United States
Environmental Protection
Agency
Utfice of the Administrator
Science Advisory Board
Washington DC 20460
SAB-EC-88-040C
September 1988
Final Report
Appendix C:
Strategies for Ecological
Effects Research
Report of the Subcommittee
on Ecological Effects
Research Strategies Committee
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NOTICE
This report has ber»a written as a part of the activities
of the Science Advisory Board, a public advisory group providing
extramural scientific information and advice to the Administrator
and other officials of the Environmental Protection Agency.
The Board is structured to provide a balanced, expert assessment
of scientific matters related to problems facing th^ Agency.
This report has not been reviewed for approval by the Agency;
hence, the contents of this report do not necessarily
represent the views and policies of the Environmental Protection
Agency or of other Federal agencies. Any mention of trade
names or commercial products do not constitute endorsement or
recommendation for use.
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U.S. Environmental Protection Agency
Science Advisory Board
Research Strategies Committee
Chairman
Dr. Stanley Auerbach, Environmental Sciences Division, Oak Ridge
National Laboratory, Oak Ridge, Tennessee 37831
Members
Dr. Philippe Bourdeau, Director, Environment and Non-Nuclear'Energy
Research, Directorate General for Sciance, Research and
Development of the Commission of the European Communities-,
200 Rue de la Loi, 1049 Brussels, Belgium
Dr. Dan Goodman, Montana State University, Department of Biology,
Louis Hall, Bozeman, Montana 59717
Dr. Rolf Hartung, Professor of Environmental Toxicology, School of
Public Health, University of Michigan, Ann Arbor, Michigan
48109
Dr. Allan Hirsch, Vice President, Health and Environmental Review
Division, Dynamac Corporation, 11140, Rockville Pike,
Rockville, Maryland 20852
Dr. Robert Huggett, Professor of Marine Science, Virginia Institute of
Marine Science, College of William and Mary, Gloucester
Point, Virginia 23062
Dr. Harold Mooney, Professor of Ecology, Department of Biological
Sciences, Stanford University, Stanford, California
94305
Dr. John Neuhold, Department of Wildlife Sciences, College of Natural
Resources, Utah State University, Logan, Utah 84322
Dr. Scott W. Nixon, Professor of Oceanography, University of Rhode
Island, Narragansett, Rhode Island 02882-1197
Dr. Paul G. Risser, Vice President for Research, University of New
Mexico, Albuquerque, New Mexico 87131
Dr. William K. Smith, Professor of Forest Biology, School of Forestry
and Environmental Studies, Yale University, 370 Prospect
Street, New Haven, Connecticut 06311
Dr. Frieda Taub, Professor, School of Fisheries, University of
Washington, Fisheries Center WH-10, Seattle, Washington
98195
Dr. Richard G. Wiegert, Professor .of Zoology, Department of Zoology,
University of Georgia, Athens, Georgia 30602
ii
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Tnvi-feed EPA_ Part: icipants
D*-. Michael * Slirr.ak, Deputy Director, Office cf Environmental
~rcriS5-=3 2 r. z E f I £ c ~ 3 , Ci z ~~ c t ?- s s e a r c r. i"~. d Zeve'c'CT. e
EPA (T3755C) , 401 .M Street, 5.W., Washingtcn, D.C. 2046G
Dr. David G. Davis, Director, Office of Wetlands Protections,
Office of Water, EPA, 401 M Street, S.W., Washington,
D.C. 20460
Science .Advisory Board Staff
Ms. Janis C. Kurtz, Environmental Scientist and Executive Secretary,
EPA, Science Advisory Board, (A101-F), 401 M Street,
S.W., Washington, D.C. 20460
Mrs. Lutithia V. Barbee, Staff Secretary, EPA, Science Advisory Board,
(A101-F), 401 M Street, S.W., Washington, D.C. 20460
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**** Table of Contents ****
1.0 EXECUTIVE ZV!2'--.?.V 2±~^ ''-
1.1 The Role cf Ecological Effects Research at EPA 1
1.2 Status of Ecological Effects Research 1
1.3 Needs and Opportunities for Strategic Ecological 1
Effects Research
1.3.1 Assessing risk to ecological systems 2
1.3.2 Defining the status of ecological systems 2
1.3.3 Detecting trends and changes in ecological ' 3
systems
1.3.4 Predicting changes in ecological systems -3
2.0 INTRODUCTION: ECOLOGICAL RESEARCH AND EPA'S MISSION 4
2.1 EPA's Responsibilities in Ecological Assessment and 4
Research
2.2 Relationship of EPA's Ecological Research Program . 4
to those of other Agencies
2.3 Mission of an Ecological Research Program for EPA 5
2.3.1 Providing a strong scientific basis for 6
ecological considerations in Agency decision^
making
2.3.2 Moving EPA into a leadership position among 7
agencies with environmental responsibility
2.3.3 Developing the organizational and intellectual 7
capabilities that will enable EPA to advance
ecological science
3.0 RISK ASSESSMENT AS A UNIFYING GOAL FOR RESEARCH PROGRAM 9
3.1 What is an Ecological Risk Assessment? ^ 9
3.1.1 Definition 9
3.1.2 Benefits 10
3.2 Shortcomings with Present Approaches to Ecological 1C
Risk Assessment
3.3 Present Approaches to Environmental Risk Assessment 11
3,4 Information Needs for Ecological Risk Assessment 12
3.4.1 The endpoint problem 12
3.4.2 Ecological dose-response relationships 12
3.5 Recommendations for Specific Approaches 13
4.0 MAJOR RESEARCH AREAS FOR ADDRESSING THE INFORMATION NEEDS 14
4.1 Ecosystem Classification and Inventory 14
4.1.1 Ecosystem components and mapping 14
4.1.2 Inventory design 15
4.1.3 Recommendations 15
IV
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4.2 Ecosystem Monitoring ' 15
4.2.1 Historical deficiencies 16
4.2.2' Ecological status assessment ]_7
4.2.3 Conclusions and recommendations -3
4.3 Predicting Ecosystem Change 13
4.3.1 Limitations in predictive ability 18
4.3.2 Considerations needed for .ecosystem effects 19
predictions
4.3.3 Recommendations for advancing predictive 21
capability
5.0 INSTITUTIONAL CONSIDERATIONS 23
5.1 Organizational Issues 23
5.1.1 Research committees 24
5.1.2 Office of monitoring 24
_5.1.3 Staffing 25
5.2 'Extramural vs. Intramural Research 25
5.3 Professional Development 26
5.4 Facilities and Equipment 26
5.5 Resources 27
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1.0 EXECUTIVE SUMMARY
1.i The Role of Ecological Effects Research at EPA
EPA was created in 1970 specifically as the regulatory
agency responsible for protecting the environment. The 1970
reorganization creating EPA transferred responsibilities for
conducting research on ecosystems from the Council on
Environmental Quality (CEQ) to EPA. In this capacity EPA has
both executive and legislative mandates to conduct ecological
research upon which other responsibilities related to its mission
depend. Congress has enacted 15 statutes, 11 enforced by EPA,
that are aimed at protecting the environment from anthropogenic
insult, such as those from chemicals, solid waste and other toxic
substances. Virtually all of the environmental statutes enacted
by Congress require EPA to protect ecological values, ultimately
requiring preparation of ecological risk assessments. Among the
important components of the environment to be protected are both
biotic and abiotic components ranging from endangered species to
biogeochemical cycling.
1.2 Status of Ecological Effects Research
Several other Federal agencies conduct or support ecological
research related to their individual missions. Much of this
ecological research contributes information that is important to
EPA's mission and responsibilities; however, this research falls
short of providing a focused and systematic answer to many of
EPA's needs.
EPA's ecological research program has been constrained by
limited resources. Therefore, the preponderance of the Agency's
research effort has been concerned with questions that directly
support immediate decision-making activities. Short-term
decisions have dominated and defined research needs; for example,
the development of single-species, toxicological test methods
for implementing the Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA). Efforts of lesser priority have
generated tools for predicting acute toxicity based on chemical
structure, and methods to extrapolate from acute to chronic
effects or from species to species, especially in aquatic
communities.
1.3~" Needs and Opportunities for Strategic Ecological Effects
Research
Recognition is growing in the U.S. and elsewhere that the
scope of ecological research must be broadened to accommodate the
spectrum of decisions concerning environmental quality that must
be made at present. A broadened scope of research is also needed
to provide for acceptable environmental conditions in the future.
Current, identifiable limitations of scope unequivocally
demonstrate that a full recognition of the need for ecological
risk assessment has not been attained. Also, the structure of
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ecological risk assessment has not incorporated current
ecological knowledge and concepts. In particular, critical areas
of resource management, population theory, and knowledge of the
mechanisms of ecosystem processes need to be incorporated into a
research effort: that is directed towards ecological risk
analysis.
Broadening the scope of ecological research is necessary to
provide the opportunity for strategic ecological effects
research. Building on past studies of effects on individual
organisms, effects on appropriate populations of organisms,
interactions in multiple media and effects on communities or
ecosystems, new studies are needed to provide a comprehensive
understanding of environmental processes and the consequences of
human activities. Studies of these ecologically realistic effects
must relate the impacts of pollution to key characteristics of
ecosystem function, such as physical habitat loss or species
diversity. General risk assessment guidelines should emphasize
investigating and assessing effects that are cumulative, long-
term, and of regional or global scale. Research pathways that
lead toward answers to these questions will provide the
understanding necessary to anticipate and evaluate both the
magnitude and consequence of ecological effects.
To build appropriate methodologies, a knowledge base, and a
data base for evaluating ecological risks and effects, and to
provide the information required to meet the overall needs of the
Agency, a research strategy with the following four components is
recommended:
1.3.1 Assessing risk to ecological systems
Interrelated research activities are required to refine and
improve environmental risk assessment procedures including: a)
identifying appropriate protocols, b) identifying meaningful
endpoints, c) characterizing and quantifying exposures, and d)
analyzing and quantifying uncertainty. These refinements should
be applied as terms in and as structures of models, when
determining appropriate assumptions or conditions of application,
and via the parameters to be measured to perform environmental
risk assessments.
1.3.2 Defining the status of ecological systems
Understanding the degree to which the quality of the
environment may decline as a result of human activities or
improve as a result of environmental management and remediation
activities depends upon a valid and accurate assessment of
environmental characteristics. Ecosystem status measurements and
analyses of these data provide the fundamental information that
is needed to characterize and understand the environmental
resource that EPA is charged with protecting.
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1.3.3 Detecting trends and changes in ecological systems
Monitoring allows detection and quantification of changes in
specific parameters that are judged to be either critical in
themselves or that serve as indicators of changes. Monitor-ing
is also necessary to assess the effectiveness of environmental
management and mitigation practices, and to provide future
generations with reference statistics.
1.3.4 Predicting changes in ecological systems
Developing new and expanded predictive methods and
assessment techniques requires considerations of complexities,
such as impacts of indirect and long-term effects, responses to
multiple insults, variability between ecosystems, and differences
in spatial and temporal scale. Developing a predictive
capability will require predictive studies, experiments in
natural ecosystems and the development and validation of models.
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2.0 INTRODUCTION: ECOLOGICAL RESEARCH AND EPA'S MISSION
2.1 EPA' s respor.sibilit.ies in eco_I_ogi,caJL assessment, and research
EPA was created in 1970 specifically as the regulatory
agency responsible for protecting the environment. In this
capacity EPA has both executive and legislative mandates to
conduct ecological research in support of other aspects of its
mission, responsibilities transferred to EPA from CEQ. Congress
has enacted 15 statutes, 11 enforced by EPA, that are aimed at
protecting the environment from anthropogenic insults such as
those from chemicals, solid waste and other toxic substances.
Many of the environmental statutes enacted by the Congress
explicitly require EPA or other agencies to prepare ecological
risk assessments. Appendix I identifies these statutes and their
provisions. Aspects of the environment to be protected include
fish and wildlife resources, food webs serving human consumption,
aesthetic and recreational values, and rare and endangered
species. EPA's mission also entails maintaining basic biotic and
abiotic life support systems, such as long-term productivity of
aquatic and terrestrial ecosystems and biogeochemical cycling.
The Agency's past emphasis with respect to anthropogenic
stresses has been on human health. This emphasis has translated
into a capability to perform human health risk assessments. This
capability far surpasses the Agency's ability to perform
environmental risk assessments, primarily due to our relative
lack of knowledge of effects other than those on human health.
The importance of maintaining viable, healthy ecosystems for
human welfare and health is increasingly recognized by the public
and private sectors. In a recently completed exploratory review
of environmental problems, EPA identified thirty-one major
environmental problem areas and characterized them in terms of
their relative importance. Twenty-two of these problem areas
were identified as important because of effects mediated by
ecological impacts [1]. These problem areas involve 16 particular
types of ecological systems; some involve entire geographic
regions, while others represent cases where the entire biosphere
is at risk.
2.2 Relationship of EPA's Ecological Research Program, to those
of other Agencies
A number of other Federal agencies conduct or support
ecological research, including the Fish and Wildlife Service
(FWS/Department of the Interior), the Forest Service (FS/U.S.
Department of Agriculture), the National Oceanic and Atmospheric
Administration (NOAA/Department of Commerce), the Department of
Defense, the Department of Energy, and the Bureau of Land
Management. Respective ecological research programs are related
to the statutory missions of those agencies. More fundamental
research in ecology is supported principally by the National
Science Foundation (NSF).
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While much of the ecological research conducted by other
agencies contributes information that is important to EPA's
mission, it falls short of providing a focused and systematic
answer to many of EPA's needs. Since each Agency has a specific
mission, it is not surprising that many direct concerns to EPA
may not be addressed at all by the other agencies. The result is
that no one agency is collecting, integrating and synthesizing
ecological information in a way that supports EPA's need to
measure the status of ecological systems and to anticipate and
detect potentially unfavorable trends and changes.
Of course, EPA should keep abreast of related ecological
research programs at sister Federal agencies, and special efforts '
should be made to encourage coordinated research wherever
feasibility and efficiency warrant. Such coordination will
complement and enhance the impact of the Agency's own strong,
independent effort, which is necessary to meet its specific goals
and obligations.
2. 3 Mission, of. _a_n ecological research program for EPA
In response to limited resources, EPA has concentrated its
research effort on immediate and obvious questions that directly
support decision-making. Of necessity, past research has
supported decisions needed in the short-term. For example,
research efforts have focused on single-species, rapid toxicity
test methods for regulatory permitting processes. These efforts
shorten the time and expense of testing at the sacrifice of
correctly identifying the hazards of slow acting toxicants or
those that will cause problems by indirect mechanisms.
There is growing recognition that the scope of "research must
broaden. This recognition is prompted, for example, by cascading
effects seen in response to acid deposition, and in far-reaching
effects seen as a result of stratospheric ozone depletion. A
broadened scope must accommodate the full spectrum of decision-
making, in both the near- and long-term. The ecological effects
of complex mixtures (as opposed to single chemicals) are now
being considered, and risk assessment methods are being explored
that can be applied at the population, community and ecosystem
levels, as well as the single organism/species level. Regional
and global scale, as well as long-term ecological problems are
being given increased attention, although little administrative
or budgetary support is apparent.
Some ongoing EPA research programs do reflect this broader
emphasis and they include investigations into effects of acid
deposition, protection of wetlands, effects of global climate
change, and questions of microbial ecology/biotechnology. Even
in these forward-looking programs, there are identifiable
limitations of scope which suggest that a full appreciation of
the needs for ecological risk assessment has not been attained.
With the exception of newer approaches described above much of
the research involves testing for toxic effects on ecological
components, rather than considering the ecological system as a
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whole. The focus of research programs generally remains on
effects of individual pollutants on individual organisms,
although some projects take a multimedia, community assessment
approach. Additionally, focus is typically placed on knowing the
pollutant, rather than on knowing the environment that we seek to
protect.
The Subcommittee on Ecological Effects envisions three main
goals for EPA's ecological research program, They are, in order
of priority: .
a. Providing a strong scientific basis for ecological
considerations in Agency decision making.
b. Moving EPA into a clear leadership position among
agencies with environmental responsibility.
c. Developing the organizational and intellectual
capabilities that will enable EPA to advance
ecological science.
2.3.1 Providing a strong scientific basis for considerations
in Agency decision-making
In planning and conducting ecological research, EPA mst
remain continually aware of the need to integrate research
findings and assessments into the regulatory responsi-bilities
which are manifest as its policy framework. This framework,
derived from current statutes and regulations, generally consist
of a set of linked questions, the answers to which should develop
from ecological considerations. These key questions include;
a. Status
How extensive is ecosystem change, and how does
it affect the human component of the ecosystem, e.g.
human values and activities?
b. Causality
What are the relationships between environmental
stresses and the effects observed?
c. Risk
What consequences are posed to ecosystems from
pollutant stresses?
d. Mitigation
What ecological improvements can be brought about
by various choices among options for mitigating
environmental impact and at what additional or alternative
ecosystem risk?
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e. Recovery
What rate and degree of ecosystem recovery can be
anticipated as pollutant stresses are reduced?
f. Prognosis
What is the probability, source and magnitude of
ecological effects anticipated in the future?
Simple consideration of direct effects (such as single
species toxicity) will not suffice to provide adequate answers
for these questions. Therefore, EPA should develop the
capability to address broader ecological questions. Such
capability will allow EPA to progress towards solutions to the 22
ecological problems that the Agency has identified [1].
The incorporation of ecological data into the decision-
making and the regulatory process can enhance the Agency's
performance and the safety of the environment by:
a. Identifying reasonacle goals and facilitating
determination of the degree to which environmental goals
are being met.
b. Providing a sound scientific basis for setting
priorities, ranking environmental problems and
allocating resources.
.c. Optimizing selection of methods for preventing,
detecting, solving or mitigating environmental
problems.
d. Expediting the clear communication and integration of
research results to EPA, state and local governments,
and the public.
2.3.2 Moving EPA into a leadership position among agencies
with environmental responsibility
At the moment, no one agency has undertaken the task of
compiling and making available the full spectrum of
environmental data or of coordinating the plans for gathering
needed data. There is an obvious need for centralized
coordination, and EPA is the logical choice for the role, both in
terms of having the greatest needs for this information and the
breadth and availability of expertise in matters of environmental
quality.
2.3.3 Developing the organizational and intellectual
capabilities that will enable EPA to advance
ecological science
The answers to many of the questions that EPA must address
are likely to require the development of new theories and
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concepts, as well as simply new data. To ensure the growth
of that knowledge base, it is necessary for EPA to participate
in the progress of the science of ecology.
The Federal support of fundamental ecological research is
primarily the province of NSF. However, NSF's research program
is primarily predicated on the interests of the Nation's
researchers, and there is no guarantee of complete congruence
between the needs of EPA and the priorities of the scientific
community at any particular time. Thus, to encourage development
of ecological science in the direction it requires, EPA should
allocate a reasonable fraction of its research effort to
fundamental research, particularly in areas where the scientific
community is not adequately addressing the needs of EPA.
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3.0 RISK ASSESSMENT AS A UNIFYING GOAL FOR THE RESEARCH PROGRAM
3.1 What is an ecolcaical risk assessment?
3.1.1 Definition
An ecological risk assessment is an estimate of the
likelihood severity and extent of ecological effects
associated with an exposure to an anthropogenic agent or a
perturbational change, in which the risk estimate is stated in
probabilistic terms that reflect the degree of certainty.
The steps in ecological risk assessment may include:
a. Hazard identification
Demonstrating the plausibility of a specific
adverse environmental effect and the mechanism linking
the effect to a particular human action.
b. Determination of the population at risk
Identifying the extent of the landscape that can
potentially be affected.
c. Source inventory
Determining the potential intensity of the activity
that generates the factor creating a hazard usually via
an environmental survey.
d. Exposure assessment
Measuring the ambient intensity of the causal factor
adjusted for transport, dispersal ecological interactions
and vulnerability patterns which modulate the effective
dose.
e. Dose-response determination
Relating the magnitude of the effect and the
intensity of the exposure to the causal factor.
f. Risk characterization
Putting together all of the pieces to obtain an
estimate of the probability distribution of a range
of outcomes.
g. Quantification of uncertainty
Documenting the uncertainty about the estimate due
to potential uncertainties in measurement and prediction
through the process.
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3,1.2 Benefits
Risk assessment is simply a systematic and formal
application cf ail t.he ir.fcrmaticr. that is available for
predicting outcomes under actual or hypothetical conditions.
The outcome is expressed as the probability of some unit of
"effect" and the hypothetical conditions have to do with
alternatives about which decisions can be made. The objective is
to process information in such a way that the most accurate
prediction possible is provided. The predictions must be
suitable for deciding among alternatives, while keeping track of
the degree of uncertainty so that the decision-maker can have
some indication of how firm the prediction is. The formal
methodology of risk assessment accomplishes this objective in a
comprehensive and logical manner.
Risk assessments are designed to promote better decisions,
A focused ecological research program can provide for more
certainty in environmental risk assessments, both in terms of
effect and assumptions, thereby offering three major types of
benefits:
a. The quality of the advice given in support of decisions
will improve, so that subsequent environmental
management and regulations will be improved.
b. The potential for making more accurate predictions will
be enhanced. Predictions can trigger preventive action,
reducing the need for costly and after-the-fact
mitigation, recovery and clean-up programs.
c. Risk estimates will be more reflective of actual risk
- posed allowing for narrower "margins of safety" and
potentially less restrictive regulation.
The accumulated procedures used to assess risk have a modest
track record in evaluating human health questions related to
environmental pollutants, but have been applied more tentatively
to ecological questions. Given the need for ecological risk
assessment at EPA, concerted emphasis should be placed on
vigorous development of ecological risk assessment methods.
3 .2 Shortcomings with some .present ar:r?roaches to ecological risk
assessment
Present ecological risk assessment practices commonly fall
short of their potential in three ways:
a. The risk assessment may fail to consider all the
ramifications in a complex causal network, so that it
presents an assessment of only some of the risks.
b. The risk assessment may fail to provide adequate
estimates of uncertainty, so the user has little or no
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basis for evaluating its results compared to those of
any other prediction methodology.
c. The knowledge base and data base may be so weak that
the uncertainty estimate associated with the risk
assessment renders the conclusion tentative, unusable
or indefensible.
If the measured uncertainty is enormous, that fact is
extremely important. In such cases the decision-maker (and the
affected constituency) need to be aware of the magnitude of the
uncertainty, both to allow for appropriate caution in the
decision and to document the need for improved information.
3.3 Present approaches to environmental risk assessment
The field of ecological risk assessment continues to evolve
as the method is applied to a variety of environmental problems.
Such applications have served to identify areas of uncertainty
in risk assessment and aid in defining areas for additional
research.
EPA's Ecological Risk Assessment Program has the primary
goal of formalizing and systematizing scientific knowledge of
ecological risks in order to provide both guidance and models
for decision-makers. For example, in EPA's Office of Pesticides
and Toxic Substances environmental risk assessments assist
decision-makers in making at least two kinds of decisions:
a. Predicting environmental impacts without access to any
observational data (the Premanufacturing Notification
requirement of the Toxic Substances Control Act)
b. Extrapolating observed behaviors from single ecosystems
(at best) to all other ecosystems that conceivably might
become exposed through, for example, the expanded use of
pesticides.
Because of experimental and observational tractability, most
of EPA's ecological risk assessment approaches have focused at
the level of single organisms. These techniques have proven
valuable, especially for certain species about which much is
known, but serious uncertainties exist in our ability to assess
broader ecological risk, which impact on the quality of
decisions. When risk assessments are based just on extrapolation
from acute or chronic dose responses of individual organisms,
potentially important indirect effects can be missed. Current
single-species tests can indicate reductions in life span,
health, and reproductive rate. However, in complex communities,
populations under stress may increase because of reduced
competition or prediction. An example of such indirect effects
occurs with algae blooms, which may occur after insecticide
treatments have removed the consumers that normally keep the
algae population at lower levels of abundance.
Overall, these efforts indicate a serious interest in
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ecological risk assessment at EPA, but the full potential of
ecological risk assessment is not being realized, both for lack
of an agreed upon systematic methodology for a complete risk
assessment and a lack of fundamental knowledge in the science of
ecology.
.3.4 Infontiation needs for ecological risk assessment
3.4,1 The endpoint problem
m
There are no. obvious ecological equivalents of "human cancer
rate" or "reactor-core meltdown probability" to serve as the
common currency for a quantitative statement of the magnitude of
the outcome where risk is of concern. This common currency is
sometimes called the "endpoint11. For the purpose of
communication, it may be necessary to find an analog to the
situation in human health risk assessment; however, non-health
ecological concerns are more difficult to reduce to a simple one-
dimensional functions. There are numerous types of ecological
effects, many of which are not interconvertible or self-evident
in terms of environmental quality or human welfare. These
include:
a. -Effects on the biosphere as a life support system
b. Effects on agricultural productivity
c. Effects on productivity of harvested wild lands
d. Effects on aesthetics/amenity functions
e. Effects on endangered species
f. Symbolic indices of our care for the environment.
To the extent that these endpoints are genuine matters of
concern for some substantial constituency, they are all
legitimate endpoints. However, they are qualitatively
diverse, difficult to compare or relate quantitatively, and not
recognized by a universal constituency. To improve the risk
assessment process, meaningful endpoints that relate to causal
factors must be found.
3.4.2 Ecological .dose-response relationships
Dose-response relationships are not only applicable to
toxicity testing of individuals but can also be extended to
the measurement of responses at the population, community, and
ecosystem levels. Often, the dose-response information
is based on the results of controlled laboratory experiments.
But simplified conditions in laboratory tests (and some modest
scale field plot tests) may not adequately mimic behavior of the
real system. Discrepancies and inconsistencies arise due to
effects of scale, complexity, boundary processes, and missing or
unrecognized factors. Further, the available laboratory data are
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usually quite restricted with respect to the number of species,
life cycle stages, and genetic strains studied, and frequently
ignore effects of multiple stresses, and population, community,
and ecosystem level effects. For these reasons, it is essential
that dose-response relationships used in risk assessments be
verified in intact systems.
Unfortunately, much of the available dose-response data
represent those systems that have been considered scientifically
interesting and convenient, so this "sample" cannot be counted on
to represent the real distribution of possibilities. Thus, we
cannot assume that means or variance in dose/response data from
this "sample" are adequate for extrapolating to a risk assessment
for a system with components other than those covered in the data
base. Even more limiting, this data base by itself is
insufficient for estimating the uncertainty of the extrapolation,
3.5 Recommendations for specific approaches
The logical, systematic framework of risk assessment offers
a means for organizing the relevant factual information that is
available which bears on predicting the outcome of some
contemplated action (or inaction) with respect to environmental
regulation, policy, and management. Risk assessment offers a
methodology for making these predictions under conditions of
uncertainty when available data are incomplete of dubious
quality. More importantly, risk assessment allows the
consequences of this uncertainty in the input data to be traced
to the resulting uncertainty in the prediction. The sections to
follow describe examples of the types of research activities that
must be carried out to improve our information base; thereby
improving our ability to perform more certain ecological risk
assessments,
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4.0 MAJOR RESEARCH AREAS FOR ADDRESSING THE INFORMATION NEEDS
4.1 Ecosystem classification and inventory
Inventory and classification measurements provide an
information base for estimating the extent and location of
specifically inventoried resources that are potentially at risk.
These measurements also provide a means for extrapolating risk
factors from small scale to larger scale systems that are
potentially at risk. Effects on or hazards to resources
supported by these ecological systems can also be evaluated. Any
indication that environmental change is imminent or has taken
place, must first be addressed by determining whether the change
has actually taken place, or is currently taking place. The
magnitude of the change and the extent of the landscape that is
affected must be determined.
4.1.1 Ecosystem Components and Mapping
In order to extrapolate risk functions or effects from small
to large scale, the landscape can be divided into natural units
with coherent ecological processes, rather than political units.
The structure of the ecosystem is currently reflected by
measurements based on species diversity, importance indices, or
selection ratios. Chemical compartmentalization is also measured
to reflect the state of ecosystems using measurements of standing
biomass or distribution and availability of nutrients. Research
is needed to guide selection of proper divisions. Some examples
of useful mapping projects are discussed below.
a. Eco-Region Concept
The eco-region concept used by EPA provides an example
of a useful mapping project and also provides an excellent
foundation for the studies described above. The concept is
based on the observation that within a region the landscape
is a mosaic of patches which form the components of
pattern. The eco-region project shares this concept with
landscape ecology, a relatively new ecological discipline,
dedicated to improving our understanding of the development
and dynamics of patterns in ecological phenomena. Research
related to eco-regions and landscape ecology contributes to
our capabilities in ecological classification -and inventory.
b« LANSAT Mapping
Another ecological mapping project is represented by
the on-going LANSAT project. This project produces maps
that depict rainfall, temperature and geomorphology and are
subjected to ground truth measurements to control accuracy.
LANSAT maps may also show the state of vegetative sere
development to reflect succession, and depict biomass
measurements to reflect ecosystem state variables in terms
of trophic level or vegetation types.
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4.1.2 Inventory design
Several specific factors should be considered in designing
the inventories used to establish landscape mapping units. These
factors include determination of the error rate for
classification of sites, determinations of within-class
heterogeneity, and determination of uncertainty in extrapolation
applications,.including the assignment of site vegetation
potential.
Data accuracy should be consistent with decision-making
demands for variables that are related to identified issues.
Furthermore, data accuracy in inventory design must be consistent
with the design of future trends-monitoring, which will be
compared to the initial inventory when making assessments.
4.1.3 Recommendations
In addition to the recommendation for approaches that can :
provide a firm foundation for extrapolation, studies documenting
or describing the major life support services or values of
various types of ecosystem should be conducted. The mapping and
inventory projects designed to provide this foundation should
include ecosystem status indicators that can be correlated with
ecosystem function and value. Experimental studies are also
needed to quantify ecosystem responses to major environmental and
anthropogenic per-turbations and to test the utility of the
parameters selected to measure ecosystem status in one or more
systems.
4.2 Ecosystem Monitoring
Strategic monitoring elements are essential for determining
changes or trends in ecological systems or environmental
parameters influencing these systems. These strategic elements
may be carried out as programs that involve repeated measurements
of selected biological functions in conjunction with physical and
chemical variables over time. Monitoring information is of
critical importance to hypothesis formulation, hypothesis
testing, ecological prediction and ecological risk analysis.
Spectral analysis and other approaches involving data aggregation
and pattern recognition techniques are proving useful. Such
advances 'lead to a mere complete understanding of ecological and
environmental phenomena and cycles.
The long-term ecological research program of EPA should
include provisions for both biological and chemical monitoring.
Extended term monitoring is needed to track environmental
pollutants such as ozone, S02, and NO^ and to reveal whether
ecological systems are improving, deteriorating or remaining
stable over time.
15
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4.2.1 Historical deficiencies
As important as monitoring efforts are, they.have histori-
cally been characterized by numerous limitations and
deficiencies. The following are some of the most important:
a. Monitoring programs frequently lack clear definition and
long-term justification.
b. Monitoring efforts commonly fail to recognize relevant
temporal and spatial dimensions or scale.
c. Data sets from uncorrelated monitoring programs-may
not be compatible nor comparable. Mathematical
characteristics, e.g. sensitivity, thresholds,
correlation, indices, efficiency and uncertainty, all
influence comparability of monitoring data. Protocol
standardization, quality assurance and quality control
measures must be coordinated in order to achieve
compatibility.
d. Monitoring programs are inherently costly, and main-
taining continuity of effort in mission, motivation,
manpower and money is a sizable challenge." Feasibility,
utility and scientific validity must be carefully
evaluated along with expense and manpower requirements
to ensure a successful strategy.
e. Monitoring efforts directed at documenting change in
biological systems do not adequately distinguish
changes induced by natural forces from changes induced
by anthropogenic forces.
f. Much of the environmental monitoring being undertaken
by state and federal agencies appears to be designed
solely or primarily to determine compliance with
regulations.
g. Existing environmental monitoring programs, such as the
air compliance monitoring program, are not well utilized
in ecological effects programs.
h. There is no research effort to determine the most
appropriate physical parameters, chemical species
and biological measurements to monitor, although
significant literature on this determination exists.
Implementation of a research program dedicated to the
identification of the most useful and cost-effective
biological parameters to monitor is needed.
Long term ecological monitoring should be an integral
part of the EPA's strategy for ecological research and risk
assessment. There are a number of unknowns which make optimal
design of such monitoring programs difficult. However, enough is
16
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known to.initiate research programs which could be highly
productive, generating observations about system status which
will also serve as the basis for hypotheses and hypothesis
testing.
4.2.2 Ecological status assessment
EPA is the most logical and appropriate organization to
carry out a regular and systematic assessment of the status of
the American environment. As a first step, the Subcommittee on
Ecological Effects recommends that the Administrator establish a
group specifically charged with and funded to carry out this
important mission. The efforts of this group should include the
following:
a. Assessment of existing and historical monitoring
efforts
b. Storage, synthesis, and interpretations of available
monitoring results
c. Identification of important gaps in the present
acquisition of environmental monitoring data
d. Analysis of major environmental perturbations, both
natural and experimental, that will assist in the
design of future monitoring programs or in the
interpretation of changes already observed
e. Development of a coordinated system for the collection
and interpretation of ecological and environmental
monitoring data within EPA.
Numerous monitoring programs have been in place for varying
periods of time in a variety of Federal, state, regional and
local agencies. Examples include the Status and Trends program
and the Mussel Watch project in NOAA, the collection of
commercial fisheries landing data by NMFS, the breeding bird
count at the National Audubon Society, and the National Timber
Inventories of the U.S. Forest Service. Numerous research
programs are associated with existing monitoring projects; for
example, the NSF Long-Term Ecological Research (LTER) sites
forest watershed research programs (e.g. Coweera, NC; Hubbard
Brook, NH, Walker Branch, TN), estuarine sites (e.g Narragansett
Bay, Chesapeake Bay) ana the National Acid Precipitation
Assessment Program efforts.
At present, there is no systematic and comprehensive
collection, synthesis and interpretation of the results of these
efforts. EPA ventured into such an effort in 1980 with
publication of their "Environmental Outlook," but the effort was
not sustained. While it may never be practical or possible to
obtain and summarize all of these data, we presently lack even
the general overview that was represented by the EPA document and
formerly provided by the Council on Environmental Quality.
17
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It is likely that an important finding from the first effort
will be that there are major gaps in all of the existing
monitoring programs. Based on a benchmark review, decisions can
then be made about reducing redundancy in programs and embarking
on new ones that may be carried out by EPA or other agencies.
4.2.3 Conclusions and recommendations
Current deficiencies in basic ecological research impede our
abilities to design and implement a comprehensive ecological
monitoring program. Nevertheless, the correct approach is to
start a monitoring program based on our best available
understanding, while at the same time initiating research
programs which will yield knowledge to be incorporated into new
and modified ecological monitoring designs. In other words, the
Agency's ecological monitoring program must be designed to evolve
for at least the first decade.
An ecological monitoring research program, taking advantage
of existing ongoing monitoring programs, such as the National
Surface Water Survey Phase IV, should be funded and implemented.
The program's design should include quality assurance, and
standardization of protocols, as appropriate. The statistical
design selected should address EPA's research and predictive
needs, as well as its regulatory requirements. In addition, EPA
should conduct a regular and systematic assessment of the status
of the American environment, applying this knowledge to determine
the status of representative ecological systems, as well as
reaching such conclusions on regional and local scales. Finally,
long term environmental monitoring should be an integral part of
the EPA's ecological research strategy.
4.3 Predicting ecosystem change
Many of the decisions that EPA must make involve predicting
and preventing environmental damage, rather than cleaning up
existing pollution. These range from discrete, relatively short-
range decisions, such as establishment of water quality criteria
for the protection of aquatic life, to long-range, even global
decisions, such as limiting chlorofluorocarbon emissions in order
to protect stratospheric ozone depletion. The Agency needs a
predictive capability to anticipate and prevent emerging
problems.
4.3.1 Limitations in predictive ability
For many issues of concern to EPA, the ability to predict
ecological consequences is limited for several reasons. First,
serious deficiencies exist in our understanding of the ecological
effects of environmental perturbations. A CEQ Report on Long-Term
Environmental Research and Development stated, "Our capacity to
estimate ecological and environmental risks is not sufficient to
ensure against either costly, and possibly irreversible, damage
to essential biogeochemical cycles or preventable extinctions of
endangered species and ecosystems" [2].
18
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Second, many ecological problems are multi-faceted and
interactive. Various stresses may be operating on a system
simultaneously. These include both man-induced stress and extreme
natural events, such as drought cycles, floods and other
variations in climate. The interactive, cumulative and long-term .
influences of both natural and human influences on ecosystems
means that their conditions often cannot be assessed in pollutant
specific or project specific terms.
Third, experimental and observational approaches to develop
predictive power need to be emphasized. EPA's research has
focused on individual, short-range problems, rather than on the
sustained and rigorous combination of approaches to ecological
research that is necessary for the development of explanatory
theory and fact to support predictive capabilities. The ability
to predict environmental changes depends on the predictive power
of the underlying science; and by strengthening this foundation,
EPA can make significant advances in predictive capability while
still carrying out its statutory responsibilities.
4.3.2 Considerations needed for ecosystem effects predictions
Developing the necessary next-generation of predictive
methods and assessment techniques requires explicit incorporation
of some important scientific considerations, including the
effects of scale, both spatial and temporal, ecological
interactions and resultant indirect effects, responses to
multiple stresses, long-term effects and ecosystem variability.
These considerations are discussed below.
a. Effects of scale, spatial and temporal
Ecological problems occur on various spatial scales:
global (e.g., climate modification), regional (e.g., estuarine
degradation), and local (e.g., site-specific fish kills.
Scale is extremely important. For example, small scale
elimination of species allows rapid replacement by
immigration while large scale elimination does not.
Extrapolation of results from one scale to another is
difficult and must be done with caution.
In addition to spatial scale, consideration must also
be given to temporal scale. Ecological systems may undergo
natural change on time scales of hours to centuries.
Ecosystems founded on primary production by plankton, such
as open ocean systems, experience hourly diurnal
fluctuations in dissolved oxygen. In contrast, forest
ecosystems undergo community changes that occur over decades
or centuries. Basic aspects of biological systems that are
responsible for natural cycling and variability must be
understood in order to clarify and predict the effects of
perturbants.
19
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b, Ecological interactions and indirect effects
Interacting communities of organisms have recovery
capabilities and redundancies that individual organisms
lack. Some populations may have extensive compensatory
capabilities in one circumstance, but be driven to
extinction in another. In ecosystems, actual effects of
chemical exposure may be different from predictions that are
based on individual organism responses. Exposure may be
increased by bioconcentration processes or decreased by
changes in bioavailability. Exposure to pollutants may
cause a population to proliferate as a result of the
elimination of its competitor or predator population, or as
a result of complex interactions.
Thus a direct effect on one population (the
predator/competitor) causes an indirect effect on another
population. Such interactions points to the need for study
of effects in complex ecosystems; that is, a study of the
characteristics and behavior of the receiving environment,
as opposed to the behavior of pollutants themselves.
c. Responses to multiple stresses
Episodic events, such as storms, droughts, and floods
are naturally occurring events that cause variable responses
in ecosystems. Pollutants also cause variations in response
due to their chemical characteristics, source and route of
exposure (e.g. point or-non-point source). Physiologic
stresses such as pH, UV or temperature also induce ecosystem
responses. Traditionally, these stresses have been studied
in isolation, to determine the mechanism of toxicity or
physiological effect. However, ecosystems often experience
multiple forms of stress, cumulating impacts over time,
which cannot be elucidated by isolated or specific
approaches.. Understanding the effects of multiple stresses
requires a more holistic approach in research design and
data analysis.
d. Long-term effects
Long-term impacts may occur over time and over
regions far removed from their source. Such responses
may vary seasonally and from year-to-year, as well as by
random a processes; therefore, they must be examined over
long time frames to understand the significance of trends.
Ecosystem level effects, such as chronic or cumulative
degradation in river basins and estuaries, and impacts of
intensive agricultural development may only be revealed by
commitments to long-term investigation.
e. Ecosystem variability
Despite their similarities, not all ecosystems respond in
a similar manner to perturbation. Many ecosystems are similar
20
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in overall structure, but differ considerably in species
composition. Therefore, it is necessary to evaluate the
effects of stress on several ecosystems. Ecologists need to
investigate degrees of appropriateness for extrapolation
among different ecological communities. Predictions are
best if extrapolations are between similar systems and
explicit knowledge of the differences between ecosystems
will enhance extrapolation between ecosystems of different
types.
4.3.3 Recommendations for advancing predictive capability
EPA's ecological research strategy must contain a minimum of
three elements which, taken together, comprise a total approach
to developing a predictive capability. Research projects
themselves may deal with individual organisms, populations or
subcomponents of the ecosystem; however, the strategic elements
of the recommended research are focused on ecosystem-level
questions. These three strategic elements are predictive
studies, field experiments, and models.
The most fundamental element of the ecological research
strategy involves predictive studies. Operational-level
hypothesis testing with short-term experiments provide the
advantages of maintaining control over experimental conditions,
yet allowing study of system-level effects. Studies of processes
such as transport, persistence, and bioaccumulation/bioconcentra-.
tion yield basic data on effects of chemicals, mixtures or other
perturbations at the ecosystem level. Microcosm research, as an
example of such studies, is still in its early stages, yet offers
great potential for advancing our understanding of system level
effects while providing the basic inputs needed for predictive
capability.
A second strategic element consists of longer-term
experiments and observations of large-scale, natural ecosystems.
In such systems, conditions are not controllable but instead
reflect reality. Field studies serve to validate and expand on
the conclusions and principles determined by short-term,
simplistic experiments. EPA has some experience with this scope
of research through whole-lake and watershed experiments designed
to investigate delayed and direct responses tc acid deposition.
Opportunity for this type of research is provided via the Long-
Term Ecological Research (LTER) Program of the National Science
Foundation which provides the vehicle for collaborative
investigation on ecosystem mechanisms and responses for a number
of key ecosystems.
The last element of the recommended strategy is a modeling
component. Fundamentally, models are used in ecosystem research
in two ways.
a. Models provide a formal means for hypothesis
development and testing along with a means for organizing
and understanding the resultant observations and data.
21
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b. Models can be used to extrapolate observations and the
results of experiments to. new or different situations.
This combination of capabilities make models powerful instruments
for predicting environmental impacts. They may range from
relatively simple, informal constructs that use prior experience
to forecast change, to models that are complex, mathematically
sophisticated, and capable of integrating and quantifying the
facets that characterize environmental problems. They may be
experiential, drawing on system measurements? empirical,
extrapolating from statistical relationships; -or qualitative
process models, which incorporate some causal relationships.
A key part of mathematical model development is field
verification and validation. Before such predictive tools can be
applied to anticipating future ecosystem effects or ecological
risk assessment, careful correlation of model predictions to
actual field conditions must be made. The validation steps
enable appropriate application of developed models to decision-
making and priority setting problems that the Agency faces
routinely. Ultimately, integration between ecological models,
economic cost/benefit models, and resource management will be
needed to facilitate policy or regulatory actions that are most
effective in meeting societal needs.
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5.0 INSTITUTIONAL CONSIDERATIONS
5.1 Organizational issues
As the Agency develops its long range ecological research
program, it should formulate plans to transfer the knowledge
gained to users outside the Agency. These plans should include
mechanisms that allow EPA to take advantage of the data and
knowledge that has been gathered outside of the Agency,
incorporating these advances and eliminating duplication.
States, localities, industries and other nations will benefit
from and need to be apprised of research and monitoring findings -
in the Federal government. This is not only to assist them in
their regulatory functions but also to allow them to evaluate the
conclusions drawn relative to their own data and experience.
Recently an EPA task force explored the need for technology
transfer and evaluated several options to facilitate such
transfers. They formulated two basic conclusions:
"EPA, working in partnership with the states, must take
action to legitimize the importance and integral nature of
technology transfer and training to its mission. As the
Agency continued to evolve and mature, technology transfer
and training must become core elements in supporting the
Agency's operations and interactions with states and local
government, industry and academic... Further, the task
force believes that failure to incorporate such an emphasis
throughout the Agency will undermine the effectiveness of
the Agency's regulatory and enforcement efforts and related
activities at the state and local levels" [3].
Significant changes will have to take place if the above
goals are to be met, and the recommendations are to be
effectively implemented.
An enhanced ecological research program would enable EPA to
achieve the following goals [4].
a. Give greater consideration to ecological impacts in the
Agency's ongoing regulatory programs e.g., bio-
technology, Superfund, and natural resources damage
assessment.
b. Play a broader leadership role as the nation's principal
environmental agency, by assessing and responding to
emerging large-scale or long-term environmental problems
not directly covered by existing EPA regulatory
activities e.g., global warming and decreased
biodiversity.
c. Contribute to the advances in the state-of-the-science
of applied ecology that will be necessary to anticipate,
23
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detect, and deal with future environmental problems,
particularly those areas not being addresses by other
Federal agencies.
5.1.1 Research committees
The current Research Committee vehicle for determining
research priorities can address the first of the goals outlined
above. However, it would be much less effective addressing the
second and third goals. The immediate regulatory pressures.
confronting the EPA program offices will inevitably dictate short
term research to supply information needs. Therefore, the
Administrator of EPA should designate a given level of funding or
percentage of EPA1 research budget as available for long-term
research, outside the purview of the Research Committees. At
this stage, we are not in a position to recommend what the
specific level or percentage should be.
At the same time, the relationship between Research
Committee short-term research and independently directed long-
term research must be sensitively handled by ORD leadership.
First, there are important interrelationships and mutual
contributions between the two types of effort. In that sense,
the overall research program, although prioritized through two
separate vehicles, should be managed as somewhat of a "seamless
whole". Second, to assure continued Agency support, it will be
important for ORD to constantly emphasize and demonstrate that
the long-term effort is relevant to the Agency's larger goals.
It is the special responsibility of research management to assure
that the long-term research is not only of top scientific
quality, but also focused and relevant to the Agency's overall
mission.
5.1.2 Office of Monitoring
The Subcommittee on Ecological Effects recommends that the
EPA establish an Office of Monitoring (or redirect the existing
Office of Monitoring within ORD) to solve identified problems and
implement the recommendations herein. This Office would:
a. Review existing monitoring programs and the information
generated by such programs for relevance to EPA's
objectives.
b. Identify important gaps in our present acquisition of
environmental and ecological monitoring data.
c. Design and implement an EPA monitoring system, which
considers quality assurance, standardization of
protocols as appropriate, and relevant statistical
design and analysis. Target this monitoring system
specifically to addressing EPA's research, prediction,
environmental and ecosystem assessment requirements.
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5.1.3 Staffing
It will be necessary to make significant changes in staffing
to implement the recommended program. Specifically, there is a
need to add additional applied ecologists to EPA's staff at both
Headquarters and at the laboratories to complement the current
cadre of environmental scientists. There are a number of
outstanding ecologists on EPA's staff; however, they are
relatively few in number and unevenly distributed among the
various research locations. It will be difficult to incorporate
some of the recommended research concepts and rationale
recommended in this report without expanding the number of
researchers and broadening the disciplinary mix.
Hiring limitations of civil service personnel could make it
difficult to implement this recommendation. However, there are a
number of vehicles already utilized by EPA which can be given
greater emphasis to achieve this goal. These include the
Visiting Scientists and Engineers Program, Interagency Personnel
Agreements (TPA), and fellowships through the American
Association for the Advancement of Science (AAAS).
Particular emphasis should be placed on vehicles for
rotating a small cadre of nationally known ecologists into EPA's
Office of Environmental Processes and Effects Research (OEPER).
These ecologists could be given significant assignments to
incorporate a range of ecological approaches e.g. landscape
ecology, adaptive environmental assessment into the Agency's
research thinking. Recent organiza-tional changes in OEPER,
specifically incorporation of the Agency's Acid Deposition
research responsibilities, should facilitate this broadening of
staff capability.
5.2 Extramural vs. intramural research
As in the case of staffing, focused use of extramural
resources can broaden scientific participation in the research
program. The current Acid Deposition research program
demonstrates that ORD can bring such resources to bear in a
focused way to address Agency needs.
We also endorse continued use of the Center of Excellence
concept. While not specifically evaluating the programs of the
two existing ecologically-oriented Centers (Cornell and
University of Rhode Island), we would point out that these Centers
have provided EPA with continuing access to necessary academic
input. We would recommend continued management attention to the
most effective use of those Centers and particularly to
continuity and increased levels of funding.
EPA should play a stronger role in support and participation
in such activities as the Man-in-the-Biosphere Program, and
related programs within the appropriate professional societies.
With relatively modest efforts, sometimes requiring only
effective liaison or limited support of workshops or similar
25
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efforts, EPA can benefit from and influence the direction of
these groups.
In addition, more explicit attention should be given to
liaison and cooperation with related federal programs such as the
National Science Foundation's LTER, the ecological research of
the DOE National Laboratories, and relevant research of such
agencies as the Forest Service and Fish and Wildlife Service.
Major benefits can be achieved through such efforts.
5.3 Professional development
Mill IK «^B_ ^^^__ inn i ..... _ _ M..-JIIII*.- f
Implementing the foregoing strategy for ecological research
will require a high level of professional ecological competence.
Two forces are at work, which are creating a professional
manpower problem within the Agency. One such force is the high
attrition rate of an already dilute ecological talent pool. The
age structure of the Agency's professional staff is inexorably
moving upward. In excess of 40% of the professional staff will
be eligible for full retirement benefits by 1990 and 75% will be
eligible by 2000.
The second force is the need to ensure that there are enough
students are in the academic pipeline to fill the spaces vacated
by the retiring professionals, let alone to meet the manpower
needs of an emerging program. Together the two forces, if left
unchallenged, pose a problem that will rapidly reach crisis
proportions. The obvious way to challenge these forces is to
counter with the resources necessary to support programs for
professional development. In the short run, use can be made of
existing mechanisms (IPA, Cooperative Agreements, etc.) to bring
talent into the Agency for relatively short (1-2 years) rotating
terms. In the long run, however, a permanent, continuing supply
of young talent can only be provided by supporting training
programs designed to produce MS and Ph.D level scientists not
only for the Agency, but for the Nation in general, since any
surplus talent produced will find its way into state, municipal
and industrial programs thus enhancing the Agency's technology
transfer effectiveness. A training program similar to the one
implemented by the Federal Water Quality Administraton (FWQA)
and later dropped by EPA is strongly recommended.
5.4 Facilities and Equipment
In addition to its own unique laboratory and field
facilities and equipment, ecological research needs strong
analytical and computing support. The Agency's Environmental
Research Laboratories were constructed twenty or more years ago
during an era emphasizing single species toxicity and water
quality testing. The equipment sufficient to accommodate that
kind of activity has aged into marginal service ability if not
become outmoded. Upgrading existing facilities and equipment is
necessary in order to maintain the integrity of existing
laboratory output. It is essential if quality ecological work is
to be performed.
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5.5 Resources
Substantial financial resources are required to fully
implement the recommendations of the Subcommittee. This will
pose significant difficulty under current budget constraints, yet
several approaches are possible for initiating the proposed
strategy. First, some of the recommended measures can be
implemented with modest resource increments. These include
strengthening and broadening ecological staffing, strengthening
support for Research Centers, and increasing liaison and
participation in relevant ecological activities. While these
efforts will not substantially increase the level of new long-
range research within EPA, they will greatly increase EPA's
awareness of and access to relevant work and scientific input.
Second, the Agency could decide to redirect a portion of its
research budget from short-term, Research Committee prioritized
research to long-term efforts, rather than seeking entirely new
resources. Such redirection could have an adverse impact on
Program Office priorities and support for research, but it could
be justified in relation to the Agency's broader goals.
Finally, It may be possible to redirect some of the Acid
Deposition resources. This will allow the Agency to begin to
address other closely related issues, such as global warming and
stratopheric ozone deletion.
Even if all of these steps for initiating the proposed
strategy are taken, successful implementation of, the ecological
research strategy will still require a significant infusion of
new funds and manpower. Anything less will serve only to compound
the uncertainties we are trying to reduce.
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References
1. U.S.EPA. 1987. Unfinished Business: A Comparative
Assessment of Environmental Problems. Washington, D.C.
2. Council on Environmental Quality. 1985. Report on Long-
Term Environmental Research and Development. Washington,
D.C.
3. U.S.EPA. 1987. Report of the Administrator's Task Force
on Technology Transfer and Training. Washington, D.C.
4. NAS/NRC. 1977. Research and Development in the
Environmental Protection Agency. Washington, D.C.
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APPENDIX I
29
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APPENDIX I
STATUTES REQUIRING AN AUTHORIZING ECOLOGICAL RISK ASSESSMENT
STATUTE
Clean Air Act (CAA)
SECTION ACTIVITY FOR WHICH ERA IS
AUTHORIZED
154(c) Studies by the National
Science Foundation
154(d) Studies by the Secretary '
of Agriculture
164(b) Redesignation of areas as
Class I, II, or III
165(e) Preconstruction requirements
for major emitting facilities
Clean Water Act (CWA)
301(g) Determinations on requests
for water quality variances
301(h) Determinations on requests for
modification of secondary
treatment requirements for
POTWS
303(c) Development of State water
quality standards and
designated uses for receiving
water
304(a) Development of Federal water
quality criteria and guidance
305(b) Development of State water
inventories
307(a) Determinations regarding
additions to, or revisions of,
the list of priority pollutan-s
311(b) Designation of hazardous
substances
316(a) Establishment of efficient
limitations for thermal
discharges
320(b) Development of estuary
protection program
30
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403(c) Development and provision
of ocean discharge criteria
404(c) Determination of the effect
of dredge and fill activites
prior to authorization to
discharge to surface waters
Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA)
105(a)(8)(A)
Revision of the National
Contingency Plan
105(d) Petition to conduct a pre-
liminary assessment of the
effects of the release or
threatened release of hazardous
substance
105(g) Addition of facilities to
National Priorities List
121(b) & (d)
Assessment of alternative
remedial actions and
degree of clean up required
311(a) Research on hazardous substance
Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA)
3(c)(5) Approval of registration of
pesticide
3(d).(l) (B)
Classification of pesticides
for general use
3(d)(1)(C)
Classification of pesticides
for specific use
5(d) Experimental use permit studies
20 Research and Monitoring
25 Development of Regulations
31
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Marine Protection, Research and
Sanctuaries Act (MPRSA)
102(a)
102(c)
104(h)
Safe Drinking Water
Act (SDWA)
Criteria for reviewing permits
for ocean dumping
Designation of sites and tiroes
for dumping
Establishment of permitting
criteria for low-level
radioactive waste dumping
Establishment of permittirig
criteria for general
radioactive waste dumping
202(a)(2) Research on ocean dumping
303(b) Designation of National
Marine Sanctuaries
1427(d) Development of criteria for
identification of critical
aquifer protection areas
Toxic Substances Control
Act '(TSCA)
4(a)
4(b)
5(b)
5(h)
Testing to develop data with
respect to environmental and
human health effects of
substances manufactured, dis-
tributed, processed, used or
disposed of
Establishment of standards
for the development of
test data
Notification and submission
of test data required for
manufacture of a new chemical
substance or the processing
of a chemical substance for
a new use
Evaluation of application for
exemption from notification
requirements for test marketing
purposes
32
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6(e) Authorization of manufacture or
use PCBs in a not totally
enclosed manner
12(a) Application for export of a
substance being manufactured
processed, or distributed
33
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Summary of Statutory Authority Implicitly Authorizing an
Ecological Risk Assessment
STATUTE
Coastal Zone Management
Act of 1972 (CZMA)
SECTION ACTIVITY FOR WHICH ERA
IS AUTHORIZED
303
305
Marine Mammal Protection
Act of 1972 (MMPA)
3(a)
Declaration of policy
Management Program Development
Grant
Moratorium and Exceptions
103 (a) & (b)
Promulgation of regulations
on taking-of marine mammals
103(b) (3)
National Ocean Pollution Research
and Development and Monitoring
Planning Act of 1978 (NPERDA)
4(a)
Consideration of the marine
ecosystem and related
environmental concerns
Preparation of comprehensive 5
year plan for the overall Federa
effort regarding ocean pollutior
research, development and
monitoring
4(b) (1) (A)
Identification of the national
needs and problems related to
the specific effects of ocean
pollution, including the effect-
on the environmental value of
the ocean and the coastal
resources
4(b)(1)(B)
Prioritize, with respect to
value and cost, the national
needs related ocean pollution
which must be met
Submit annual report to Congres.
which estimates environmental
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Resource Conservation and
Recovery Act (RCRA)
Wild and Scenic Rivers Act
1008(a)
impact of increased importing
of foreign oil, evaluates the
Federal government's ocean
pollution research and monitorir.
capability, and summarizes the
efforts undertaken to coordinate
federal programs related to
such research and monitoring
Development and revision o,f
guidelines for solid waste
management
3004(b)
%
3004(d) & (e)
Authorization for placement
of hazardous waste
Authorization for land disposal
of hazardous waste
3004(g) Land disposal prohibitions of
hazardous waste
3004(m) Development of waste treatment
standards
3005(j) Study and Report to Congress
on existing.surface impoundment:
8001(a) Research, demonstration, and
training relating to hazardous
waste management
8002 Special waste studies
Act in general
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