REPORT OF THE
AD HOC COMMITTEE
TO REVIEW THE
NATIONAL ACID PRECIPITATION
ASSESSMENT PROGRAM
(NAPAP)
United States Environmental Protection Agency
Science Advisory Board
Washington, D*C. 20460
i983
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NOTICE
This report has been written as part of the activities of
the Environmental Protection Agency's Congressionally established
Science Advisory Board, a public group providing advice on scientific
issues. The Board is structured to provide a balanced, independent,
expert assessment of scientific matters it reviews, and hence, the
contents of this report do not necessarily represent the views and
policies of the Environmental Protection Agency nor of other agencies
in the Executive Branch of the Federal government.
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TABLE OF CONTENTS
PAGE
I. EXECUTIVE SUMMARY .....,..„..,..,.. . . 1
II. INTRODUCTION ......... ..,.*.».,.., 3
A. Policy Expectations For NAPAP Program .....«.«*.*. 4
B. Review Committee Procedure ................. 5
C. Outline Of This Report ................... 5
III, DESCRIPTION OF THE PRESENT NAPAP PROGRAM ..,**.,..... 6
A* How the present interagency system worlcs .......... 6
B. Strengths of the present approach ....*.**.,... 9
C. Weaknesses of the present approach .,*..*..».... 10
D. General findings on the present NAPAP efforts ........10
IV. SOME OUTSTANDING TECHNICAL ISSUES IN THI NAPAP PROGRAM ..... 16
V. RECOMMENDED CHANGES TO THE NAPAP PROGRAM ............ 17
R. Management chancfes--a proposed two-tier approach
to acid deposition R&D .................. .17
B. Revised budgeting procedure ...».*....».*,.. .22
c. Key areas requiring additional resources .......... .24
D. Control technology .....................25
E* Mitigation strategies ................... .25
F. Improving the quality of basic science ............ 25
VI, APPENDICES
A — Roster of the Ad Hoc Committee to Review the
National Acid Precipitation Assessment I'rogratn. . . * .A-l
B -- Terms of Reference *.«.,......,..... .B-l
C -- Sorae Pertinent Studies Related to NAPAP .....*., .c-1
D -- Inter-Agency Task Force on Acid Precipitation ...» .D-l
E — NAPAP Budgets PY'82 — P¥'S4 ,..,....»,... .E-l
F -- Ad Hoc Committee Recommendations on WAPAP Budget ... .F-l
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I * Executive Summary
This is the final report of the A
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The report also notes some technical areas which need greater
emphasis and resources. These include air monitoring, accelerated
development of techniques for dry deposition monitoring, more
precise determination of resources at risk, and attention to the
relationship of acid deposition to other air pollution phenomena,
The need for additional research on mitigation strategies is also
noted as well as the need for a greatly expanded program on control
technologies to be carried out by the Department of Energy (DOE)
outside the NAPAP program.
The principal recommendations of the Review Committee address
management changes, revised budgeting procedures, key areas requiring
additional resources^ and the need to improve the scope and quality
of the basic science effort underlying the entire NAPAP effort.
There should also be greater cooperation with foreign countries
facing the acid deposition problem.
The recommended Management changes involve the addition of a
full-tine Director of Assessment who would be an Assistant Admin-
istrator or Deputy Assistant Administrator of EPR. This individual
would be the EPA representative on the Joint Chairs of the NAPAP
interageney Task Force, and he or she would be responsible for the
functions of (!) technical support for policy development, (2)
integration of research results and technical assessment, (3)
broad research guidance to the NAPA1? Research Coordination Council,
and (4) the management of new, large scale projects* The existing
NAPAP interageney process would be maintained to carry out the bulk
of the research effort.
The principal budget recommendation concerns changing the
manner in which resources are provided to agencies participating in
NAPAP. Any additional funds allocated above the FY*84 budget levels
should be provided as "new" money to the participating agencies.
The Director of Research, task group leaders, and the proposed
Director of Assessment must have control over the NAPAP approved
research budgets for which they are responsible.
The Review Group believes that it is essential to strengthen
and expand the fundamental science component of the NAPAP program*
ft standing, external scientific advisory committee for NAPAP is
proposed and increased emphasis is recommended for publication of
scientific results in the peer reviewed scientific! literature to
provide a mechanism for debate on controversial issues* A funda-
mental research effort is essential to clarify many questions
about the environmental impact of acid rain* Therefore, the basic
research must be protected from the budgetary demands of more
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short-term research efforts and larger projects. To insure broad
participation by qualified scientists, an external research grant
program, open primarily to industry and universities, should he
established as a matter of nigh priority with an anticipated funding
level of $10 million per year in new funds*
II* Introduction
This is the final report of the EPA Science Advisory Board's
Ad Hoc Committee to Review the National Acid Precipitation Assessment
program (NAPAP). The Committee was established on August 17, 1983
at the request of the Secretary of Agriculture John Bloc^c, Environ-
mental Protection Agency Administrator William "Ruckelshaus *nd
National Oceanic and Atmospheric Administration Administrator John
Byrne. The membership of the Review Committee is presenter! in
Appendix A*
The charge of the Comaittee was "to review and evaluate the tech-
nical quality of the national^grogram^and suggest future research".
The review included an examination of the plans and objectives of
the program, program implementation, and how well the planned
program will pursue Key scientific questions relevant to decision
making* The complete terms of reference are included in Appendix
B.
There have been several recent technical reviews pertinent to
the MA.PAP program. In addition to the peer reviews undertaken
semi-annually by the NAPAP program, pertinent studies have been
undertaken by the National Academy of Sciences, the Office of
Science and Technology Policy, the Office of Technology Assessment
of the Congress, the Electric Power Research Institute, Jason, and
Working Groups under the US-Canada Memorandum of Intent. A list
of these studies is included in Appendix C.
The present review differs substantially from these prior
efforts. This Committee saw as its principal task to conduct a "top-
down" review of the research management of the HAPAP program.
Thus, the Committee's principal objective -was not .to review NAPAF
on an individual project basis (a task which is satisfactorily
carried out by the NAPAP peer review process)' :'but '"to assess the
adequacy of H&PAP plans and programs for producing scientific
knowledge to improve the scientific basis for decision making.
Host of the Committee's recommendations are directed toward this
end. The reason for adopting this posture Is the recognition that
the fundamental purpose of the NAPAP research program should be to
provide scientific information needed to make more informed regula-
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tory decisions and to accumulate scientific information which win
reduce technical uncertainty over time. Th e pr ,g. s m n £ Comm i 1 1 e e ........ _r gj> -
resents _ the f irst^systematic _ ex tern_al^ review ........ of the adequacy of t h e
HAPAF program and its plans for meeting policy concerns . ~"
A « Pol icy Expectations for the MAgAP Program
The Review Committee is strongly aware of the a harg tension
which exists_ ...... between policy expectations and the prospects f_oi d_e_-
_ecienti_fic Answers withadeguate confidence. On the one
..... __ _
hand, the decision maker confronts a serious public issue which
requires political resolution. In this circumstance , it is under-
standable that the decision maker will seek to establish a research
program which will be responsive to short-term policy concerns and
which will yield results that will permit more informed decisions
to be made on a cost-effective basis. On the other hand, the
scientific community is mindful of the great complexity of the
acid deposition problem and the need for a longer-term research
program which will provide reliable scientific knowledge. No
natter how large the commitment of resources to acid rain research,
some information is beyond the reach of scientists on a time scale
which matches the needs of policy makers.
There are several reasons fox1 this judgment. First, some of
the key scientific questions, e.g., effects on soils, forests,
biological species, watersheds, and materials and structures, require
very long periods of time to document* Second, the physical, chemical,
meteorological, and biological phenpnena involved in acid deposition
are remarkably complex; many years of scientific study will be
required to understand the phenomena adequately, especially if one
requires verification of models and laboratory prediction by field
study. Third, the resources and time required to design and develop
improved control measures and to appreciate the response of ecosys-
tems to change are also considerable. Finally, there is growing
realization that acid deposition is just one of a class of interre-
lated problems, e.g*, ozone, trace metals* carbon dioxide, visibil-
ity, solid waste disposal, and water quality, that society must
confront over the long term if the quality of Jtne global environment
is to be preserved and enhanced. • •.,•»••'?>. . , * .
accordingly, the !_ Review Committee talces -the position "that con-
tinuing investment .in a long-tern,, ..... research program is rqguired.._.re-
flardleBS of the policy decisions which argi taken_ ........ :or are »ot taken
d u ring this d e c a. d e . The Committee's recommendations are designed
to improve the long-term effectiveness of the research program.
Policy makers should clearly understand that a sustained program,
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requiring resources substantially in excess of current, levels, is
the only course of action which will produce information of practi-
cal value in the short-run and which will also generate knowledge
in the long-run that will provide a comprehensive basis for dealing
with the problem oi acid deposition.
B * Review Committee Procedure
The Ad Hoc Review Committee held five meetings for a total of
nine days* The Committee reviewed past studies on acid deposition
(see Appendix C), and net with representatives of the Joint Chairs
(Department of Agriculture,' Invironmental frotection Agency and
National Oceanic and Atmospheric Administration} of the Interageney
Task Force on Acid Precipitation. Extensive briefings were provided
to the Committee by the NAPAP program office staff and by each of
the ten N&P&P Task Groups, In addition, the Committee met the
Chairman and the review panel leaders of the two tt&P&p peer reviews
which have been-held. The Committee also benefitted from a briefing
on the research activity of Electric Power Research Institute
(EPRI) and this organization's views of the NAPAP program, the
need for expanded research, and the prospects for improved control
technologies*
Throughout the Review Committee's deliberations, all of the
agencies and individuals involved in the NAPAP program were extremely
cooperative. The Committee is greatful for this cooperation and
wishes to thank especially Dr. Chris Bernabo, Executive Director
of the NAPAP program, for his efforts in arranging constructive
meetings with all of the participants in the NAPAP program,
C. Outlineofthis Report
The body of this report consists of three major sections.
Section III consists of a description of how the present interageney
NAPAP system works and discusses its strengths and weaknesses.
Section IV is devoted to discussion of some outstanding technical
issues in the NAP&l? program which the Review Committee believes are
not receiving adequate attention. The changes recommended by the
Committee to the NAPAP program are presented in Section V separated
into the areas of management changes, revised budgeting procedures,
key areas requiring expanded resources, control technology, miti-
gation strategies and improving the quality of NAPAP1a basic science
component. An Executive Summary of the Committee's conclusions and
recommendations is provided in Section I of the report.
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111 * Descri.pjt.^ic-n of the Present NAPAP Program
A, HOW the present interagency system works
The NAPAP program is run by an Interagency Task Force composed
of twelve agencies. These include the Departments of Agriculture
(DOA), Commerce (DOC), Energy (DOE), Health and Human Services
(HHS), Interior (DOI), State (DOS), and the Council on Environ-
aental Quality (CEQ), Environmental Protection Agency (EPA), Na-
tional Aeronautics and Space Administration (NASA), National Oce-
anic and Atmospheric Administration (NCAA), National Science Foun-
dation (NSF)t and Tennessee Valley Authority (TVA). The business
of the Task Force is conducted by the "Joint Chairs" filled by
representatives of the heads of three agencies, DOA, IPA and NOAA.
There is an interagency Program Coordination Office, housed in CEQ,
which manages the interagency program and provides staff support.
support. In addition, there is a legislative requirement for four
public members and representatives from four national laboratories:
Argonne, BrookhaVen, Oak Ridge, and Pacific Northwest. An organiza-
tional chart of the interagency program is included in Appendix D»
The work of the NAPAP program is carried out by ten Task_Grgups
each of which is phaired by a representative of a "coordinating"
agency. The ten task groups and the coordinating agencies are:
Task Group Coordinating Agency
A. Natural Sources NOAA
B. Man-made Sources D01
C. Atmospheric Processes NOAA
D. Deposition Monitoring DOI
B, Aquatic Effects SPA
F* Terrestrial Effects DOA
G. Effects on Materials DOI
and Cultural Resources
H. Control Technologies EPA
I. Assessment and Policy Analysis EPA
J. International Activities DOS
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OTiere is a Research Coordination Council, composed of the task
group leaders and agency representatives* which oversees the work
of the task groups and coordinates their activities. The Council
is responsible for developing the NAfAP research plan and for prepa-
ring an annual interageney budget request.
1. The present rg^earch plan^-Participants in the interageney
process are responsible for developing the objectives and research
plans of the NAPAP program. A ten year "National Acid Precipitation
Assessment Plan" was prepared in 1981 as were supporting documents
on "Research Goals and Objectives" and "Major Deliverables. w These
documents describe the results expected from the research activity
and how the outputs of the individual tasX groups relate to each
other. The, _l9r82_1ga.gft.P__[i Annual' Report to ..... the President and Congress
summarizes the program in some detail and establishes three important
milestones for integrated assessments to be prepared in 1985, 1987,
and 19S9. In ^general, the existing KAPAP ^research plans adopt rele-
vant.. ob jectives ........ and define the important research .............. i.sstles involved in
the origins and effects of acid deposition*
2* Management ........... ojF^the^ re search activities--The process of esta-
blishing research objectives and plans Is carried out by an intec-
ageney process. The work plans of the individual task groups are
determined through a negotiating process between the coordinating
interagency process and the participating agencies* Thus, the
HAPAP program is technically de gen trail a eg t with the research
effort determined by compromising what the Research Coordination
Council views as important and what each participating agency
views as important* This situation results in part from legitimate
concerns of the various participating agencies about those aspects
of the acid deposition problem that are most closely related to
their agency's mission, about 'their own research priorities and
the need to maintain their in-house research organization. In
part, the decentralization results from th6 method of funding the
NAPAP program, discussed below.
in principle, the technical direction for the MAlAP program
conies from the Joint Chairs and the task group leaders meeting at
the Research Coordination Council* It is important to realize that
none of these individuals devotes full titne Hbo ' the «&PAP effort.
However, there is an Executive Director who is full time and has
a staff of four individuals.
3* Technical review M^rQceBs-"->ghe NAPAP program has built a
high quality system of Independent peer review. Tbere is a» open
annual meeting at which a_ll of the projects undertaken
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are reviewed by a panel which is organized according to the task
groups. To date, three program peer reviews have been held; in
Fredericksburg, VA in September 1982? Raleigh, MC in February 1983;
«nd Boston, MA in August 1983. They not only provide a technical
review of all ongoing projects but, equally important, these
meetings are an opportunity for informal communication among the
scientific researchers in the NAPAP program.
The Review Committee believes that these periodic technical
reviews_arg__gf ..great value an d., should be continued* An important
question about the periodic peer reviews is the manner in which the
recommendations of the review panels should be implemented. There
is a need to strengthen_the procesj? for following irg the recommends--
tlons^of the peer review panels and assuring that meritorious sugges-
tions are addressed and actually adopted- The present interagency
structure does not possess sufficient authority over the agency
programs to enforce many of the reasonable recommendations made by
the peer review panels.
4. The funding meChanisai^-At present, the budget for NAPAP is
established by OMB review of a joint interagency Submission. The
interageney submission is constructed from requests from the parti-
cipating agencies through the task groups and the Research Coordina-
tion Council* When OMB approves a budget level and associated prp-
grarn, J;he ag-eneies are required to carry out the program within their
existing. Agency research resources*
The consequences of this practice are far reaching and very
detrimental to high quality research on acid deposition* The
reason is simple: each agency is effectively funding, out of its
research base, an interagency research program over which it has
only partial control and interest. At a time when the research
base of most of the participating agencies is eroding, the SAPAP
program is viewed to be a not entirely welcome competition for
resources which address other research and development issues of
importance to the agencies* The inevitable result is that (a) the
agencies seek to substitute work and research performers, i.e.,
their in-house laboratories* which arm not . ac^n-tral /*o .key acid
deposition research or of the highest quality/ and Cfc) t.»e agencies
are reluctant (EPA is an exception} to propose or accept pertinent
new work for fear that it further erodes their base research program*
The outcome is that the NAP&P research proram is far lean effective
and less flexible than it should be to achieve ita goals.
j|__aerloua consequence of this fundlttgjBethgJ 'in 'that the task
group leaders effectively do not..ha. ye authority iitOTer _thc research
that they are expected to direct* Several task groups have
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projects funded by several agencies, e.g., in FY'83 Task Group D,
Deposition Monitoring, had its $4 million budget split between
four separate agencies. The fact is that the research program of
each task group i- limited by what the individual agencies are
willing to do and 'illing to support. This means that the task
group leaders and th ', Interagency Task Force have little ability
to select work or change direction when it would be in the best
interest of the overall research effort. Such authority is essential
to maintain quality control.
Thus, the present funding and budgetary control procedure is
a fundamental flaw in thj»_NAgAg__pyotrraa* It should be revised to
provide (a) "new" research funds to the participating agencies so
that the NAPAP program is not seen as competing with existing agency
research needs, and (b J authority for the task group leaders to
carry out the research program approved by the Interageney Task
Foece through its Joint Chairs to permit the best research to be
undertaken by the most qualified research performer.
In sum, while the existing joint submission of an intet-%gency
budget with OMB review is an excellent way to formulate an integrated
program which involves diverse scientific disciplines and agency
interests, the present manner by which the budget support is provided
effectively removes authority from the task group leaders, who are
responsible for the research program, and impairs the effectiveness
of the overall research effort,
B « Strengths of thepresent 'approach
The NAPAP program has been in existence for over two years*
The progress which has been made during that time is good* Such
progress is not easy, and the NAP&P program is respected both by
this Review Committee and by much of the external scientific commu-
nity.
The interagency process which has been established to manage
HAPAP has many advantages* In particularf an effective forum has
been established to coordinate the views and research activities of
•the various agencies* Such coordination 'is absolutely essential to
the success of the program, whiqh must integrate diverse research
results which are sponsored by many different agencies* The Review
Committee belieyes^hat^the^ inter«gepc_v__|>rgceBB ic particularly ap~
gropriate for the research 'activity of NAPAP, especially an activity
composed of relatively small_|>irQJ[ectB. The process is less satisfac-
tory for the functions of integrating research results, assessment,
and technical analysis to support policy formulation and for the
design and escecution of larger-scale, multi-year projects.
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*- * Weaknesses of the pjce__sejit approach
The NAP&P research program has made commendable progress durin,
its relatively brief existence, but there are some important weak-
nesses* Repairing these weaknesses will lead to a more effective
research program over the long-term.
Perhaps the central weakness of the NAPAP program is that there
is no single technical individual in charge of the entire effort
with both the responsibility and the authority to execute and Inte-
grate the program. It is noteworthy that neither the Joint chairs
nor the task group leaders devote full time to their N&PAP responsi-
bility or view NAPAP as their principal job. The lack of NAPAp
management control over funds has been discussed above. such a
decentra-l_.iz<6d /.. interagency program .is. not lively to be capable of_
undertaking major projects which require disciplined attention to
s c he d ti 1 e and costs* Nor is the present structure likely to be
capable of integrating diverse research results in a manner which
addresses, in a timely fashion, the short-term concerns of the
policy maker. The problem is aggravated by the inordinate expecta-
tions of policy makers as well as the lack of "new money" at a
time when larger projects, e.g., survey of resources at risk, moni-
toring, Imrge-sqale experiments, are being proposed.
The pressure to undertake large, more short-term projects at a
time when agency research budgets are shrinking results in both
inadequate attention to basic science in the program and _ a tendency
to favor in-house laboratories at the expense of the broader scien-
tific community in industry and especially universities. Moreover,
the effort to stretch inadequate resources to cover the vast array
of acid deposition problems has resulted in projects that are
underfunded and too short in duration* A research program which
is characterized by such sub-critical projects cannot "he expected
to attract the highest quality technical people.
t
D . general findings., on the pre sent .......... NAPAP efforts
fhe judgments of the Review Committee about the present NAPAP
effort largely follow from the strengths and weaknesses of the
HAJPAP program mentioned above. Some of the salient findings of the
Review Committee follows
( 1 ) The _asaessment milestones of t,he_jjAgHlt .%l»n in 1985, 1§87
and 1989 are unlikely to be met in a satisfactory way.
Given the level of resources provided* the complexity
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of the. acid deposition problem and the need for indepth
systematic field study, the present ' 13APAP milestones as
summarized/ foz example, in the 1982 N&P&P Annual Report
are too ar.*: itious.
(2} Insu f f ieie n t Attentionis being given to the verification
of iataosjghericti..i>roee_g_8models {which relate emissions to
deposition)and to the development and verification of bio-
logical effects .models.* Since these models are key to the
evaluation of trends in acid deposition and proposed control
strategies, inadequate attention to veritification is most
serious. A principal reason, which leads the Committee to
believe that adequate assessments will not be available
in 1985 and 1987, is the absence of a field measurement
program which would need to be in place now if verified
models were to be available in 1987. Also, field confirma-
tion will take considerably more time than has been allot-
ted.
^ 3 ) Insuf f ic^j^ent attention is ^eing devoted to. the,, integration
of '.'th.e_research results of the various task groups into an
oyerj^l£__assj^sgment» At present* relatively littl«» Intellect-
ual effort is underway to combine research results in a
manner that will lead to understanding at a higher level of
aggregation than individual projects* Up to the present.
Task Group I (Assessment and Policy analysis) has spent most
of Its effort in assembling research material rather than in
doing research which builds on the results of the other
task groups* This circumstance is an inevitable result of
the NAPAP interagency process. Intellectual leadership is
required here*
f ** ^ ghe KAgAP__pjr oggaro mis _ devoting too little attest ion to inter-
national cooperation on acid deposition research. The Review
Committee believes that wore could be learned by additional
international cooperation, especially with Canada, England,
Germanyi Sweden, Norway and Japan* Other nations have done
more research than has the United States (US) on soae subjects,
e.g., Sweden has an extensive lining program, and Norway
and Germany have been studying the effects of. acid rain on
forests for many years. Moreover-, if understanding of acid
deposition is to be considered satisfactory, the models
should be transportable to other areas .and , still provide
reliable predictions with appropriate change of iaput data.
The proposed us program on acid deposition is quite self-
contained* It is not planned as a cooperative effort with
various European countries, even though acid deposition
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seem especially severe there. Our research program
for 1995 does not explicitly consider this or the European
response to it* In some crucial aspects of the ecological
impact problem this is especially regrettable. Thus, German
and central European forests have been subjected to even
greater stresses from sulfur oxides and other atmospheric
pollutants than have our own. Understanding the relationship
of this pollution to widespread forest damage in those coun-
tries would seem to be critical to understanding what may
be or become at risk here to unmanagect soils and forests.
f5) The statusof atmospheric modelling remains primitive.
Present models for acid deposition are forced to use rather
rough parameterizations because of insufficient knowledge
of relevant atmospheric chemistry, dry deposition, cloud
physics, upward transport out of the mixing layer, etc,
Therefore £ griogj. confidence in the detailed predictions
of Models is not yet warranted. Rather, a record of success-
ful testing and evaluation of various extensive data bases
on air and precipitation chemistry taken simultaneously
over several years would be needed to "verify" a model.
Except perhaps for sulfate and nitrate in precipitation,
however, such data bases are not yet available. Although
very general features and trends for acid in precipitation
should be reasonably described, particular source-receptor
correlations for emission changes ar«s much more questionable.
Models should play a more crucial role both in the design
Of experiments and in data analysis* Support is needed
for such developments and for incorporation of deeper under-
standing of extended data bases as they become available,
But, in the absence of such, the use of present models with
the intent of quickly offering detailed answers for near-term
policy decisions is risky,
(6) Controltechnologyis a central component of the acid deposi-
tion problem mnd iscurrently not includedin the NAPAP pro-
gram* The Federal funding level for development and demon-
stration of new control technology should be increased sub-
stantially to complement on-going industry commitments. The
development of «ew and improved, retrofitable, emission con-
trol technologies followed by successful pilot- and demon-
stration-scale testing, is of key importance in the poten-
tial long-term mitigation of acid deposition.
A number of improved control technologies to reduce
source emissions are under development at various scales of
operation. All have incremental associated capital and
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operating costs which must be compared to the present scales
of development and accumulated operating experience* The
urgent need for a technically sound basis to evaluate the
benefits anc costs of these control options and tightened
regulations requires an accelerated national program of
development and demonstration over at least the next five
fears*
These developmental processes include (a) physical and
cfc-attlcal coal benefleiation (cleaning) prior to use, (b)
combined $Q% and NOX removal, either though furnace sorbent
injection (limestone, dolomite, etc*) in conjunction with
staged combustion or though development of improved flue
gas cleanup (scrubbing) processes, (c) modification of pul-
verized coal furnaces to fluidized bed combustion having
much lower SO2 and NOX emission characteristics, and (d>
intensive coal cleanup through conversion to clean synthetic
petroleum or solid fuels- In addition, increased research
emphasis should also be placed on the impacts of these
retrofitable processes on water quality, and the quantity
and the Duality of solid waste produced-
Because control technology is integrally related to
combustion system design and because of the magnitude of
the required RsD effort, the Review Committee recommends
that the federal focas for this national program be th*
DOE and that it be planned and implemented in conjunction
with the private sector* UP& should maintain its current
support role in technology development, thus avoiding con-
flict of interest while maintaining a strong information
base for regulatory decision making.
A major Federal program (several tens of millions of
dollars per year) for development and demonstration is
needed in addition to basic research support for longer-term
fundamental studies* These studies include the general
areas of coal clean up, combustion control, post-combustion
monitoring, effluent identification, and novel techniques
for cleanup.
Both furnace sorbent injection and fluidized bed conver-
sion are two promising process developments which particularly
require expanded development and demonstration efforts. This
will resolve remaining engineering uncertainties ana will
provide confidence on commercial application to both ae-w
and existing combustion sources by the end of this decade.
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The importance of this expanded emission control develop-
ment and demonstration program Is underscored by the fact
that approximately 40% of the total cost of a coal-fired
power plant today is related to environmental control. The
results of the proposed program will support accelerated
resolution of this perceived conflict between coal and the
environment, while avoiding unnecessarily expensive and in-
efficient solutions which freeze control technologies in
today's plants.
f ? 5 Mitigation--The subject of mitigation IB not adequately
treated in the current program*. Scientific feasibility
studies ofmitigation strategiesprior to possible field
implementationshould be developed. Mitigation programs
for aquatic, terrestrial and materials effects may be carried
out in the future. Before extensive experimental mitigation
Studies, such as lake liming, are undertaken, intensive
baseline data collection is required* The appropriate task
groups should support such data collection to study the
feasibility of mitigation to their corresponding effects.
Research additions to the aquatic and terrestrial task
groups should be made to fully utilise data obtained from
foreign and domestic lining programs currently underway.
(8) Basic science _isof great importance to__the N-APAPeffort
and is receiving too little attention* To understand the
impact of any environmental change requires information on
the magnitude of the change itself, the resources at risk
and the resiliency of these resources. All three of these
areas have components of applied and basic science that are
poorly addressed by the NAP&P. Previous statements in this
document have discussed how to improve the applied assessments
program of the NAPAP. However, assessments depend upon
our basic understanding of how acidic deposition interacts
with the receiving systeffls-aquatie ecosystems, terrestrial
ecosystems and materials* If the fundamental knowledge is
lacking, the assessments will be weak. Improperly formulated
and counter productive. To insure 'that current assessments
will be reasonable and that future assessments will be
better, the basic Science component of th* -jfHAPAf must be
strengthened. Specificallys
1. The basic science program should be. •«'-stable , long-
term component of the liAFAP* Since progress in basic science
is achieved over longer time scales than are assessment acti-
vities, the management of the NAPAP should be structured
-------
15
so that the basic science program will be protected from
interruptions in funding and from the more immediate concerns
of the assessment activities.
2* The federal Interagency Task Force should be involved
in the basic science activity* Since our understanding of
the interaction of acidic deposition with receiving systems
requires the involvement of most scientific disciplines,
strong interaction among federal agencies is required to
have a balanced research effort. laeh task group shouia
have a " full time individual* with control of financial
resources, who works with other task group leaders and the
Director of Research to ensure such an approach is successful.
Once the general goals and resource availabilities have
been established* the task group leaders should rely on
universities to manage and to perform the research.
3. The basic science research program managed by the
North Carolina State University (NCSU) Acid Precipitation
program should be expanded and emulated* This program has
received high reviews for both the quality of its •ndsage^artt
and its basic research. It has been the only program of
the NAPAP to bring in new scientists in a coordinated manner
to address basic questions regarding acid deposition. If
future advances are to be made in our basic understanding
of the impacts of acid deposition * programs such as the
NCSU must be continued on a long-term basis*
The expanded basic science program will improve knowledge
of the basic processes and mechanisms occurring in natural
ecosystems and accordingly will stremthen the ability to
assess the impacts of future environmental changes*
(9) Scieatif ic_CQamunicatip_n should ..be., strengthened. The tfAPAP
peer review panels have noted that NAP2LP project investigators
were not always cognizant of available research results* and
that there is not adequate communication between task groups
on subjects which are necessarily related. The single most
important mechanism to assure both credibility and use of
research results is publication in peer reviewed scientific
journals. The_,uR_e__viev Committee strongly "urges that the com-
munications ^among^the task group project ittves-tigatoys be
strengthened,. . .and that all investigators be encouraged to
publish their^ Lresuits in the peer reviewedjaclentific
literature*
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16
In addition to these general conclusions of the Review Committee,
these are several more specific technical issues deserving attention
that emerged during the Connittee *s deliberations. These issues
are discussed in the next section.
IV. Seme Oytstanding_Technical Issues in .the. NAPAP.Program
Listed below are several technical questions which the Committee
believes require greater emphasis within, the NAPJkP program* in many
cases these issaes have not received adequate attention because of
the limitation on the resources which have been devoted to the NAPAP
program. In certain cases, the gap exists because the NAPAP program
organization and research plan is compartmentalized» A susttiary of
the budget of the NAPRP program is included in Appendix E. The
Committee reeemmends_that_the_,Joint Chairs charge ..the NAPAP program
tj3_ev_aluate__t.he^ statug_of____ea_ch___ of the technical issues ntentioned be-
low and to recommend steps to repair existing__d^f iejlericies.
(1) The resources at ri^ajc neeS to be better defined by detailed
geographical surveys) emphasis should be placed on lake
watersheds and forests.
(2) High quality, long-term {20 years needed) study of the J-,n___s_ito
biological response of fish, forests, ami soils are of
najor importance to the program*
( 3 ) Studiee_Qit_aci j,, deposition ..induce j_chetiical_ef f ects .9n._lake_g
and, .streams, coupled with watershed, and soil response, are
urgently needed on_a_n_ecoBysteB basis*
(4) Expanded air monitoring is required for model verification;
this ts a major gap in the program.
( 5 } Accurate , nt^thods__f gr__dry. degosit ipn_monitoring in the field
must be developed before establishing a monitoring network^
(63 The present NAPAP effort on Ba.n~ma d6 sources BUB t. b e g t ££ ng t h -
ened, especially quality control on the source inventory.
{7) Significant attention shottld be devot«a .to the relationiship
of_acid degoaitiott. ghenogjena_and ef fects tc ot;her atmospher-
ic pollutants, e»g.f ozoae, trace netals»
{8} Additional_j.aborat.ory__and field experiments are ttecded to__
6luci3ate__the^nechanisas of the chemical ^ •tr'ansforaations
which ocewr in the atmospherej more work on clou<3 processes
is also desirable.
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17
{9} Basic studies of the mechanisms and extent of materials
damage by corrosion from acidic substances should be initi-
ated. There have been few significant studies on the
influence of acid rain on the mechanical properties of
materials. There are no quantitative data on the effects
of pH and comr .-sition of acid rain or fog, and time and
temperature of exposure under conditions of stress, strain
and alternating stresses. The least studied of these
phenomena is corrosionf atigue of materials in acid rain
environments. Corrosion-fatigue will occur even in environ-
ments in which stress-corrosion cracking does not occur.
(10) Adequate baseline data should be gathered for the assessment
of the effects of possible mitigation strategies, e,g,,
lake liming.
The preceding list, in conjunction with the general findings
presented in Section ill O, summarizes the major gaps and deficiencies
that the Ad Hoc Review Committee found in the NAPAP program. Most of
these gaps and deficiencies can be removed by management attention,
additional resources, and time.
V . Recommended Changes to the MAPAP
In this section the main recomendations of the Ad Hoc Review
Committee are presented.
A. Managejnent_changes " ..'& g-rQBQged_twQ-tier approach to acid
deposition_JRSD
The limitations of the present decentralized management approach
of the NAPAP Program have been discussed in Section III C. These
limitations include (a) the absence of a single technical manager
with both the responsibility and authority to carry out a research
program of high scientific quality which is responsive to key policy
issues and the schedule for their resolution, (b) an organization
which does not have sufficient technical and administrative support
to undertake larger projects and applied studies, and (c) lack of
authority and intellectual, leadership to .address the demanding
technical issues of integration of research. results and quantitative
assessment of alternative courses of action for dealing with acid
deposition. The Review Committee believes that strengthening the
management and organization of the MAPAP program is an essential
prerequisite for realizing major ipprpveaent in the acid deposition
research effort*
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is
In principle, the Review Committee favors a management structure
for an applied RfiD program in which a single technical individual is
in charge and where the program is located primarily in a single
agency. Such an R&0 organization is most likely to yield effective
research results.
The Ad Hoc Review Committee does not believe that it is feasible
to adopt, at the present time, a centralized lead agency approach
for the NAPAP program for -two reasons- First, the acid deposition
problem involves the direct and legitiraate Interest of too many
agencies to permit a single agency to acquire full control of the
program. Second, the NAPAP interagency approach is basically
functioning well, and it would b© a mistake to undertake a major
reorganization which would almost certainly interfere with a research
process that is gaining strength* Indeed the Review committee is
eager to see steps taken to strengthen the Interagency process.
in sum, any management structure proposed for NAPAP Bust
balance a centralized and decentralized approach. Thus, no ideal
solution to the management organization IB likely to exist. The
Review committee has arrived at a proposed two-tier approach which
it believes strikes an appropriate balance and, most importantly,
provides the opportunity for a much aore effective and high quality
research program.
The essential feature of the two-tierapproach recommended fay
the Review Committee is that certain functions be removed front the
taskgroup structure and assigned to a »»»> full-time, high-level
technical manager housed inEPA. These functions are;
1* Technical support to policy development*
2* Integration and Program Assessment (presently Task Group I).
3. Broad research guidance to the HAPAP Research Coordination
Council *
4* Management of large scale projects and research studies
which require project management and -administrative or
technical support* >.>i""
This new position would be at the level of A««i»tant Administrator
(AA) or Deputy Assistant Administrator (DAA) within BPA, and the
individual would be the EPA Administrator's representative at
meetings of the Joint Chairs* The title of tills »ew full-time
-------
position should be something such as Director of Assessment of the
N&PA.P Program. The relationship of the Joint Chairs to the Inter-
agency Task Force would remain unchanged, although the full-time
EPA Director of Assessment would mot as convenor of the Joiiit:
Chairs. In addition, this new EPA AA. or DAA would be responsible
for the performance of -ork ty EPA under the sponsorship of the
task groups. The HA nager would also be able to draw on E£A
administrative resource., and external technical support contractors
to carry out the functions of (2) program integration and assessment
and (4) project management. A proposed^ NAPAF organization chart
is attached.
There are several advantages to the proposed new management
structure. With regard to the assessment tier the advantages are
fJLrst, a single individual would be responsible for many of the
technical aspects of the NAPAP program. This person would be in a
position to implement larger scale projects, for example,,, the design
and operation of deposition monitoring networks, which are likely
to be a progressively greater part of the KAPRP program. SecondT
the critical function of program integration and assessment would
be strengthened and would receive the greater empUaais which this
function deserves. Th^rjl, a mechanism would be created for providing
short-term technical support to policy makers. This function is
very badly needed at a time when many different policy proposals
are being put forward* But, the function of short-term technical
support to policy deliberations must not be permitted to interfere
with the on-going research program* the proposed two-tier arrangement
avoids this danger. Fourtht the strengthened assessment activity
will permit improved research planning and resource management in
the NAPAP program. It is anticipated that the new Director of
Assessment will be in a better position to provide research guidance
to the Research Coordination Council because of the additional
intellectual effort that will be devoted to integration of existing
research results and to assessments.
Fundamental research should also benefit from.theproposed two-
tier aggrgach* First, the on-going* largely effective', interagency
process for undertaking research would remain in" place. To some
extent the separation of the assessment function from the research
activity should improve the ability of the program 'to'^direct its
efforts toward addressing key research questions without the distrac-
tions of entering into short-run policy debates or attempting to
manage larger projects on an interagency basis. Second, the proposed
separation should provide some degree of protection for the research
budget from the growing demands to fund large scale, more applied
projects such as monitoring networks or resource surveys* In sum.
-------
Interagency Task Force
Joint Chairs*
(Executive Secretary)
Advisory Committee
1
National Laboratory
Consortium
Assistant Administrator
or
Deputy Assistant Administrator
(EPA)1
Functions
1
•n
s
«a
o
w
w
D
Research Coordination Council (RCCJ
(Director of Research}
Technical support &
Policy Development
Integration & Program
Assessment
(Formerly Task Group 1)
Research Guidance to RCC
through Joint Chairs
Management of Large
Scale Projects
Responsible for EPA
Performance on Task
Groups
a. External technical
support
b. Contractors S other
contract performem
Task Groups^
I
u
n i
ta
3
G
i
3
t)
D*
t)
1BPA Con ve nor o f Jo i nt ChaIr Meet 1nys
2lxecutive Secretary--CEQ member liaison to policy makers
3Task Group I (Integration anrt Program ftssossment} to DAA RPA; Task Group H to DOE;
new Task Group K on Mitigation to DOI
-------
21
the Review Committee anticif^t«.B that the proposed management
structure will strengthen
-------
22
community. The advisory committee would be of value to the NAPAP
program managers and would increase the credibility if the program
in the scientific community.
B« Rgv i s e d buJ ge ting |» g gcedur_£
In Section III.A.4, the present method of funding the NAPAP
program was described. From this discussion, it is evident that
pa j or change s should be yadf in the_ia»nner by which acid depgsTtion
r e s e a r ch_b u d get s a r e___p r gy i d e d. If these changes are not put into
place the result will be that (U the participating agencies will
progressively refuse to undertake NAPAP work because it displaces
significant research activities which they view as more central to
their agency's mission and/or !2) the agencies will continue to label
work and research performers as "acid deposition related" in order
to protect their base research activities or in-house laboratories.
Continuation of the present practice of funding NAPAP research
out of (declining) agency research budgets will lead to bad research.
The present mec» \nism for funding MAPAP research from agency research
budgets undercuts the Adninistration* a stated interest in supporting
research on acid deposition*
A second important adverse consequence of the budgetlngsystem
is that task group leaders do not have effective control of the
funds required to carry out their approved research programs* This
is because the task group projects are placed into the budgets of
several agencies after a negotiation process over which pro5ects and
performers will be supported. A, task group leader cannot change a
project or select a different research performer without the
agreement of the agency, which frequently Is reluctant to shift
resources away from projects that serve agency interests.
A major revision,of these budgeting procedures is required.
The revision must be based on three preiaisess
{1} Substantial addition* I r e s o a r c e s will ft e ___ required to
support acid deposition research over the next several
decades*
(2) The ac i d deposition re sea rch b udget jaast b e provided
as "nev^ money to the participating;raqency and not from
the existing, declining research programs of these agencies.
(3 > The task group leaders and the new__j>roposed Director
ofAssessment. in_EPA musthavecontrol over the NAPAP
approved budgets for which they are jcespynaible. They
should be dedicated full time to their functions.
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23
The revisions required to achieve -thes* .objectives can be made
bF strengthening the existing interagency budgeting process -through
OMB. At present* OMB reviews an interagency "budget request submitted
by the Joint Chairs » The problem with the ..-Axis. ting approach is
that OMB does not fund the research by adding resources to agency
budgets but rather directs that the UAPAP program be carried out
within existing1 agency budget levels* 'The Review Committee recom-
mends that /_f_oll_oving_gMB review of the interageacy._NAPAP_budget
submission ,__OMS^add__,the^ajgpjfQved, f ttndiBg_,,leve_l8__ito agency budgets
in the final passback__to__the_agency^ In this passback the funds
added _to^the .agency budgets must be earmarked
^
the HAPAP j>ro,yram« The expenditure of the funds should be under
the authority of the task group leaders and the Director of Assess-
ment, subject to approval by the Research Coordination Council
and/or the Joint Chairs* These changes would assure that »ore
effective research would "be undertaken with greater flexibility to
pursue emerging ideas and to attract the most qualified research
investigators *
The FY'84 NAPAP fr"dget__level is $27 million* The Review Connit-
tee believes _ that any additions above this level must be provided as
"_fiew^__ttonev_ _ into the participating agency budget ................ afld ........... not .............. f.,£ont "the
base of the participating agencies*
It is difficult to specify precisely the level to which the
NAPAP research program may neefl to grow. However, the Review
Committee is certain that substantial additional resources will be
required, over a period of tine, to answer the important technical
questions* It is of fundamental importance .that Administration
officials recognize and accept that the research program will require
a long-term commitment and that erratic increases or decreases in
the allocated budget be avoided. Accordingly, the Review Committee
favors a slow but sustained growth of the NAPAP research effort
rather than a crash expansion*
The Committee is especially concerned that large projects
i.f.stipated_ttal_CQ8t in__excess,_gf .,-li
_ ___
til _t hf^.1, g jllow j. Si ^S ix ^j t fjgs^a r e _t a K e n « These lacludes
(1) Preparation of a written research plan describing what is
'to be done t why it should be done, and how it will be
done*
(2) Independent technical peer review of the research plan*
Preparation of an adequate research plaa will typically
require significant resources*
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24
(3) Description of how the project will be managed.
'{4} Preparation of an estimated cost and time schedule to
complete the project.
(5) Designation of a single technical individual who is reponsi-
ble for the project.
(6) Provision made for analysis and dissemination of results.
The Review Committee expects that over time the NAPAP program
could grow to a level of approximately S100 million per year for
several years. However, it will take some time before the NAPAP
program can effectively employ such a resource level. The Commit-
tee's recommendations for the FY'Si NAP&p budget level have been
transmitted separately by letters dated October 21 and November .16,
1983 to the Joint chairs (See Appendix F).
The manner in which such a resource level should best be
deployed depends, in part, upon the research activities undertaken
by industry, states, and foreign governments. The Committee encou-
rages the_NJLPAP program to continue to coordinate its research acti-
vities with thege entitiesand with gPRIand to cooperate onparti-
cular projects and_pregra_ms. .where appropriate*
C. Key areas requiringadditional resources
The Review Committee has stressed in this report its view that
the acid deposition research program is underfunded relative to the
complexity of the scientific issues which should be addressed. In
this section, the Committee wishes to draw attention to certain key
areas which require additional resources and greater emphasis in the
programs* These key areas are:
1. Integrated Assessments;
2. In-depth studies (requiring perhaps...5 to 10 y«ars of field
measurements) of aguati^c and terrestria! effects particular-
ly soils, forests and watersheds! • • •
3, verification of source-re eeptor_jngdj6l9y including ambient
(ground and elevated) air qualityt event *ret deposition,
and dry deposition monitoring*
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25
D. CQn_t r Q 1 t e c hno 1 Q g_j_
As discussed in Section III.D, little attention has been
devoted to control technology within the NAPAP program. Yet controls
are essential to coping with acifl deposition.
The process of developing new control technologies for coal
cleaning, combustion, and clean-up should be central to the design
of combustion systems and requires analysis of trade-offs between
capital costs, fuel typef etc* The development of a control technol-
ogy within a combustion system requires substantial RsD (hundreds
of millions of dollars) at the required scale (hundreds of megawatts)
and substantial time to yield reliable test data on cost and perfor-
mance. For these reasons, the Review Committee believes that advanc-
ed control technology development should be primarily a DOE responsi-
b i11 y * The^Review Group recommends that DOE be given the task, out-
sideof the_Nfl.PflP program, to formulate a_ comprehensive and agefres;-*
siye program,in cooperation vith industry, for advanced ^control
technology development* NAPAP's role in control technology should
be limited to awareness of developments in the technology and in
the trade-offs possible; the NAPAP program should not undertake
control technology hardware programs. The respoisibility for devel-
oping cost-effective control technologies should be assigned to DOE.
^ * Miti_gation strategies
The Review Committee believes that before embarking on large-
scale liming or other mitigation programs, it is essential to study
the effects that such actions have on ecosystems. To prepare for
assessing the consequences of possible mitigation programs, a
substantial amount of research is needed {including field experi-
ments) by appropriate task groups.
F• Improving the quality of the basic science
The Review Committee is concerned that insufficient emphasis
is being given to maintaining the quality of the long-term funda-
mental research, which must be an important component of any nation^
al effort on acid deposition. In particular, the Committee believes
that insufficient attention is being given to sopportiftg research
of a fundamental nature which is relevant to the long-term objectives
of the NAPft.P program but which is not narrowly directed to task
group needs* Such research is of major long-term benefit to the
program because it stimulates new ideas that test the mainline
research approach. Research of this type, which is largely
performed in universities, should be supported through a peer
-------
26
reviewed grants program. The Revie* Group recommends that a grants
program of approximately $10 million per year be established within
the NAP-iP program with an initial level Of $5 million in FY"85.
This Acifl Precipitation Act of 1980 included an authorization
of $5 million per year to NGAJL to fill gaps in the NAPAP. The Com-
mittee recommends that this money be appropriated in FY'85 through
the existing authorization, which has never been appropriated.
The sioney should b0 used to fill important, basic science needs of
NAPAP. The allocation of these funds should "be managed by the
Director of Research for the Research Coordination Council.
The Contmlttee recommends that in FY' 86 and beyond the authori-
zation be increased to $10 million per ye*r»
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APPENDIX A
SCIENCE ADVISORY BOARD
AD HOC COMMITTEE TO REVIEW THE NATIONAL ACID
PRECIPITATION ASSESSMENT PROGRAM
Dr« John Deutch, Chairman
Dean of Science
Massachusetts Institute of
Technology
Building 6, Room 123
77 Massachusetts Avenue
Cambridge, Massachusetts 02139
Dr. Terry F» Yosie, Executive Secretary
Staff Director
Science Advisory Board (A-1Q1)
Environmental Protection Agency
401 M street, sw
Washington, D.C. 20460
Dr. Richard Balzhiser
Senior vice-President for
Research and Development
llectrie Power Research Institute
Rooa 1-296
3412 Hillview Avenue
Palo Alto, California 94303
Dr« James N* Galloway
Department of Environmental
Sciences
Claris Hall
University of Virginia
Charlottesville, Virginia 22903
Or* George Hidy
General Manager
Environmental Research and
Technology
2625 Towngate Road
Westlake Village, CA 91361
Dr* William Klewperer
Department of Chemistry
12 Oxford
Harvard University
Cambridge, Massachusetts
02138
Dr. Gene 1* Likens
Institute of Icosyatems Studies
The New York Botanical Garden
Gary Arboretum, Box AB
New York 12545
Dr, Stanford s. tenner
Energy Center (B-Q103
University of California at
San Diego
La Jolla, California §2093
Dr* Malvin Ruderman
Department of Physics
Columbia University
Hew York, New York 10027
Br* Michael Qppenheimer
Environmental Defense Fund
444 Park Avenue South
New York, Hew York 10016
Dr* Herman
Director
Oak Ridge national Laboratory
P.O* Box I
Oak Hldi^e, Tennessee 37831
A *
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APPENDIX B
of Reference
for the A3 Hoc Committee to Review the National
Acid Precipitation Assessment Program
The Administrator of ;*""•&, NQAA and the Secretary of Agriculture
have requested that an external group of scientific experts review
the National Acid Precipitation Assessment Program (NAPAP) to
assess its initial progress and future plans and to make recommen-
dations on how the effectiveness of the program can be improved.
The review panel is requested to complete its deliberations and
report by 30 December 1983*
PURPOSE - To review and evaluate the technical quality and progress
of the National Program and suggest future research.
CHARGE - Evaluate the strengths and weaknesses of the program,
particularly the ability of the planned effort to answer
the scientific questions most pertinent to policy develop-
ment* The review will cover an examination of:
• Plans and_0bjegtiv£s_i Are the objectives of the program
clear, complete, and appropriate fiv^ti the overall purpose
of the research program? Are the objectives realistic?
Are the plans responsive to the objectives? Are the
resource allocations across and within major research
areas adequate, excessive, inadequate? Do the schedules
for results seem reasonable? Is there reasonable proba-
bility of success in meeting program objectives? Are
there any overlaps, duplication, or gaps in the plans?
Is there an appropriate balance between basic and applied
research efforts?
• Imp j^egenta t ion t How well does the management structure
and process for planning and implementing work? Are the
projects being performed and the various individual
agency efforts well coordinated? Do the projects
address the program's objectives? How well are the
agencies working together? Are national objectives,
not just agency mission requirements, being net?
* Applications; Will the planned program address the
critical scientific questions most relevant to decision
making? Do the plans and projects demonstrate progress
toward usable assessments of the problem and possible
solutions? Are the proposed assessments well conceived?
Will the information generated be useful and of lasting
scientific and policf-making value?
B - 1
-------
PROCEDURE - The Committee will pursue its inquiry through discussion
with Federal officials reponsible for the research
program, researchers in the prograa (both in govern-
ment and non-government laboratories) and external
experts. Attention will be given to the relevance of
the program's current and planned activities to the
urgent needs for better scientific information to
develop sound policies*
I|J|CO M HEN DA T ION S - The report of the ad hoe review panel may address any
aspects of the research program. However, particular
emphasis should be given tot
- identifying possible future research in scientific
areas most relevant to policy concerns
- suggesting wayg of improving the program and its
management
- recommending how to ensure the outputs of the program
are most effectively communicated and utilized
- indicating way* to strengthen the scientific quality
of the program
- suggesting changes in the level and direction of
effort in pertinent areas.
B - 2
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APPENDIX C
^ii,::r^jj j1 ,f ,; v 9a.1 * j r?*ir>D £.,
go me Pertinent g;tajii^es _KgljLfcg.3_tQ NAPAP
1. NAPAP, National Acid Precipitation Assessment. Plan, .June 1982
2. NAPAP Annual Report, 1982
3* Report of the First Annual Review Meeting Of the NAPAP,
Fredericksbarg, VA, September 1982
4* Report on the Effects Research Review Meeting of the NAt>Al>,
Raleigh, NC, February 1983
5. Report on Atmospheric Review Meeting of the NAPAP
Boston, WA, August 19S3
6. Office of Technology Assessment Report, July 1§82
7. National Academy of Sciences Study a 1981 b)Calvert 1983
8. Jason Report
9, EPRI R&D plan
10. Working Groups under DS/Cana«Ja Mefnorandum of Intent* 1983
11* office of Science and Technology Policy Report, Executive
Office of the President
C - 1
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TASK FORCE ON ACID PttRrtPITATlON
Program Coordination
Office
Interayency Task Fnrc«
Director of Research
D
I
H
Hatural
Sources
NOAA
Man-Kade
Sources
DOE
Atmos-
pheric
Processes
NOW A
_L_ . L
Oejios i t Ion
Monitor Iny
Aquatic
Kff'JCtS
W)E BPA
Research
Coordination
Council
Task
1
National
Laboratory
Consortium
Groups
Torres-
trial
Bf EisctJj
IIOA
1
KttttGttt Control Assess-
on Tech- ments and
HatertaTn nologJes Policy
,ii til r Analysis
Cultural
Resources '
(M)i BPA EPA
Inter-
national
Activities
DOS
nj
TJ
M
4-1
X
Coordinating Agoneies
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APPENDIX I
Task Group
A,. Natural Sources
B* Man-made Sources
C. Atmospheric Processes
D» Deposition Monitoring
E* Aquatic Impacts
F« Terrestrial Impacts
G. Effects on Materials
H* Control Technologies
I. Assessment an<3 Policy
J* International
1CJDSETS ($OQO
FY82
1365
1790
F184
. 600
1170
4863
3103
3017
3S83
485
700
1350
5558
4803
3363
4437
§85
955
1350
7097
5796
3913
4437
1498
2375
18,236
22,276
27,418
I - 1
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APPENDIX F
| UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
riCM I 6 J"
OPPICE OF
THE ADMINISTRATOR
Mr. William D. Ruckelshaus
Administrator
Environmental Protection Agency
401 M Street, S.W,
Washington, D.C. 20460
Mr. John E. Block
The Secretary of Agriculture
Administrative Building, Room 2QOA
12th Street & Jefferson Drive, S.W.
Washington, D.C. 20250
Ms. Nancy Maloley
Council on Environmental Quality
722 Jackson Place, N,W.
Washington, D,C. 20250
Mr. John V. Byrne
Administrator
National Oceanic and Atmospheric Administration
Herbert C, Hoover Building
14th Street & Constitution Avenue, N.W.
Washington, D.C. 20230
This letter conveys an interim report from your Ad Hoc Committee to
review the National Acid Precipitation Assessment Program (NAPAP) con-
cerning our judgments on the FY 85 interagency budget submission. The
principal purpose of the review committee is to evaluate the technical
progress of the NAPAP program and to make recommendations for change
that will strengthen this vital national research program. Our final
report, due to you before December 30, 1983, will address the progress
of the NAPAP program In detail. This letter reponds to a request to
comment on the proposed FY 85 NAPAP budget at a time appropriate for
budget cycle consideration. .'•'•'••
Throughout the Ad Hoc Committee deliberations we have been impressed
with the complexity of the scientific and technical questions which must
be answered in order to respond In a cost/effective wanner to the acid
deposition problem. The required technical program demands a sustained
research effort which addresses both policy concerns and fundamental
scientific Issues. This research effort tmdoubtably deserves, in light
of the potential environmental effects and the economic costs of control,
much larger research budgets during the coming years. However aany of
the key scientific questions, e.g., long term biological and ecological
effects, will require many years of research to answer. In part because
of the time scale of natural processes; accelerated funding cannot in
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cases lead to better answers sooner. Thus, It is of paramount
importance to establish a research program which is of the highest
technical quality and recognized to require sustained support. It Is
essential to avoid the oscillation In research support which all too
frequently affects programs that command momentary political attention,
We have reviewed the FY 85 budget from this viewpoint. The NAPAP
interagency process has requested $82.027 million at level III and
$35.247 million at level II for FY 85 compared to $27.468 million In
FY 84. We believe that the program should receive, at most, a 100%
Increase in FY 85 to a level of about 55 million. Earlier we have
advised Ms. Maloley and Mr. Ala as to the extreme importance of
providing any increment above the FY. 84 NAPAP level as "new" fenced
money in the agency passback ia order to avoid eroding the existing
research base of the participating agencies and to assure that the
best technical talent is applied to the unique problems of the NAPAP
program, A copy of this letter is attached for your consideration.
The $55 million FY 85 budget which we advise evidently will require
a choice anong the several NAPAP proposed research projects which the
iflteragency task force recommended as "essential" or "highly desirable"
within their level III increment* Our committee has not done the work
necessary to reach precise judgments on which of the proposed projects
should be deferred. However the Committee wishes to note some projects
which it believes would be especially valuable to include in any increment
above level I. These projects are:
Task Group B: (1) third party verification of the man-made sources
emission Inventory;
Task Group C: (2) ambient air quality monitoring (similar in scope
to the past SURE project);
(3) provision for participation in a large scale
atmospheric field study (this could be either
the proposed EPRI MATSX experiment, the DOE
non-linear experiment or the EPA source receptor
study);
(4) increased attention to laboratory studies which
bear an atmospheric chemistry;
Task Group D: (5) augmentation of the wet deposition network;
(6) accelerated development of new reliable methods
for measuring dry deposition;
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Task Group 1; (7) expansion and continuation of the survey of lake
water quality and fish resources including water-
shed parameters;
(8) intensive ecosystem monitoring;
(9) scientific feasibility studies of mitigation
strategies prior to field implementation- and
Task Group Fs (10) quantification of significant changes in soil
and forest productivity and stability due to
acid deposition and other potentially damaging
pollutants.
In addition, the Committee believes that advanced control technologies
are of great importance to the acid deposition problem; this issue will
be addressed in detail in our final report.
In the Committee's review it became apparent that the NAPAP program
Increasingly will be proposing larger projects of longer duration. For
these projects (estimated total cost greater than $5 million) it Is
especially important that a process be established to assure five steps
have been taken before project approvals
(1) Preparation of a written research plan describing what is to
be done, why it should be done, and how it will be done.
(2) Independent technical peer review of the research plan
(3) Description of the management of the project
(4) Preparation of an estimated cost and tine schedule to
complete the project
(5) Designation of a single technical individual who is responsible
for the project at each stage of development.
Finally, the Committee notes its concern that the perceived need
to obtain basic data and answer near cent policy concerns is outweighing
increased attention to more fundamental scientific inquiry bearing on broader
questions involving the mechanisms of pollutant transport, environmental
damage, long term biological effects, and new control concepts. Since acid
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budget. Tills will assume both a more effective and higher quality research
program that will move this Cation to resolve the substantial scientific
uncertainties over the
cc:
Mr. Willian Ruckelshaus
Mr, John Block
Mr. John Byrne
Dr. Courtney Riordan
Dr. Orville Bentley
Dr. Lester Machta
Dr. Chris Bernabo
Dr. Terry F. Yosie
John peuteFrT Chairman
A3 Hoc Committee to Review
the National Acidic'
Precipitation assessment
Program
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