UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O,C, 20460
April 21, 1992
EPA-SAB^EC-COM-92-006
Honorable William K. Reilly , OFF.CEOF
Administrator THE AOWINISTHATOB
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Dear Mr. Reilly;
The Executive Committee of the Science Advisory Board
invites your attention to the recently issued report of the
National Research Council (NEC) Opportunities in Applied
Environmental Research and Development1, in particular the
section on Anticipatory Research. We were briefed on this study,
sponsored by EPA, ATSDR and NIEHS, at our 7 January meeting by
Dr. R.N.L. Andrews, Chair of the NRG Committee preparing this
report. The need for anticipatory research also was pointed out
in our 1988 Future Risk report,2 Given the importance of these
issues and the initial, but limited, progress that the Agency is
making in some of these areas, we would like to indicate our
continuing support of and our persistent concern about the
Agency's efforts in anticipatory research. This letter
summarizes the principal arguments from these two reports, which
are still relevant and germane.
Society frequently finds itself reacting to environmental
problems when they become public crises and wishing that timely
research had helped either to anticipate the-crises or to provide
means to deal with them. Acid deposition, biomagnification of
DDT, asbestos fibers, and clean-up standards for ground water and
soil, all are examples of problems for which we might have been
better prepared. The absence or inadequacy of relevant
scientific knowledge and understanding frequently makes it
difficult to generate rational environmental policy to deal with
problems as they arise.
There are a number of steps EPA should take to enhance its
ability to anticipate environmental problems before crises
develop, and before costly, after-the-fact clean-up actions are
required. For example:
1) Continue to stress programs that monitor environmental
quality (such as EMAP) and human exposure (such as
NHEXAS) and develop ways to predict the ecological and
health consequences of continued patterns of pollutant
loadings.
2) Conduct expert workshops to review emerging basic
science information for early indicators of potential
env i ronmenta1 prob1ems.
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3) Monitor technological trends supported by soeioeconomie
responses and trends and develop ways to predict their
environmental and health consequences. Conduct
activities that develop goal-oriented, surprise-
oriented, and other scenarios that reveal potential
environmental and health problems,
4} In addition to improved early identification of new
problems, conduct more basic research in areas we know
need to be shored up for EPA to be ready to address
emerging environmental quality and health needs.
5) Establish a dedicated group within EPA to conduct the
above work and to prepare periodic reports on new,
emerging, and escalating ecological, health, and
welfare problems caused by environmental stressors.
Ways to mitigate such problems should be identified.
The afore-cited reports provide more details on these and other
proposed anticipatory research studies*
In light of your new vision for the Agency with its emphasis
on information and data, it is important that anticipatory
research be available to guide future directions and decision.
The EMAP effort (fl above) is clearly a step in this direction, a
course which the SAB has encouraged in the past and continues to
support today. We understand that |2 may be addressed as a
consequence of the Expert Panel Report*3 We are also award of
initiatives being considered to upgrade basic scientific and
social science research (#4).
However, we also encourage the Agency to think creatively
about methods for identifying emerging technological and
sociological trends that could generate or amplify environmental
problems and develop scenarios that can reveal emerging problems
(#3) ? and, most importantly, to organize and/or to analyze
efforts |1 to |4 into a coherent strategy and operation (|5). We
are aware that some of these actions are included in the February
14 Draft Research Issue Strategy for Anticipatory Research for
Emerging Environmental Issues, but your special attention still
seems needed to activate this long-considered, but long-dormant
effort. We are also aware that the National Advisory committee
on Environmental Policy and Technology (NACEPT) has an interest
in anticipatory research and could participate in any reviews
from a policy perspective.
We look forward to your response and update on the status of
these suggestions.
Raymond C, Loehr, Ph.D.
Chair, Science Advisory Board
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1. Opportunities in Applied Environmental Research and Pavelppment.
National Research Council, National Academy Press, Washington, DC
1991 (ppl59-171),
2»Eature Risk; Research Strategies for the 1990'a. SAB-EC-8S-04Q,
Sevteajber 1988 (Recommendation No. 4 and Section 3.2 of Appendix
D).
3* Safeguarding theFuture; credible Science. Credible Decisions,
EPA/600/9-91/050, March 1992.
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