UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, B.C. 20460
OFFICE OF
APMINISTRATOR
Dr. Courtney Etonian
Acting Assistant Administrator
for Research and Development
U.S. Environmental Protection Agency
Washington, B.C. 20460
Dear Dr. Riordan;
The Research Outlook Review Subcommittee of the Science
Advisory Board met on May 2, 1983, to review the Office of
Research And Development's (QRD) research strategies for fiscal
year 198S, The Subcommittee members had a number of comments
and recommendations, which are summarized in this letter.
Generally, the Subcommittee members were disappointed in
the lack of preparation by those presenting the strategies.
The Energy Research Strategy document had not been sent to
Subcommittee members beforehand, making any comments thereon
nearly impossible; a number of the presenters were unable to
adequately address many of the Subcommittee's questions.
There also seemed to be some confusion as to when certain ORD
personnel were to make their presentations. Although the
Office of Exploratory Research had been requested to write a
strategy document only shortly before the May 2 meeting, the
Subcommittee would have appreciated a brief overview of proposed
extramural research. A lack of supervisory overview seemed
apparent in that the strategy documents varied in format and
did not present a cohesive overall ORD strategy, btit rather a
collection of seemingly unrelated research goals.
The Subcommittee members felt that they could not respond
critically to the substance of the research strategies because
of the general treatment of the proposed research. Only two
strategies appeared to be reasonably well-directed by identify-
ing specific research needs! the Air Pollutants Research
Strategy and the Water Research Strategy.
The Subcommittee did make some general comments and raised
some questions about the various strategies, and these follow.
Air Pollutants^ Research Strategy*
Questions were raised as to the ability of EFA to carry
out research on fine particle epidemiology, in FY 1985, when
there is presently no in-house expertise for either conducting
the research in-house or managing it extramurally* Some
areas that are not addressed include exposure to diesel emis-
sions; models for calculating the effects of oscidant control
activities; risk assessments for CO at high altitudes; studies
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into health effects from carbon monoxide; and monitoring of
acidic aerosols. Tfce Subcommittee members felt that the Air
Pollutants Research Strategy does not sufficiently Identify,
among the research needs stated, the air pollutant: research
priorities for FY 1985.
Energy Research Strategy
Because the Subcommittee members did not see this strategy
document prior to the meeting and only a few responded with a
critique subsequent to the meeting, the comments on the
Energy Research Strategy were limited. The. strategy for acid
deposition appears to have been lifted directly from the
Interagency report, and EPA's strategy raises several questions:
Why is no activity projected for control technology when an in-
house capability for control technology responsibility exists?
Why are the reponslbilities of the different agencies not
delineated even though they expend considerable funds? It is
not made clear In the strategy which parts of the interagency
plan are EPA's responsibilities. We feel that effects of
terrestrial systems on water quality are crucial to the study
of acid deposition. Yet statements made In the strategy document
lead one to believe that important Interagency elements are
not aware of its significance nor of work already done In the
area by the Soil Conservation Service (SCS) and the Forest
Service.
Water Research Strategy
The members raised a number of concerns. Among these
were the following:
-v
a. The apparent lack of water quality
research into possible intermediate
and long-term effects on non-human
population viability and dynamics.
b* fhe la-ek of integration into the
strategy of the work presently under
development by the Agency and under
review by the SAB, I.e., the review of
site-specific water quality criteria.
e. The need to validate the assumptions
made in the extrapolation of inhalation
data to ingestion exposure.
d* The need to separate engineering and
technology research issues for ground-
water from those of surface water. For
example, further investigations are
needed into the technology for avoiding
contamination between different aquifers
resulting from widespread use of multi-
aquifer wells*
e. The overall water research priorities
should be more clearly spelled out.
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Pesticides Research Strategy
There were a number of concerns voiced by members in this
area. Included ataong these were the following;
a. There is a paucity of information about
pesticide exposure in daily human activity
patterns.
b. More long-tern research should, be
done with subjects potentially at
greatest risk by reason of biological
susceptibility, i.e., pregnant women
and children.
c. There should be some discussion regard-
ing the need for or lack of need for
control technology for the pesticides
industry.
d* The strategy is too general and could
use a statement indicating the justifi-
cation for selecting particular areas
and directions of research.
Toxic Substances Research Strategy
A number of items In the strategy appeared to be overly
ambitious, for example, the research into structure-activity
relationships (SAR), proposed occupational health research,
and research into stratospheric modification. There should be
a sharper focus on what goals can actually be met in these
areas during the stated time frames. Although the goals of
the strategy are laudable, there Is too little depth In the
document for the members to adequately comment.
* "~--x
Superfund Strategy
the Subcommittee was concerned with two questions regarding
mobile technologiesj
s
a. How will EPA define the mechanism for
establishing technologies for intermediate-
sized mobile facilities? Present mobile
facilities are too small for a number of the
kinds of problems encountered at Superfund
sites.
b. How will E?A deal with the problems of
placing mobile facilities in densely -"
populated areas?
The Subcommittee members also commented that the Superfund
area was not receiving adequate research support by relying
upon research conducted In other program areas. Because of
that lack of research support, the SAB recommends that EPA and
Congress work to amend the Superfund legislation to provide
authority for separate research for Superfund-related activities.
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-4-
Hazardous j[a_sj:es Frog ran Strategy
The question was raised about problems arising from
reclaiming "old fields" that were once extensively treated with
pesticides. Because of the number of these "old fields,"
research into this area may be warranted.
Exploratory Research
A strategy on exploratory research was not available for
review. The Subcoamittee expressed its concern that this
important area be given a significant position in OID's research
strategy.
The Subcommittee members, as a whole, felt that they
could not respond critically to the majority of the strategy
documents because of their inability to get a coherent, overall
picture of EFA's proposed research. It was suggested that EPA
establish some reasonable criteria for writing future research
strategies.
We hope that these comments have been useful to your office
in the early preparation of the Research Outlook 1984* We look
forward to receiving the draft Research Outlook ia September 1983
Sincerely,
John M. Neuhold
Chairman
Research Outlook Review
Subcommittee
ce: Alvin Aim
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