April 28, 1998
EPA-SAB-RSAC-98-006
Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
401 M. Street, SW
Washington, DC 20460
Subject: An SAB Report: Review of the FY1999 Presidential Budget
Request for the Office of Research and Development (ORD)
Dear Ms. Browner:
On February 26-27, 1998, the Research Strategies Advisory Committee (RSAC) of the
Science Advisory Board (SAB) met to review the FY1999 Presidential Budget Request for the
Office of Research and Development (ORD) of the US Environmental Protection Agency (EPA).
This review was carried out by RSAC in order to provide the Agency and the Congress with
advice and insights on the adequacy of this budget to implement a research program of high
scientific quality and one that is responsive to the needs of the Agency.
The review meeting was conducted in public session under the provisions of the Federal
Advisory Committee Act (FACA). The Committee was provided with background documents
supplied by the Agency, supplemented by briefings from Agency senior managers during the
meeting. The Committee was very pleased to see the significant improvement in the quality of the
background materials as compared to previous years. In addition, we were impressed with the
depth of knowledge exhibited and the level of coordination and cooperation displayed by the
ORD senior staff members during the full day of presentations and briefings that helped us
understand the FY1999 budget more clearly.
The overall form of the budget and the manner of its presentation were clear and well-
organized; the budget follows EPA and ORD Strategic Plans; and the budget is goal-based and
incorporates the intent of GPRA. The Committee was pleased to see the Agency change the
budget presentation this year away from the media-specific format of previous years. It would be
useful for ORD to provide more detail on how the budget is allocated to individual objectives and
research programs and how this year's budget fits in to the contemplated budgets over the
planning horizon of the Strategic Plan. In addition, we recommend that future ORD budget
requests should reflect not only the single year but the budget projected to meet each goal in the
outyears.

-------
While pleased with the presentation of the budget, we were disturbed to note that the
research budget is declining when viewed as percentage of the overall Agency budget, as well as
in real purchasing power. Environmental concerns are complex and need more scientific insights
than the budget can deliver; as a result, important issues cannot be adequately addressed. In
particular, we concluded that the budgets proposed in several areas were not likely to be sufficient
to meet the goals established by the Agency and ORD in their Strategic Plans. These areas
included particulate matter, endocrine disruptors, ecosystem protection, global climate change,
waste site remediation technologies, microbial pathogens and indoor air.
As part of the review process, the Committee responded to the following charge
questions:
a)	How well does the budget request reflect priorities identified in the EPA and
ORD Strategic Plans? The Committee compliments the Agency for substantial
improvements in the development and presentation of its budget in a goal-based
format. As a result, we find that the budget is aligned with the EPA and ORD
strategic priorities. The Agency has done a good job of justifying its budget
requests on the basis of the research and development needs for each of the
strategic goals.
b)	How well does the budget request support a reasonable balance in terms of
attention to core research on multimedia capabilities and issues and to
media-specific problem-driven topics? It is appropriate that ORD should
distribute its research resources to problem, program, regional and user needs as
well as to continuing more fundamental core research themes. In its FY1999
budget allocation, ORD indicated that approximately 60 percent of resources are
dedicated to core research and approximately 40 percent is devoted to problem
research. This distribution was considered reasonable by the Committee.
However, we note that there is no correct ratio or "balance" in a given year
between budgetary allocations to these two activities beyond recognition of the
need for both.
c)	Does the proposed budget request balance attention to near-term and to
long-term research issues? In terms of the balance between long and short
duration programs, the Committee did not reach a conclusion concerning the
current budget request because there is no indication of the potential duration of
the programs nor an indication of what is anticipated as results become available.
There is also no indication concerning how programs are evaluated for termination
when they have fulfilled their objectives.
d)	Can the objectives of the research and development program be achieved at
the resource levels requested? The Committee is concerned that the Agency has
not adequately demonstrated that this proposed ORD budget is sufficient, in a
2

-------
number of areas, to sustain the appropriate level of science and technology core
research developments that the Agency needs to be equipped to protect human
health and to safeguard the environment. In fact, if the FY1999 ORD requested
funds are allocated it will be the lowest in the 1990's when corrected for inflation.
This erosion in ORD's and the Agency's science and technology funds occurs at the
same time that the science involved with environmental issues is ever more
complex and challenging. To fully meet stated goals, certain topics/goals need
additional support.
e) How ORD can improve upon the Government Performance and Results Act
(GPRA) structure to communicate research plans, priorities, research
requirements, and planned outcomes? It would be valuable to have an
indication of how the present year fits into the flow of the research program
funding by providing an indication of what the past year's funding was for each
goal and the anticipated direction of funding (more, less, the same) for the next
three years. In addition, EPA needs to develop a set of criteria for success of
research in ORD, whether it is done intramurally or extramurally. These criteria
can then be incorporated into a process of reevaluation of research goals as they
evolve over time to determine the continuing need for a particular research
program and its potential value for informing the regulatory mission of the Agency.
We appreciate the opportunity to review and provide advice on the FY1999 Presidential
Budget Request for the Office of Research and Development. The Research Strategies Advisory
Committee would be pleased to expand on any of the findings in the attached report, and we look
forward to your response.
Sincerely,
/signed/
/signed/
Dr. William Randall Seeker, Chair
Research Strategies Advisory
Dr. Joan M. Daisey, Chair
Executive Committee
Science Advisory Board
Committee
Science Advisory Board
3

-------
NOTICE
This report has been written as part of the activities of the Science Advisory Board, a
public advisory group providing extramural scientific information and advice to the Administrator
and other officials of the Environmental Protection Agency. The Board is structured to provide
balanced, expert assessment of scientific matters related to problems facing the Agency. This
report has not been reviewed for approval by the Agency 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, nor does mention of trade
names or commercial products constitute a recommendation for use.
1

-------
ABSTRACT
On February 26-27, 1998, the Research Strategies Advisory Committee (RSAC) of the
Science Advisory Board (SAB) met to review the FY1999 Presidential Budget Request for the
Office of Research and Development (ORD). The Committee considered how well the proposed
budget request: a) reflected priorities identified in the EPA and ORD Strategic Plans; b)
supported a reasonable balance between core research on multimedia capabilities/issues and
media-specific problem-driven topics; c) balanced near-term and long-term research issues; d) had
sufficient resources to achieve the objectives of the research and development program; and e)
how ORD can improve upon the Government Performance and Results Act (GPRA) structure to
communicate research plans, priorities, research requirements, and planned outcomes.
The Committee noted that the FY1999 ORD and EPA budgets are the first goals-based
research budgets put forth by the Agency. The budget represented a concerted effort on the part
of the ORD to develop the requested funding allocations around the ORD Strategic Plan. The
plan and budget were developed in concert with the program offices to develop goals consistent
with customer needs. For the first time it is possible to examine and evaluate how the money is
allocated to various programs, to science and technology activities and to various strategic goals.
While pleased with the presentation of the budget, RSAC was disturbed to note that the
research budget is declining when viewed as percentage of the overall Agency budget, as well as
in real purchasing power. In particular, the Committee concluded that the budgets proposed in
several areas were not likely to be sufficient to meet the goals established by the Agency and ORD
in their Strategic Plans. These areas included particulate matter, endocrine disruptors, ecosystem
protection, global climate change, waste site remediation technologies, microbial pathogens and
indoor air.
Keywords: GPRA, budget, research, strategic planning
11

-------
US ENVIRONMENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
RESEARCH STRATEGIES ADVISORY COMMITTEE (RSAC)
CHAIR
Dr. W. Randall Seeker, Senior Vice President, Energy & Environmental Research Corp., Irvine,
CA
MEMBERS
Dr. William Adams, Director, Environmental Science, Kennecott Utah Copper Corp., Magna,
UT (was not able to attend review meeting, but provided written input and comment
during development of this report)
Dr. Stephen L. Brown, Director, Risks of Radiation and Chemical Compounds, Oakland, CA
Dr. Theo Colborn, Director, Wildlife and Contaminants Program, World Wildlife Fund,
Washington, DC
Dr. Edwin L. Cooper, Professor, Department of Neurobiology, School of Medicine, UCLA, Los
Angeles, CA
Dr. Charles Gerba, Professor, Program in Microbiology, University of Arizona, Tucson, AZ
Dr. Philip Hopke, R. A. Plane Professor of Chemistry, Clarkson University, Department of
Chemistry, Potsdam, NY
Dr. Paulette Middleton, Vice President, Science & Policy Associates, Inc., Boulder, CO
Dr. Ishwar Murarka, Technical Executive, Electric Power Research Institute, Palo Alto, CA
Dr. William Smith, Professor of Forest Biology, School of Forestry and Environmental Studies,
Yale University, New Haven, CT
SCIENCE ADVISORY BOARD STAFF
Mr. A. Robert Flaak, Designated Federal Officer, U.S. Environmental Protection Agency,
Science Advisory Board (1400), 401 M Street, SW, Washington, DC 20460
Ms. Dorothy M. Clark, Staff Secretary, US Environmental Protection Agency, Science Advisory
Board (1400), 401 M Street, SW, Washington, DC 20460
in

-------
TABLE OF CONTENTS
1.	EXECUTIVE SUMMARY 	1
2.	INTRODUCTION	3
2.1	Background and Schedule	3
2.2	Charge to the Committee 	3
2.3	Format of this Report 	3
3.	OVERVIEW OBSERVATIONS AND COMMENTS 	4
4.	RESPONSE TO THE CHARGE 	7
4.1	Reflecting Priorities in the Strategic Plans	7
4.2	Balance Between Core Research and Problem Centered Research	7
4.3	Near-Term v. Long-Term Research	8
4.4	Objectives of Research v. Available Resources 	9
4.4.1	Strategic Goal: Clean Air	9
4.4.2	Strategic Goal: Clean and Safe Water 	10
4.4.3	Strategic Goal: Safe Communities	10
4.4.4	Strategic Goal: Safe Waste Management	11
4.4.5	Strategic Goal: Global Environmental Risk Reduction	11
4.4.6	Strategic Goal: Environmental Right to Know	11
4.4.7	Strategic Goal: Sound Science	12
4.5	Improvements to GPRA Structure	14
REFERENCES CITED	R-l
iv

-------
1. EXECUTIVE SUMMARY
On February 26-27, 1998, the Research Strategies Advisory Committee (RSAC) of the
Science Advisory Board (SAB) reviewed the FY1999 Presidential Budget Request for the Office
of Research and Development (ORD). The Committee was very pleased to see the significant
improvement in the quality of the review materials as compared to previous years. In addition, we
were impressed with the depth of knowledge exhibited and the level of coordination and
cooperation displayed by ORD staff during the full day of presentations and briefings that helped
the Committee members understand the FY1999 budget more clearly.
The overall form of the budget and the manner of its presentation were clear and well-
organized; the budget follows EPA and ORD Strategic Plans; and the budget is goal-based and
incorporates the intent of GPRA. The Committee was pleased to see the Agency change the
budget presentation this year away from the media-specific format of previous years. It would be
useful for ORD to provide more detail on how the budget is allocated to individual objectives and
research programs and how this year's budget fits in to the contemplated budgets over the
planning horizon of the Strategic Plan. In addition, we recommend that future ORD budget
requests should reflect not only the single year but the budget projected to meet each goal in the
outyears.
The Committee was disturbed to note that the research budget is declining when viewed
as percentage of the overall Agency budget, as well as in real purchasing power. Environmental
concerns are complex and need more scientific insights than the budget can deliver; as a result,
important issues cannot be adequately addressed. In particular, we concluded that the budgets
proposed in several areas were not likely to be sufficient to meet the goals established by the
Agency and ORD in their Strategic Plans. These areas included particulate matter, endocrine
disruptors, ecosystem protection, global climate change, waste site remediation technologies,
microbial pathogens and indoor air.
In addition to its general comments, the Committee also provided responses to the five
charge questions:
a)	How well does the budget request reflect priorities identified in the EPA and ORD
Strategic Plans? RSAC notes that the budget is aligned with the EPA and ORD
strategic priorities. The Agency has done a good job of justifying its budget
requests on the basis of the research and development needs for each of the
strategic goals.
b)	How well does the budget request support a reasonable balance in terms of
attention to core research on multimedia capabilities and issues and to media-
specific problem-driven topics? In its FY1999 budget allocation, ORD indicated
that approximately 60 percent of resources are dedicated to core research and
approximately 40 percent is devoted to problem research. This distribution was
considered reasonable by the Committee. However, we note that there is no
1

-------
correct ratio or "balance" in a given year between budgetary allocations to these
two activities beyond recognition of the need for both.
c)	Does the proposed budget request balance attention to near-term and to long-term
research issues? In terms of the balance between long and short duration
programs, the Committee did not reach a conclusion concerning the current budget
request because there is no indication of the potential duration of the programs nor
an indication of what is anticipated as results become available. There is also no
indication concerning how programs are evaluated for termination when they have
fulfilled their objectives.
d)	Can the objectives of the research and development program be achieved at the
resource levels requested? The Committee is concerned that the Agency has not
adequately demonstrated that this proposed ORD budget is sufficient, in a number
of areas, to sustain the appropriate level of science and technology core research
developments that the Agency needs to be equipped to protect human health and
to safeguard the environment. In fact, if the FY1999 ORD requested funds are
allocated it will be the lowest in the 1990's when corrected for inflation.
e)	How ORD can improve upon the Government Performance and Results Act
(GPRA) structure to communicate research plans, priorities, research
requirements, and planned outcomes? It would be valuable to have an indication
of how the present year fits into the flow of the research program funding. In
addition, EPA needs to develop a set of criteria for success of research in ORD,
whether it is done intramurally or extramurally.
2

-------
2. INTRODUCTION
2.1	Background and Schedule
The Science Advisory Board (SAB) review of the proposed budget for the Office of
Research and Development is normally an annual event. The timing associated with the public
availability of the budget materials often makes scheduling of a formal review difficult. Reviews
completed by the Research Strategies Advisory Committee also require formal public review and
approval of the SAB's Executive Committee. This year, the budget materials were released in
early February, with the review materials made available to the Committee on or about February
18th. The Committee then met on February 26-27th, with formal review and approval by the
Executive Committee completed on April 15, 1998.
Generally, the Chair or another Member of the RSAC provides expert testimony to the
House Committee on Science during its annual budget hearings, which are normally scheduled
shortly after the release of the proposed budget. This years budget hearing was held on March
11, 1998 with Dr. Murarka testifying on behalf of the RSAC. In addition, Dr. Hopke, an RSAC
Member who holds a joint appointment with the SAB's Clean Air Scientific Advisory Committee
(CASAC), testified on behalf of the CASAC.
2.2	Charge to the Committee
During the review meeting, the Committee considered how well the proposed budget
request for FY1999: a) reflected priorities identified in the EPA and ORD Strategic Plans; b)
supported a reasonable balance in terms of attention to core research on multimedia capabilities
and issues and media-specific problem-driven topics; and c) balanced attention to near-term and
long-term research issues. In addition, the Committee offered its advice on: d) whether the
objectives of the research and development program can be achieved at the resource levels
requested; and e) how ORD can improve upon the GPRA structure to communicate research
plans, priorities, research requirements, and planned outcomes.
Responses to these questions, and others the Committee wishes to address, are provided
to both the Agency and the Congress.
2.3	Format of this Report
Following the Executive Summary and this Introduction, this report contains two principal
sections which cover the observations and conclusions of the Committee. Chapter 3 discusses the
Committee's overall observations on the budget process and review, and offers some general
comments. The specific responses to the questions in the Charge to the Committee are included
in Chapter 4.
3

-------
3. OVERVIEW OBSERVATIONS AND COMMENTS
The Research Strategies Advisory Committee (RSAC) last formally reviewed the Office of
Research and Development (ORD) budget for FY1995. At that review, the Committee had
difficulty evaluating the adequacy and appropriateness of the budget plan due to the complexities
in the accounting and reporting approach used by the Agency. In addition, the relationship
between the budget and ORD goals was not well defined. The Committee recommended
significant changes in the way that ORD planned research and reported the budget. In the current
review, the RSAC noted substantial improvements in EPA-ORD planning and budgeting and it
commends the Agency and the Office of Research and Development in making great strides.
Clearly, a significant reason that the Committee liked the budget presentation this year was that it
broke free from the media-specific format of previous years. The process developed by EPA and
ORD allowed a more functional presentation of the proposed budget and a clear rationale for the
funding levels requested for individual program elements.
Overall we had concerns regarding the adequate recognition and accounting for the key
research and science and technology activities being conducted by EPA outside of EPA's ORD.
There appear to be key activities ongoing in other parts of the Agency that are not captured in the
science and technology budget numbers. A science and technology budget was developed which
combined the ORD budget with Program Office laboratories. However, this does not account for
the program office activities that are directed at regulatory development. The Committee is aware
of the existence of "science for compliance" in program offices which also needs to be counted in
a true measure of the Agency's science and technology budget.
The FY1999 ORD and EPA budgets are the first goals-based research budgets put forth
by the Agency. The ORD budget represented a concerted effort to develop the requested funding
allocations around the ORD Strategic Plan. The plan and budget were developed in concert with
the program offices to develop goals consistent with customer needs. For the first time it is
possible to examine and evaluate how the money is allocated to various programs, to science and
technology activities and to various strategic goals. By presenting the requested fund allocations
in the framework of the goals previously established in the ORD Strategic Plan, the Agency, and
in turn, this committee could more clearly examine the relationship between the priorities
articulated in the plan and the budget. In later sections, the Committee comments on its
evaluation of the ORD and EPA requested science and technology allocations relative to each of
the specific strategic goals. Regardless of the comments to be made on the specifics of the budget
elements, the allocation mechanism was a clear improvement to the planning and review process.
ORD has established a process that allows for more transparent accounting and can be built upon
in the future for making allocation decisions in line with strategic goals and objectives. In later
sections the Committee recommends some changes to the reporting process that will aid in future
budget reviews as well as aid ORD's internal analysis of the budget.
The Committee notes the continued erosion of the ORD and Science and Technology
budget relative to the overall EPA budget request — if the FY1999 ORD requested funds are
allocated it will be the lowest in the 1990's when corrected for inflation. This erosion in ORD's
4

-------
and the Agency's science and technology funds occurs at the same time that the science involved
with environmental issues is ever more complex and challenging. For example: a) the range of
pollutants of interest to the Agency has been dramatically expanded with the passage of such
significant legislation as the 1990 Clean Air Act Amendments, the 1996 Safe Drinking Water Act
Amendments, and the 1996 Food Quality Protection Act; b) the need to address the levels of
impacts of pollutants known to occur at trace concentrations; c) ranges of mixture effects that
have been recognized; d) the need to more completely address ecosystem impacts as well as
susceptible human impacts; and e) the emerging environmental effects on which little is known
such as endocrine disruptors. In the face of scientific uncertainty, and the need to control low
levels of pollutants, EPA policy makers must make decisions balancing the potential for risk
against the potential for substantial economic impacts from the decisions. Thus, decisions have to
be made with potential for significant cost and benefit and must be done in the face of scientific
uncertainties. It appears to the Committee to be inconsistent to have a proportionately and
actually smaller science and technology budget in the face of the significance of the issues and the
associated scientific uncertainty.
The Committee is concerned that the Agency has not adequately demonstrated that this
proposed ORD budget is sufficient, in a number of areas, to sustain the appropriate level of
science and technology developments that the Agency needs to fulfill its mission to protect
human health and to safeguard the environment. It appears that the ORD has used its view of the
realities of budget constraints to limit their vision of what research and science and technology
activities they should be conducting. The ORD has developed its Strategic Plan and its goals and
objectives within the bounds of the perceived budgetary constraints. The perception of the
budget constraints appears to be driving the program planning and budget process and not the
actual scientific needs.
It is not clear to RSAC that the ORD and EPA have developed the vision of where they
should be going to fully support the science mission of the Agency. The Agency needs to build
on its strategic planning process to add an evaluation process which allows an assessment of
problems that should be addressed that will support EPA's overall mission as well as support
program office activities. It is important for EPA to develop this evaluation process so that it can
better account for existing efforts (intramural and extramural) and to better assess needs for new
research areas. In particular, the Committee concluded that goals may need to be expanded
particularly with respect to identifying and addressing emerging environmental problems. In
addition, the Committee concluded that the budgets proposed in several areas were not likely to
be sufficient to meet the goals established by the Agency and ORD in their Strategic Plans. These
areas included particulate matter, endocrine disruptors, ecosystem protection, global climate
change, waste site remediation technologies, microbial pathogens and indoor air.
The Committee frequently found it difficult to understand in detail how the budget for a
major research goal would be distributed among the subsidiary objectives and individual research
programs. For example, the Sound Science goal shows a budget of $50 million for the objective
of anticipating future risks (termed "emerging risk issues" in this report), but the materials
provided to the Committee do not show how it is allocated to the "One Atmosphere" program,
endocrine disruptors, or the other components of this objective. This lack of detail makes
5

-------
evaluating the adequacy of the budget difficult. In the future, ORD should provide sufficient
detail for such evaluations.
The EPA (and ORD) must coordinate and draw upon the resources of other agencies and
industry if it is to meet its overall mission of protecting human health and the environment. The
SAB has often recommended that the Agency place a priority on the building of appropriate
partnerships. The RSAC questions whether ORD has the capability to play a leadership role in
the environmental protection field and simultaneously develop a larger interagency and
government-industry interaction. There is significant power in leveraging funds and coordinating
activities with other organizations involved in environmental science and technology. In several
cases (e.g., the STAR (Science to Achieve Results) program involving requests for applications
developed jointly and funded with other agencies, and the PM monitoring program) partnerships
among EPA and other agencies and other private sector groups are being developed to leverage
and coordinate funds better to meet ORD goals. These partnerships should be highlighted
wherever possible in budget presentations to demonstrate EPA's initiative at seeking creative and
cost-effective ways of meeting its objectives. It was not clear in the budget information provided
to RSAC if the proper allocation of resources were being devoted to ORD coordination of
external research projects. The necessary resources include a travel budget that allows Agency
scientists to communicate and coordinate more effectively with other groups as well as the
allocation of researchers time to these important activities. In future budget presentations, RSAC
recommends that ORD provide information that would allow an evaluation of the adequacy of the
funding for coordination with organizations outside of EPA.
6

-------
4. RESPONSE TO THE CHARGE
4.1	Reflecting Priorities in the Strategic Plans
Charge Question: How well does the budget request reflect priorities identified in the
EPA and ORD Strategic Plans?
The RSAC completed its review of the FY1999 budget request recognizing the realities of
the ORD budget history and the program directions. The Committee compliments the Agency for
substantial improvements in the development and presentation of its budget in a goal-based
format. As a result, we find that the budget is aligned with the EPA and ORD strategic priorities.
The Agency has done a good job of justifying its budget requests on the basis of the research and
development needs for each of the strategic goals. The goal-based budget presentation is very
clear and easy to understand. The Committee observes that this budget has placed increased
emphasis on empowering people and global change goals. This budget also places highest priority
for clean air, clean and safe water, and sound science goals.
4.2	Balance Between Core Research and Problem Centered Research
Charge Question: How well does the budget request support a reasonable balance in
terms of attention to core research on multimedia capabilities and issues, and to
media-specific problem-driven topics?
It is appropriate that ORD should distribute its research resources to problem, program,
regional and user needs as well as to continuing more fundamental core research themes. Core
research activities can address multimedia issues, experimental designs, inter-agency cooperative
activities, and emerging issues as well as issues that have extended-term significance to the
Agency.
The National Research Council (NRC, 1997) has recently identified three important
components of "core environmental research":
a)	Investigation of the underlying processes that drive environmental systems,
b)	development and demonstration of innovative research tools, including
measurement techniques, models, and methods, and
c)	collection and dissemination of accurate long-term environmental data.
Under ORD's current budget request, for example, the Ecosystems Protection and Human
Health Risks objectives of the Sound Science Goal (core research) appear very consistent with the
NRC's core environmental research areas.
7

-------
The ORD indicated that in its FY1999 budget allocation, approximately 60 percent of
resources are dedicated to core research and approximately 40 percent is devoted to problem
research. This distribution was considered reasonable by the Committee. However, the
Committee notes that there is no correct ratio or "balance" in a given year between budgetary
allocations to these two activities beyond recognition of the need for both. For a specific budget
year the resources distributed to problem and core research should be directed by the ORD
Strategic Plan. This Plan, revised at minimum on a five-year cycle, should broadly define the
relative allocations appropriate for its plan horizon and strive toward equal allocation to both
themes over extended time.
It is also important for the Agency to build and maintain core competencies in critical
environmental science and technology areas in order to be prepared for both foreseeable and
unforeseeable environmental threats. Core competency includes both the facilities and the
personnel expertise. The current budget report does not allow the RSAC or the Agency to
examine the adequacy of the funding required to maintain the proper balance of core
competencies in critical core areas. The Committee recommends that ORD undertake a review of
the core competencies that it needs for the future to meet its long range mission. We believe that
ORD should review both its current core competencies and its core competencies that will be
substantially lost with the retirement of its aging personnel. The budget request should then
reflect the resources needed to develop and maintain the required range and levels of core
competencies.
4.3 Near-Term v. Long-Term Research
Charge Question: Does the proposed budget request balance attention to near-term
and to long-term research issues?
Most of the review materials focus on near term efforts. The core science program
addresses longer term activities, in particular in the area of emerging issues. The new activities
initiated to investigate the multiple pollutant impacts (e.g., One Atmosphere — see section
4.4.7c)) program is a good example of longer term research that could provide a sound basis for
future regulatory reform. In our view, more effort needs to be placed on identifying longer term,
proactive research agendas for EPA.
This charge focuses attention on a major problem in how we think about research issues.
In general, research plans contain some research needs that can be accomplished in a limited time
period and then ended. Other research areas may require five to ten years to provide significant
new information, but potentially can produce some useful results in the near-term as well.
Additionally, there may be some areas where there will not be short-term or intermediate results
that contribute to near-term policy decisions. Finally, there are programs that should not be
started until current research better defines the problem. Length of research programs should be
defined in the Strategic Plan and represented in the annual budgets. Too often emphasis has been
placed on programs that provide results in a time frame that is driven by regulatory schedules
rather than their value to obtaining the critical understanding that is needed to proceed wisely with
either more research or new regulations. Alternatively, it is better to think in terms of programs
8

-------
to be started now or started in the future and those that may or may not have intermediate results
as the program progresses.
In terms of the balance between long and short duration programs, the Committee did not
reach a conclusion concerning the current budget request because there is no indication of the
potential duration of the programs nor an indication of what is anticipated as results become
available. There is also no indication concerning how programs are evaluated for termination
when they have fulfilled their objectives. For major programs, we recommend that the five-year
time line provided in individual research plans be conveyed in the budget with an indication of
anticipated funding levels and major milestones. Within the limits of our review, the programs
only envisioned intermediate results and thus, certain types of research, such as long term
epidemiological studies, may be excluded. Such programs are likely to be important in certain
areas and thus, it appears that there is undue emphasis on programs with short term results.
4.4 Objectives of Research v. Available Resources
Charge Question: Can the objectives of the research and development program be
achieved at the resource levels requested?
In the summary of the FY1999 budget, the EPA identifies the ten strategic, long-term
goals from its Strategic Plan. These goals help to define the Agency's planning, budgeting,
analysis, and accountability process. Seven of the ten goals apply to ORD and are discussed
below: a) Clean Air; b) Clean and Safe Water; c) Preventing Pollution and Reducing Risk in
Communities, Homes, Workplaces and Ecosystems; d) Better Waste Management, Restoration of
Contaminated Waste Sites, and Emergency Response; e) Reduction of Global and Cross Border
Environmental Risks; f) Expansion of Americans' Right to Know about their Environment; and g)
Sound Science, Improved Understanding of Environmental Risk, and Greater Innovation to
Address Environmental Problems.
4.4.1 Strategic Goal: Clean Air
In this goal there is a major reduction in requested funding. Although the Committee
understands the Agency policy of not requesting continuation of earmarked funds that are
directed to specific organizations, it appears that in the case of the additional funding for
particulate matter (PM) research, the request to have the National Academy of Sciences prepare a
5-year research plan, and the results of the in-house research planning process including the
workshop held in November 1997, the Agency has not shown that there will be the resources
necessary for a research program that would produce a significant improvement in our
understanding of the ambient PM health effects. To delay the implementation of the plan that will
be delivered in the National Academy reports (due in March and November 1998) until the
FY2000 budget represents an undesirable delay in the study of what is described by EPA to be the
most serious ambient air quality threat to public health and which will be extremely costly to
implement. It could be reasonably anticipated that more than the base resources with a small
increment will be needed in FY1999 to continue the program being initiated with the FY1998 PM
9

-------
funds that Congress has allocated for this purpose. See also the report of the Clean Air Scientific
Advisory Committee (CASAC) on PM research needs (SAB, 1997a).
Part of the ORD air budget deals with the development of MODELS-3. The usefulness of
this modeling tool depends on the adequacy of emissions inventories used by the modeling
system. The extent to which other areas outside of ORD in EPA are addressing this concern
should be noted.
Although it was EPA's desire to emphasize the implementation of the new PM and ozone
(03) standards, it would make more sense to put the continuing costs of preparing criteria
documents such as the one for carbon monoxide (CO) in this budget category rather than putting
it under Emerging Issues. Since the law requires a regular cycle of criteria documents, it would
make more sense to set aside a place for the continued funding of this review effort under the
Clean Air Goal.
4.4.2	Strategic Goal: Clean and Safe Water
The water research agenda focuses on the immediate research needs for the
implementation of regulatory approaches under the Safe Drinking Water Act. Other objectives
are designed to provide information to better conserve and enhance the ecological health of the
nation's waters and aquatic ecosystems. The objectives recognize the most critical needs and are
highly focused, which should allow them to be achieved with the resources requested.
The Agency has made major efforts in adapting the risk paradigm to better focus its
research agenda. Resources have been committed to develop and address critical needs in
chemical and ecological risk assessment. The same commitment is needed to develop a microbial
risk assessment paradigm that addresses multimedia exposure to pathogenic microorganisms.
This is critical to address emerging pathogens in our water and food supplies. Specific research
monies are needed to develop this paradigm so that these threats can be better identified and
research objectives and regulatory needs better focused. Current efforts are only designed to
address drinking water regulatory needs in controlling microbial pathogens. This effort should be
expanded to address issues such as recreational water quality, aerosol exposures, contaminated
sediments, and pesticide efficacy. These microbial pathogen issues represent a research gap that
has not been addressed by any agency.
4.4.3	Strategic Goal: Safe Communities
ORD proposes to devote $12 million to the goal of ensuring safe communities, homes,
work places, and ecosystems. Of the research areas described in its Budget Plan, the substantial
majority are categorized as increasing the use of safer or "greener" chemicals in commerce.
However, the specific research topics are poorly related to that goal. While they may be valuable
endeavors for achieving the overall goals of the Agency, it is difficult to evaluate the adequacy of
the budget to achieve the stated goals. A much smaller budget ($2 million) is devoted to research
on the human health risks of indoor air contaminants, which do seem relevant to the stated
objective of increasing the indoor air quality for 15 million more Americans than in 1994.
10

-------
Although the budget request appears adequate to conduct the specific programs identified here, it
is less certain that this budget is sufficient to address the overall problem of indoor air quality. On
this same topic, it is possible that the balance between programs in indoor and ambient air is not
optimal when their respective risk profiles are considered.
4.4.4	Strategic Goal: Safe Waste Management
The FY1999 budget request funds research under the Superfund Innovative Technology
Evaluation (SITE), the Hazardous Waste Identification Rule (HWIR), and soil and groundwater
remediation topics. It appears that the resources requested for this goal are adequate to achieve
the results highlighted in the ORD Strategic Plan.
The Environmental Engineering Committee (EEC) of the Science Advisory Board (SAB)
recently completed an in-depth review of the Waste Research Plan for EPA (SAB, 1998). The
major findings of this review indicated that the overall planning process and the prioritization of
research issues are appropriate and important. However, the waste research plan can be improved
by capturing and documenting the decision process more completely and increasing the flexibility
of the process to add or delete research topics depending on the emerging needs. The SAB/EEC
review also recommended that ORD establish linkages between the waste research strategy and
parallel efforts within and outside the Agency.
4.4.5	Strategic Goal: Global Environmental Risk Reduction
The ORD global climate budget appears to be only a small part of the overall EPA global
climate initiative budget. Given the current importance of global climate change and the size of
the overall Global Change Technology Initiative budget, it is important to better document how
other areas within EPA are addressing critical research-related issues currently not covered within
the ORD budget.
4.4.6	Strategic Goal: Environmental Right to Know
The RSAC endorses the emphasis on the EMPACT (the President's Environmental
Monitoring for Public Access and Community Tracking) program, which is aimed at working
directly with metropolitan areas to make information relevant and available to the public. Because
the effort is expected to produce new processes for communication and data development and
distribution, it is appropriately placed in ORD.
The Toxic Release Inventory (TRI) has been one of EPA's success stories. Using the TRI
has expanded EPA's ability to empower people with information they need to make educated
decisions and choices to protect their health. Information such as this also provides tools and
guidance for those charged with protecting local, regional, and statewide public health. The
RSAC concludes that the budget increment here is adequate to test the effectiveness of
EMPACT.
11

-------
4.4.7 Strategic Goal: Sound Science
This goal included four major objectives: ecosystem protection, human health risks,
emerging risk issues and pollution prevention.
a)	Ecosystem Protection - ORD's ecological resource research activities presently
emphasize the Environmental Monitoring and Assessment Program (EMAP),
development of stressor/response models, ecosystem assessment methods and
ecosystem restoration technologies. In recognition of the value of these research
themes, the importance of ecological resources to human societies, and the
importance of EPA's need to distribute its activities on both human health and
ecosystem health protection, RSAC was concerned to see a reduction in budget
allocation in FY1999 relative to past fiscal years.
The ORD Strategic Plan, the reorganized EMAP, and new STAR initiative all
provide exciting research opportunities in the ecological resource area. The
Committee is concerned about the reduction in the momentum of these efforts by
imposing a budget reduction.
Part of the reduction will be accompanied by establishing fewer "index sites" in
National Parks under the new EMAP initiative. Reducing the number of index
sites in National Parks is appropriate as many forms of research activities are
excluded from National Park facilities. For nationwide representation, however,
index sites need to be increased rather than reduced and they need to be located in
facilities fully supportive of manipulative as well as descriptive research activities.
Index sites should be expanded to include some long-term ecological research sites
supported by the National Science Foundation (NSF). The SAB's Ecological
Processes and Effects Committee (EPEC) has provided similar comments on index
sites (SAB, 1997b).
b)	Human Health Risks - Under this objective, ORD proposes to conduct research
programs in multimedia/multipathway exposure models, mechanistic dose-
response models, and susceptible populations. Although these program areas are
quite broad, the budget request for $48 million seems adequate to make good
progress during FY1999. The multimedia/multipathway residential exposure
model is relevant to indoor air issues as well as (for example) household pesticides
or consumer products. Mechanistic models for dose-response are sorely needed to
replace default assumptions. While this effort will require ongoing attention over
many years, the FY1999 budget should enable good progress on key
environmental agents. ORD should continue its attention to investigating first
those mechanisms and agents where uncertainties most limit decisions on the need
for and severity of control measures.
c)	Emerging Risk Issues - Within the objectives of emerging issues there are two
components: "One Atmosphere" and "Endocrine Disruptors". The Committee
12

-------
commends the Agency for setting aside resources in order to explore emerging
issues. However, at this time, there is no clearly defined process by which such
issues are identified. Among other methods, the Exploratory Research Program
could be helpful in identifying and initiating research in new areas that may emerge
in the future. Thus, a focus on high risk, high reward research may provide a
major payback. A consideration of this possibility may require an additional
increment to provide the basis for truly exploratory projects.
1)	One Atmosphere - The initiation of a program to examine the combined
interactions of multiple species in the atmosphere is an important step forward. In
the latest PM criteria document review, it was recognized that, although the
strongest effects that could be extracted from the data were due to PM2 5, there
were statistically significant effects of other criteria pollutants. There are species
that are important to both the formation of 03 and PM2 5. There are many other
examples of where the broader examination of the atmosphere is essential to really
define and resolve the issues. Thus, the start of a program examining the
atmosphere in a holistic fashion is a valuable research initiative.
2)	Endocrine Disruptors - The 1996 Safe Drinking Water Act Amendments and
the 1996 Food Quality Protection Act require EPA to provide a set of screens and
tests for compounds that could be found in drinking water or food that are
estrogenic or may have other effects on the endocrine system. In light of these
requirements, RSAC questions whether the FY1999 allocation for endocrine
disruption research is adequate. To date, there are no approved or validated
screening methods or assays to thoroughly analyze the testing requirements of the
Acts. In essence, the policy is far ahead of the science in this case. For example,
the Agency has until August 1998 to produce a set of screens and assays that will
have passed peer review (by the Science Advisory Board or the Federal
Insecticide, Fungicide and Rodenticide Act (FIFRA) Scientific Advisory Panel -
two commonly used Agency Federal Advisory committees) for an interim trial
program using 24 chemicals. This program must be implemented in fiscal year
1999, and by the year 2000, EPA must have evaluated the program and report
back to Congress. The budget as presented does not provide enough specific
information for the Committee to evaluate where current dollars are allocated or
what is in the longer term research agenda to address endocrine disruption. Of the
four areas under endocrine disruptors one is devoted to the topic of integrating
field studies of human/wildlife populations.
d) Pollution Prevention - The focus and the related effort in Safe Wastes is not well
articulated and the Committee had difficulty in fully understanding the differences
in what was to be supported under these different goals. See also the Science
Advisory Board report on pollution prevention (SAB, 1998b).
13

-------
4.5 Improvements to GPRA Structure
Charge Question: How can ORD improve upon the GPRA structure to communicate
research plans, priorities, research requirements, and planned outcomes?
EPA should be commended on its development of a goal-based budget and planning
process. The process is much easier to interpret and review and also provides a solid basis for
identifying EPA program interconnections within EPA. RSAC strongly recommends that EPA
now take the next important step in its strategic planning — the development and implementation
of an evaluation process for determining program effectiveness. This evaluation process will help
justify budget decisions and help identify where changes are needed. It will also need to reflect
the relationships between ORD and other Agency functions.
It would also be valuable to have an indication of how the present year fits into the flow of
the research program funding by providing an indication of what the past year's funding was for
each goal and the anticipated direction of funding (more, less, the same) for the next three years.
Since most environmental problems are complex, it will take time to develop a real scientific basis
for solutions. The continuity or lack thereof from year to year is an area that RSAC should
comment on and thus, the Committee needs the data on which to base their review.
EPA needs to develop a set of criteria for success of research in ORD, whether it is done
intramurally or extramurally. These criteria should include measures of the quality of the science
(e.g., as indicated in peer reviewed journal papers) and the relevancy of the research to policy
decisions that the Program Offices are required to make and the determination of the relative
importance of emerging environmental issues and concerns. These criteria can then be
incorporated into a process of reevaluation of research goals as they evolve over time to
determine the continuing need for a particular research program and its potential value for
informing the regulatory mission of the Agency.
In developing the criteria, we also recommend that the evaluation be results, not process,
oriented. Criteria should focus on measures that relate to products that inform policy makers. A
full set of criteria forjudging the value of both long term and short term problem-focused research
need to be developed. Similarly, criteria forjudging both required and anticipatory research need
to be included.
14

-------
REFERENCES CITED
NRC. 1997. Building a Foundation for Sound Environmental Decisions. National Research
Council. National Academy Press, Washington, DC, 87 pp.
SAB. 1997a. Evaluation of Research Needs for the Particulate Matter National Ambient Air
Quality Standards (NAAQS). Clean Air Scientific Advisory Committee, Science Advisory
Board, US EPA, Washington, DC. EPA-SAB-CASAC-LTR-97-004, March 12, 1997.
SAB. 1997b. An SAB Report: Evaluation of the Environmental Monitoring and Assessment
Program (EMAP) Research Strategy and Research Plan. Ecological Processes and
Effects Committee, Science Advisory Board, US EPA, Washington, DC. EPA-SAB-
EPEC-97-009, September 30, 1997.
SAB. 1998a. A Review of the Waste Research Strategy of the Office of Research and
Development. Environmental Engineering Committee, Science Advisory Board, US EPA,
Washington, DC. EPA-SAB-EEC-98-005, February 27, 1998.
SAB. 1998b. "Pollution Prevention Review" - Environmental Engineering Committee, Science
Advisory Board, US EPA, Washington, DC. Draft Report in Progress.
R- 1

-------
DISTRIBUTION LIST
Administrator
Deputy Administrator
Assistant Administrators
Deputy Assistant Administrator for Science, ORD
Director, Office of Science Policy, ORD
EPA Regional Administrators
EPA Laboratory Directors
EPA Headquarters Library
EPA Regional Libraries
EPA Laboratory Libraries
Library of Congress
National Technical Information Service
Congressional Research Service

-------
United States
Environmental
Protection Agency
Science Advisory
Board (1400)
Washington, DC
EPA-SAB-RSAC-98-006
April 1998
SEPAAN SAB REPORT: REVIEW
OF THE FY1999
PRESIDENTIAL BUDGET
REQUEST FOR THE OFFICE
OF RESEARCH AND
DEVELOPMENT (ORD)
A REVIEW BY THE RESEARCH
STRATEGIES ADVISORY
COMMITTEE (RSAC) OF THE
SCIENCE ADVISORY BOARD

-------