UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

 WASHINGTON D.C. 20460 

 

OFFICE OF THE ADMINISTRATOR 

SCIENCE ADVISORY BOARD 

May 5, 2009 

EPA-SAB-09-013

The Honorable Lisa P. Jackson 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460 

Subject: Science Advisory Board (SAB) Comments on EPA’s Immediate Science Needs 

Dear Administrator Jackson: 

It was a great honor to meet with you in February and to introduce you to the SAB. As 

you know, the SAB is a multi-disciplinary, multi-sector board of experts that provides 

independent objective scientific advice to you to assist and inform you in decision-making. We 

are pleased to welcome you as the leader of the US Environmental Protection Agency and to 

your role as the nation’s chief environmental protection official. We thank you for your April 

21, 2009 letter responding to the SAB’s advisory report on EPA’s strategic research vision. We 

are pleased it reaffirms your commitment to science as the backbone of the Agency’s practice as 

well as to scientific integrity and the clear articulation of EPA’s policy judgments and actions in 

ways that account for knowledge gaps and scientific uncertainties. We look forward to working 

with you in the coming years as the nation addresses its most critical environmental issues. 

Since 1979, the SAB has provided independent advice to EPA Administrators on a wide 

range of scientific and technical topics, especially key EPA scientific assessments, models, 

guidelines, and research plans. It has become increasingly apparent that for EPA to respond 

successfully to the changing nature of the nation’s environmental problems, EPA should improve 

its science program, including an emphasis on research that develops the knowledge and 

methods to assess and manage environmental problems. The Office of Research and 

Development (ORD) “transformation initiative” that you mention in your letter will be a key part 

of gaining the knowledge that we now lack on many of the large, and as we are increasingly 

learning, connected environmental problems faced by the nation and the world. 

The issues identified in the following paragraphs highlight key observations that the SAB 

has made during interactions with EPA over many years. At our recent SAB retreat we 

highlighted some key issues, identified in the paragraphs below, that we felt you should consider 

as early as possible as part of the EPA science program. It is very reassuring that some of these 
were mentioned in your April 21st letter. However, we state them again because the SAB 

believes they are foundational to a transformed EPA research program that meets the needs of a 

more complex view of human and environmental health. The ordering of these issues does not 

imply any particular prioritization. 

• EPA should increase its efforts to address issue evaluation and management in an 

integrated manner that recognizes the complexity of the world in which the 

problems occur. 

As your letter recognizes, we now see more clearly than ever that human health and 

environmental problems are interrelated, are often associated with multiple stressors, and 

often involve exposures from more than one medium. Although such complexity makes 

designing effective solutions ever more challenging, the SAB believes effective 

integration of the science is the key to generating knowledge essential for credible 

science-based decision-making. This message was certainly emphasized in the SAB 

“Reducing Risk” report of 1990i

, the SAB’s 2000 report “Toward Integrated 

Environmental Decision Makingii,” as well as in a recent National Research Council 

report, “Science and Decisionsiii,” that addresses risk assessment in decision-making. 

• EPA should support new research frameworks to overcome barriers that now limit 

development of knowledge of integrated environmental problems and their 

solutions. 

As you suggest, through its strategic planning process, EPA has already begun to design a 

program to conduct integrated multidisciplinary research on complex environmental 

issues. However, if integration is to be more than a slogan, EPA must expand its 

investments in new interdisciplinary research fields that will require sustained financial 

commitments in order to be successful. The SAB stands ready to provide the external 

scientific perspectives and advice necessary to assist in this transformation. 

• EPA should move to restore the budget for research and development in order to 

maintain the U.S. as an international leader in environmental protection. 

The SAB understands the challenges raised by the current state of the economy. EPA 

must commit to establishing a research base that will make it possible for the nation to 

acquire the knowledge needed to address the difficult environmental problems that we 

now face and which will only grow in complexity and magnitude in the future. Examples 

of such challenging issues include urban sustainability and the built environment; land 

use, renewable energy, water resources and climate change; materials management and 

human health; and the wise conservation of resources. 

• EPA should develop more robust partnerships and innovative approaches to 

supporting cutting-edge research and development, both domestically and 

internationally. 

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Your letter notes that EPA has long worked with other organizations on environmental 

issues. Because of its unique role as an agency established to provide overarching 

consideration and management of the nation’s environmental problems, EPA should take 

a leadership role in advocating for an even richer cooperative and collaborative approach 

to learning about and solving complex environmental problems. Therefore EPA should 

seek new and innovative opportunities to expand the ways in which it both supports R&D 

and cooperates with government and other organizations, including those in the 

international arena. 

• Research and operational capacity in the social sciences should be augmented. 

Decision, Behavioral and Social Sciences are critical to framing, designing and 

implementing EPA decision processes and to the effective and credible resolution of 

environmental problems. These sciences are key elements in effective problem 

formulation, risk characterization, benefits evaluation, and to engaging with citizens and 

stakeholders on needed actions on these problems.

• EPA should take the lead in assessing the environmental and health implications of 

energy and climate change policies. 

Energy and climate change issues stand out in their importance to the nation’s and the 

world’s well-being. The EPA should be the nation’s lead agency in analyzing the human 

health and environmental implications of energy and climate change policies and guiding 

the country to optimal strategies. 

Members of the SAB look forward to discussing our initial recommendations in this letter 

with you at your earliest convenience. We plan to provide more specific advice regarding longerterm science needs as the result of the study that I discussed with you recently aimed at 

strengthening EPA’s risk assessment practices in a more integrated way. We intend to report to 

you on that study in 2010.

Sincerely, 

/Signed/ 

Dr. Deborah L. Swackhamer 

Chair 

US EPA Science Advisory Board 

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i

 US EPA SAB (1990) Reducing Risk: Setting Priorities and Strategies for Environmental Protection, SAB-EC-90-

021, September 1990. The SAB recommended that EPA target opportunities for the greatest risk reduction and that a 

stove-pipe approach to environmental protection was no longer suited for use in addressing real world 

environmental problems. 

ii US EPA SAB (2000) Toward Integrated Environmental Decision-Making, EPA-SAB-EC-00-011, April 2000. In 

this report, the SAB reinforced its call for a more integrated approach to environmental management noting that a 

“...focus on assessing and controlling chemical contaminants pollutant by pollutant in single media has resulted in a 

regulatory system that is neither systematic nor comprehensive,” and which “...can be inefficient both in reducing 

the major burdens of environmental impacts on human health and ecosystems and in allocating society’s resources 

in the face of multiple demands on limited budgets.” iii National Research Council (2009) Science and Decisions Advancing Risk Assessment, Committee on Improving 

Risk Analysis Approaches Used by the U.S. EPA., Board on Environmental Studies and Toxicology. reinforces the 

call for integration in its framework for risk-based decision-making that imbeds risk assessment within a phased 

process that links assessment to existing real-world conditions and the ultimate use of the assessment itself in 

managing that risk.