UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 204SO
January 10, 1980
OFFICE OF THE
A.0MINI STSATOR
The Honorable Douglas M. Costle
Administrator
U, S. Environmental Protection Agency
Washington, D, C. 20460
Dear Mr. Costle:
This letter constitutes the report of the Research Outlook
Review Subcommittee of your Science Advisory Board, The
Subcommittee, drawn froiti the Science Advisory Board to represent a
broad cross-section of expertise in research areas of importance 'to
EPA, was to review and provide comments on Research Outlook 1980. Our
report includes those items about which members of the Subcommittee
felt most strongly. A list of Subcommittee members is attached as
Tab A, and comments by individual members are attached as Tabs B
through G. For the most part, individual cosnments enlarge upon
points made in our Subcommittee report.
The Subcommittee is mindful that its role is to review and
provide comments on Research Outlook I980_ prepared by the Office of
Research and Development, not to participate in the research planning
upon which the report is based. It would be most appropriate for a
subcommittee to conduct its review of the document after its
completion but prior to its submission to the Congress,
Unfortunately, the very short interval between completion of the
document and its submission makes this approach impractical for
review o£ a document as extensive as Research Outlook 1980. The
Subcommittee, therefore, met on November 19, 1979, to review the first
draft and on December IS to review a revised draft of the report.
Although comments made by the Subcommittee and its members may have
been incorporated in the report, the Subcommittee does not consider
that it participated in the research planning process but only in the
plan's presentation.
The Subcommittee considers Research Outlook 1930 as a
substantial improvement over earlier Research Outlooks, Earlier
Outlooks gave little evidence of research planning — this Outlook
does. Research Outlook 198,0 reflects the work of Research Committees
made up of members of ORD and relevant program offices. The active
participation of users of research results in the research planning
process has almost certainly made the planned research much more
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responsive to needs of the regulatory arm of the Agency, . Perceived
lack of responsiveness to program office needs has been a chronic
problem for ORD since EPA was formed, and this planning process
should go far toward improving the relationships between ORD and the
rest of the Agency. On the other hand, the use of the ^Research
Committees does result in increased compartroentalizatidh and in
concentration on solving near-term problems. The Research Outlook
primarily treats the research issues as separable problems — in air,
"in water, on land. There is some departure from this narrow approach
in the sections, Toxic Substances, Energy, and Anticipating
Environmental Problems.
We believe that it is necessary to adopt a more broadly based
view of the research needs on environmental issues, Such a broader
view would consider the multimedia aspects of the problemsj would
identify interactions between media; would set priorities to deal
with the urgent problems in order; and, finally, would identify
research necessary to quantify trade-offs between media.
This need has been recognized in the current Research Outlook*
To quote from the document:
"Since there is no 'free dumping ground'
an integrated approach is necessary to
determine the best mix of environmental
controls to minimize the adverse effects
of pollution."
We suggest that this philosophy play an increasing role in the
Agency's research planning and in the preparation of future Research
Outlook documents.
i The Research Outlook Review Subcommittee believes that special
mechanisms will need to be devised to provide:
o Greater integration of short-term and
long-term research. (Anticipatory research
is not an end in itself.)
X
o More attention to intermedia and multimedia
problems.
o More explicit ordering of research programs
to deal with high priority items .first and
see them to some stage of completion.
The current Research Outlook presents three principal Agency
priorities:
o "reduce public exposure to dangerous
pollutants;
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o protect sensitive ecological systems? and
o improve management of our environmental
regulatory programs,"
We believe the statement of these general goals is*an excellent
step. In fact we feel that these themes should be reflected
throughout the research planning process as well as forming a common
framework for the Research Outlook documents. Each section could
list and discuss the planned research as it relates to these guiding
priorities. We are not suggesting formal rigidity. Individual
sections and their particular problems may change the priority order
or emphasis. This is natural and probably desirable.
Research Outlook 1980 is a five-year plan, one in a series of
such plans that is updated annually. Thus each document in the
series overlaps four years with the documents that precede and follow
it. One of the requirements in research management and resource
allocation is a sense of continuity,, since the present is built on
the past and the future is shaped on present conceptions and
structures. A greater sense of continuity would be helpful in
Research Outlook reports, Sy this we mean the historical roots,
successes, and failures that shape the current Outlook's research
efforts and how the present problems are shaping the future, Explici'
statements about what is newly included or emphasized, and why? and
what has been eliminated or de-emphasised, and why, would strengthen
the report.
Research Outlook 1980 explicitly identifies eleven research
areas~and allocates a chapter of the report to each. However, more
attention should be given to the documentation of the research work
to be done, the anticipated milestones that show accomplishments, and
the amount of text allocated to each subject in proportion to the
importance of each environmental research area to ORD and to the
Agency, For example, we note that the toxic substances research
area, which is described in the Introduction (page 2) as a program of
much importance, is discussed with not much more depth than the noise
research area. This latter program, not one of the topics presently
addressed by its own^Research Committee, seems to be given much more
attention in the report than the allocation of ORD resources justify.
While it is important not to overlook or ignore research work
that expends ORD resources, we believe that a comprehensive inclusion
of the details of many research topics dilutes the attention of the
readers, offers a false sense of priority, and detracts from the
major topics. We recommend less attention to the comprehensive
coverage of all the environmental research within ORD and recommend
more attention to the setting of research priorities around major
topics.
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The Outlook in many chapters expresses an intention to execute
very ambitious programs, such as large scale epidemiological studies,
which we feel.do not adequately reflect the resources that are
available to complete these studies. The reader would be better
served if long-term research "hopes and dreams" can be related to the
resources which may be necessary to fulfill this work. ""Some promised
programs are simply unrealizable with the resources available to the
Agency,
It is worthwhile to address the problems that may arise when
QRD is not able to meet some technical goals of the Agency. Some
concepts such as "zero discharge of pollutants," which have meaning
in the words of law, are not achievable in a strict thermodynaiaic
sense. The Research Outlook can be a vehicle to provide a more
careful measure of the Agency objectives that are and are not
achievable by researcht The report suggests that all technical
objectives are reachable through support of the research program.
This is, of course, a major overstatement and leads to
disappointment, lack of credibility, and unfulfilled promises.
There is an implicit sense in the report that technologies are
known, but developed to a very limited extent, for the control of
specific chemical substances. This is work that will support the
control of toxic substances at levels of detectability. We believe
that this sense of the state of control technology is misleading and
does not reflect the true situation. Control technology for
particular chemical species at levels of detectability is at the very
fringe of science. We are much further advanced in the ability to
detect the presence of a chemical species than we are able to
engineer systems to control waste streams at these same levels. This
is a major problem and deserves more careful planning, evaluation,
and research on whether or not the concept of control technology at
level of detectability will ever be realizable. The goal of the law
(and the Agency) is clear with regard to the control of the release
of toxic materials, but the expectations to be realized from
technical research should not be confused with societal goals. The
scientific advances that permit detection of chemicals at lower and
lower concentrations are not paralleled today with similar
achievement in the s-tate-of-the-art of control technology.
We understand that hard and fast divisions of budget, in any
year, are not possible to predict with accuracy, and possibly the
division of options into media makes it easier for Research
Committees, in their present set-up, to operate. The approach,
however, also leads to vagaries of description so that one cannot
really decipher exactly what projected work will be. In view of the
ambition of the Agency to achieve quality assurance, perhaps a
beginning point should be in the use of language to describe needed
projects (as well as the result of their research). Thus we can
avoid having to deal with such non-quantitative terms as "diminished
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effort"; "growth of effort",- "greatly extended"; "focus more on1*,- and
"major growth area" — all of which are presented to the reader
without modifiers.
There is no explicit expression of what the priorities are in
each mission. Thus, it is difficult to understand -exact-ly what would
be done in the cases of high, moderate, low, or no growth and to have
an idea of what specific projects are to be enhanced or dropped. Yet,
there is an allotted sum of money for each mission. Just what is the
breakdown of allotment for each mission, and how does it correlate
with each set of priorities? It would be much more logical to show
more explicitly how each Research Committee treats the problem.
Furthermore, although there were no Research Committees — as yet —
for energy, anticipatory, and noise, a sum is allotted in each case.
Just what did QRD have in mind with regard to specific priorities and
their costs when these amounts were apportioned?
Outlook could be more useful if it contained a more explicit
identification of the resources (people, facilities, equipment, and
dollars) available to carry out the proposed research* Such an
identification of resources should consider those available within
the Agency as well as those available in other government agencies,
universities, and industry. Clearly, the research needs of the
Agency have not and cannot be met totally within the Agency and,
thus, the assistance of others is essential. Planning for use of the
assistance should be explicit and not on an ad hoc , as the need
arises, basis as has frequently occurred in "tHe past.
The Agency proposes to develop short-term tests to predict the
toxic effects of chemicals in humans and the ecosystem and models to
predict the long-term fate and effects of a range of pollutants. Such
tests and models often become entrenched before they have been
validated. Historically, the Agency has tended to postpone the
expensive and elegant work required for validation, and thus to have
available at any given time a range of tests for which there is no
scientific consensus on validity, le search Outlook 1980 appears to
continue this trend, with validation scheduled for completion three
to five years after development of tests and models. This is a
planning and researgh mistake of major dimensions. Predictive tests
and models should be validated concurrently — or nearly so • — with
development.
In the 1980 Outlook, as in 1979, introductory materials and
program descriptions recognize ecological effects and even effects on
ecosystems as substantial problems. Planned research, however, fails
to reflect the importance of these problems. Research on ecosystems
is apparently almost nonexistent in EPA. The Subcommittee believes
future Outlooks should give more consideration to research directed
at understanding ecosystem functioning and the degree to which such
functioning is impaired by pollutants.
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In summary, Research Outlook jLgSj) is substantially better than
proceeding Outlooks.The Research Outlook Review Subcommittee is
hopeful that the criticisms that we have made, singly and
collectively, will lead to continued improvement in these reports.
John L. Buckley f<
Chairman /'
Research Outlook Review
Subcommittee
Science Advisory Board
Attachments
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TAB A
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U. S. ENVIRONMENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
RESEARCH OUTLOOK REVIEW SUBCOMMITTEE
Dr, John L. Buckley, Chairman
Consultant
Whitney Point, New York 13862
Dr. Leonard Greenfield
Consultant
5600 S.W, 86th Street
Miami, Florida 33143
Mrs. Patricia G. Guida
Manager, Information Center
Booz-*Allen & Hamilton Inc.
Florhara Park, New Jersey 07932
Dr. Roger O. McClellan
Director, Inhalation Toxicology Research
Institute
Lovelace Foundation
P. O. Box 5890
Albuquerque, New Mexico 87115
Dr. Francis McMichael
Professor o£ Civil Engineering and
Engineering and Public Policy
Carnegie-Mellon University
Pittsburgh/ Pennsylvania 15213
Dr. John M. Neuhold
Professor of Wildlife Sciences and Ecology
Utah State University
Logan, Utah 84321
j
Mr. Donald H, Pack
Consultant
1826 Opalocka Drive
McLean, Virginia 22101
Dr* Winona Vernberg
Dean
School of Public Health
University of South Carolina
Columbia, South Carolina 29205
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TAB B
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Review of Besear& Options and Resources from the draft of
Research Outlook for 1980
Research Options
General Beasarks
As stated in tJie test of the research options, -Ihese are
organised "by media. More effective would be to organize them
by specific problems or problem areas and how they impact on
the .media, intermedia, and people (health). In this manner,
research committees can decide how to approach these same pro-
blems with the expertise already under their control.
It is understood, I believe, that hard and fast divisions
of budget, in any year, are not possible to predict with
and possibly the division-:of options into media makes it easier
for research committees, in their present set-up, to operate*
Shis approach, however, also leads to vagaries of description
so that one cannot really decipher exactly what projected works
will be. In view of the ambition of the Agency to achieve quality
assurance, perhaps a beginning point should be in the use of lang-
uage to describe needed projects (as well, as the result of their
researches), fhus we can avoid having to deal with such non-quan-
titative terms as: ^diminished effort", "growth of effort",
"-greatly extended-", Jlfocus more on£, and " sia^or growth area "
- all of which are presented to the reader without modifiers.
There is no explicit expression of what the •priorities are
in. each mission. Thus it is difficult to understand exactly what
would be done in the cases of high, moderate, low, or no growth
and to have an idea of what specific projects are to be enhanced
or dropped. Yet there is an allotted sun of money for each mission.
Just what is the breakdown of allotment for each mission and how
does it correlate with each set of prioroties? It would be much
more logical to show more erslicitely how each research committee
treats the problem. Furthermore, although there are no research
committees - as yet - for energy, anticipatory, and noise, a sum
is allotted in each case, «Tust what did OED have in mind with re-
gard to specific priorities and their costs when these amounts
were apportioned.
j
Specific Items
Some explicit points stand out enough to warrant further
remarks.
1* There is considerable doubt that "short term" tests can lead
to reliable prediction of medical or ecological effects. Fur-
thermore if "rough, screenings" are to be used, there needs to
be more detailed information as to their reliability - especially
if they are what more intensive investigations are based upon.
2, There is practically no mention of the consideration of
economies In areas where enforcement lill be stressed. 3ia.ee we
are given no detailed information about these lutute enforcement
areas, we cannot tell whether or not there is a diminished or
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or advantageous return on their application — more candidly r are
they worth it with regard to the general public and how much
stress will there be on the private sector, and in what ways
can each situation be alleviated or solved,
3- Health effects are mentioned frequently, but in no case do
we learn what specific type of liaison there is between the
research and health studies or whether the health authorities
are working on short-term effects or long range research. Are
health studies included in these "budgets or do they have theii*
own?
Resources
Along with tliis discussion of research options in which
I have already noted that neither specific priorities nor bud-
get allotments are given foe these areas within each mission,
the same Tagaries apply to resources, ¥e have no idea how
"budgetary breakdown is placed within missions, fhis means that
we have no idea how many persons are involved in any one project
or whether the task is' to "be contracted externally* The status
of equipment and facilities to carry out the task functions is
also an unknown entity. In addition there is no projection of
change in facilities aad' equipment although "projections of
large sums are readily forthcoming.
Shis lack of specificity in presentation of options and
resources makes it very difficult to assay the worth, of projec-
ted tasks* Any reviewer of the research outlook mast be aware of
this. Certainly brevity of text along with a rather "outlined"
presentation with greater specificity would be most desirable.
Leonard J« Greenfield
Dee* 27, 1979
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TAB C
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INHALATION TOXICOLOGY RESEARCH INSTITUTE
LOVELACE B1OMEOICAL ANO ENVIRONMENTAL RESEARCH INSTITUTE, INC,
P.O. Box S8SQ Albuqti«rqu«, Now KUxico 87115
December 26, 1979
Dr. John R. Buckley, Chairman
Research Outlook Review Subcommittee
IPA Science Advisory Board
Whitney Point, New York 13862
Dear Dr, Buckley;
I have carefully reviewed the October and December drifts of Research
Outlook 1980 and Participated in the November 19th and December 18th, 1979
meeting of the Subcomnittee. I offer the following comments on the Science
Advisory Board participation in the Review of the report and on the report
itself.
L The approach used the past three years in which the SAB reviewed and
commented on successive drafts and then attempted to critique the
report is unsatisfactory on several counts,
(a) Involvement of the SAB in reviewing and commenting on early drafts
and then later in preparing a critique of the report for the
Administrator puts the SAB in the role of critiquing what is
in part its own efforts.
(b) The nature of SAB involvement in changing a report on a
research plan that should exist elsewhere puts the SAB in the
position of making superficial adjustments that are primarily
of a cosmetic nature, i.e. it is not clear that the changes
suggested by the SAB.really extend beyond the report into the
heart of the plan itself.
(c) The role of the SAB in the report preparation process can be,
and indeed has been, misinterpreted as being a role of active
participation in the planning process. It should be made clear
to the Assistant Administrator for Research and Development,
the Administrator and the Congress that the SAB role has been
restricted to reviewing the report. The SAB has not been an
active part of the research planning process. This may be the
most appropriate role for the SAB, In any event, it should not
be misrepresented,
2. The document reflects a general improvement in the research planning
process within EPA, Indeed, in the first several 5-year plan documents,
it was not clear from the documents that a planning process existed.
Within the present document there is clear evidence of a planning
process, a process that places major emphasis on promoting a linkage
between research and development activities (Office of Research and
Development) and users of research information {Program Offices).
3. The strong emphasis on use of problem area oriented research coirmittees
Oporated for tha U.S. Department of Energy yndor Contract £Y*76-C-0«-1013
An Equal Opportunity/Affirmative Action Employer
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Dr. John R, Buckley, Chairman
Page 2
in the research planning process raises concerns that the research
program will be excessively compartmentalized by problem areas. Many
of the research committees are oriented to a single media, i.e. air
or water and thus, there is potential for losing sight of the multi-
media nature of many, if not most, of the problems of pollutants
impacting on ecosystems and ultimately man.
4. The almost exclusive use of research committees that are strongly
problem oriented for planning the agencies research program results
in a potential for the research program favoring effort on well-
identified problems that can be tackled in the near term, i.e. short-
term efforts yielding relatively predictable results. Conversely,
inadequate attention may be given to the conduct of research that may
not be as applicable to a given immediate problem or may require
support over a longer period of time. Such long~term research has
the potential for yielding results that may have greater impact than
the short-term research, even if the results are not so predictable.
5. Many of the legislative mandates of the agency are very precise
leading to specific identification of associated research needs.
Most of the research outlined in this document is of this type.
Such research must be performed, however, there should be more
adequate recognition that some research needs extend beyond the
explicit needs of the legislative mandates if the agency is to
fulfill its broad charter. Two examples will illustrate the point.
Under the Clean Air Act as amended, the agency is required to
periodically review and revise ambient air quality standards. Much
of air pollution research is directed toward developing information
used in this review and revision process. What is missing from the
research plan is a broader program directed at understanding how
airborne pollutants are released, transformed, transported,
ultimately inhaled and deposited in the human respiratory tract
and produce respiratory disease. The second example relates to the
agencies relative lack of involvement in the field of ecological
research. The lack of attention given to this area is presumably
related to the-lack of need for ecological data to meet explicit
legislative mandates. Despite the lack of explicit mandates, many
individuals have the impression that the agency has a strong implied
responsibility to support the conduct of s broad range of ecological
studies. Such studies are needed to better understand how roan and
his environment Inter-relate to detect changes in the environment as
a result of man's activities and to predict potential adverse impacts.
6. The research document frequently and appropriately calls for the
development and use of models for predicting the fate and effects of
pollutants. These models are of several types. For example, there
is extensive reference to the use of short-term test models for
predicting long-term health effects such is cancer. Other models
are proposed to predict the dispersal and fate of airborne pollutants.
The usefulness of these models is directly related to the extent to
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Dr. John R. Buckley, Chairman
Pige 3
which the models are validated. With the research plan, inadequate
attention is given to such validation leading, in some ca^es, to what
appears to be overly optimistic statements as to the usefulness of
the models.
IP*
7. The usefulness of the report could be enhanced if it contained a more
explicit Indentification of the resources (people, facilities, equip-
ment and dollars) available to carry out the proposed research. Such
an identification of resources should consider those available within
the agency as well as those available in other government agencies,
universities and industry. Clearly, the research needs of the agency
have not and cannot be met totally within the agency and thus, the
assistance of others is essential. Planning for use of the assistance
should be explicit and not on an ac[ hoc_, as the need arises, basis
as has frequently occured in the past.
8. A statement of problem areas and objectives as contained within
Research Outlook 1980 is obviously only part of a dynamic research
process. To be effective the research plan must include an
implementation strategy based on consideration of the objectives
and the resources available to meet them. An appropriate implementation
strategy defines how available resources will be deployed to achieve
the stated objectives. For example, it would identify the areas
in which the agency has adequate manpower (with the required level
and type of expertise), facilities and equipment at its disposal
either within or outside the agency and how they will be deployed.
Equally important, the strategy will identify areas where adequate
manpower, facilities and equipment are not available to meet the
objectives and propose alternative solutions. By failing to lay
out an implementation strategy, the agency leaves the impression that
it can realize all the stated objectives if only enough funds are
provided. In a number of areas this is not the case, i.e. funds
are not the major constraint 1n meeting the objectives. For example,
a doubling or tripling of the agencies budget in areas requiring
expertise in epidemiology, camparative pathology or toxicology will
not substantially increase the probability for success in these areas
because the agency does not have a sufficient number of people well-
trained in these disciplines,
9. Beyond statements of objectives and a strategy for realizing them
there must also be a system for monitoring of research results to
evaluate the effectiveness of the process used to plan and conduct
the research. In short, a determination roust be made of plan's
value as an effective management tool in obtaining high quality
responsive research results. If the appropriate results have not
been obtained then consideration must be given to altering the planning
and implementation process. This may include revision of objectives.
In the past there has appeared to be an absence of this type of feed-
back loop in the agencies research operations.
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Dr. John R. Buckley, Chairman
Page 4
10. The section on anticipatory research does not provide an adequate
description of this important area of endeavor. As presented, it
leaves the impression that anticipatory research in something apart
from the mainstream of the research program. In my view, I see
anticipatory research as the leading edge of the agency's core
research program.
If you have need for any further input from me, please do not hesitate to
call me.
Sincerely,
Roger 0. McClellan, D.V.M,
Director
ROM:If
xc: Dr, J, F. Allen
SAB Research Outlook Review
Subcoruni ttee
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TAB D
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December IB, 1979
TO: John L. Buckley, Chairman
PROM; or. F. C. McMichael ,** v»v *******<'/yi
SUBJECT: Items 3 and 4: Research Outlook 1980 Subcommittee Review
"Item 3
The Research outlook 1980 explicitly identifies eleven research
areas and allocates a chapter of the report to each topic. However,
more attention should be given to the documentation of the research
work to be doner the anticipated milestones that show
accomplishments, and the amount of text allocated to each subject in
proportion to the importance of each environmental research area to
ORD and to the Agency. Por example, we note that the toxic
substances research area, which is described in the Introduction
(p.2) as a program of much importance is discussed with approximately
the same amount of text as the noise research area. This latter
program, which is not one of the topics presently addressed by its
own ORD research committee, seems to be given much more attention in
the report than the allocation of other ORD resources justify.
While it is important not to overlook or ignore research work
that expends ORD resources, we believe that a comprehensive inclusion
of the details of many research topics dilutes the attention of the
readers and offers a false sense of priority away from the major
topics. We recommend less attention to the comprehensive coverage of
all the environmental research within ORD and recommend more
attention to the setting of research priorities around major topics.
Item 4
The Research Outlook 1980 clearly describes the initiation of
the research committee system which provides a working forum for the
planning of a research program that is responsive to the needs of the
program offices. We recognize the importance of the need for the ORD
to provide support to the rest of Agency, however we feel that the
report does not adequately explain the relationship between some
resarch programs and the Agency objectives.
The report in many chapters expresses an intention to execute
very ambitions'programs, such as large scale epidemiological studies,
which we feel do not adequately reflect the resources that are
available to complete these studies, the reader would be better
served if long-term research "hopes and dreams* can be related to the
resources which may be necessary to fulfill this work. Some promised
programs are simply unrealizable with the resources available to the
Agency.
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It is worth while to address the problems that may arise
when ORD is not able to meet some technical goals of the Agency.
Some concepts such as "zero discharge of pollutants" which have
meaning in the words of law are not achievable in a strict
theme-dynamic sense. The Research Outlook can be a vehicle to
provide a more careful measure of the Agency objectives that are
and are not achieveable by research. We believe the report
suggests that all technical objectives are reachable through
support of the research program. This is, of course, a major
overstatement and leads to disappointment, lack of credability,
and many unfulfilled promises.
There is an implicit sense in the report that technologies
are known, but developed to a very limited extent, for the
control of specific chemical substances. This is work that will
support the control of toxic substances at levels of
detectability. We believe that this sense of the state of
control technology is misleading and does not reflect the true
situation. Control technology for particular chemical species
at levels of detectability is at the very fringe of science. We
are much farther advanced in the ability to detect the presence
of a chemical species than we are able to engineer systems to
control waste streams at these same levels. This is a major
problem and deserves more careful planning, evaluation, and
research on whether or not the concept of control technology at
level of detectability will ever be realizable. The goal of the
law (and the Agency) is clear with regard to the control of the
release of toxic materials, but the expectations to be realised
from technical research should not be confused with societal
goals. The scientific advances that permit detection of
chemicals at lower and lower concentrations are not paralleled
today with similar achievement in the state-of-the-art of
control technology.
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TAB E
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COLLEGE OF NATURAL RESOURCES
UMC §2
Utah Stiti Univtra'ty
Logan, Utah 84322
Dtpartrnent Wildlife Science
7S2-410GEXT. 7i28
January 7, 1980
Dr. John Buckley, Cnairman
Research Outlook Saview Subcoaniittee
Science Advisory Board
Environmental Protection Agency
Washington, D. C . 20460
Dear Dr. Buckley:
I have reviewed the "Besearcn Outlook, 1980" and submit the
following comments in criticism of the report:
1. This "Outlook" is the best of the reports I have reviewed
since their production was mandated. It is, in general, well
organized, rational in its presentation, and reasonabally well
written.. It is an improvement over last year's.
2. When one makes an effort to relate the priorities as
listed in the "Introduction" to the description of the tasks
at the end of each of the chapters concerning "Toxic Substances",
"Air", "Water Quality", "Pesticides", and "Energy" one gets the
impression that human health (first order of priority) is over-
emphasized while ecological systems (second order of priority)
are hardly mentioned at all. It seems important to me that if
ecosystems are to be emphasized as a second order priority, more
space should be devoted to them.
3. I recognize the importance of establishing some ex-
peditiously followed protocol for the screening of toxic
substances. I also, however, see a problem emerging in sub-
sequently establishing criteria for standards as a result of
too much emphasis on the screening of toxic substances and
not enough on the effects the substances will have on ecosystems
or their components- I often wonder why a search has not been
undertaken to establish, a) the most sensitive systems to chem-
ical disturbances, b) the most sensitive organisms in Horch
American ecosystems, and c) the most vital organisms of these
systems. Such a search could afford EPA with a. substantially
simplified criterion establishment effort.
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Buckley, January 7. U80, page 2
4, Though the remarks made in 3 above are made relative
to the effort in toxic substances, the saae remarks hold for
"Air", "Water Quality", "Pesticides", and "Energy",
5, I an still very much concerned with what I believe_to be
the snort-sighted ecological view expressed by most of the Agency's
scientists and/or regulators, I agree that human health should
be emphasized but not at the exclusion of ecological studies. This
attitude is still very much an expression of a short term
concern and ignores the ultimate long term human welfare effects.
We do need information oti the long term human welfare consequences
of our control efforts and we are not getting it with our current
human health philosophies.
Sincerely Yours
John M» Seuhold
Professor
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TAB F
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DONALD H. PACK
CQNSUL,TIN<3
OPAL.OCKA DRIVE
MCl-EAN. VIRGINIA 221 Ot
(•703) 3»S-*a33
November 1, 1979
Dr. John Li Buckley, Chairman
Research Chitlook Subcommittee, SA3
P.O. Box 263
Whitney Point, New York 13862
Dear Dr. Buckley:
I have worked my way, twice, through the "1930 Research Outlook, First Draft".
The Initial approach was quite conventional - note taking, identifying
research problems not addressed,, etd. This effort was quickly overtaken "by
the sheer mass of material. There are pages on pages of research project
listings, milestones, etc. to the extent that an item "by item critique dees
not seen feasible. Instead of such detail I would like to raise what I "believe
are larger issues.
1. The Outlook does not contain any synthesis or statement of over-all
Agency priorities, Some individual sections (e.g. Pesticides) had a convincing
internal logic "but no where is there any comparison, of the importance say,
of noise vs toxic substances ( or air pollution vs solid -Hastes. Within the
categories individual substances are often listed without providing any
statement of relative importance (e.g. Air Pollution - inhalaKLe particulates
vs oxidants),
2. Much of the research effort is mandated "by legislation. Should these
"no choice" efforts be identified separately from those SPA chooses, independently,
to pursue?
3. The multi -media issue is neither clearly stated nor is there such
research described to evaluate the relative hazards of polluting the air vs
the water vs the soil. To tafc a potentially controversial example - What is
the trade-off "between air pollution reduction "by stack gas cleaning vs increased
solid waste/water pollution? How are the benefits/ costs/research issues of
the multi -media problem resolved by the present EPA Besearch Comaittee Systesi?
4. Modelling is playing an increasingly central role in determining the
the fate of contaminants and tracking them through the environment. What are
the common factors between media? Should there be multi-media models? Sees
SPA have adequate computer facilities to operate these models? Can the computer
facilities be made more accessible and efficient? The Research Outlook does
not address this issue,
5- The section on Energy involves: Air pollution, Toxic substances, Water
Quality, Industrial wastes, Solid and Hazardous wastes. This section epitomises
the need for iiuantifying trade-offs between media. If techniques (e.g. very
tall stacks) could keep utility HO levels below concentration? inimical to
human health would the acid precipitation effects be sufficiently severe
to require NO^ removal? The social/economic penalty of either course of action
requires study.
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DONALD H. PACK
6. It seems to ac that the concept of zero hazard to the total population
is neither viable or relavant in an industrial society, This zero risk concept
seeds implicit In much of the Outlook especially in the Toxic substances area,
Further it seems more defined by the lowest level of detectability, which will
certainly change, than by quantified population risks. What level of insult
or risk is socially ami economically acceptable perhaps even unavoidable?
If the population at risk Is sufficiently small what R & D on direct protection
for this segment should be done? For example I have a friend in Los Arureles
who has an activated carbon filter on the air intake to his automobile's interior
I do not quarrel with the methodology or the divisions established by 0?»L
to produce the Research Outlook, The environment is a total system and can
be sliced in an infinite variety of ways, none of which will be completely
satisfactory,
I do believe however that the Outlook very much needs a synthesis section
on goals and priorities that indicates:
Where are we going
tfhat comes first
Kow we get there
Finally the work described accumulates to a staggering task. Despite the
preceding comments the Research Outlook is a valiant attempt to move towards
environmental improvement in an industrial society.
Sincerely
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DONALD H. PACK
CONSULTING METEOROLOGIST
1S2S OPAL.OCKA DRIVE
MCUEAN, VIRGINIA S21O1
December 17, 1979
Dr. John L, Buckley, Chairman
Research Outlook Subeomdttee, SA2
Dear Dr. Bucfeleys
The revised draft of the 19SO Research Outlook received with Z»r. Cage's
memo of December 10, 1979 has been reviewed,
The present version is much more readable but is still not quite collets .
1 especially missed the Summary and Any account of the activities of the
crucial inter-governmental effort represented by the Izvterageney Task Force
on Savironir.ettta.1 Data and
Ky initial comments of November 1, 1979 stand* Konever I was pleased to see
text revisions emphasizing the multi-media characteristics of environmental
pollution, The "no free dumping ground" phrase (p. 6 af the draft) indicates
to me a perception of the problems that is beginning to parallel that
towards the birth-to-grave evaluation required of the nuclear energy industry.
I believe that such an attitude is all to the
It will be interesting to follow the evolution of these ideas through future
Besearch Outlooks, Determination of multi-media, trade-offs required to
minimize socio-enviroiraental problems (locally, regionally, and globally)
is a aost challenging and difficult problem.
Sincerely
^~*~~~ - )
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TAB G
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Dr, Winona Vernberg
1/4/80
In many respects the report tends to be unrealistic in terms of
what EPA can accomplish, and there are many, many instances where the
ghrase "we will do * . *w is used seemingly without regard to
reality. For example, costly and time consuming epidemic-logic
studies had been proposed tot
(1) Determine the possibility that drinking water contamination
causes birth defects,
(2) To do a perspective study of cardies-vascular desase in a
group of middle age men,
{3} To undertake epideraiological studies to establish if there
is a relationship between sodium and 35 other inorganic
contaminants that may occur in drinking HjQ,
(4) Epidemiological studies of people exposed of hazardous
wastes and RF radiation,
(5) And to conduct an epidemiological study of people living in
high density areas where air quality standards are sometimes
exceeded. This is not to say that these proposed studies
are not noteworthy, but implementation of all of them would
'require the major portion of the S&D budget.
Another illustration of unrealistic planning is the proposed
research on the effects of noise. If even one of the proposed
studies were designed and carried out as it should be it would take
all the money allocated for noise research in EPA,
One of the major constraints placed upon an agency such as EPA
is that research must be related to regulation. The trap that is
easy to fall into* however, is that proposed research designs are too
limited to enable the researcher to answer any more than the most
narrow and specific set o£ questions. In turn this means that
closely related questions that could have great bearing on a
particular problem cannot be addressed. If the scientific community
is to be able to address the multiple environmental concerns of our
nation, then it is imperative that EPA recognize that research
programs most go beyond a narrow or precise legal mandate.
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