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Draft of January 18, 2007
The Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Subject: Science Advisory Board (SAB) Report on the Office of Research
and Development's (ORD) Sustainability Research Strategy and
the Science and Technology for Sustainability Multiyear Plan
Dear Administrator Johnson:
At the request of the Office of Research and Development (ORD), the SAB
recently reviewed ORD's Sustainability Research Strategy (Strategy) and the related
Science and Technology for Sustainability Multiyear Plan (Plan).
The SAB's Environmental Engineering Committee, augmented with other SAB
members for this advisory, strongly endorses the Agency's proposal to establish a
research program on environmental sustainability because such a program will improve
the scientific foundation for a sustainable environment. Historically, environmental
protection at the Agency has been carried out in single-media regulatory programs. The
Committee applauds the Agency's steady movement towards a systems approach that
reflects the complexity of the world in which we live and effectively balances
environmental protection, economic viability and societal interests.
The Strategy, which emphasizes interdisciplinary approaches to environmental
protection, provides an effective road map for the transition of the Agency's Pollution
Prevention and New Technologies program to the new Science and Technology for
Sustainability program. The Strategy identifies research that will support risk-based
environmental protection decisions without compromising society's economic or social
development goals.
The Plan, which describes the Agency's proposed sustainability research and
technical activities, describes the right focus that points the Agency in the right direction
to achieve sustainability. However, more financial support and identification and
reallocation of the right resources is needed for all the short and long-term outcomes to
be achieved in the five-year time frame specified.
The Committee supports the systems-based approach to environmental
decision-making that is central to the sustainability paradigm. Success of this program
will require the development of a workforce with training and skills related to
sustainability. The Committee encourages the Agency to establish creative human
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resource programs that will develop and foster the requisite sustainability expertise
within the Agency's current workforce, and that will effectively target uniquely trained
individuals from outside the Agency.
To be effective, a sustainability-centered workforce must be supported by a
management structure that appreciates the value of a systems approach to
environmental issues and has the skills to facilitate its adoption. The Committee
encourages Senior Agency management to re-examine the current lines of authority
and accountability within the Agency hierarchy to identify and remove any structural
impediments that could adversely affect decision-making supported by the sustainability
paradigm.
The Plan and Strategy call for the integration of sustainability research
throughout the Agency's research programs. The modest funding of the program limits
what can be achieved during the five-year time period of the Plan. The Committee is
disappointed at the modest level of budgetary support allocated to the Plan. This
limitation suggests that sustainability-focused research programs are not a priority for
the Agency. A substantially higher commitment is needed to have a serious impact on
internal research priorities, managerial buy-in, and program visibility and growth.
This research program provides the Agency with an opportunity to promote and
coordinate sustainability-focused research activities across the federal government and
with private sector partners as well. Other government agencies (both national and
international), commercial industry and many non-governmental organizations and
private citizens have already endorsed and adopted environmental sustainability as a
framework for environmental management. The Agency's sustainability research can
provide a scientific foundation for environmental decisions at EPA, in other federal
agencies, and in the private sector.
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Thank you for the opportunity to provide advice on this important and timely
topic. The Committee applauds the Agency's leadership in advancing the scientific
foundation for environmental sustainability. The Committee would also like to
acknowledge its pleasure in working with a very dedicated, knowledgeable and
responsive ORD staff. Please feel free to contact us if you have any questions
concerning this review.
Sincerely,
Dr. Granger Morgan, Chair
EPA Science Advisory Board
Dr. Michael J. McFarland, Chair
Environmental Engineering
Committee
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NOTICE
This report has been written as part of the activities of the EPA 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 the 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. Reports of the EPA Science Advisory Board are posted on the EPA website at
http://www.epa.gov/sab.
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U.S. Environmental Protection Agency
Science Advisory Board
Environmental Engineering Committee Augmented for Sustainability
Advisory
CHAIR
Dr. Michael J. McFarland, Utah State University, Logan, UT
ENVIRONMENTAL ENGINEERING COMMITTEE MEMBERS
Dr. Viney Aneja, North Carolina State University, Raleigh, NC
Dr. David A. Dzombak, Carnegie Mellon University, Pittsburgh, PA
Dr. T. Taylor Eighmy, University of New Hampshire, Durham, NH
Dr. Catherine Koshland, University of California, Berkeley, Berkeley, CA
Dr. Reid Lifset, Yale University, New Haven, CT
Dr. Mark Rood, University of Illinois, Urbana, IL
Dr. John R. Smith, Alcoa Inc., Alcoa Center, PA
OTHER SAB MEMBERS
Dr. Anna Alberini, University of Maryland, College Park, MD
(Environmental Economics Advisory Committee)
Dr. William Mitsch, The Ohio State University, Columbus, OH
(Ecological Processes and Effects Committee)
Mr. David Rejeski, Woodrow Wilson International Center for Scholars, Washington, DC
(chartered Science Advisory Board)
Dr. Thomas L. Theis, University of Illinois at Chicago, Chicago, IL
(chartered Science Advisory Board)
Dr. Valerie Thomas, Georgia Institute of Technology, Atlanta, GA
(chartered Science Advisory Board)
SCIENCE ADVISORY BOARD STAFF
Ms. Kathleen White, Washington, DC
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1 Table of Contents
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Executive Summary
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Responses to Charge Questions on the Strategy
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Responses to Charge Questions on the Plan
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Additional Advice
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1. Executive Summary
The SAB Environmental Engineering Committee, augmented with other SAB members,
was in unanimous agreement that, together, the Strategy and Plan form an excellent
first step in the Agency's transition from the historical single media or "stovepipe"
approach to environmental protection to a systems approach that continues to focus on
and achieve environmental protection. The Strategy, which basically describes a
research framework for addressing the technical, social and economic complexity of
current and emerging environmental protection issues, constitutes a new paradigm that
explicitly embraces the application of life-cycle principles in support of short and long-
term risk management decisions.
Accompanying the Strategy is the Agency's sustainability Plan, which describes the
specific research and technical activities proposed by the Agency that will support future
sustainability-focused environmental decision-making. The Committee fully endorses
the Plan as the blueprint for the Agency to achieve both its short and long term
sustainability outcomes. However, the Committee also recognizes that ensuring
successful sustainability outcomes depends on the Agency's ability to commit sufficient
resources to support the development, dissemination and application of new
environmental monitoring and assessment technology as well as the design and
implementation of suitable sustainability metrics and indicators. The Committee is
confident that full implementation of the sustainability Plan will generate vital scientific
and technical information that will enable Agency decision-makers to better address
both present and emerging environmental issues.
The Committee strongly supports the Agency's decision to establish a sustainability
research program to address the multifaceted nature of current and emerging
environmental problems. The Committee applauds the Agency's determination to look
beyond the media-specific regulatory model to explore a more integrative approach to
environmental protection that is cognizant of the economic and social impacts of
environmental decision-making. Environmental protection decisions that also support
the economic and social well being of future generations is of paramount importance to
Agency decision-makers and the Strategy clearly establishes the path for achieving that
goal.
Similarly, given the expanding technical and social science based information needed to
support sustainability-focused environmental decisions, internal restructuring of the
Agency's current programs is required to manage and direct data collection and
processing. To this end, the Committee acknowledges that the Strategy provides a
clear road map for facilitating the Agency's transition from the Pollution Prevention and
New Technology (PPNT) program to the Technology for Sustainable Outcomes
program.
Of particular importance to achieving broad Agency adoption of the sustainability
paradigm is the creation and deployment of a technical workforce effectively trained in
the practical application of environmental sustainability concepts and methods. The
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Committee encourages ORD to work with senior Agency management to establish and
reinforce the institutional changes necessary to foster a greater understanding and
appreciation for the economic and societal benefits of sustainability-centered
environmental protection.
The Committee strongly supports the Agency's decision to advance environmental
stewardship and collaborative problem solving as a means to achieve measurable,
sustainable outcomes. The Committee applauds the Agency's progression from
pollution control to pollution prevention to sustainability.
Because of the Agency's international reputation as a scientifically credible steward of
environmental protection, the Committee strongly encourages the Agency to assume a
more substantive and visible role in conducting and disseminating results of
sustainability research. Other government agencies (both national and international),
commercial industry and a myriad of non-governmental organizations and private
citizens have endorsed environmental sustainability. Moreover, as global recognition of
the economic and societal impacts on environmental decision-making increases, the
interdisciplinary approach to solving environmental issues endorsed by the Strategy and
Plan elevates the Agency's environmental stewardship profile. EPA's scientific
capability can be of great value to the sustainability concepts for environmental
management. By providing a scientific foundation for sustainability approaches, EPA
provides a sound basis for its own sustainability programs and for those of others .
1. The Committee recommends that the Agency better define those terms
associated with the sustainability strategy and the measurement of sustainability
outcomes.
To minimize the confusion and ambiguity for the targeted audience of both the Strategy
and the Plan, the Committee encourages the Agency to define more clearly what is
meant by the term sustainability. Both documents would benefit from explicit
acknowledgement of the competing definitions of sustainability, thereby providing a
context for the Agency's choice among the various definitions of this term and
recognition of alternative views of this contested and often nebulous topic.
2. The Committee supports application of sustainability principles to address and
resolve specific, multi-faceted environmental problems.
The Committee acknowledges that the judicious selection of research projects within
the Plan will help to facilitate the diffusion and adoption of the sustainability paradigm
both within and outside the Agency. To ensure a successful Agency transition from the
traditional media-specific "stove pipe" approach to a more integrated systems approach
to environmental protection requires that the sustainability research activities be
scientifically compelling and have wide national visibility. Moreover, the sustainability
research products should strategically integrate into the Agency's other 16 multi-year
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plans and provide the technical focus that guides the sustainability research activities
conducted by other federal agencies.
The Agency should be prepared to undertake some "higher risk - higher payoff"
projects, i.e., projects that because of complexity, data requirements, methodological
novelty, and interdisciplinary focus may be difficult to carry out successfully, but would
have a large impact if they are indeed developed successfully. The project portfolio
should also balance targeted Agency needs and geography. The project portfolio
should become the basis for articulating the relationship between projects and products
for the annual performance measures (APM) and annual performance goals (APG)
described in the Plan.
3. To encourage broad adoption and implementation of sustainability-based
approaches to environmental protection across the EPA, the Committee strongly
urges the Agency to be creative and strategic in developing its human resources
programs.
If the Agency is serious about sustainability, it should have the right skill set to
implement it and have champions positioned throughout the Agency. If the Agency is to
pursue the critical social dimensions of sustainability, it needs to employ individuals with
backgrounds beyond the physical sciences, engineering and economics. Stronger
social science expertise is needed in fields such as anthropology for ethnographic
assessments (how individuals, households and communities think, behave and interact
with products, technologies and natural systems), psychology (behavioral economics),
and decision theory.
4. The Committee encourages the Agency to enhance the diffusion of environmental
sustainability principles and practices within and outside the Agency
The Plan correctly points out that, as the value of the ORD sustainability program
becomes recognized, other program directors and offices will understand the value of its
attributes, goals, and metrics, and become active in seeking out collaborative projects.
This research program gives the Agency opportunities to define environmental
sustainability both internally and externally and to promote the use of related research
products.
To assume a leadership role in promoting the economic and societal benefits of the
sustainability paradigm, a true systems approach will be needed. This means involving
personnel from many different areas including different Agency program offices,
regional offices and other federal agencies (e.g., Department of Defense, Department of
Energy, Department of Agriculture, etc.), local environmental groups, private industry
and other community stakeholders.
ORD could further solidify its leadership role in promoting sustainability-based
environmental decision-making by developing greater capacity in sustainability
research. This could be achieved through a combination of: hiring new personnel with
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training in sustainability research, establishing incentives for existing personnel to apply
their technical expertise in support of the sustainability paradigm, pioneering new
models of cooperative research with industry and development of sustainability "think-
tanks" within the Agency.
5. Support for sustainability is widespread. Both sound science and senior
management support can further the paradigm..
While not universally accepted as the sole approach to environmental protection,
support for sustainability, as both a goal and a means of approaching decisions, is
widespread. The concept and practice of sustainability now permeates the Agency and
many other institutions. Both a strong scientific base and the overt support of EPA
management can promote wider implementation of the sustainability paradigm. These
activities are mutually enhancing as well. Sound science provides a basis for support
by senior management and senior management can advocate for the resources with
which to further strengthen the science base.
6. The Committee recommends that the Agency make judicious use of targeted
collaborations with other federal agencies as well as the private sector.
The Agency's research budget for this Plan is small. There are benefits to seeking
opportunities to collaborate with others to leverage funds to meet goals. There is also a
risk that the research program could be diluted by demands for time and resources.
The key is pursuing the right opportunities. If resources allow, the field as a whole
would benefit from the Agency providing overall leadership and focused coordination to
these external entities because none presently exists.
The responses to the specific Sustainability Research Strategy Charge Questions are
briefly summarized here.
S1. Does the SAB agree with the central premise of the Strategy that sustainability is
all about decision making and that ORD research support should aim to inform and
allow decision makers at all levels of government and in the private sector to choose
courses of action that will lead to achieving sustainable outcomes?
The Committee does not agree with the central premise that sustainability is "all about
decision making" and "aiming to inform." The Sustainability Strategy document is a
careful and thoughtful effort to capture the opportunity to implement an important
paradigm shift across much of the Agency's jurisdiction.
The Strategy will serve as an important companion document to the Plan as the
sustainability paradigm is adopted within the Agency. It will also be important as the
Agency works externally with other Federal agencies and stakeholders across the
nation. Rather than simply focusing on decision-making and the use of sustainability-
based research to inform decision-makers (albeit critically important), the Committee
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offers the following expansive view of the programmatic needs of the sustainability
Strategy:
1. Agency-sponsored core research focused on sustainability science is
needed.
2. Public stakeholders are part of the cultural aspect of responding to and
implementing sustainability at the local level and should be explicitly
acknowledged within the Sustainability Strategy.
3. The definition of sustainability may benefit from additional interpretation.
The research portfolio would be more compelling if ORD were more explicit
about the interdependence of the three pillars of sustainability (environment,
social aspects and the economy).
4. ORD needs to explicitly promote and integrate a life-cycle approach to
environmental protection decision-making within the Sustainability Strategy that
goes beyond simply generating information and furnishing it to decision makers.
The life-cycle approach would support the need for behavioral change and
outcome measurement over time.
S2. Does the strategy make a compelling case for ORD and EPA that Sustainability
Research is a priority for ORD?
The Committee agreed with the case made in the Strategy that a systems view is
needed in order to address environmental problems and that a sustainability framework
encompasses a systems approach. Allocation of resources, on the other hand, does not
indicate that Sustainability Research is a priority for ORD. The level of Agency
resources currently allocated to support sustainability research is woefully inadequate
for a meaningful scientific research program. Further, if the resources allocated to the
Sustainability Research Strategy reflect Agency priority setting, then sustainability
research does not currently appear to be a priority within ORD.
S3. Does the strategy focus on priority national issues and identify the right research
questions?
The Strategy is cross-media. The areas and questions outlined are quite
comprehensive, and expand upon the initial themes. Nevertheless the Committee is
concerned that insufficient attention is devoted to certain issues (such as climate
change research), the interface of social science and economics research with chemical
and /biological research, and the difficulty of developing a meaningful suite of
sustainability metrics.
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54. Does the strategy identify the right implementing steps to address research
questions and achieve sustainable outcomes (Advance technology, develop tools
and approaches, advance systems research and disseminate and apply results.)
As the discussion of implementation progresses, the specificity of the Strategy
decreases as does ORD's control over the outcomes. The Strategy should
acknowledge increasing resource demands tied to coordination with multiple entities.
Neither the Strategy nor the Plan specify how the Agency will identify and pursue future
research opportunities, what resources will be used, or how success might be
evaluated. Finally, it is unclear what happens to the Agency's focus on pollution
prevention. Prevention has been an important part of the EPA message for over 15
years and one that resonates with the public, NGO community and industry.
55. Does the strategy adequately and correctly connect to policy and/or decision-
makers inside and outside EPA for achieving desired sustainability outcomes?
Policy and decision-making are two different, but related, aspects of the problem.
Decision-making depends on the way policy is implemented and requires that
appropriate incentives (i.e. policy tools) be established. The Strategy focuses on
activities, offices, and regions within EPA, and coordination among these entities.
There is limited discussion of connections to and collaborations with decision-makers
and organizations outside of EPA. The Strategy does connect to EPA decision-makers
by arguing that environmental sustainability research is important and appropriate for
ORD as well as by seeking to negotiate with other EPA program managers and
decision-makers about the content and future of sustainability research at EPA.
56. Does the Strategy enable ORD to prioritize its research investments? Does the
Strategy define an appropriate role for EPA relative to other funding agencies?
Does it sufficiently encourage other Federal agencies and organizations to relate
their sustainability efforts to EPA's so as to promote co-funding and/or
collaboration where appropriate?
The Strategy document clearly states that it is up to the individual multi-year plans and
to the National Program Directors to identify their priority sustainability research areas
and presents criteria for setting priorities that are consistent with those found in the
Strategy. Moreover, the Strategy emphasizes that each individual multi-year plan
should develop a balanced research portfolio with a good mix of short-term and long-
term projects, known and emerging issues, projects that are traditionally central to
EPA's mission and others that are more on the boundaries (e.g. agriculture and aquatic
species.
The Committee had mixed reactions to this agenda and criteria for setting priorities.
Recognizing both the importance to ORD of establishing a scientifically credible
presence in sustainability-based research and the reality of limited budgetary resources,
the Committee recommends a two-pronged approach that (i) pursues core research on
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sustainability and sustainability metrics, and (ii) establishes a small number of
demonstration projects that would give ORD high visibility in the sustainability arena.
57. Does the Strategy outline an adequate roadmap for ORD to implement this
program (P2 transition to Sustainable Technology, coordination among NPD and
across existing multi-year plans, leveraging interagency cooperation, and
defining emerging research areas?)
The Strategy lists specific projects and programs with a sustainability emphasis or focus
in other agencies. It also identifies other federal agencies with overlapping interests for
each of the six broad research themes, as well as international partners. Despite these
lists, however, and EPA's acute awareness of other nations' focus and recent advances
on sustainability matters, the discussion and the information offered is too cursory to
allow the Committee to judge whether these other agencies have sufficient incentive to
establish partnerships with EPA and promote co-funding and collaborations.
58. Does the SAB believe that sustainability research is a sufficiently strong concept
for integrating and coordinating across ORD research programs?
From a science perspective, sustainability is a strong concept that has value in
integrating and coordinating sustainability-based activities across ORD research
programs. However, there are inherent obstacles and historical impediments to such
change. The SAB recommends the Administrator and senior leadership consider a
variety of approaches to ensuring the success of the implementation of this Strategy
throughout the Agency's research program.
The responses to the Multi-Year Plan Charge Questions are briefly summarized here.
P1. Does the organization of the new Sustainability Technology Plan provide a clear
logical framework for implementing an element of the overall Sustainability
Strategy? Does the Plan follow appropriately from the Sustainability Research
Strategy? Are the research issues identified in the Plan consistent with the
research questions identified within the Sustainability Research Strategy?
The Plan provides a clear and logical framework for implementing an element of the overall
Strategy. Within the context of limited resources, the Plan identifies a set of issues that are
consistent with the Sustainability Research Strategy and current ORD capabilities.
The criteria for project selection should be reviewed to ensure that they are appropriate for
identifying those research activities that will more effectively support the Strategy.
The Committee is largely satisfied with the content of the Plan through Chapter 4. The
Committee did engage in extensive discussion about Chapter 5, which presents the
specifics of the planned research program. The Committee's comments are included
later in this document.
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P2. For each major research track addressed within the Plan (e.g., Decision Support
Tools, Education, Technologies, Systems, and Metrics/Indicators), do the Annual
Performance Goals (APGs) and Annual Performance Measures (APMs)
represent a logical progression of activities and intended outcomes? Does the
Plan identify the specific issues motivating the research program?
Within each major research goal related to metrics, tools and technologies, the
respective annual program goals and measures represent a logical progression of
activities and intended outcomes.
However, the long-term goals themselves should be re-ordered. A more logical
progression is:
1. Develop the appropriate metrics
2. Develop any decision support tools required for analysis (keep this systems
based if possible and linked to metrics).
3. Investigate technological options to reach the goal and try to get the technologies
in place (SBIR grants, performance incentives...).
Recognizing the budgetary constraints and the desire to achieve high profile measures
of success, the Agency might consider selecting one or two key demonstration projects
that are focused on a real and current sustainability issues. To the extent practicable,
the projects should support sustainability metrics development, development and
application of sustainability decision support tools and sustainability technology
development and demonstration. The actual projects identified should have a major
impact for the municipality, region, or even industry that is affected with the information
gained easily transferred to other entities.
P3. Does the Plan lay out a balanced program addressing both short-term and
longer-term research that meets current needs while positioning the Agency to
respond to emerging issues?
The Committee is convinced that the most pressing need is for short term successes to
gain further support for the research program. Looking at the longer term, the
Committee is persuaded the program should have the capability to detect emerging
problems and inform the Agency. A prescriptive numerical balance, in dollars, work
years, number of projects, variety of disciplines is not recommended
P4. Do the long-term goals address the high-priority science, engineering, and
technology needs of users that will help the Agency meet its strategic goals relating to
sustainability? Do the long-term goals clearly relate to the research tracks within the
Plan framework? Do they provide a picture of what the program is trying to achieve?
Will the proposed research activities lead to progress towards these goals? Are the
goals appropriately linked to long-term environmental outcomes?
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Addressing the longer term outputs and outcomes of the program is important because
ORD research has historically been focused on shorter term needs. The Plan explains
clearly the linkages of the annual performance goals to the long-term goals and the
long-term goals to the Strategy. However, it is not clear whether these long-term goals
will significantly advance sustainable approaches to management and address specific
sustainability challenges. The weakest part of the Plan is the integration between the
long-term goals and long-term environmental outcomes. The outcomes, while
measurable, are not scientifically compelling nor are they focused on achieving goals
through the application of sustainability principles. A tenuous link between sustainability
goals and outcomes leaves the Plan vulnerable to claims that ORD is retreating to the
historical single-media "stove pipe" approach to environmental protection.
While the development of new, more sustainable technologies is usually best left to the
private sector, the Agency has a critical role to play in certifying and evaluating data and
making it available to the sustainability community. Furthermore, the Agency is
encouraged to engage in research that is specifically focused on developing incentives
for private companies to invest in and adopt new technologies.
The Plan alludes to but does not explicitly develop the Agency's role in conducting
"regular and continuous assessments of environmental trends". If indeed the Agency
assumes this role, and makes such assessments available to the public, then it will be
performing a valuable service that can enable decision makers at all levels to respond
to both emerging as well as legacy environmental issues.
P5. Are the research products supportive of the strategic target as set forth in the
Agency's Strategic Plan under Objective 5.4?
Objective 5.4 of the Agency's Plan focuses on enhancing society's capacity for
sustainability through science and research. The long-term goals support this strategic
target by establishing sustainability metrics, creating decision-support tools, and
developing and applying cutting-edge technologies to solve environmental problems.
However, it is unclear who will be leading the proposed efforts, how funding will be
prioritized, or how the research products will be defined. Given the lack of detail, it is
difficult to assess the nature of the products or their significance. With the limited
budget projections, it is unlikely that products will have a large impact on enhancing the
science or decision-support of sustainability.
P6. Does the scope of work proposed within the Plan complement research being
supported by other programs inside and outside EPA?
The Committee found that the scope of work appeared to complement research inside
the Agency and perhaps outside the Agency. The Committee urges the Agency to
conduct more extensive investigation and documentation of external research related to
the Plan.
P7. Are there other potential emerging research areas that the Plan should consider?
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The long-term goals are sufficiently broad to cover most emerging issues, however, it is
unclear how the Agency will identify, prioritize, and respond to emerging issues on an
on-going basis. The plan should explicitly address this concern since it has both
resource and coordination implications.
P8. Is the level of resources specified by the Plan sufficient to address the research
issues that it identifies, allowing ORD to achieve the intended outcomes of the
research program? Is the Plan's relative allocation of those resources among the
research tracks of the sustainability research program appropriate, based on a
consideration of scientific and programmatic needs?
The level of support specified for the Plan is less than one one-thousandth of the
Agency's overall budget and no more than 1 % of the S&T budget. In the Committee's
opinion, a substantially higher commitment is needed to have a serious impact on
internal research priorities, managerial buy-in, and program visibility and growth. The
level of support allocated will limit progress and suggests to the Committee that the
Agency does not ascribe a high level of importance to sustainability-based research
activities. In the Committee's opinion, the area of environmental sustainability should
become a main thrust of ORD, with allocation and resources established at a level
commensurate with its importance to current and future Agency decisions.
P9. Does the Plan appropriately address findings and recommendations in
evaluations of the program and its components?
ORD is clearly interested in working with other parts of the Agency and organizations
outside of the Agency. However, the descriptions of how such collaborations will be
developed and implemented need to be strengthened in the Plan.
Overall, the Plan is too vague when it describes proposed results and outcomes that
pertain to sustainability. Planned efforts to quantitatively describe those planned results
and outcomes need to be expanded in light of future external assessments of the
sustainability program.
This Committee's review and the upcoming BOSC review should address the concerns
delineated in the PART evaluation. Regarding the integration of the elements of the
P2NT (now sustainability) research program, the Plan provides evidence of substantial
efforts at coordination and integration. The Committee's evaluation of those effects is
described in the responses to other Plan charge questions.
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2. Responses to Charge Questions Relating to the Strategy
S1 Does the SAB agree with the central premise of the Strategy that
sustainability is all about decision making and that ORD research
support should aim to inform and allow decision makers at all levels
of government and in the private sector to choose courses of action
that will lead to achieving sustainable outcomes?
The Sustainability Strategy document is a careful and thoughtful effort to capture the
opportunity to implement an important paradigm shift across much of the agency's
jurisdiction and, along with other Federal partners and stakeholders, the national
landscape. The Agency is to be commended for its work here.
The document will serve as an important companion document to the Plan as the
sustainability paradigm is adopted internal to the Agency. It will also be important as the
Agency works externally with other Federal agencies and stakeholders across the
national landscape.
Many of the comments offered here reflect initial thoughts by the Committee that
eventually resulted in the seven overarching comments being developed during the
Committee meeting (presented in section 4 of this report). Consequently, these
comments in response to S1 may be elaborative in nature.
The Committee does not agree with the central premise that sustainability is "all about
decision making" and "aiming to inform." Rather, four additional, expansive views are
offered:
First, Agency-sponsored core research focusing on sustainability science is needed. By
defining sustainability as "all about decision making," the Strategy mixes together
scientific questions with assumptions about likely policy directions. Overtly combining
sustainability research activities with possible policy decisions weakens and limits the
scientific aspects of the Strategy to only those environmental issues that can be
addressed in the near term.
Development of decision support tools implies a foundation of knowledge about
sustainability. In some areas, there is this foundation: for example, the benefits of
energy efficiency are widely acknowledged. But, by not explicitly acknowledging the
critical need for conducting research specifically focused on defining the fundamentals
of sustainability science, the Strategy may not fully support sustainable outcomes. ORD
research support should not just aim to inform decision makers, but should enable the
Agency to establish a systematic and transparent process for identifying and prioritizing
major environmental concerns that can be effectively addressed through application of
sustainability principles. Sustainability research should provide the Agency with the
scientific tools to deliver maximum value back to stakeholders in terms of a balance to
economic, social and environmental improvements (the three pillars of sustainability).
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It is of critical importance that the Strategy be able to distinguish between two related,
yet distinct functions: clarifying sustainability principles, and implementing sustainability
solutions. The strength of ORD research has traditionally been focused on clarifying and
documenting environmental impacts. This role for ORD research is commendable and
should be expanded to include clarifying the Agency's current understanding of
sustainability principles. Implementing sustainability solutions to a recognized
environmental problem will be primarily a policy decision. After policy decisions are
made, ORD research could then appropriately focus on applied research to implement
the policies. For instance, ORD's efforts to "develop a set of appropriate metrics to
gauge society's progress towards sustainability" (ES-page 14) should, in part, be based
on metrics already available (e.g., energy efficiency) and allow greater focus on current
and future policy and regulations. With such existing metrics, then society could
proceed with the task of developing technologies and approaches to achieve these
goals.
Second, the public and public stakeholders are clearly part of the cultural aspect of
responding to and implementing sustainability at the local level.
Sustainable decision-making will take place at many levels and across both the public
and private sectors, from individuals to neighborhoods, municipalities and regions,
countries and continents, NGOs and private firms, and consumers and producers. Any
plan to inform and support decision-making on such a scale is a large undertaking
involving research on; material and energy flows, information dissemination, economic
incentives and expectations for present and future payback. As such, integration of
social factors into the science that ORD has traditionally employed is an essential
element of the sustainability paradigm. Typically, major legislative actions and federal
policy are needed that respond to public perception of need. The sustainability
paradigm is of such a nature, a radical departure from past ways of perceiving
humankind's relationship to the environment.
An important premise in the sustainability paradigm is informed decision making for
change agents (e.g., government) and for the practitioners (e.g., the public). In general,
the difficult component of decision-making is having the needed information. In this
regard, it is important that the Strategy focus on decision-making and identify
"information driven" processes. A sustainability-focused solution to environmental
concerns is effective only if information is coupled with incentives (or disincentives) that
can drive behavioral change (and prevent backsliding to traditional unsustainable
solutions). The Strategy fails to explicitly acknowledge the role of the public and other
stakeholders besides local, state and federal government and the regulated entities.
The public should be apprised of and might well be interested in learning about what
technological advances funded by ORD have been adopted private industry. In addition,
the metrics and indicators developed under the auspices of ORD research program
would serve the interests of the public at large, not just those of government officials
and decision makers.
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Third, the definition of sustainability may benefit from additional interpretation. The
research portfolio would be more compelling if the interdependence of the three pillars
of sustainability (environment, social aspects and the economy) were clarified.
Currently, economic growth and population change appear to be treated as exogenous
variables that determine the pressure imposed on the environment.
Fourth, ORD needs to explicitly promote and integrate a life-cycle approach to
environmental protection decision-making within the Strategy that goes beyond simply
generating information and furnishing it to decision makers. The life-cycle approach
would support the need for behavioral change and outcome measurement over time,
both internal to and external to the Agency.
S2 Does the strategy make a compelling case for ORD and EPA that
Sustainability Research is a priority for ORD?
The Committee unanimously agreed a systems-based approach is needed in order to
address environmental problems and that a sustainability framework supports that a
systems methodology. Other points of agreement included concern that the category of
"decision maker" was construed rather narrowly. Committee members argued that the
long-standing problem of "silos"—division of environmental problems into individual
media and/or pollutants—was not sufficiently addressed as a core source of the
problems facing environmental policy and the Agency.
Allocation of resources, on the other hand, does not indicate that Sustainability
Research is a priority for ORD. The level of Agency resources currently allocated to
support sustainability research is woefully inadequate for a meaningful scientific
research program. Further, if the resources allocated to the Sustainability Research
Strategy reflect Agency priority setting, then sustainability research does not currently
appear to be a priority within ORD.
S3 Does the strategy focus on priority national issues and identify the right
research questions?
The Strategy organizes its priority research questions according to the six critical
research themes in Chapter 4 (Natural Resource Protection, Non-renewable Resource
Conservation, Long Term Chemical and Biological Impacts, Human Built Systems and
Land Use, Economics and Human Behavior, and Information and Decision Making).
These themes, and the questions that are derived from them, have both a generic (i.e.
nothing to distinguish EPA's role), and EPA-specific focus which, in general,,
emphasizes issues related to human interactions with the environment. To its credit, the
Agency has tried to derive a strategy that is cross-media. The areas and questions
outlined are comprehensive, and expand upon the initial themes. The Committee
encourages the Agency to apply the principles of sustainability in supporting research
activities aimed at addressing high profile environmental concerns e.g., global climate
change, energy production, etc. The Committee strongly endorses the efforts by the
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Interagency Sustainable Development Indicators group to develop a suite of
scientifically defensible sustainability metrics.
The Committee acknowledges the inherent difficulty in establishing sustainability
metrics that are acceptable to a broad range of public and private stakeholders.
However, successful transition of the Agency from its single-media regulatory focus to a
systems-based approach to environmental decision-making is dependent on the
formulation of scientifically defensible sustainability metrics.
Owing to the early advances of the international community in conducting state-of-the-
art research on sustainability, Committee recommends that the Agency critically
examine the practices of the European Union (EU) countries, Japan, and others as a
means of establishing reasonable sustainability benchmarks while developing a
distinctive sustainability research model that is patterned after the Agency's
sustainability paradigm, i.e. collaborative, forward-focused, inclusive, adaptive, and
integrative.
S4 Does the strategy identify the right implementing steps to address
research questions and achieve sustainable outcomes (advance
technology, develop tools and approaches, advance systems
research, and disseminate and apply results)?
The Strategy refers to four implementing steps: (1) transition the current pollution
prevention and new technology research program into a Science and Technology for
Sustainability Research Program, (2) coordinate with 16 other multi-year plans, (3)
collaborate and partner with EPA Program and Regional Offices and other government
organizations, and (4) identify and pursue future research opportunities.
As one proceeds from implementing step 1 to 3 a number of things occur:
1. There is less and less specificity of how this will work in the Strategy.
2. ORD has less and less direct control of the outcomes and this will lead to
measurement problems.
3. There will be increasing resource demands tied to coordination with multiple
entities (important given limited resources).
Step 4 (identify and pursue future research opportunities) appears in various forms
throughout the strategy but neither the Strategy nor the Multiyear plan specify how this
will be done, what resources will be used, or how success might be evaluated.
Finally, it is not clear what happens to pollution prevention (step 1). Though always
under-resourced, prevention has been an important part of EPA message for over 15
years and one that resonates with the public, NGO community and private industry.
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The Plan should make clear how the S&T for Sustainability Research Program views
the concept of "prevention."
S5 Does the Strategy adequately and correctly connect to policy
and/or decision-makers inside and outside the EPA for achieving
desired sustainability outcomes?
Policy and decision-making are two different, but related, aspects of the problem. US
environmental policy is, and will most likely remain, risk-based. Whether this is
inconsistent with "sustainability-based" policy will only be known when the outcomes of
research on sustainability become apparent.
Decision-making depends on policy, or more precisely the way policy is implemented,
and requires that appropriate incentives (i.e. policy tools) be implemented. It can relate
to long or short-term courses of action, the longer the term the greater the uncertainty in
the outcome. This is why it is important to view sustainability metrics and standards as
evolving, i.e., a moving target whose descriptions are continuously refined as research
results are generated.
The Strategy focuses on activities, offices, and regions within EPA, and coordination
among these entities. There is limited discussion of connections to and collaborations
with decision-makers and organizations outside of EPA. The Strategy does connect to
EPA decision-makers by arguing that environmental sustainability research is important
and appropriate for ORD, as well as by seeking to negotiate with other EPA program
managers and decision-makers about the content and future of sustainability research
at EPA.
The Strategy does not propose any significant connections to federal policy and/or
decision-makers outside EPA. External collaborations and partnerships are discussed
in a summary manner on pages 70-73. Ongoing programs and relationships are noted,
with some specific examples given. There is more discussion of connections with other
Federal agencies than with regulated bodies (industry), communities, and consumers.
Although the Strategy refers on page 63 to the need for balance between research that
supports decision making within EPA and by other government organizations and
industry, it neglects to mention the role of consumers or non-governmental, non-
regulated parties that may be involved in policy recommendations or decisions, be they
individual life-style decisions or those that affect local or regional communities. There is
little in the Strategy about partnering with academic research or even how EPA might
better leverage information and research generated by the regulated parties
themselves.
The general nature of the discussion of external connections is consistent with the tone
of the rest of the Strategy, which examines six broad themes of environmental
sustainability in a general manner. It is not clear, however, how much of an impact the
collaborations and partnerships will actually have in advancing sustainable approaches
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to management and protection of the environment. There is no discussion of
connections with specific kinds of decision-makers or policies linked with specific
sustainability challenges. Certainly, specific connections within public and private
sectors will evolve as the program develops, but the Strategy recognizes that this effort
must be (and will be enhanced by) connections with other efforts in EPA and outside
EPA.
ORD is clearly interested in connecting to policy and decision makers within and outside
of Agency in the Strategy and Plan. However, as formulated, the Strategy does not
require the identification of specific kinds of decision-makers and policies. Weakness in
this respect probably reflects resource constraints rather than failure of intention and
foresight. If the Strategy was built around specific sustainability challenges, which it is
not, then the need for identifying decision-makers and policies would be more apparent.
The Strategy should do more to prepare to discuss research results with policy makers.
After ORD clarifies and strengthens its research strategy, it should develop an active
program to connect to policy makers and decision makers. In this regard, the strategy
could be more explicit in its goal of trying to change behavior through the development
of metrics and tools that might move all parties towards decisions that create
environmental sustainability - that recognize something beyond straight measures of
economic productivity. It's almost too subtle in that regard. At the same time, it is critical
that the Strategy acknowledge that decisions will always be made in the absence of
complete information; development of approaches to decision making that address
uncertainty are essential.
The Strategy could also do more to move us away from a waste-centered view of
environmental protection. The Strategy appears to view "sustainability" as following
logically, temporally, and philosophically from the current emphasis on waste
management as a means to healthy environments. It may be more useful to view things
the other way around, regardless of how policy has historically been implemented. The
problem with seeing sustainability as derived from a waste-centered view is that it then
becomes very difficult to refocus our (EPA managers and scientists, the government in
general, and the citizenry) environmental frame of reference. This inevitably leads to
inadequate organizational structures, poor prioritization, and seeking answers to the
wrong questions. Interestingly, this has been recognized in the Agency's Strategic Plan
under Goal 3 (Land Preservation) in which it is stated "Our ultimate goal is to move the
Nation from a waste-oriented to a life-cycle management way of thinking about
materials".
ORD has an opportunity to provide leadership both internal to the Agency and external
among the federal agency family and other organizations. This can be accomplished by
coordination and leadership in the definition of environmental sustainability and in the
use of related research products which will influence how other federal agencies and
organizations move forward with their sustainability programs.
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The scope of environmental sustainability research efforts outside EPA is vast and the
ORD has only skimmed the surface. To take one example, there is no mention of the
scholarly literature on environmental sustainability. There are several key
academic/scientific journals devoted to this topic and, of course, many more that touch
on it. A more deliberate effort at ongoing literature review is warranted in this respect -
to exploit what has been created by others, to stay abreast of developments in the field
and to identify vehicles (e.g., journals) through which ORD research should be
disseminated.
S6 (a) Does the strategy enable ORD to prioritize its research investments?
(b) Does the strategy define an appropriate role for EPA relative to other
funding agencies? Does it sufficiently encourage other Federal agencies
and organizations to relate their sustainability efforts to EPA's so as to
promote co- funding and/or collaboration where appropriate?
S6(a): Does the strategy enable ORD to prioritize its research investments?
The Strategy document identifies five objectives for ORD research (understanding of
systems, development of decision-support tools, development of technologies,
collaborative approaches to decision-making, development of metrics and indicators)
and six broad research areas ("themes"—namely renewable resource systems, non-
renewable resource systems, long-term term chemical and biological impacts, human-
built systems and land use, economics and human behavior, information and decision-
making).
Examples of more specific, but still sufficiently broad, research questions are offered for
each of the six research themes. In this document, ORD elected to present criteria that
could be used to set priorities, rather than trying to identify research priorities directly.
Specifically, these criteria are (i) "high impact;" (ii) "true to EPA's research capabilities;"
(iii) "true to EPA's role" and mission; (iv) "leverage:" higher priorities on research that
ultimately leads to sustainability on a large scale, with EPA partnering in initial research
or through transfer and diffusion of knowledge, methodologies, and approaches; and (v)
systems context.
The Strategy clearly states that it is up to the individual multi-year plans and to the
National Program Directors to identify their priority sustainability research areas.
(Indeed, the Plan document presents criteria for setting priorities—grouped into primary
and secondary criteria—that are consistent with those in the sustainability strategy
document.)
Moreover, the Strategy emphasizes that each individual multi-year plan should develop
a balanced research portfolio with a good mix of short-term and long-term projects,
known and emerging issues, projects that are traditionally central to EPA's mission
(e.g., water) and projects that are at the boundary of EPA's responsibility but still
important for sustainability (e.g., agriculture and the health of aquatic systems),
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research that supports decision-making within EPA (programs and regional offices) and
research that supports decision-making in the industry and in other local, state and
federal organizations.
The Committee had mixed reactions regarding the efficacy of this agenda and the
criteria employed for setting research priorities. The Committee determined that, on
the whole, the research portfolio composition was appropriate for ORD. However, in
practice, several Committee members expressed reservations over whether the
compelling science questions and priorities that truly speak to sustainability and its
cross-cutting issues would be addressed as part of ORD's sustainability research
program.
Recognizing that the Agency is poised to assume a global leadership role in
sustainability research, the Committee strongly recommends that, in light of ORD's
limited budget, that the following parallel activities be conducted immediately: (i)
conduct core research on sustainability focusing on the development of defensible
sustainability metrics, and (ii) implement a small number of Agency-sponsored
technology demonstration projects that provide ORD with the opportunity to achieve
significant visibility within the sustainability research arena. It is important that these
demonstration projects move away from waste/end-of-pipe approaches to take a
broader, system-based perspective. Examples of such projects might include an
assessment of (i) biofuels policies and options, which are topical and encompass a
broad range of issues and potential impacts on emissions of greenhouse gases,
agriculture, dependence on imports of fossil fuels, etc. and may imply a variety of
economic incentives; (ii) a study of the hypoxic environment in the Gulf of Mexico or the
Chesapeake Bay, and (iii) wastewater practices and infrastructure needs in regions and
cities with accelerated population growth.
S6(b): Does the strategy define an appropriate role for EPA relative to other
funding agencies? Does it sufficiently encourage other Federal agencies and
organizations to relate their sustainability efforts to EPA's so as to promote co-
funding and/or collaboration where appropriate?
The Strategy lists specific projects and programs with a sustainability emphasis or focus
in other agencies. It also identifies other federal agencies with overlapping interests for
each of the six broad research themes, as well as international partners. Despite these
lists, however, and EPA's acute awareness of other nations' focus and recent advances
on sustainability matters, the discussion and the information offered on page 71-73 is
too cursory to allow the Committee to judge whether these other agencies will feel
encouraged to establish partnerships with EPA and promote co-funding and
collaborations.
S7 Does the Strategy outline an adequate roadmap for ORD to implement this
program (P2 transition to Sustainable Technology, coordination among NPD and
across existing multi-year plans, leveraging interagency cooperation, and
defining emerging research areas?)
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The roadmapfor implementation of the program is described in Chapter 6, pp. 61-75,
beginning on page 64 and includes four implementing steps: (1) transition the current
pollution prevention and new technologies research program into a Science and
Technology for Sustainability Research Program; (2) coordinate with other multi-year
plans; (3) coordinate and partner with EPA Program and Regional Offices and other
government organizations, communities, nonprofit organizations, universities, and
industry; and (4) identify and pursue future research opportunities.
The Committee supports ORD's roadmap for implementation of the Sustainability
Research Strategy. Coordination with other multi-year plans is essential to the success
of the Sustainability Research Strategy. The implementation of the Sustainability
Research Strategy through a number of multi-year plans will begin to provide the
Agency with a distributed core of sustainability research in ORD. Coordination with
EPA program and regional offices and other government organizations will provide
additional needed capacity to carry out the research program.
Implementation of the Strategy is organizationally challenging because it relies on
cooperation throughout ORD and EPA. The Strategy is an important step for ORD and
for the Agency, and the Committee supports ORD's initiative. Explicit management
support of the Sustainability Research Strategy would be important to ensuring
successful implementation.
S8 Does the SAB believe that sustainability research is a sufficiently strong
concept for integrating and coordinating across ORD research
programs?
In the face of exponential economic and population growth, in addition to the threats of
a possible oil crisis, global warming, and ozone depletion, it is clear that novel actions
must be taken in order to ensure the continued prosperity and progress of our
generation and those of the future. New methods must be developed to balance the
needs of present and future populations with the real limits of our natural resources.
Attempting to remedy ecological damage by "stovepipe" policies represents an
incomplete understanding of pollution and the environment. Thus, environmental
scientists and decision-makers are presented with a multitude of environmental
challenges in developing new models, methods, and technologies to deal with pollution
and environmental protection in a holistic, systems-based manner. The philosophy of
sustainability has the capacity to provide the answers to these challenges when applied
to relevant scientific, social, and economic fields.
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Sustainability impacts and is impacted by variety of disciplines, and thus a
multidisciplinary and multimedia approach to managing our environment is required
Building on the definition taken from the well-known Brundtland Report, the ORD draft
document defines sustainability as "meeting basic environmental, economic, and social
needs now and in the future without undermining the natural systems upon which life
depends." Thus sustainability is conceptualized as a dynamic process, an open-ended
challenge, in which scientists, economists, and lawmakers work together to solve
present problems and anticipate future issues.
More precisely, the Strategy identifies "Six Themes of Environmental Sustainability,"
that will underpin the Agency's approach to sustainability. They are: natural resource
protection, non-renewable resource conservation, long-term chemical and biological
impacts, human-built systems and land use, economics and human behavior, and
information and decision-making. These themes reflect the concept upon which the
Strategy is predicated - that "the nation is most capable of achieving sustainable
environmental outcomes by investigating resources ... in a systems-based context and
incorporating the influences of economy and human behavior where appropriate."
The report of the 2005 National Academies of Sciences cited in the ORD draft
document identified eight priority sustainability areas in need of government support,
including green chemistry and engineering, energy intensity of clean processing, and
separation sciences, among others. These fields all represent the frontier of
environmentally conscious sciences, as well as representing specific research areas in
which the ORD has a vested interest, and an accordingly strong presence.
In addition to intramural research programs, the Strategy proposes ORD involvement
and collaboration with government programs at the federal and state level, and also with
industrial programs. Thus, sustainability effectively helps to coordinate and integrate a
broad range of ORD research programs. However, two main issues are not
emphasized;
(1) increasing food (both crop and animal) production and its
consequences to the environment; and
(2) multimedia nature of a sustainable strategy.
The EPA is the Federal agency most concerned with research designed to protect and
utilize the natural resources of the environment. It is, therefore, appropriate for the
Agency to fund research programs that will serve its mission, and, where possible,
assist the missions of other agencies. The Strategy will create opportunities for co-
funding/coordination between the EPA and other Federal agencies in science,
engineering, economic and social fields, as sustainability comes to the forefront of
research programs in many different disciplines.
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1 While sustainability research can play an important role in integrating and coordinating
2 across ORD research programs, the exigencies of Agency mandates and to a lesser
3 extent resource constraints and the "ownership" of key topics by other agencies, means
4 that the portfolio of ORD research programs is not likely to be completely conducive to
5 integration in this manner. However, sustainable development must be taken seriously
6 by the entirety of upper management at the Agency and a critical core of Agency
7 scientists.
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3. Responses to Charge Questions Relating to the Plan
P1 Does the organization of the new Sustainability Technology Plan provide a
clear logical framework for implementing an element of the overall
Sustainability Strategy?
Does the Plan follow appropriately from the Sustainability Research Strategy?
Are the research issues identified in the Plan consistent with the research
questions identified within the Sustainability Research Strategy?
Yes. The Committee agrees that the organization of the new Sustainability Technology Plan
provides a clear logical framework for implementing an element of the overall Sustainability
Strategy. The Committee recognizes that financial and personnel resources are limited for this
program. Within this context, the Plan identifies a set of issues that are consistent with the
Sustainability Research Strategy and current ORD capabilities. The criteria for project
selection should be reviewed to ensure that they effectively focus research on projects that will
contribute more effectively to the Sustainability Research Strategy.
The Committee is largely satisfied with the content of the Plan through Chapter 4. These parts
of the Plan discuss the shift to sustainability, the foundation of a sustainability program,
creation of a framework for the Plan, and prioritization of the Plan research. The Committee did
engage in extensive discussion about Chapter 5, which presents the specifics of the planned
research program. The Committee has a number of comments on the specifics of the planned
research program. These comments are included later in this document.
P2 For each major research theme addressed within the Plan (e.g.,
Sustainability Metrics, Decision Support Tools, and Technologies), do
the Annual Performance Goals (APGs) and Annual Performance
Measures (APMs) represent a logical progression of activities and
intended outcomes? Does the Plan identify the specific issues
motivating the research program?
On the one hand, within each major research goal related to metrics (LTG 1), tools
(LTG 2) and technologies (LTG 3), the respective APGs and the APMs do represent a
logical progression of activities and intended outcomes. While one could debate the
choice of LTGs and related APGs and APMs, for those cited there is a logical
progression of events for intended outcomes.
While on the other hand, if one looks at the progression of the three major LTGs, the
Plan appears to be chronologically inconsistent. Technology development is identified
as a major focus in the short term while development of sustainability metrics is not
addressed until 2008-2011. A more logical progression within the context of a overall
focused sustainability research project is described as follows:
1. Develop the appropriate metrics
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2. Develop any decision support tools required for analysis (keep this systems
based if possible and linked to metrics).
3. Investigate technological options to reach the goal and try to get the technologies
in place (SBIR grants, performance incentives...).
Again, the goal is to link metrics, with decision support, with technological innovation
within one project that can be completed with available resources. Currently, there is no
clear progression among the 3 LTGs described in the document.
Does the Plan identify the specific issues motivating the research program?
While there does appear to be a logical progression of activities and intended outcomes
presented within each LTG, it is difficult to determine the overarching objective and
specific goals for the research program proposed. While the overall strategy is
appropriate insofar as sustainable outcome measures related to energy, air, water,
materials, land and ecosystems are concerned (see Table 1.1), there is no clear
integration between the research program and how these outcomes will be achieved.
Furthermore, the probability of achieving the intended outcomes is low due to resource
(appropriate personnel and funding) constraints. Realizing such constraints and
wanting to achieve maximum impact for the resources invested, one recommendation is
to select one or two key demonstration projects, focused on a real and current
sustainability issue where the approach can include all the aspects of metrics
development, development and application of decision support tools, and technology
development and demonstration. The actual projects identified should have a major
impact for the municipality, region, or even industry that is the focus of the project, with
the information gained easily transferred to other entities.
P3 Does the Plan lay out a balanced program addressing both short-term
and longer-term research that meets current needs while positioning the Agency
to respond to emerging issues?
The Science and Technology for Sustainability Multi-Year Plan (Plan) builds upon the
framework of the Pollution Prevention and New Technologies (P2NT) Research
Program, created in 2000. Under the P2NT program, much progress has been made in
a variety of fields pertaining to sustainability, such as the development of Environmental
Impact Assessment Models, the Small Business Innovation Research Program, and the
Technology for a Sustainable Environment programs.
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The P2NT program was reviewed by the Federal Government's Office of Management
and Budget, and several recommendations were made to improve the program,
including "becoming more focused on the need of Agency client offices, fostering more
collaboration with other researchers (academic, industrial, and government), and
developing an ability to measure and track program results over time." Thus, the Plan
benefits from being created with these recommendations in mind, focusing on
coordinating interdisciplinary programs, setting long- and short-term goals, and
measuring the program's performance in an effective way.
The Plan establishes three long-term goals (LTGs), with the overall vision of "providing
support to regional and national sustainability polices and initiatives." First, the Plan
seeks to identify and create scientifically based sustainability metrics, which will allow
scientists a clearer picture of what a healthy, sustainable ecological system looks like.
Next, the Plan calls for the development of decision-support tools that promotes
environmental stewardship and sustainable management practices. Thirdly, the Plan
calls for the development, application, and demonstration of innovative technologies
that solve environmental problems and provide sustainable outcomes.
The description of these three long-term goals is sufficiently broad to allow flexibility in
their execution, but specific enough to establish criteria for their measurement. In
addition, the related research program also has several performance measures which
rely upon feedback from the Agency's clients, e.g., individuals, communities,
government and private companies.
Furthermore, the ORD has established criteria by which research activities may be
prioritized. The primary criteria are: resource availability, relevance to the Agency's
Mission and Addressing Program Office Needs, and Staying True to ORD's Research
Capabilities. These criteria raise serious questions regarding implementation in that the
draft document reports that the resources allocated to the existing P2NT research
program are modest and, in fact, are expected to decline. With this in mind, are the
long-term goals of the Plan attainable? Will new research programs fail to be funded,
although there may be potential for a highly positive environmental impact? Is the Plan
itself a sustainable program? This question is of the utmost importance as all goals and
plans are predicated upon the availability of adequate resources.
The Plan calls for responding to emerging issues, but lays out no strategy for identifying
these issues or organizing a coherent response. ORD needs to be specific about how it
will track emerging issues, prioritize them, and decide how best to address them. This
function will be important in terms of also identifying future partners within the
government, industry and academia. The resource demands for issue tracking are not
extensive, but ORD or other Agency program offices must be responsible for tracking
not just relevant environmental issues but changes in industrial production technologies,
social behavior and economic drivers that may result in new opportunities to achieve
sustainable outcomes.
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If this is a more helpful interpretation around the topic of balance, then it might be useful
to weight the balance somewhat in favor of short term research projects that develop
useful products in the next year or two; and slightly less towards long term (i.e. research
projects that develop useful products within five years) so that early successes are
ensured.
P4 Do the long-term goals address the high-priority science, engineering,
and technology needs of users that will help the Agency meet its
strategic goals relating to sustainability? Do the long-term goals clearly
relate to the research tracks within the multi-year plan framework? Do
they provide a picture of what the program is trying to achieve? Will the
proposed research activities lead to progress toward these goals? Are
the goals appropriately linked to long-term environmental outcomes?
(a) Do the long-term goals address the high-priority science, engineering, and
technology needs of users that will help the Agency meet its strategic goals
relating to sustainability?
This set of charge questions requests commentary from the SAB on the long term
efficacy of the proposed sustainability research program. Addressing the longer term
outputs and outcomes of the program is important because ORD research has
historically been focused on shorter term needs, often driven by political imperatives
rather than science-based prioritization.
Chapter 3 of the Plan explains clearly the linkage of the LTGs to the Sustainability
Research Strategy, which examines six broad themes of environmental sustainability. It
is not clear, however, how much of an impact the general LTGs will actually have in
advancing sustainable approaches to management and addressing specific
sustainability challenges. The LTGs address high-priority science, engineering, and
technology needs mostly indirectly. Moreover, specific sustainability challenges involve
more than just science, engineering, and technology research needs (i.e., the need to
integrate economics, social sciences, architecture, and planning).
The Committee encourages the Agency to identify and document its role in facilitating
the development of new, more sustainable technologies (APG 3.2). Although, in the
majority of cases, such development is best left to the private sector, the Agency can
play a unique and major role in highlighting the cross-cutting environmental problems
for which sustainability technology is urgently needed. Moreover, the Agency can
facilitate the interfacing between the federal government and private industry through
the P2 program, certify and evaluate data and making it available to the sustainability
community (consistent with proprietary requirements), verify sustainability technologies,
ensuring that consistent metrics are used by all stakeholders (including various Agency
offices and programs), and conduct research on ways to incentivize companies to invest
in and adopt new technologies.
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(b) Do the long-term goals clearly relate to the research tracks within the multi-
year plan framework? Do they provide a picture of what the program is trying to
achieve?
In Chapter 5 of the Plan, the planned research described via the APGs is consistent
with the LTGs under which the APGs are listed. The inclusion of particular APGs can
be debated, and other possible APGs could be suggested. The proposed research
activities represented by the APGs will clearly lead to progress, but the likely impact of
this progress in helping to address specific long term sustainability challenges is not
clear.
One clear role that the Agency can play to which the Plan alludes but does not explicitly
develop is that of conducting "regular and continuous assessments of environmental
trends". If indeed the Agency assumes this role, and makes such assessments
available to the public, then it will be performing a valuable service that can enable
decision makers at all levels to respond to emerging issues as well as ongoing ones.
(c) Will the proposed research activities lead to progress toward these goals?
The document has specific deliverables but it is unclear where the research questions
are developed and prioritized. There is little in the Plan about cooperative research with
universities and industry. In the latter case, there needs to be a shift in Agency policy to
move from one of regulation to one more focused on demonstrating the business case
for sustainability. In this regard, having regulations in place to drive certain sustainability
initiatives, once identified, can help but should be done judiciously.
The Committee notes that Plan LTG 1 focuses on the development of metrics for
assessing environmental systems, but the Agency fails to follow this same approach for
prioritizing its research. Without such an approach, the sustainability research portfolio
may not reach its maximum long term value.
(d) Are the goals appropriately linked to long-term environmental outcomes?
This area is perhaps the weakest part of the Plan. The outcomes, while measurable, are
not focused on achieving goals through the application of sustainability principles (such
as dematerialization, material substitution, development of alternative energy sources,
process modification, fostering of innovative technologies, organizational change,
supply-chain management, and total cost accounting, to name a few). Without this
aspect, the plan runs the risk of retreating to a focus on single-media, end-of-pipe
treatment.
P5 Are the research products supportive of the strategic target as set
forth in the Agency's Strategic Plan under Objective 5.4?
Objective 5.4 of the Agency's Plan focuses on enhancing society's capacity for sustainability
through science and research. More specifically, it states that the Agency will "(C)onduct
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leading edge, sound scientific research on pollution prevention, new technology development,
socioeconomic, sustainable systems and decision tools. By 2011, the products of this
research will be independently recognized as providing critical and key evidence in informing
Agency policies and decisions and solving problems for the Agency and its partners and
stakeholders."
The LTGs set forth in the Plan certainly support this strategic target, by establishing
sustainability metrics, creating decision-support tools, and developing and applying cutting-
edge technologies to solve environmental problems. However, it is not clear who will be
leading the proposed efforts, how funding will be prioritized, or how the research products will
be defined. In Section 4.2, a series of research questions is provided that are directed at the
LTGs. Each of these questions are important and complex and in Chapter 5 the planned
research program presents APGs that address these questions. Limited detail is provided in
the Plan with regard to what the research products will be and therefore, it is difficult to assess
the nature of the products or their significance. With the limited budget projections, it is
unlikely that products will have a demonstrable impact on enhancing the science or decision-
support of sustainability.
P6 Does the scope of work proposed within the Plan complement research
being supported by other programs inside and outside EPA?
The Committee found that the scope of work appeared to complement research inside
the Agency and perhaps outside the Agency. More extensive investigation and
documentation of external research related to the Plan is urged.
P7 Are there other potential emerging research areas that the Plan should
consider?
The LTGs are sufficiently broad to cover most emerging issues, however, it is unclear
how the Agency will identify, prioritize, and respond to emerging issues on an on-going
basis. The plan should reflect this since it has both resource and coordination
implications (for instance, coordination with the 16 other MYPs). What criteria will be
used to define "emerging" issues, how will they be prioritized, and what type of criteria
could be used to evaluate "success" in terms of addressing an emerging sustainable
development challenge (versus an existing one)?
What should the balance be between existing and emerging, which is related to the
broader issue of how to allocate resources using a portfolio-of-initiatives approach?
P8 Is the level of resources specified by the Plan sufficient to address the
research issues that it identifies, allowing ORD to achieve the intended
outcomes of the research program? Is the Plan's relative allocation of
those resources among the research tracks of the sustainability research
program appropriate, based on a consideration of scientific and
programmatic needs?
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The level of support specified for the Plan is $2.7 million external and 36.5 internal full-
time equivalents (FTEs). Assuming the 36.5 FTEs translate into something on the order
of $4 million, this suggests that the Agency is allocating about $6.7 million to
sustainability research (with the hope that it will increase by 10-20% in the near future).
Even in times of declining budgets, EPA is still a $7.3 billion agency, meaning that the
sustainability initiative is less than one one-thousandth of the Agency's budget. Even if
the comparison is made only against the S&T budget, the fraction approaches to no
more than 1%. No other multi-year plan is allocated such a miniscule resource base.
The Committee is perplexed by such modest levels of support for a program that
promises to re-focus the way the Agency does research and re-evaluate the basis for
the risk-based paradigm. Given the enthusiastic and expansive goals and metrics for
this program, and assurances of "traction" of the sustainability theme within the Agency,
the Committee is, frankly, disappointed that the Agency is unwilling to initiate this
program at a more substantial level. The Plan correctly points out that as the value of
the sustainability program becomes recognized, other program directors and offices will
become more compliant with its attributes, goals, and metrics, and will presumably
become active in seeking out collaborative projects. Even so, in the Committee's
opinion, this initial allocation, even if grown in the short term by 20%, falls far short of
that needed to elevate the sustainability paradigm to a level where it is visible within the
Agency, the federal government, and the nation. In the Committee's opinion, a
substantially higher commitment is needed to have a serious impact on internal
research priorities, managerial buy-in, and program visibility and growth.
The level of support allocated will limit progress and suggests that the Agency does not
assign high significance to sustainability-based themes into its research programs. For
example, the priorities for future research activities (Section 5.4 of the Plan) would result
in further narrowing ORD sustainability research into the areas of its existing expertise.
Instead, the Agency could seek to develop new and greater capacity in sustainability
research through a combination of new personnel with training in sustainability research
(directed hires), incentives for existing personnel to explore ways in which their
expertise could be incorporated into the sustainability model (such as focused
sabbaticals for Agency scientists), pioneering new models of cooperative research
(such as partnering with industry and other agencies), and sustainability "think tanks"
within the Agency. In the Committee's opinion, environmental sustainability should
become a main thrust of ORD with allocation of resources assigned to a level
commensurate with its importance for current and future decision-making.
P9 Does the Plan appropriately address findings and recommendations in
evaluations of the program and its components?
Discussions between ORD officials and members of the SAB Committee revealed that
this question pertains to the responsiveness of ORD to the feedback from the Program
Assessment Rating Tool (PART) Review of USEPA's Pollution Prevention and New
Technologies Research Program (P2NT).
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In addressing the PART Review of the P2NT Program, the Plan briefly expresses
concerns about: 1) becoming more focused on the need of Agency client offices, 2)
fostering more collaboration with other research programs and 3) developing an ability
to measure and track program results over time. Discussions with the Agency indicated
that concerns had emerged during the PART review related to the lack of a timely
review and failure to integrate all parts of the P2NT program.
ORD's responses in the Plan to P2NT's PART review was insufficient for the Committee
to provide a comprehensive response as more detailed information about issues
pertaining to the PART review should be included in the Plan.
The Plan and feedback from ORD during the June 13-15 meeting indicated ORD is
interested in working with other Agency program offices as well as regional offices and
state agencies. The Committee applauds ORD's commitment to enhancing inter and
intra-Agency interactions on sustainability-related activities but suggests that ORD
provide greater clarification within the Plan regarding the specific steps that will be
followed to achieve meaningful collaboration. In particular, ORD needs to explicitly
describe how it will work with other governmental organizations and achieve
measurable outcomes that will be helpful for future assessments of the sustainability
program.
There is also information in the Plan that demonstrates ORD's intent on increasing
collaborative efforts with research programs external to the Agency. More explicit
descriptions of how such collaborations will be developed and implemented need to be
strengthened within the Plan. The issue of developing methods to measure and track
program results is briefly described as part of LTG1 in terms of identifying and creating
scientifically based sustainability metrics. Such efforts aimed at developing techniques
to measure and track sustainability program results should be described in greater
detail. Overall, the Plan is commendable but in many instances is vague particularly
when describing proposed results and outcomes that pertain to sustainability. Planned
efforts to quantitatively describe those planned results and outcomes need to be
expanded in light of future external assessments of the sustainability program.
This Committee review and the upcoming BOSC review should address the concerns
delineated in the PART evaluation about timely review. Regarding the integration of the
elements of the P2NT (now sustainability) research program, the Plan provides
evidence of substantial efforts at coordination and integration. The Committee's
evaluation of those effects is described in the responses to other Plan charge questions.
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4. Additional Advice
1. The Committee recommends that the Agency better define those terms
associated with the sustainability strategy and the measurement of sustainability
outcomes.
The Strategy and the Plan need to define sustainability more clearly and overtly. In this
regard, the documents would benefit from explicit acknowledgement of competing
definitions of sustainability—thereby providing both context for the Agency's choice
among the various definitions and recognition of alternative views of this contested and
often vague topic. Similarly, the Agency should acknowledge the emphasis in its
approach on environmental sustainability. (There should also be greater care taken to
avoid conflating sustainability and sustainable development.) Clarity about these
definitions will help readers better grasp choices made by the Agency and help them
locate their own understanding of sustainability relative to the Agency's deliberations.
In addition, some discussion of the attributes of sustainability (already implicit in the
draft documents)—e.g., systems approach, integrative science—making clear where
possible if the attributes are unique, necessary or sufficient markers of sustainability, will
help the Agency avoid problems where the programs, Plan and other constituencies
that it hopes to enlist in sustainability research, deem their existing activities as falling
under this rubric without appropriate expansion, amendment or enhancement.
2. Picking Projects to Increase Internal and External Integration
The Committee feels that the careful selection of multifaceted research projects within
the Plan is helpful to the adoption of the sustainability paradigm both within and outside
the Agency. EPA has a prominent leadership mandate in the sustainability arena and its
research projects and their products are important for adoption of the paradigm. The
projects should have visibility and be nationally compelling. The research products
should strategically integrate into the other 16 multi-year plans across the Agency and
allow the Agency to guide other Federal agency research on sustainability.
A portfolio of projects should be considered that has balance with respect to factors
such as risk, early winners, and geography. The portfolio might include regional
projects, projects conducted with CRADAs with industry, projects conducted jointly with
other agencies, or projects conducted in cooperation with programs overseas. The
Agency has conducted many prior compelling studies and efforts that may be amenable
to analysis and produce excellent sustainability science, so some retrospective analysis
may be helpful. A portion of the portfolio may be considered high risk with anticipated
high rewards. An internal "skunk works" might be considered as it can be strategic and
allow certain higher risks projects to be conducted, particularly in emerging areas, to
advance important sustainability science products. The portfolio should become the
basis for articulating projects and products for the APMs and APGs in the MYP.
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Criteria for assembling the portfolio should be developed that include parameters such
as balance, probability of success, and targeted product needs for internal and external
adoption. These criteria should be more detailed than the primary and secondary
criteria presently offered. Criteria for projects of high value but uncertain success may
differ. The depiction of a clear linkage between criteria, project, product, and APMs and
APGs in the Plan would be helpful.
Budgetary restrictions limit ORD's options in terms of sustainability technologies to
explore, sustainability projects to fund and participate in, and aspects of sustainability to
study within a project. Yet, to become a presence in the sustainability arena, ORD
should be encouraged to think creatively and "outside the box."
For example, given the importance of water resources and water resource
development, especially in the West, why not explore options for reuse/recycle of grey
waters, or collection and reuse of rain water, even if they are not envisioned within the
current regulatory framework and current practice?
Likewise, the portfolio of projects to fund or directly participate in might also include,
along with obvious "winners", projects that examine unusual aspects of sustainability or
innovative policy options and their relation to sustainability. The willingness to undertake
such studies and to have a diversified portfolio would, in the Committee's opinion,
enhance the Agency's scientific credibility within the sustainability research field.
The same might apply when selecting which aspects of sustainability to examine in
depth within a given project. Consider, for example, biofuels and biofuels policy options.
In addition to studying the implications of biofuels use on greenhouse gas emissions,
the impacts of biofuel crops on agriculture and the environmental consequences of
biofuel crop practices, it might be valuable to examine how such environmental
consequences are linked to social aspects of biofuel use and production. Similar
considerations might apply to a project that studies hypoxia in the Gulf of Mexico,
including implications for upstream agricultural practice and wastewater treatment,
impacts on communities, economic activities and ecosystems at risk. ORD could serve
as a coordinator for such a project. Another type of project where ORD would be an
excellent leader and coordinator might be one focused on wastewater treatment, a real
problem in communities with undersized capacity and high projected growth in
population.
The Committee believes that ORD's long-term success in establishing itself as a major
stakeholder in sustainability research activities will depend on its research portfolio,
which should include a mix of projects that are central to EPA's mission (e.g., watershed
protection), projects that reside at the boundaries (e.g., agriculture and the health of
aquatic ecosystems), and projects that specifically address emerging issues. To pursue
them, ORD might consider partnerships with other agencies and/or international
organizations as well as hiring personnel with the appropriate background, as discussed
in overarching theme #3.
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3. The Committee encourages the Agency to become more creative and
strategic in developing its human resources programs with the goal of
establishing a critical number of champions of the sustainability
approach to environmental protection
In an era of constrained resources, it is essential that the Agency be strategic in the
development and deployment of its human capital. It needs to address more explicitly
the human resource implications of working on sustainable development. This involves
combining the right talent with the right management structures, as well as addressing
the issue of where the people are located in the EPA hierarchy. Just integrating
sustainable development and outcomes into the existing ORD structures and programs
may not be the best approach.
If it were to achieve the goals of the Strategy and the Plan, there is a need to fill talent
gaps. The Agency needs to acquire the requisite expertise through new hires, or
through redirection of the workforce through transformation of existing skill sets or
efforts of current staff, and through partnering and leveraging other programs in ORD or
the agency as a whole. A sabbatical program to enable current staff to retool would
allow the agency to better employ talented individuals whose current work is no longer
supported. EPA should consider the use of internal transfers for EPA employees, the
Intergovernmental Personnel Act (IPAs) to bring in academics, details for people from
other agencies and fellowships for post-docs such as AAAS Science Fellows. It might
be worth bringing in someone from another country that has worked on developing and
implementing a national sustainability plan. This approach could allow another 6-10
individuals with needed skills and talents to be added to the existing 35 FTEs as well as
better positioning the current 35 FTEs.
There are several areas identified for development. There are no in-house experts with
a background in decision theory. If the Agency is to pursue the critical social dimensions
of sustainability, even if its focus were limited to environmental sustainability, it needs to
hire individuals with backgrounds beyond the physical sciences, engineering and
economics. Stronger social science components that go beyond economics are needed.
Such fields and tools include anthropology for ethnographic assessments (how
individuals, households and communities think, behave and interact with products,
technologies and natural systems) and psychology (behavioral economics) among
others.
If it were to be a knowledge agency as well as a regulatory one, it needs to devote
some resources to analyses and syntheses of the outcomes of both intra-mural and
extra-mural research as well as of the efforts world wide in this area. There is still more
thinking that is needed around sustainable development and EPA's role as well as the
need to catalyze additional people and resources. A part of this overhauled team should
be isolated in a skunk works-type program (maybe 5-8 people) to do out of the box
strategic thinking on this topic for at least a year without being saddled with
management responsibilities.
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4. The Committee encourages the Agency to enhance the diffusion of
sustainability concepts and practices within and outside the Agency (related to
strategic human resource development, careful project selection and linkage with
other multi-year plans, consideration of sustainability components for internal
and external research projects, and securing and exploiting senior management
buy-in).
There is a need for, and EPA should provide, leadership both internal to the Agency and
external among the federal agency family and other organizations. The EPA has an
opportunity to coordinate and lead in the definition of environmental sustainability and in
the use of related research products that will influence how other federal agencies and
organizations move forward with their sustainability programs. The Plan correctly points
out that as the value of the EPA ORD sustainability program becomes recognized, other
program directors and offices will become more compliant with its attributes, goals, and
metrics, and will become active in seeking out collaborative projects.
To achieve leadership by EPA in promotion of environmental sustainability, there needs
to be a paradigm shift at EPA. The shift needs to be away from the current silos related
to air, water, solid waste, etc and more towards a true systems approach involving
personnel from many different areas, including different offices within EPA, the EPA
regions, other government agencies such as DOD and DOE, community stakeholders
(i.e., general public), and industry.
There are many opportunities for EPA ORD to step up to a leadership role, even in the
context of limited resources. ORD could seek to develop new and greater capacity in
sustainability research through a combination of new personnel with training in
sustainability research, incentives for existing personnel to explore ways in which their
expertise could be incorporated into the sustainability model, pioneering new models of
cooperative research within the Agency and with industry, and development of
sustainability "think tank" within the Agency.
The development and diffusion of sustainability metrics, tools, and technologies can be
accelerated via the creation of in-house think-tank to consider how to infuse
environmental sustainability approaches and thinking. The think-tank, a group of
perhaps 5-8 people, could develop the messages that can catalyze additional people
and resources. Such a program could become attractive since there are not many
places in government now where out-of-the-box thinking on this topic can take place.
These people should be kept out of the "weeds" to be able to think strategically about
the topic for at least one year. Members of the think-tank group need to be systems
thinkers with diverse backgrounds to focus and be agents of change within EPA.
Careful project selection and demonstrated integration with other multi-year plans do
matter. Internal and external interest in ORD sustainability research will be driven at
least partially by successes (or failures) of early projects. The Science and Technology
for Sustainability Plan should have some definitely achievable APGs and APMs for
prioritized themes that will quickly deliver research product "winners."
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The research products should clearly tie into the other 16 multi-year plans. This way,
results of the EPA ORD program in sustainability will be immediately relevant to the
larger EPA, and will encourage more EPA groups to adopt the sustainability paradigm.
The ORD should require the applicants for both extramural and internal research
support to state how their proposed research impacts, affects, or enhances
environmental sustainability. Similar to the "broader impacts" component required in all
NSF proposals, a statement about "sustainability relevance" could be a required section
in all proposals received by the Agency.
To encourage a systems approach in EPA research, care should be taken to encourage
systems thinking in proposals and to have an extramural review process that rewards
not only good reductionist science but broad systems science that investigates many
variables in one or a few systems.
5. The Committee strongly supports a greater and more explicit endorsement of
the sustainability approach by the Agency Administrator as well as other senior
Agency management personnel
EPA needs to demonstrate leadership both internal to itself and external among the
federal agency family with respect to sustainability and environmental stewardship. To
that end, within ORD, the position of National Program Manager for Sustainability needs
to be created. Such a position should be expected to lead not only in ORD but in the
Agency as a whole. Management of the overall team if developed as outlined in Section
3 above will require skill and care. The National Program Manager, as well as
leadership of the various programs directed at sustainability should be chosen carefully.
Explicit support from the Administrator of this effort, and of this position is critical. It is
also important that the Agency recognize that the opportunity for leadership across the
federal agencies is now, and that a commitment from the highest levels will be
transformative.
6. The Committee recommends that the Agency establish more effective and
substantive collaborations with other federal agencies as well as the private
sector.
The Agency and the ORD should be applauded for their recognizing the need to
establish partnerships with sustainability related programs and activities being carried
out by others as summarized in Section 5.2 of the Plan. However, the Committee feels
that this is such an important item that more specific plans and goals in this regard
should be clearly identified related to the specific environmental sustainability projects to
be performed.
As environmental sustainability relates to achieving a balance among the three areas of
economic growth and viability, social responsibility and environmental protection,
organizations associated with all three aspects need to be engaged. With much effort
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and focus being given to the issue of environmental sustainability by numerous groups
ranging from governmental organizations, the private sector and academia, EPA could
move into the key role of providing overall leadership and coordination among these
different organizations by providing structure and focus as none presently exists.
The Committee recommends that the Agency immediately initiate a thorough bench-
marking exercise of different organizations dealing with environmental sustainability,
both within the US and internationally as well as covering all the different stakeholder
groups. This will serve to help bring the Agency personnel quickly up the learning curve
as well as even help to identify some key focus areas that EPA could begin participating
in directly. As a first step, ORD could just determine what is happening within other
Agency program offices and determine what opportunities exists for greater
coordination and resource leveraging. The lessons learned internally by the Agency
could be expanded to other governmental organizations, academia and the private
sector.
In conclusion, actively engaging many of the other organizations focused on
environmental sustainability can be the first step in EPA becoming the body that first
brings the different groups to the table, and then provides the coordinating structure that
holds them together to achieve true sustainability. This could also be the first step for
all the other programs within EPA to be focused and coordinated under an overall
environmental sustainability paradigm.
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