of sustainability may benefit from additional interpretation. The research
portfolio would be more compelling if the interdependence of the three pillars of sustainability
(environment, social aspects and the economy) were clarified. Currently, economic growth and
population change appear to be treated as exogenous variables that determine the pressure
imposed  on the environment.

Fourth, ORD needs to explicitly promote and integrate a life-cycle approach to environmental
protection decision-making within the Strategy that goes beyond simply generating information
and furnishing it to decision makers.  The life-cycle approach would support the need for
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behavioral change and outcome measurement over time, both internal to and external to the
Agency.

S2     Does the strategy make a compelling case for ORD and EPA that Sustainability
       Research is a priority for ORD?

The Committee unanimously agreed a systems-based approach is needed in order to address
environmental problems and that a Sustainability framework supports a systems methodology.
Other points of agreement included concern that the category of "decision maker" was construed
rather narrowly. Committee members argued that the long-standing problem of "silos"—division
of environmental problems into individual media and/or pollutants—was not sufficiently
addressed as a core source of the problems facing environmental policy and the Agency.

Allocation of resources, on the  other hand, does not indicate that Sustainability Research is a
priority for ORD. The level of Agency resources currently allocated to support Sustainability
research is woefully inadequate for  a meaningful scientific research program.  Further, if the
resources allocated to the Sustainability Research Strategy reflect Agency priority setting,  then
Sustainability research does not currently appear to be a priority within ORD.


S3     Does the strategy focus on  priority national issues and identify the right research
       questions?

The Strategy organizes its priority research questions according to the six critical research
themes in Chapter 4 (Natural Resource Protection, Non-renewable Resource Conservation, Long
Term Chemical and Biological  Impacts, Human Built Systems and Land Use, Economics and
Human Behavior, and Information and Decision Making). These themes, and the questions that
are derived from them, have both a  generic (i.e. nothing to distinguish EPA's role),  and EPA-
specific focus which, in general, emphasizes issues related to human interactions with the
environment. To its credit, the Agency has tried to derive a strategy that is cross-media. The
areas and questions outlined are comprehensive, and expand upon the initial themes. The
Committee encourages the Agency  to apply the principles of Sustainability in supporting research
activities aimed at addressing high profile environmental concerns e.g., global climate  change,
energy production, etc.  The Committee strongly endorses the efforts by the Interagency
Sustainable Development Indicators group to develop a suite of scientifically defensible
Sustainability metrics.

The Committee acknowledges the inherent difficulty in establishing Sustainability metrics that
are acceptable to a broad range of public and private stakeholders. However, successful
transition of the Agency from its single-media regulatory focus to a systems-based approach to
environmental decision-making is dependent on the formulation of scientifically defensible
Sustainability metrics.

Owing to the early advances of the international community in conducting state-of-the-art
research on Sustainability, Committee recommends that the Agency critically examine  the
practices of the European Union (EU) countries, Japan, and others as a means of establishing
reasonable Sustainability benchmarks while developing a distinctive Sustainability research
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model that is patterned after the Agency's sustainability paradigm, i.e. collaborative, forward-
focused, inclusive, adaptive, and integrative.

S4     Does the strategy identify the right implementing steps to address research
       questions and achieve sustainable outcomes (advance technology, develop tools
       and approaches, advance systems research, and disseminate and apply results)?

The Strategy refers to four implementing steps:

       Step  1: transition the current pollution prevention and new technology research program
             into a Science and Technology for Sustainability Research Program,

       Step 2: coordinate with 16 other multi-year plans,

       Step 3: collaborate and partner with EPA Program and Regional Offices and other
             government organizations, and

       Step 4:  identify and pursue future research opportunities.

As one proceeds from implementing steps one to three, a number of things occur:

       1.     There is less and less specificity of how this will work in the Strategy.

       2.     ORD has less and less direct control of the outcomes and this will lead to
             measurement problems.

       3.     There will  be increasing resource demands tied to coordination with multiple
             entities (important given limited resources).

Step 4 (identify and pursue future research opportunities) appears in various forms throughout
the strategy but neither the Strategy nor the Multi-year plan specify how this will be done, what
resources will be used, or how success might be evaluated.

Finally, it is not clear what happens to pollution prevention (step 1).  Though always under-
resourced, prevention has been an important part of EPA message for over 15 years and one that
resonates with the public,  NGO community and private industry.  The Plan should make clear
how the S&T for Sustainability Research Program views the concept of "prevention."
S5     Does the Strategy adequately and correctly connect to policy and/or decision-
       makers inside and outside the EPA for achieving desired sustainability outcomes?

Policy and decision-making are two different, but related, aspects of the problem. US
environmental policy is, and will most likely remain, risk-based. Whether this is inconsistent
with "sustainability-based" policy will only be known when the outcomes of research on
sustainability become apparent.
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Decision-making depends on policy, or more precisely the way policy is implemented, and
requires that appropriate incentives (i.e. policy tools) be implemented. It can relate to long or
short-term courses of action, the longer the term the greater the uncertainty in the outcome. This
is why it is important to view sustainability metrics and standards as evolving, i.e., a moving
target whose descriptions are continuously refined as research results are generated.

The Strategy focuses on activities, offices, and regions within EPA, and coordination among
these entities.   The Strategy does connect to EPA decision-makers by arguing that
environmental sustainability research is important and appropriate for ORD, as well as by
seeking to negotiate with other EPA program managers and decision-makers about the content
and future of sustainability research at EPA.

The Strategy does not propose any significant connections to federal policy and/or decision-
makers outside EPA.  External collaborations and partnerships are discussed in a summary
manner on pages 70-73. Ongoing programs and relationships are noted,  with some specific
examples given. There is more discussion of connections with other Federal agencies than with
regulated bodies (industry), communities, and consumers.  Although the  Strategy refers on page
63 to the need for balance between research that supports decision making within EPA and by
other government organizations and industry, it neglects to mention the role of consumers or
non-governmental, non-regulated parties that may be involved in policy recommendations or
decisions, be they individual life-style decisions or those that affect local or regional
communities. There is little in the Strategy about partnering with academic research or even how
EPA might better leverage information and research generated by the regulated parties
themselves.

The general nature of the discussion of external connections is consistent with the tone of the rest
of the Strategy, which examines six broad themes of environmental sustainability in a general
manner. It is not clear, however, how much of an impact the collaborations and  partnerships will
actually have in advancing sustainable approaches to management and protection of the
environment.  There is no discussion of connections with specific kinds of decision-makers or
policies linked with specific sustainability challenges. Certainly, specific connections within
public and private sectors will evolve as the program develops, but the Strategy recognizes that
this effort must be (and will be enhanced by) connections with other efforts in EPA and outside
EPA.

ORD is clearly interested in connecting to policy and decision makers within and outside of
Agency in the  Strategy and Plan. However, as formulated, the Strategy does not require the
identification of specific kinds of decision-makers and policies.  Weakness in this respect
probably reflects resource constraints rather than failure of intention and foresight. If the
Strategy was built around specific sustainability challenges, which it is not, then the need for
identifying decision-makers and policies would be more apparent.

The Strategy should do more to prepare to discuss research results with policy makers. After
ORD clarifies  and strengthens its research strategy, it should develop an  active program to
connect to policy makers and decision makers.  In this regard, the strategy could be more explicit
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in its goal of trying to change behavior through the development of metrics and tools that might
move all parties towards decisions that create environmental sustainability - that recognize
something beyond straight measures of economic productivity.  It's almost too subtle in that
regard. At the same time, it is critical that the Strategy acknowledge that decisions will always be
made in the absence of complete information; development of approaches to decision making
that address uncertainty are essential.

The Strategy could also do more to move us away from a waste-centered view of environmental
protection toward a life cycle approach.  The Strategy appears to view "sustainability" as
following logically, temporally, and philosophically from the current emphasis on waste
management as a means to healthy environments. It may be more useful to view things the other
way around, regardless of how policy has historically been implemented. The problem with
seeing sustainability as derived from a waste-centered view is that it then becomes very difficult
to refocus our (EPA managers and scientists, the government in general, and the citizenry)
environmental frame of reference. This inevitably leads to inadequate organizational structures,
poor prioritization, and seeking answers to the wrong questions. Interestingly, this has been
recognized in the Agency's Strategic Plan under Goal 3 (Land Preservation) in which it is stated
"Our ultimate goal is to move the Nation from a waste-oriented to a life-cycle management way
of thinking about materials".

ORD has an opportunity to provide leadership both internal to the Agency and external among
the federal agency family and other organizations. This can be accomplished by coordination
and leadership in the definition of environmental sustainability and in the use of related research
products which will influence how other federal agencies and organizations move forward with
their sustainability programs.

The scope of environmental sustainability research efforts outside EPA is vast and the ORD has
only skimmed the surface.  To take one example, there is no mention of the scholarly literature
on environmental sustainability.  There are several key academic/scientific journals  devoted to
this topic and, of course, many more that touch on it. A more deliberate effort at ongoing
literature review is warranted in this respect - to exploit what  has been created by others, to stay
abreast of developments in the field and to identify vehicles (e.g., journals) through  which ORD
research should be disseminated.

S6     (a) Does the strategy enable ORD to prioritize its research investments?
       (b) Does the strategy define an appropriate role for EPA relative to other
       funding agencies? Does it sufficiently encourage other Federal agencies and
       organizations to relate their sustainability efforts to EPA's so as to promote co-
       funding and/or collaboration where appropriate?

S6(a): Does the strategy enable ORD to prioritize its research investments?

The Strategy document identifies five objectives for ORD research (understanding of systems,
development of decision-support tools, development of technologies, collaborative approaches to
decision-making, development of metrics and indicators) and six broad  research areas
("themes"—namely renewable resource systems, non-renewable resource systems, long-term
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term chemical and biological impacts, human-built systems and land use, economics and human
behavior, information and decision-making).

Examples of more specific, but still sufficiently broad, research questions are offered for each of
the six research themes. In this document, ORD elected to present criteria that could be used to
set priorities, rather than trying to identify research priorities directly. Specifically, these criteria
are:

       1.      "high impact;"

       2.      "true to EPA's research capabilities;"

       3.      "true to EPA's role" and mission;

       4.      "leverage:" higher priorities on research that ultimately leads to sustainability on
              a large scale, with EPA partnering in initial research or through transfer and
              diffusion of knowledge, methodologies, and approaches; and

       5.      systems context.

The Strategy clearly states that it is up to the individual multi-year plans and to the National
Program Directors to identify their priority sustainability research areas. (Indeed, the Plan
document presents criteria for setting priorities—grouped into primary and secondary criteria—
that are consistent with those in the sustainability strategy document.)

Moreover, the Strategy emphasizes that each individual multi-year plan should develop a
balanced research portfolio with a good mix of short-term and long-term projects, known and
emerging issues, projects that are  traditionally central to EPA's mission (e.g., water) and projects
that are at the boundary of EPA's responsibility but still important for sustainability (e.g.,
agriculture and energy), research that supports decision-making within EPA (programs and
regional offices) and research that supports decision-making in the industry and in other local,
state and federal organizations.

The Committee had mixed reactions regarding the efficacy of this agenda and the criteria
employed for setting research priorities.  The Committee determined that, on the whole, the
research portfolio composition was appropriate for ORD.  However,  in practice, several
Committee members expressed reservations over whether the compelling science questions and
priorities that truly speak to sustainability and its cross-cutting issues would be addressed as part
of ORD's sustainability research program. When people have few resources and much work,
there is a natural tendency to continue existing programs changing their description  and little
else. That temptation should be avoided here.

Recognizing that the Agency is poised to assume a global leadership role in sustainability
research, the Committee strongly  recommends that, in light of ORD's limited budget, that the
following parallel activities be conducted immediately:
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       1.      conduct core research on sustainability focusing on the development of defensible
              sustainability metrics, and

       2.      implement a small number of Agency-sponsored technology demonstration
              projects that provide ORD with the opportunity to achieve significant visibility
              within the sustainability research arena.

It is important that these demonstration projects move away from waste/end-of-pipe approaches
towards a broader, system-based perspective. Examples of such projects might include an
assessment from a sustainability perspective of:

       1.      biofuels policies and options, which are topical and encompass a broad range of
              issues and potential impacts on emissions of greenhouse gases, agriculture,
              dependence on imports of fossil fuels, etc. and may imply a variety of economic
              incentives;

       2.      a study of the hypoxic environment in the Gulf of Mexico or the Chesapeake Bay,
              and

       3.      wastewater practices and infrastructure needs in regions and cities with
              accelerated population growth.

S6(b): Does the strategy define an appropriate role for EPA relative to other funding
agencies? Does it sufficiently encourage other  Federal agencies and organizations to relate
their sustainability efforts to EPA's so as to promote co-funding and/or collaboration
where appropriate?

The Strategy lists specific projects and programs with a sustainability emphasis or focus in other
agencies. It also identifies other federal agencies with overlapping interests for each of the six
broad research themes, as well as international partners. Despite these lists, however, and EPA's
acute awareness of other nations'  focus and recent advances  on sustainability matters, the
discussion and the information offered on page 71-73 is too cursory to allow the Committee to
judge whether these other agencies will feel encouraged to establish partnerships with EPA and
promote co-funding and collaborations.

S7     Does the Strategy outline an adequate roadmap for ORD to implement this
       program (P2 transition to Sustainable Technology, coordination among NPD and
       across existing multi-year plans, leveraging interagency cooperation, and defining
       emerging research areas?)

The roadmap for implementation  of the program is described in Chapter 6, pp. 61-75, beginning
on page 64 and includes the four implementing steps identified in the response to S4 on page 14
of this document.
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The Committee supports ORD's roadmap for implementation of the Strategy.  Coordination with
other multi-year plans is essential to the success of the Strategy. The implementation of the
Strategy through a number of multi-year plans will begin to provide the Agency with a
distributed core of sustainability research in ORD. Coordination with EPA program and regional
offices and other government organizations will provide additional needed capacity to carry out
the research program.

Implementation of the Strategy is organizationally challenging because it relies on cooperation
throughout ORD and EPA. The Strategy is an important step for ORD and for the Agency, and
the Committee supports ORD's initiative. Explicit management support of the Sustainability
Research Strategy would be important to ensuring successful implementation.

S8       Does the SAB believe that sustainability research is a sufficiently strong concept
         for integrating and coordinating across ORD research programs?

In the face of rapid economic and population growth, in addition to the threats of a possible oil
crisis, global warming, and ozone depletion, it is clear that novel actions must be taken in order
to ensure the continued prosperity and progress of our generation and those of the future. New
methods must be developed to balance the needs of present and future  populations with the real
limits of our natural resources. Attempting to remedy ecological damage by "stovepipe" policies
represents an incomplete understanding of pollution and the environment. Thus, environmental
scientists and decision-makers are presented with a multitude of environmental challenges in
developing new models, methods, and technologies to deal with pollution and  environmental
protection in a holistic, systems-based manner. The philosophy of sustainability has the capacity
to provide the answers to these challenges when applied to relevant scientific,  social, and
economic fields.

Sustainability impacts and is impacted by variety of disciplines, and thus a multidisciplinary and
multimedia approach to managing our environment is required. Building on the definition taken
from the World Commission on Environment and Development issued its 1987 report, Our
Common Future,  better-known as the Brundtland Report, the ORD draft document defines
sustainability as "meeting basic environmental, economic, and social needs now and in the future
without undermining the natural systems upon which life depends." Thus sustainability is
conceptualized as a dynamic process, an open-ended challenge, in which scientists, economists,
and lawmakers work together to solve present problems and anticipate future issues.

More precisely, the Strategy identifies "Six Themes of Environmental  Sustainability," that will
underpin the Agency's approach to sustainability.  They are: natural resource protection, non-
renewable resource conservation, long-term chemical and biological impacts, human-built
systems and land use, economics and human behavior, and information and decision-making.
These themes reflect the concept upon which the Strategy is predicated - that "the nation is most
capable of achieving sustainable environmental outcomes by investigating resources ... in a
systems-based context and incorporating the influences of economy and human behavior where
appropriate."
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The 2005 National Research Council report, Thinking Strategically: the Appropriate Use of
Metrics for the Climate Change Science Program cited in the ORD draft document identified
eight priority sustainability areas in need of government support, including green chemistry and
engineering, energy intensity of clean processing, and separation sciences, among others. These
fields all represent the frontier of environmentally conscious sciences, as well as representing
specific research areas in which the ORD has a vested interest, and an accordingly strong
presence.

In addition to intramural research programs, the Strategy proposes ORD involvement and
collaboration with government programs at the federal and state level, and also with industrial
programs. Thus, sustainability effectively helps to coordinate and integrate a broad range of
ORD research programs. However, two main issues are not emphasized;

       1.     increasing food (both crop and animal) production and its consequences to the
              environment; and

       2.     multimedia nature of a sustainable strategy.

The EPA is the Federal agency most concerned with research designed to protect and utilize the
natural resources of the environment. It is, therefore, appropriate for the Agency to fund research
programs that will serve its mission, and, where possible, assist the missions of other agencies.
The Strategy will create opportunities for co-funding/coordination between the EPA and other
Federal agencies in science, engineering, economic and social fields, as sustainability comes to
the forefront of research programs in many different disciplines.

While sustainability research can play an important role in integrating and coordinating across
ORD research programs, the exigencies of Agency mandates and to a lesser extent resource
constraints and the "ownership" of key topics by other agencies, means that the portfolio of ORD
research programs is not likely to be completely conducive to integration in this manner.
However, sustainable development must be taken seriously by the entirety of upper management
at the Agency and a critical core of Agency scientists.
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               Responses to Charge Questions Relating to the Plan

PI       Does the organization of the new Sustainability Technology Plan provide a clear logical
         framework for implementing an element of the overall Sustainability Strategy?
         Does the Plan follow appropriately from the Sustainability Research Strategy? Are the
         research issues identified in the Plan consistent with the research questions identified
         within the Sustainability Research Strategy?

Yes. The Committee agrees that the organization of the new Sustainability Technology Plan provides a
clear logical framework for implementing an element of the overall Sustainability Strategy. The
Committee recognizes that financial and personnel resources are limited for this program. Within this
context, the Plan identifies a set of issues that are consistent with the Sustainability Research Strategy
and current ORD capabilities.  The criteria for project selection should be reviewed to ensure that they
effectively focus research on projects that will contribute more effectively to the Sustainability Research
Strategy.

The Committee is largely satisfied with the content of the Plan through Chapter 4. These parts of the
Plan discuss the shift to Sustainability, the foundation of a Sustainability program, creation of a
framework for the Plan, and prioritization of the Plan research. The Committee did engage in extensive
discussion about Chapter 5, which presents the specifics of the planned research program.  The
Committee has a number of comments on the specifics of the planned research program. These
comments are included later in this document, particularly in response to questions P4 and P5 and in
chapter 4.

P2       For each major research theme addressed within the Plan (e.g., Sustainability
         Metrics, Decision Support Tools, and Technologies), do the Annual Performance
         Goals (APGs) and Annual Performance Measures (APMs) represent a logical
         progression of activities and intended outcomes? Does the Plan identify the
         specific issues motivating the research program?

On the one hand, within each major research goal related to metrics (LTG 1), tools (LTG 2) and
technologies (LTG 3), the respective APGs and the APMs do represent a logical progression of
activities and intended outcomes. While one could debate the choice of LTGs and related APGs
and APMs, for those cited there is a logical progression of events for intended outcomes.

While on the other hand, if one looks at the progression of the three major LTGs, the Plan
appears to be chronologically inconsistent. Technology development is identified as a major
focus in the short term while development of Sustainability metrics is not addressed until 2008-
2011. A more logical progression within the context of a overall focused Sustainability research
project is described as follows:

       1.     Develop the appropriate metrics.

       2.     Develop any decision support tools required for analysis (if possible, the tools
   should be systems-based and linked to metrics).
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       3.     Investigate technological options to reach the goal and try to get the technologies
             in place (SBIR grants, performance incentives...).

Again, the goal is to link metrics, with decision support, with technological innovation within
one project that can be completed with available resources.  Currently, there is no clear
progression among the 3 LTGs described in the document.

Does the Plan identify the specific issues motivating the research program?

While there does appear to be a logical progression of activities and intended outcomes presented
within each LTG, it is difficult to determine the overarching objective and specific goals for the
research program proposed.  While the overall strategy is appropriate insofar as sustainable
outcome measures related to energy, air, water, materials, land and ecosystems are concerned
(see Table 1.1), there is no clear integration between the research program and how these
outcomes will be achieved. Furthermore, the probability of achieving the intended outcomes is
low due to resource (appropriate personnel and funding) constraints. Realizing such constraints
and wanting to achieve maximum impact for the resources invested, one recommendation is to
select one or two key demonstration projects, focused on a real and  current sustainability issue
where the approach can include all the aspects of metrics development, development and
application of decision support tools, and technology development and demonstration. The
actual projects identified should have a major impact for the municipality, region, or even
industry that is the focus of the project, with the information gained easily transferred to other
entities.

P3       Does the Plan lay out a balanced program addressing both short-term and longer-
         term research that meets current needs while positioning the Agency to respond
         to emerging issues?

The Science and  Technology for Sustainability Multi-Year Plan (Plan) builds upon the
framework of the Pollution Prevention and New Technologies (P2NT) Research Program,
created in 2000. Under the P2NT program, much progress has been made in a variety of fields
pertaining to sustainability, such as the development of Environmental Impact Assessment
Models, the Small Business Innovation Research Program, and the Technology for a Sustainable
Environment programs.

The P2NT program was reviewed by the Federal Government's Office of Management and
Budget, and several recommendations were made to improve the program, including "becoming
more focused on  the need of Agency client offices, fostering more collaboration with other
researchers (academic, industrial, and government), and developing an ability to measure and
track program results over time." Thus, the Plan benefits from being created with these
recommendations in mind, focusing on coordinating interdisciplinary programs, setting long- and
short-term goals,  and measuring the program's performance in an effective way.
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The Plan establishes three long-term goals (LTGs), with the overall vision of "providing support
to regional and national sustainability polices and initiatives." First, the Plan seeks to identify
and create scientifically based sustainability metrics, which will allow scientists a clearer picture
of what a healthy, sustainable ecological system looks like. Next, the Plan calls for the
development of decision-support tools that promotes environmental stewardship and sustainable
management practices. Thirdly, the Plan calls for the development, application, and
demonstration of innovative technologies that solve environmental problems and provide
sustainable outcomes.

The description of these three long-term goals is sufficiently broad to allow flexibility in their
execution, but specific enough to establish criteria for their measurement. In addition, the related
research program also has several performance measures which rely upon feedback from the
Agency's clients, e.g., individuals, communities, government and private companies.

Furthermore, the ORD has established criteria by which research activities may be prioritized.
The primary criteria are: resource availability, relevance to the Agency's Mission and
Addressing Program Office Needs, and Staying True to ORD's Research Capabilities. These
criteria raise serious questions regarding implementation in that the draft document reports that
the resources allocated to the existing P2NT research program  are modest and, in fact, are
expected to decline. With this in mind, are the long-term goals of the Plan attainable? Will new
research programs fail to be funded, although there may be potential for a highly positive
environmental impact? Is the Plan itself a sustainable program? This question is of the utmost
importance as  all goals and plans are predicated upon the availability of adequate resources.

The Plan calls for responding to emerging issues, but lays out no strategy for identifying these
issues or organizing a coherent response.  ORD needs to be specific about how it will track
emerging issues, prioritize them,  and decide how best to address them.  This function will be
important in terms of also identifying future partners within the government, industry and
academia.  The resource demands for issue tracking are not extensive, but ORD or other Agency
program offices must be responsible for tracking not just relevant environmental issues but
changes in industrial production technologies, social behavior and economic drivers that may
result in new opportunities to achieve sustainable outcomes.

If this is a more helpful interpretation around the topic of balance, then it might be useful to
weight the balance somewhat in favor of short term research projects that develop useful
products in the next year or two; and slightly less towards long term (i.e. research projects that
develop useful products within five years) so that early successes are ensured.
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P4       Do the long-term goals address the high-priority science, engineering, and
         technology needs of users that will help the Agency meet its strategic goals
         relating to sustainability?  Do the long-term goals clearly relate to the research
         tracks within the multi-year plan framework? Do they provide a picture of what
         the program is trying to achieve? Will the proposed research activities lead to
         progress toward these goals?  Are the goals appropriately linked to long-term
         environmental outcomes?

(a) Do the long-term goals address the high-priority science, engineering, and technology
needs of users that will help the Agency meet its strategic goals relating to sustainability?

This set of charge questions requests commentary from the SAB on the long term efficacy of the
proposed sustainability research program. Addressing the longer term outputs and outcomes of
the program is important because ORD research has historically been focused on shorter term
needs, often driven by political imperatives rather than science-based prioritization.

Chapter 3 of the Plan explains clearly the linkage of the LTGs to the Sustainability Research
Strategy, which examines six broad themes of environmental  sustainability.  It is not clear,
however, how much of an impact the general LTGs will actually have in advancing sustainable
approaches to management and addressing specific sustainability challenges. The LTGs address
high-priority science, engineering, and technology needs mostly indirectly. Moreover, specific
sustainability challenges involve more than just science, engineering, and technology research
needs (i.e., the need to integrate economics, social sciences, architecture, and planning).

The Committee encourages the Agency to identify and document its role in facilitating the
development of new, more sustainable technologies (APG 3.2). Although, in the majority of
cases, such development is best left to the private sector, the Agency can play a unique and
major role in highlighting the cross-cutting environmental problems for which sustainability
technology is urgently needed.  Moreover, the Agency can facilitate the interfacing between the
federal government and private industry through the P2 program, certify and evaluate data and
making it available to the  sustainability community (consistent with proprietary requirements),
verify sustainability technologies, ensuring that consistent metrics are used by all stakeholders
(including various Agency offices and programs), and conduct research on ways to provide
incentives for companies to invest in and adopt new technologies.

(b) Do the long-term goals clearly relate to the research tracks within the multi-year plan
framework? Do they provide a picture of what the program is trying to achieve?

In Chapter 5 of the Plan, the planned research described via the APGs is consistent with the
LTGs under which the APGs are listed. The inclusion of particular APGs can be debated, and
other possible APGs could be suggested. The proposed research activities represented by the
APGs will clearly lead to  progress, but the likely  impact of this progress in helping to address
specific long term sustainability challenges is not clear.

One  clear role that the Agency can play to which the Plan alludes but does not explicitly develop
is that of conducting "regular and continuous assessments of environmental trends". If indeed the
Agency assumes this role, and makes such assessments available to the public, then it will be
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performing a valuable service that can enable decision makers at all levels to respond to
emerging issues as well as ongoing ones.

(c) Will the proposed research activities lead to progress toward these goals?

The document has specific deliverables but it is unclear where the research questions are
developed and prioritized. There is little in the Plan about cooperative research with universities
and industry. In the latter case, there needs to be a shift in Agency policy to move from one of
regulation to one more focused on demonstrating the business case for sustainability. In this
regard, having regulations in place to drive certain sustainability initiatives, once identified, can
help but should be done judiciously.

The Committee notes that Plan LTG 1 focuses on the development of metrics for assessing
environmental systems, but the Agency fails to follow this same approach for prioritizing its
research. Without such an approach, the sustainability research portfolio may not reach its
maximum long term value.

(d) Are the goals appropriately linked to long-term environmental outcomes?

This area is perhaps the weakest part of the Plan. The outcomes, while measurable, are not
focused on achieving goals through the application of sustainability principles (such  as
dematerialization, material substitution, development of alternative energy sources, process
modification, fostering of innovative technologies, organizational change, supply-chain
management, and total cost accounting, to name a few). Without this aspect, the plan runs the
risk of retreating to a focus  on single-media, end-of-pipe treatment.

P5       Are the research products supportive of the strategic target as set  forth in the
         Agency's Strategic Plan under Objective 5.4?

Objective 5.4 of the Agency's Plan focuses on enhancing society's capacity for sustainability through
science and research. More specifically, it states that the Agency will "(Conduct leading edge, sound
scientific research on pollution prevention, new technology development, socioeconomic,  sustainable
systems and decision tools.  By 2011, the products of this research will be independently recognized as
providing critical and key evidence in informing Agency policies and decisions and solving problems
for the Agency and its partners and stakeholders."

The LTGs set forth in the Plan certainly support this strategic target, by establishing  sustainability
metrics, creating decision-support tools, and developing and applying cutting-edge technologies to solve
environmental problems.  However, it is not clear who will be leading the  proposed efforts, how funding
will be prioritized, or how the research products will be defined. In Section 4.2, a series of research
questions is provided that are directed at the LTGs.  Each of these questions are  important and complex
and in Chapter 5 the planned research program presents APGs that address these questions. Limited
detail is provided in the Plan with regard to what the research products will be and therefore, it is
difficult to  assess the nature of the products or their significance. With the limited budget projections, it
is unlikely that products will have a demonstrable impact on enhancing the science or decision-support
of sustainability.
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P6     Does the scope of work proposed within the Plan complement research being
       supported by other programs inside and outside EPA?

The Committee found that the scope of work appeared to complement research inside the
Agency and perhaps outside the Agency. More extensive investigation and documentation of
external research related to the Plan is urged.

P7       Are there other potential emerging research areas that the Plan should
         consider?

The LTGs are sufficiently broad to cover most emerging issues, however, it is unclear how the
Agency will identify, prioritize, and respond to emerging issues on an on-going basis. The plan
should reflect this since it has both resource and coordination implications (for instance,
coordination with the 16 other MYPs). What criteria will be used to define "emerging" issues,
how will they be prioritized, and what type of criteria could be used to evaluate "success" in
terms of addressing an emerging sustainable development challenge (versus an existing one)?

What should the balance be between existing and emerging, which is related to the broader issue
of how to allocate resources using a portfolio-of-initiatives approach?

P8       Is the level of resources specified by the Plan sufficient to address the research
         issues that it identifies, allowing OKD to achieve the intended outcomes of the
         research program? Is the Plan's relative allocation of those resources among the
         research tracks of the sustainability research program appropriate, based on a
         consideration of scientific and programmatic needs?

The level of support specified for the Plan is $2.7 million external and 36.5 internal full-time
equivalents (FTEs). Assuming the 36.5 FTEs translate into something on the  order of $4 million,
this suggests that the Agency is allocating about $6.7 million to sustainability research (with the
hope that it will increase by 10-20% in the near future). Even in times of declining budgets, EPA
is still a $7.3 billion agency, meaning that the sustainability initiative is less than one one-
thousandth of the Agency's budget. Even if the comparison is made only against the  S&T
budget, the fraction approaches to no more than 1%. No other multi-year plan is allocated such a
miniscule resource base.

The Committee is perplexed by such modest levels of support for a program that promises to re-
focus the way the Agency does research and re-evaluate the basis for the risk-based paradigm.
Given the enthusiastic and expansive goals and metrics for this program, and assurances of
"traction" of the sustainability theme within the Agency, the Committee is, frankly, disappointed
that the Agency is unwilling to initiate this program at a more substantial level. The Plan
correctly points out that as the value of the sustainability program becomes recognized, other
program directors and offices will become more compliant with its attributes, goals, and metrics,
and will presumably become active in seeking out collaborative projects. Even so, in the
Committee's opinion, this initial allocation, even if grown in the short term by 20%, falls far
short of that needed to elevate the sustainability paradigm to a level where it is visible within the
Agency, the federal government, and the nation. In the Committee's opinion, a substantially
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higher commitment is needed to have a serious impact on internal research priorities, managerial
buy-in, and program visibility and growth.

The level of support allocated will limit progress and suggests that the Agency does not assign
high significance to sustainability-based themes into its research programs. For example, the
priorities for future research activities (Section 5.4 of the Plan) would result in further narrowing
ORD sustainability research into the areas of its existing expertise. Instead, the Agency could
seek to develop new and greater capacity  in sustainability research through a combination of new
personnel with training in sustainability research (directed hires), incentives for existing
personnel to explore ways in which their expertise could be incorporated into the sustainability
model (such as focused sabbaticals for Agency scientists), pioneering new models of cooperative
research (such as partnering with industry and other agencies), and one or more small groups of
experts in sustainability within the Agency who could undertake analysis and other related tasks.
In the Committee's opinion, environmental  sustainability should become a main thrust of ORD
with allocation of resources assigned to a level commensurate with its importance for current and
future decision-making.

P9       Does the Plan appropriately address findings and recommendations in
         evaluations of the program  and its components?

Discussions between ORD officials and members of the SAB Committee revealed that this
question pertains to the responsiveness  of ORD to the feedback from the Program Assessment
Rating Tool (PART) Review of USEPA's Pollution Prevention and New Technologies Research
Program (P2NT).

In addressing the PART Review of the P2NT Program, the Plan briefly expresses concerns
about:

       1.     becoming more focused  on the need of Agency client offices,

      2.     fostering more collaboration with other research programs, and

      3.     developing an ability to measure and track program results over time.

Discussions with the Agency indicated that concerns had emerged during the PART review
related to the  lack of a timely review and  failure to integrate all parts of the P2NT program.

ORD's responses in the Plan to P2NT's PART review was insufficient for the Committee to
provide a comprehensive response as more detailed information about issues pertaining to the
PART review should be included in the Plan.

The Plan and feedback from ORD during the June 13-15 meeting indicated ORD is interested in
working with other Agency program offices as well as regional offices and state agencies. The
Committee applauds ORD's commitment to enhancing inter and intra-Agency interactions on
sustainability-related activities but suggests that ORD provide greater clarification within the
Plan regarding the specific steps that will  be followed to achieve meaningful collaboration. In
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particular, ORD needs to explicitly describe how it will work with other governmental
organizations and achieve measurable outcomes that will be helpful for future assessments of the
sustainability program.

There is also information in the Plan that demonstrates ORD's intent on increasing collaborative
efforts with research programs external to the Agency. More explicit descriptions of how such
collaborations will be developed and implemented need to be strengthened within the Plan. The
issue of developing methods to measure and track program results is briefly described as part of
LTG1 in terms of identifying and creating scientifically based sustainability metrics. Such
efforts aimed at developing techniques to measure and track sustainability program results
should be described in greater detail.   Overall, the Plan is commendable but in many instances
is vague particularly when describing proposed results and outcomes that pertain to
sustainability. Planned efforts to quantitatively describe those planned results and outcomes need
to be expanded in light of future external assessments  of the sustainability program.

This Committee review and the upcoming BOSC review should address the concerns delineated
in the PART evaluation about timely review. Regarding the integration of the elements of the
P2NT (now  sustainability) research program, the Plan provides evidence of substantial efforts at
coordination and integration.  The Committee's evaluation of those effects is described in the
responses to other Plan charge questions.
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                     Discussion of General Recommendations
1.     The Committee recommends that the Agency better define those terms associated
       with the sustainability strategy and the measurement of sustainability outcomes.

The Strategy and the Plan need to define sustainability more clearly and overtly. In this regard,
the documents would benefit from explicit acknowledgement of competing definitions of
sustainability—thereby providing both context for the Agency's choice among the various
definitions and recognition of alternative views of this contested and often vague topic.
Similarly, the Agency should acknowledge the emphasis in its approach on environmental
sustainability.  (There should also be greater care taken to avoid conflating sustainability and
sustainable development.) Clarity about these definitions will help readers better grasp choices
made by the Agency and help them locate their own understanding of sustainability relative to
the Agency's deliberations.

In addition, some discussion of the attributes of sustainability (already implicit in the draft
documents)—e.g., systems approach, integrative science—making clear where possible if the
attributes are unique, necessary or sufficient markers of sustainability, will help the Agency
avoid problems where the programs, Plan  and  other constituencies that it hopes to enlist in
sustainability research, deem their existing activities as falling under this rubric without
appropriate expansion, amendment or enhancement.

2.     Picking Projects to Increase Internal and External Integration

The Committee feels that the careful selection  of multifaceted research projects within the Plan is
helpful to the adoption of the sustainability paradigm both within and outside the Agency. EPA
has a prominent leadership mandate in the sustainability arena and its research projects and their
products are important for adoption of the paradigm.  The projects should have visibility and be
nationally compelling. The research products should  strategically integrate into the other 16
multi-year plans across the Agency and allow the Agency to guide other Federal agency research
on sustainability.

A portfolio of projects should be considered that has balance with respect to factors such as risk,
early winners,  and geography. The portfolio might include regional projects, projects conducted
with CRADAs with industry, projects conducted jointly with other agencies, or projects
conducted in cooperation with programs overseas. The Agency has conducted many prior
compelling studies and efforts that may be amenable  to analysis and produce excellent
sustainability science, so some retrospective analysis may be helpful. A portion of the portfolio
may  be considered high risk with anticipated high rewards.  One approach might be the
development of a small,  internal, creative and somewhat protected group that can be strategic
and conduct certain higher risks projects, particularly in emerging areas, to advance important
sustainability science products. The portfolio should become the basis for articulating projects
and products for the APMs and APGs in the MYP.
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Criteria for assembling the portfolio should be developed that include parameters such as
balance, probability of success, and targeted product needs for internal and external adoption.
These criteria should be more detailed than the primary and secondary criteria presently offered.
Criteria for projects of high value but uncertain success may differ. The depiction of a clear
linkage between criteria, project, product, and APMs and APGs in the Plan would be helpful.

Budgetary restrictions limit ORD's options in terms of sustainability technologies to explore,
sustainability projects to fund and participate in, and aspects of sustainability to study within a
project. Yet, to become a presence in the sustainability arena, ORD should be encouraged to
think creatively and "outside the box."

For example, given the importance of water resources and water resource development,
especially in the West, why not explore options for reuse/recycle of grey waters, or collection
and reuse of rain water, even if they are not envisioned within the current regulatory framework
and current practice?

Likewise, the portfolio of projects to fund or directly participate in might also include, along
with obvious "winners", projects that examine unusual aspects of sustainability or innovative
policy options and their relation to sustainability. The willingness to undertake such studies and
to have a diversified portfolio would, in the Committee's opinion, enhance the Agency's
scientific credibility within the sustainability research field.

The same might apply when selecting which aspects of sustainability to examine in depth within
a given project. Consider, for example, biofuels and biofuels policy options.  In addition to
studying the implications of biofuels use on greenhouse gas emissions, the impacts of biofuel
crops on agriculture and the environmental consequences of biofuel crop practices, it might be
valuable to examine how such environmental consequences are linked to social aspects of
biofuel use and production. Similar considerations might apply to a sustainability-based project
that expands the Agency's current hypoxia research efforts in the Gulf of Mexico.  This new
activity could include evaluating the implications for upstream agricultural practice and
wastewater treatment, impacts on communities, economic activities and ecosystems at risk. ORD
could serve as a coordinator for such a project. Another type of project where ORD would be an
excellent leader and coordinator might be one focused on wastewater treatment, a real problem
in communities with undersized capacity and high projected growth in population.

The Committee believes that ORD's long-term success in establishing itself as a major
stakeholder in sustainability research activities will depend on its research portfolio, which
should include a mix of projects that are central to EPA's mission (e.g., watershed protection),
projects that reside at the boundaries (e.g., agriculture and the health of aquatic ecosystems), and
projects that specifically address emerging issues. To pursue them, ORD might consider
partnerships with other agencies and/or international organizations as well as hiring personnel
with the appropriate background, as discussed in overarching theme #3.
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3.     The Committee encourages the Agency to become more creative and strategic in
       developing its human resources programs with the goal of establishing a critical
       number of champions of the sustainability approach to environmental protection.

In an era of constrained resources, it is essential that the Agency be strategic in the development
and deployment of its human capital. It needs to address more explicitly the human resource
implications of working on sustainability research. This involves combining the appropriate
personnel skill set with the most effective management structure as well as addressing where
certain skill sets are employed within the Agency hierarchy. Simply establishing sustainability
outcomes within the context of the existing ORD management structure and research program
goals may not yield the best results.

If it were to achieve the goals of the Strategy and the Plan, there is a need to fill talent gaps. The
Agency needs to acquire the requisite expertise through new hires, or through redirection of the
workforce through transformation of existing skill sets or efforts of current staff, and through
partnering and leveraging other programs in ORD or the agency as a whole. A sabbatical
program to enable current staff to retool would allow the agency to better employ talented
individuals whose current work is no longer supported.  EPA should consider the use of internal
transfers for EPA employees, the Intergovernmental Personnel Act (IPAs) to bring in academics,
details for people from other agencies and fellowships for post-docs such as AAAS Science
Fellows. It might be worth bringing in someone from another country that has worked on
developing and implementing a national sustainability plan. This approach could allow another
6-10 individuals with needed skills and talents to be added to the existing 35 FTEs as well as
better positioning the current 35 FTEs.

There are several areas identified for development. There are no in-house experts with a
background in decision theory. If the Agency is to pursue the critical social  dimensions of
sustainability, even if its focus were limited to environmental sustainability, it needs to hire
individuals with backgrounds beyond the physical sciences, engineering and economics.
Stronger social science components that go beyond economics are needed. Such fields and tools
include anthropology for ethnographic assessments (how individuals, households and
communities think, behave and interact with  products, technologies and natural systems) and
psychology (behavioral economics) among others.

If EPA were to be a knowledge agency as well as a regulatory one, it would need to devote some
resources to analyses and syntheses of the outcomes of both intra-mural and extra-mural research
as well as of the efforts world wide in this area. There is still more thinking that is needed around
sustainable development and EPA's role as well as the need to catalyze additional people and
resources.  A small, internal, creative, and somewhat protected team of five to eight individuals,
for example, could do out of the box strategic thinking on this topic for at least a year without
being saddled with management responsibilities.
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4.     The Committee encourages the Agency to enhance the diffusion of sustainability
       concepts and practices within and outside the Agency (related to strategic human
       resource development, careful project selection and linkage with other multi-year
       plans, consideration of sustainability components for internal and external research
       projects, and securing and  exploiting senior management buy-in).

There is a need for, and EPA should provide, leadership both internal to the Agency and external
among the federal agency family and other organizations. The EPA has an opportunity to
coordinate and lead in the definition of environmental sustainability and in the use of related
research products that will influence how other federal agencies and organizations move forward
with their sustainability programs. The Plan correctly points out that as the value of the EPA
ORD sustainability program becomes recognized, other program directors and offices will
become more compliant with its attributes, goals, and metrics, and will become active in seeking
out collaborative projects.

To achieve leadership by EPA in promotion of environmental sustainability, there needs to be a
paradigm shift at EPA.  The shift needs to be away from the current silos related to air, water,
solid waste, etc and more towards a true systems approach involving personnel from many
different areas, including different offices within EPA, the EPA regions, other government
agencies such as DOD and DOE, community stakeholders (i.e., general public), and industry.

There are many opportunities for EPA ORD to step up to a leadership role, even in the context of
limited resources. ORD could seek to develop new and greater capacity in sustainability
research through a combination of new personnel with training in sustainability research,
incentives for existing personnel to explore ways in which their expertise could be incorporated
into the sustainability model, pioneering new models of cooperative research within the Agency
and with industry, and development of sustainability "think tank" within the Agency.

The development and diffusion of sustainability metrics, tools, and technologies can be
accelerated via the creation of in-house think-tank to consider how to infuse environmental
sustainability approaches and thinking.  The think-tank, a group of perhaps 5-8 people, could
develop the messages that can catalyze additional people and resources.   Such a program could
become attractive since there are not many places in government now where out-of-the-box
thinking on this topic can take place. These people should be kept out of the "weeds" to be able
to think strategically about the topic for at least one year.  Members of the think-tank group need
to be systems thinkers with diverse backgrounds to focus and be agents of change within EPA.

Careful project selection and demonstrated integration with other multi-year plans do matter.
Internal and external interest in ORD sustainability research will be driven at least partially by
successes (or failures) of early projects. The Science and Technology for Sustainability Plan
should have some definitely achievable APGs  and APMs for prioritized themes that will quickly
deliver research product "winners."

The research products should clearly tie into the other 16 multi-year plans. This way, results of
the EPA ORD program in sustainability will be immediately relevant to the larger EPA, and will
encourage more EPA groups to adopt the sustainability paradigm.
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The ORD should require the applicants for both extramural and internal research support to state
how their proposed research impacts, affects, or enhances environmental sustainability.  Similar
to the "broader impacts" component required in all NSF proposals, a statement about
"sustainability relevance" could be a required section in all proposals received by the Agency.

To encourage a systems approach in EPA research, care should be taken to encourage systems
thinking in proposals and to have an extramural review process that rewards not only good
reductionist science but broad systems science that investigates many variables in one or a few
systems.

5.     The Committee strongly supports a greater and more explicit endorsement of the
       sustainability approach by the Agency Administrator as well as other senior
       Agency management personnel

EPA needs to demonstrate leadership both internal to itself and external among the federal
agency family with respect to sustainability and environmental stewardship. To that end, within
ORD, the position of National Program Manager for Sustainability needs to be created. Such a
position should be expected to lead not only in ORD but in the Agency as a whole. Management
of the overall team if developed as outlined in Section 3 above will require skill and care. The
National Program Manager, as well  as leadership of the various programs directed at
sustainability should be chosen carefully. Explicit support from the Administrator of this effort,
and of this position is critical. It is also important that the Agency recognize that the opportunity
for leadership across the federal agencies is now, and that a commitment from the highest levels
will be transformative.

6.     The Committee recommends that the Agency establish more effective and
       substantive collaborations with other federal agencies as well as the private sector.

The Agency and the ORD should be applauded for their recognizing the need to establish
partnerships with sustainability related programs and activities being carried out by others as
summarized in Section  5.2 of the Plan.  However, the Committee feels that this is such an
important item that more specific plans and goals in this regard should be clearly identified
related to the specific environmental sustainability projects to be performed.

As environmental sustainability relates to achieving a balance  among the three areas  of economic
growth and viability,  social responsibility and environmental protection, organizations associated
with all three aspects need to be engaged.  With much effort and focus being given to the issue of
environmental sustainability by numerous groups ranging from governmental organizations, the
private sector and academia, EPA could move into the key role of providing overall leadership
and coordination among these different organizations by providing structure and focus as none
presently exists.

The Committee recommends that the Agency immediately initiate a thorough bench-marking
exercise of different organizations dealing with environmental sustainability, both within the US
and internationally as well as covering all the different stakeholder groups. This will serve to
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help bring the Agency personnel quickly up the learning curve as well as even help to identify
some key focus areas that EPA could begin participating in directly. As a first step, ORD could
just determine what is happening within other Agency program offices and determine what
opportunities exists for greater coordination and resource leveraging.  The lessons learned
internally by the Agency could be expanded to other governmental organizations, academia and
the private sector.

In conclusion, actively engaging many of the other organizations focused on environmental
sustainability can be the first step in EPA becoming the body that first brings the different groups
to the table,  and then provides the coordinating structure that holds them together to achieve true
sustainability. This could also be the first step for all the other programs within EPA to be
focused and coordinated under an overall environmental sustainability paradigm.
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