UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

 WASHINGTON D.C. 20460 

OFFICE OF THE ADMINISTRATOR 

 SCIENCE ADVISORY BOARD 

November 26, 2008 

EPA-SAB-09-006 

The Honorable Stephen L. Johnson 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460 

Subject: EPA’s Strategic Research Directions 2008: An Advisory by the 

EPA Science Advisory Board 

Dear Administrator Johnson: 

In October 2007, the chartered EPA Science Advisory Board (SAB) initiated a 

series of interactions with EPA's Office of Research and Development (ORD) senior 

management and National Program Directors (NPD) to develop a better understanding of, 

and offer advice on, the strategic directions for EPA's research programs. This set of 

activities was motivated by a desire to move beyond the SAB's annual review of a single 

year's research program budget and to think more strategically about the Agency's overall 

research program in relation both to EPA's stated needs and the SAB's perspectives on

the environmental challenges the Agency is likely to face in coming years. 

The Agency asked the SAB to consider where EPA research should be as it plans 

its research for the next five years and beyond. To assist the SAB in its review, ORD 

prepared an overview of ORD’s strategic research directions for each of its research areas 

and provided brief documents that summarized the strategic directions and current focus 

for each specific area. Additionally, EPA staff and Board members discussed these 

strategic research descriptions in break-out sessions during the October 2007 SAB 

meeting. The SAB continued its discussions of EPA’s research vision in several 

meetings. Though quite valuable, these sessions did not provide sufficient depth of 

information to allow the SAB to develop a detailed understanding of each research area 

or provide a full assessment of those programs. 

However, the briefings and other interactions have provided the SAB with 

sufficient insight about current Agency plans to begin to develop broad strategic advice. 

The SAB plans to continue to conduct follow-up discussions with ORD, and possibly 
other EPA scientists, on EPA’s strategic research program directions and from time to 

time offer additional, more complete and detailed, advice.

 The Agency’s research and development program provides the scientific 

foundation and support for EPA’s actions to carry out its mission to protect human health 

and the environment. Included in these activities are: i) conducting research and 

development to identify, understand, and solve current and future environmental 

problems; ii) providing technical support to EPA’s Programs and Regions; iii) 

collaborating with EPA’s scientific partners in academia, other agencies, state and tribal 

governments, private sector organizations, and nations; and iv) exercising leadership in 

considering and preparing to deal with emerging environmental issues and advancing the 

science and technology of risk assessment and risk management. 

ORD’s research program structure contains sixteen (16) specific research areas. 

These program areas address EPA’s science and technology needs in topics such as: 

human health; air and global change; economics and sustainability; environmental 

technology; ecosystems; water; and homeland security. In this Advisory, the SAB 

discusses and comments on the fundamental and overarching issues associated with these 

programs. More detailed comments are provided in the Appendix of this report. 

The SAB believes that EPA has made progress in identifying the strategic needs 

within its 16 focused research areas. Similarly the National Academy of Sciences has 

remarked on the importance to research efficiency of good planning and implementation, 

and concluded that “...EPA and its ORD have a sound strategic planning architecture that 

provides a multi-year basis for the annual assessment of progress and milestones for 

evaluating research programs, including their efficiency” (NAS, 2008). The SAB is 

pleased by the EPA's efforts to engage in a dialogue on strategic research planning. This 

willingness to engage the Board and others openly about research directions and 

strategies is laudable as EPA comes to grips with the need for major new science 

understandings to meet current environmental protection issues, as well as the emerging 

issues that will be a part of its mission in the future. 

The Agency's current 16 focal areas are important. However, if it is to be prepared 

to address future needs, EPA’s research program will have to adopt a more integrated 

view, one that reflects the inherent complexities and interconnections among human and 

ecological systems, gives greater consideration to feedbacks, and focuses on the relevant 

scales of each issue. In this context, it is clear that if the Agency is to truly protect the 

environment, it must undertake a larger program of research that goes beyond its 

immediate regulatory needs and address the broad array of environmental problems 

facing the nation. 

Of course, focused research in support of current regulatory programs is needed. 

However, it appears to the SAB that a balanced program that has been recommended by 

the SAB and the National Academy of Sciences in a number of past reports (NAS, 2000; 

SAB, 2006; SAB 2007) is being lost as a result of constant pressures to address the near2 
term data needs of the Agency’s operating programs in the face of ever more serious 

resource constraints. 

 Several changes are needed to address pressing environmental problems that do not 

fall neatly within existing regulatory mandates. Today these needs are only addressed 

within the Agency's research plans in fragmentary ways, even though they are often 

interrelated. In its research programs, the SAB believes that EPA should: 

1) Broaden the interpretation of "land preservation" to take a greater leadership 

role in future land-use decision making and in managing the consequences of biofuels, sprawl, green-field development, and the pressures of unconstrained coastal 

development. This program has historically focused on cleanup activities 

associated with contaminated sites and releases. In addition, issues associated 

with the Resource Conservation Challenge have been a part of the program. 

Though latitude for change in this program may be limited by funding 

restrictions, EPA should consider broadening the program to enable it to focus on 

issues that are key to the success of EPA’s new Sustainability programs, including 

research to understand the environmental and ecosystem consequences of 

incentive structures associated with land use decisions. 

2) Expand the focus on the environmental consequences of new technologies to 

include a broader consideration of the life-cycle of new products and their 

globalization. Understanding changes in where and how products are 

manufactured and in the types of products manufactured are important to 

understanding risks. Shifting locations of production within and outside the U.S. 

can present unique risks to the U.S. population (e.g., changed water and energy 

usage and availability, contaminated products, long-range transport of pollutants, 

and movement of living organisms to new locations of the world, to name a few). 

EPA must conduct research to better understand these issues and how they 

influence human health and the environment, as well as conduct research on the 

efficacy of alternative regulatory mechanisms for protecting human health and the 

environment in the face of these changes. 

3) Expand the analysis of water infrastructures, supply, demand and quality in light 

of changing socio-economic pressures and climate. Increased water demand from

expanding populations in water-short or drought-stricken areas is leading 

governments and agencies to consider agreements for large-scale transfers of 

water from one watershed or region to another. EPA needs to conduct research 

that will improve our understanding of ecosystem and service impacts associated 

with such transfers to be prepared to make informed decisions on water 

management issues in the future. 

4) Reinvigorate and modernize research on sensitive human and ecological 

populations including research involving chemical mixtures. EPA should 

continue to give primary emphasis to sensitive populations – this information 

will also provide critical data to protect the general population. In this sense, 

3 
sensitive populations refer to humans as well as to plant and animal populations, 

where the latter may be part of an interdependent ecological web. These studies 

will also help identify effective interventions when needed. Studies should also 

address the critical need for information on chemical mixtures that are reflective 

of actual situations in the world.

5) Improve the science foundation needed to respond to unexpected and emerging 

problems and environmental disasters. The science and technologies impinging 

on human health and environmental evaluations are exponentially expanding in 

terms of complexity and pace of development. Examples include the likely 

emergence of transforming sciences such as toxicogenomics and 

nanotechnology. Resource-limited organizations such as EPA will be 

increasingly challenged to develop creative mechanisms to provide the Agency 

access to this science within the realistic constraints of EPA human and budget 

resources. On the topic of environmental disasters, the SAB has recently sent you 

a separate self initiated report, which includes a number of research 

recommendations (SAB, 2008). 

6) Expand policy-relevant research on developing, testing and evaluating new and 

innovative alternatives to conventional command and control regulation. There

is a modest research literature on the relative advantages and disadvantages of 

different approaches in different contexts and on the development of new 

approaches. However, that literature is too small and insufficiently 

comprehensive given the importance of the issues that are at stake. Since existing 

programs are subject to review from time to time, and new issues such as the need 

to control of the emissions of greenhouse gases will likely arise in the future, the 

Agency would be well advised to build a vigorous research program that is 

focused on developing, testing and evaluating alternative strategies that might be 

able to more effectively and efficiently achieve future environmental goals. 

7) Improve dramatically the integration of economics and the decision and 

behavioral social sciences into research and policy development across the 

Agency. The new research focus on ecosystem services is designed to provide 

inputs in a form that can be used in economic analysis and assessment of Agency 

programs. However, to be successful, evaluations of ecosystem services must 

build on an underpinning of solid ecological science, an area in which EPA has 

recently been dramatically reducing its research investments. The Agency will 

need to reverse this trend if the effort in ecosystem services is to meet its full 

potential. While the agency has reasonable staff resources in economics, and 

maintains some research on issues in environmental economics, its capability in 

the behavioral social sciences, and decision sciences, is so limited that it typically 

is not even in a position to ask the right questions. Given that risk perceptions 

and the behavioral response of members of the public are central to the design of 

many of the Agency's most important programs, the lack of staff resources and 

the absence of a coherent behavioral and sciences research program is a 

deficiency in urgent need of attention.

4 
8) Continue to work on improving the effective communication of research results to 

potential users both inside and outside the Agency. The Agency has a variety of 

formal and informal strategies to move the results of its research into the hands of 

government and private decision makers, research groups in universities and the 

private sector, and the general public. Clearly if the results of EPA research are to 

have maximum value in promoting good environmental understanding, and 

informed decision making, these activities will require continued attention. 

 

The SAB appreciates the very considerable assistance that it has received from

Senior Staff in ORD, and the ongoing opportunity to work with the Agency in 

understanding and contributing to the improvement of its research vision. With a 

renewed commitment to reversing the recent trend of shrinking ORD research budgets, 

the SAB believes that EPA research will be able to address, well, the Agency’s future

needs for knowledge of human health, ecosystems, human behavior and the environment. 

In doing this, it should strive to build a broader and more forward-looking research 

program, and continue its efforts to break down barriers and promote greater strategic 

integration across its research programs. The SAB also believes that in this way, EPA 

research can set a high standard internationally for creative, forward looking, missionmotivated environmental research. 

The SAB looks forward to your comments on its reflections on the EPA strategic 

research vision, and to its continued interactions with EPA on these critically important 

issues. 

 Sincerely, 

 / Signed / / Signed / 

Dr. Deborah L. Swackhamer, Chair Dr. M. Granger Morgan 

Science Advisory Board Immediate Past Chair 

 Science Advisory Board

 

5 
NOTICE 

This report has been written as part of the activities of the EPA Science Advisory Board (SAB), 

a public advisory group providing extramural scientific information and advice to the 

Administrator and other officials of the Environmental Protection Agency. The SAB is 

structured to provide balanced, expert assessment of scientific matters related to problems facing 

the Agency. This report has not been reviewed for approval by the Agency and, hence, the 

contents of this report do not necessarily represent the views and policies of the Environmental 

Protection Agency, nor of other agencies in the Executive Branch of the Federal government, nor 

does mention of trade names of commercial products constitute a recommendation for use. 

Reports of the SAB are posted on the EPA website at http://www.epa.gov/sab. 

i 
U.S. Environmental Protection Agency 

Science Advisory Board 2008* 

CHAIR

Dr. M. Granger Morgan, Lord Chair Professor in Engineering; Professor and Department Head, 

Department of Engineering and Public Policy, Carnegie Mellon University, Pittsburgh, PA 

SAB MEMBERS

Dr. Thomas Burke, Professor and Co-Director Risk Sciences and Public Policy Institute, Bloomberg 

School of Public Health The Johns Hopkins University, Baltimore, MD 

Dr. James Bus, Director of External Technology, Toxicology and Environmental Research and 

Consulting, The Dow Chemical Company, Midland, MI 

Dr. Deborah Cory-Slechta, J. Lowell Orbison Distinguished Alumni Professor of Environmental 

Medicine, Department of Environmental Medicine, School of Medicine and Dentistry, University of 

Rochester, Rochester, NY

Dr. Virginia Dale, Corporate Fellow, Environmental Sciences Division, Oak Ridge National Laboratory,

Oak Ridge, TN 

Dr. Kenneth Dickson, Professor, Institute of Applied Sciences, University of North Texas, 

Denton, TX 

Dr. David Dzombak, Professor, Department of Civil and Environmental Engineering, Carnegie Mellon 

University, Pittsburgh, PA 

Dr. Baruch Fischhoff, Howard Heinz University Professor, Department of Social and Decision Sciences, 

Department of Engineering and Public Policy, Carnegie Mellon University, Pittsburgh, PA 

Dr. James Galloway, Professor, Department of Environmental Sciences, University of Virginia, 

Charlottesville, VA 

Dr. James K. Hammitt, Professor of Economics and Decision Sciences, Harvard Center for Risk 

Analysis, Harvard University, Boston, MA 

Dr. Rogene Henderson, Scientist Emeritus, Lovelace Respiratory Research Institute, Albuquerque, NM 

Dr. James H. Johnson, Professor and Dean, College of Engineering, Architecture & Computer Sciences, 

Howard University, Washington, DC 

Dr. Bernd Kahn, Professor Emeritus and Director, Environmental Resources Center, School of Nuclear 

Engineering and Health Physics, Georgia Institute of Technology, Atlanta, GA 

 __________

*The SAB roster reflects the membership during Fiscal Year 2008. 

ii 
 

Dr. Agnes Kane, Professor and Chair, Department of Pathology and Laboratory Medicine, Brown 

University, Providence, RI 

Dr. Meryl Karol, Professor Emerita, Graduate School of Public Health, University of Pittsburgh, 

Pittsburgh, PA

Dr. Catherine Kling, Professor, Department of Economics, Iowa State University, Ames, IA 

Dr. George Lambert, Associate Professor of Pediatrics, Director, Center for Childhood 

Neurotoxicology, Robert Wood Johnson Medical School-UMDNJ, Belle Mead, NJ 

Dr. Jill Lipoti, Director, Division of Environmental Safety and Health, New Jersey Department of 

Environmental Protection, Trenton, NJ 

 

Dr. Michael J. McFarland, Associate Professor, Department of Civil and Environmental Engineering, 

Utah State University, Logan, UT 

Dr. Judith L. Meyer, Distinguished Research Professor Emeritus, Institute of Ecology, University of 

Georgia, Lopez Island, WA 

Dr. Jana Milford, Associate Professor, Department of Mechanical Engineering, University of Colorado, 

Boulder, CO 

Dr. Rebecca Parkin, Professor and Associate Dean, Environmental and Occupational Health, School of 

Public Health and Health Services, The George Washington University Medical Center, Washington, DC 

Mr. David Rejeski, Director, Foresight and Governance Project , Woodrow Wilson International Center 

for Scholars, Washington, DC 

Dr. Stephen M. Roberts, Professor, Department of Physiological Sciences, Director, Center for 

Environmental and Human Toxicology, University of Florida, Gainesville, FL 

Dr. Joan B. Rose, Professor and Homer Nowlin Chair for Water Research, Department of Fisheries and 

Wildlife, Michigan State University

Dr. James Sanders, Director, Skidaway Institute of Oceanography, Savannah, GA 

Dr. Jerald Schnoor, Allen S. Henry Chair Professor, Department of Civil and Environmental 

Engineering, Co-Director, Center for Global and Regional Environmental Research, University of Iowa, 

Iowa City, IA 

Dr. Kathleen Segerson, Professor, Department of Economics, University of Connecticut, Storrs, CT 

Dr. Kristin Shrader-Frechette, O'Neil Professor of Philosophy, Department of Biological Sciences and 

Philosophy Department, University of Notre Dame, Notre Dame, IN 

Dr. Kerry Smith, W.P. Carey Professor of Economics, Dept. of Economics, Carey Scl of Business, 

Arizona State University, Tempe, AZ 

Dr. Deborah Swackhamer, Professor, School of Public Health and Co-Director, Water Resources 

iii 
Center, University of Minnesota, Minneapolis and St. Paul, MN 

Dr. Thomas L. Theis, Director, Institute for Environmental Science and Policy, University of Illinois at 

Chicago, Chicago, IL 

Dr. Valerie Thomas, Anderson Interface Associate Professor, School of Industrial and Systems 

Engineering, Georgia Institute of Technology, Atlanta, GA 

Dr. Barton H. (Buzz) Thompson, Jr., Robert E. Paradise Professor of Natural Resources Law at the 

Stanford Law School and Director, Woods Institute for the Environment Director, Stanford University, 

Stanford, CA 

Dr. Robert Twiss, Professor Emeritus, University of California-Berkeley, Ross, CA 

Dr. Lauren Zeise, Chief, Reproductive and Cancer Hazard Assessment Branch, Office of Environmental 

Health Hazard Assessment, California Environmental Protection Agency, Oakland, CA 

LIAISONS

Dr. Steven Heeringa, (FIFRA SAP), Research Scientist and Director, Statistical Design Group, 

Institute for Social Research (ISR), University of Michigan, Ann Arbor, MI 

Dr. Melanie Marty, (CHPAC Chair), Chief, Air Toxicology and Epidemiology Branch, Office 

of Environmental Health Hazard Assessment, California EPA, Oakland, CA 

Dr. Henry Anderson, (CHPAC Alternate), Chief Medical Officer, Division of Public Health, 

Wisconsin Division of Public Health, Madison, WI

SCIENCE ADVISORY BOARD STAFF

Mr. Thomas Miller, Designated Federal Officer, 1200 Pennsylvania Avenue, NW 

1400F, Washington, DC, 20460

iv 
Table of Contents 

1. Introduction................................................................................................................................ 1

2. US EPA Research Program Structure......................................................................................... 2 

3. Response to the Charge............................................................................................................... 4

3.1 General Comments................................................................................................................ 4 

3.2 Human Resources for the Conduct of Science at EPA....................................................... 10 

3.3 Comments on Research Effectiveness and Efficiency........................................................ 12 

3.4 Moving Forward with the SAB – EPA Strategic Research Discussions............................ 16

Appendix A SAB Comments on Specific Research Areas....................................................... A-1 

v 
EPA’s Strategic Research Directions 2008: An SAB Advisory 

1. Introduction

The EPA Science Advisory Board (SAB), senior managers of the EPA Office of 

Research and Development (ORD), and the ORD National Program Directors (NPD), 

began an evaluation and dialog on the strategic directions for EPA's research program in 

October, 2007. This dialog has continued over several meetings since that time, and the 

parties intend that these discussions continue for at least the next several years. This 

interaction between the SAB and EPA is motivated by a desire to begin to think about 

EPA's strategic vision for research in a way that is broader than the view that can be 

obtained through the lens of each year's annual review of the EPA research program

budget. Both the SAB and EPA want to engage and to think more strategically about the 

Agency's overall research program in relation both to EPA's stated needs and the SAB's 

perspectives on the environmental challenges the Agency is likely to face in coming 

years. 

In initiating this interaction, the EPA Assistant Administrator for Research and 

Development asked the SAB to consider the strategic directions for EPA's 16 specific 

research areas and to provide its perspectives on: 

a) Where EPA research should be in the next five years, i.e., 2012 and beyond in 

terms of: 

i. Research areas that will need continued emphasis; 

ii. Research areas that might need increased emphasis; and 

iii. Research areas that might be given decreased emphasis over the next several 

years. 

b) What scientific factors EPA should consider to get to this point?

i. Changes in “environmental science" itself;

ii. Ways in which the workforce, and the skills available through the workforce, 

might be adjusted to further evolve and improve the research program (i.e., 

strategic workforce planning); and 

iii. Opportunities for efficiency 

• Are there areas with opportunities for greater coordination and synergy 

within ORD, across EPA, and across other organizations both inside and 

outside of government; 

• Are there other research “themes” that could strengthen EPA’s research 

strategy (e.g., cross-cutting advice on sprawl, disasters, climate change); 

and 

• How might the SAB – EPA dialogue on strategic science planning for 

research be improved in the future?

1 
Section 1 of this “enclosure to the letter to the Administrator” is this Introduction. 

Section 2 identifies EPA’s 16 research areas as they were presented to the SAB during 

October 2007 and groups them according to how they were considered by the SAB at that 

meeting and since. In Section 3 the SAB offers its initial response to the Agency’s 

charge to the SAB for these interactions. Specifically, Section 3.1 offers general SAB 

comments on a number of overarching issues that emerged during its October 2007 

discussions with EPA on its strategic research directions. In Section 3.2 the SAB 

comments on the human scientific resource needs of EPA, focusing on the problems of 

sustaining and renewing EPA's excellent and highly motivated scientific research staff. 

In Section 3.3 the SAB comments on strategies that ORD might consider in enhancing its 

research effectiveness and efficiency. In Section 3.4 the SAB offers some suggestions 

for additional dialogue between the SAB and EPA on its strategic research vision. 

Finally, in the Enclosure, the SAB offers more specific comments on the current research 

program directions described in EPA’s 16 strategic research area descriptions (SAB, 

2007a). However, as noted above, these are preliminary comments because the depth 

with which the SAB was able to learn about each strategic research area was at best 

modest during these initial interactions with ORD. 

2. EPA Research Program Structure

The EPA Office of Research and Development (ORD) began a new strategic 

planning effort during 2006 that involved ORD’s National Program Directors (NPD), the 

ORD Executive Council (OEC) and the ORD Science Council (SC). ORD also involved 

EPA’s program and regional offices in this effort. 

ORD research is intended to provide the scientific foundation to support EPA’s 

mission by: 

a) conducting research and development to identify, understand, and solve 

current and future environmental problems; 

b) providing responsive technical support to EPA’s Programs and Regions; 

c) collaborating with EPA’s scientific partners in academia, other agencies, state 

and tribal governments, private sector organizations, and nations; and 

d) exercising leadership in addressing emerging environmental issues and 

advancing the science and technology of risk assessment and risk management. 

For its interactions with the SAB, ORD structured its research program

descriptions around sixteen specific research areas. These program areas are summarized 

in a set of strategic documents that formed the information base for the SAB – EPA 

discussions during its October 2007 meeting. The sixteen specific research programs are 

listed in Table 1. 

2 
Because of an SAB request during the SAB-EPA interaction on the FY 2008 and 

2009 research budgets, ORD moved toward discussing examples of cross-cutting 

research (e.g., in cross cutting areas such as sprawl, climate change, sensitive 

populations, etc.). Though a cross-cutting view of these themes is not directly addressed 

in the descriptions listed in Table 1, ORD can identify and describe a number of linkages 

across research areas and they jointly plan some parts of this research across a variety of 

specific areas. In addition, EPA views the individual programs as being either ProgramTargeted Research (e.g., Clean Air, Drinking Water, Water Quality, Land Preservation, 

Safe Pesticides and Products, Homeland Security, Global Change, and GEOSS/AMI) or 

Cross-Program Research (e.g., Human Health, Computational Toxicology, Human 

Health Risk Assessment, Endocrine Disrupting Chemicals, Ecosystems, Economics and 

Decision Sciences, Science and Technology for Sustainability, and Nanotechnology). 

Table 1. EPA Research Areas 

SAB Grouping ORD Research Areas 

Technology i) Land Preservation and Restoration

ii) Nanotechnology

iii) GEOSS / Advanced Monitoring Initiative 

Economics and Sustainability i) Economics and Decision Sciences 

ii) Technology for Sustainability

Ecosystems, Water and

Security 

i) Ecosystems Protection

ii) Water Quality 

iii) Drinking Water 

iv) Homeland Security 

Air and Global Change i) Clean Air 

ii) Global Change

Human Health i) Human Health

ii) Computational Toxicology

iii) Endocrine Disruptors 

iv) Human Health Risk Assessment 

v) Safe Pesticides and Products 

3 
3. Response to the Charge

3.1 General Comments 

The SAB believes that EPA has made progress in identifying the strategic needs 

within its sixteen focused research areas. Similarly the National Academy of Sciences 

Committee on Evaluating the Efficiency of Research and Development at the U.S. 

Environmental Protection Agency1

 has noted, “The key to research efficiency is good 

planning and implementation. EPA and its ORD have a sound strategic planning 

architecture that provides a multi-year basis for the annual assessment of progress and

milestones for evaluating research programs, including their efficiency” (NRC, 2008)2

. 

The SAB is pleased by the EPA's efforts to engage in a dialogue on strategic 

research planning. This willingness to engage the Board and others openly about 

research directions and strategies is laudable as EPA comes to grips with the need for 

major new science understandings to meet current environmental protection issues, as 

well as the emerging issues that will be a part of its mission in the future. 

All of the Agency's current focal areas are individually important. However, if it is 

to be prepared to address future needs, EPA’s research program should adopt a more 

integrated view, one that recognizes the inherent complexities and interconnections

among human and ecological systems, gives greater consideration to feedbacks, and 

focuses on the relevant scales of each issue. In this context, it is clear that if the Agency 

is to truly protect the environment, it must undertake a larger program of research that 

goes beyond its immediate regulatory needs and addresses the broad array of 

environmental problems facing the nation. 

Of course, focused research in support of current regulatory programs is needed. 

However, it appears to the SAB that a balanced program that has been recommended by 

the SAB and the National Academy of Sciences in a number of past reports (NRC, 2000; 

SAB, 2006; SAB 2007) is being lost as a result of constant pressures to address the nearterm data needs of the Agency’s operating programs in the face of ever more serious 

resource constraints. 

 

1

National Research Council, Evaluating Research Efficiency in the U.S. Environmental Protection Agency, 

Report of the Committee On Evaluating The Efficiency Of Research And Development Programs At The 

U.S. Environmental Protection Agency, 132pp, 2008. 

2

The NRC Committee also provided a framework for evaluating the efficiency of EPA research. The

Committee identified two types of research efficiency. Investment Efficiency addresses three questions: 

are the right investments being made, is the research being performed at a high level of quality, and are 

timely and effective adjustments being made in the multi-year course of the work to reflect new scientific

information. NAS states that these questions are best evaluated by use of expert judgment not quantitative 

measures. Process Efficiency involves quantitative measures of inputs and outputs (e.g., publication rates, 

time required to conduct research, and percent of grants that are peer-reviewed) and these can be measured 

in units such as dollars, hours and numbers. PART emphasizes Process Efficiency. Investment Efficiency

is best judged by expert advice. 

4 
 Several changes are needed to address pressing environmental problems that do not 

fall neatly within existing regulatory mandates. Today these needs are only addressed 

within the Agency's research plans in fragmentary ways. In its research programs, the 

SAB believes that EPA should: 

1) Broaden the interpretation of "land preservation" to take a greater 

leadership role in future land-use decision making and in managing the 

consequences of bio-fuels, sprawl, green-field development, and the pressures 

of unconstrained coastal development.

The Agency’s Land Preservation area has historically focused on cleanup 

activities associated with contaminated sites, uncontrolled releases, spills, and 

leaking underground tanks. There are genuine, and considerable, needs 

associated with containing and removing contamination in the land environment, 

but while the Agency continues to address these issues, the Board believes that its 

focus should be broadened. For example, there is little research on land use topics 

such as measuring the benefits of Brownfields clean up and revitalization, urban 

sprawl and the built environment, and the multiple land sustainability issues that

surround agriculture and biofuels. 

There have been recent efforts to include waste minimization activities, mostly 

through the Resource Conservation Challenge (RCC), a voluntary partnering 

program aimed at helping companies and institutions overcome barriers to 

implementing waste minimization programs. This is a potentially valuable 

program, but it has not been systematically evaluated to assess its efficacy or to 

develop plans for improvement. This should be done. 

Private actions associated with land use decisions, local and regional land use 

policies motivated by short-term commercial concerns (especially in coastal 

regions), water needs for residential and agriculture uses, bio-fuels as responses to 

shortfalls in conventional energy resources, globalization of the supply chain for 

increasing numbers of commodities and numerous other examples, illustrate 

choices made in response to the incentives provided by private markets and 

current regulations. Too often we learn the environmental consequences of these 

incentive structures only after problems have emerged. EPA’s research in all 

media needs to better anticipate environmental and ecosystem costs and benefits 

of the incentives faced by independent individuals and organizations as they make 

decisions and drive developmental choices. 

2) Expand the focus on the environmental consequences of new technologies to 

include a broader consideration of the life-cycle of new products and their 

globalization.

A number of factors associated with product life cycles influence the types of 

risks that are emerging in the U.S. and worldwide, as well as how and why those 

risks emerge. It matters where products are manufactured and how they are 

5 
manufactured. In addition, new technologies are emerging that will have to be 

considered in view of their own life cycles. 

EPA needs to understand where things will be manufactured in the future. Thirty 

years ago, 80 percent of automobile-related manufacturing took place in less than 

20 counties in the U.S. Today that number is less than 50 percent. Auto 

manufacturing left the Rustbelt and moved into the American southeast (a shift 

from Brownfields to Greenfields). Just-in-time inventory processes have 

dramatically increased the transportation-related impacts for the production life 

cycle, especially for high-weight, low value inputs. Thus, the location of 

production and any attendant risks has changed within the U.S. The increase of 

international trade has made it more important to think about how human health 

and the environment in the U.S. might be influenced by manufacturing outside 

our boarders. 

Examples of US human health and environmental problems that can result, at 

least partially from pollution released in other countries, include not only global 

effects such as climate change and stratospheric ozone depletion, but also 

environmental transport of pollutants such as particulate matter and mercury. 

Additionally, transport of contaminants through products (e.g., lead in children’s 

toys; pesticides in food products), and accidental or incidental transport of living 

organisms associated with increased global transportation (e.g., invasive species 

such as zebra mussels, disease vectors) can cause adverse effects to human health 

and the environment in the U.S. 

ORD should develop mechanisms, and next generation of environmental impact 

assessment tools, to anticipate significant changes in the methods and locations of 

industrial production that could have impacts on EPA’s mission and programs. 

Shifts in hydrocarbon synthesis (biofuels) are already on the radar screen but 

other changes loom large. Research is needed to better understand the effects of 

globalization on risks to human health and the environment in the US and 

elsewhere. 

Production locations and methods are not only changing for existing products, but 

new technologies are giving rise to new types of products that must be evaluated. 

For example, to continue to reduce the cost and size of computer chips, the 

semiconductor industry is exploring alternative production methods ranging from

water-based lithography to the use of DNA and nano-scale quantum techniques to 

produce logic. Similar transitions are underway in the production of batteries as 

companies explore alternatives to lithium ion such as nano-phosphate. These 

shifts in industrial production methods could result in dramatic changes in 

material inputs, water and energy requirements, emissions, and end-of-life issues. 

When they happen, where, and how all need to be better understood by EPA. 

The growing globalization of the world’s economy also presents challenges. 

When supply chains stretch to other parts of the world, especially into developing 

6 
countries, it becomes difficult to assure that environmental impacts are being 

adequately addressed. This can be further complicated by World Trade 

Organization (WTO) free-trade rules. There is a need for work on alternative 

approaches such as programs to assist non-US producers in developing or 

adopting more environmentally or health-friendly products and processes (e.g., 

ongoing US-China efforts, development of energy-star, and other product 

standards). 

3) Expand the analysis of water infrastructures, supply, demand and quality in 

light of changing socio-economic pressures and climate. 

Expanding populations, depleted reserves of fossil ground water, and the growing 

impacts of climate change are making water supply an ever more pressing issue in 

a number of water-short or drought-stricken areas of the U.S. such as, Atlanta, 

Las Vegas, and Phoenix. This, in turn, is leading local government water 

management agencies to negotiate agreements for large-scale transfers of water 

from distant regions. The long-term ecosystem and ecosystem service impacts, 

and water quality impacts, of such transfers have received little study. Because 

interest in inter-basin transfers of water is likely to grow in the future, an 

improved understanding of the ecosystem impacts associated with such transfers 

will be necessary to make informed decisions on regional and interstate water 

management/reuse as well as land uses which contribute to increased water 

demand. In addition, these impacts must also be understood in the context of 

climate change. 

These first three items reflect problems that arise when many independent decisions 

are made by individuals and organizations that do not face prices, other incentives, or 

regulations that capture the externalities, full life cycle and longer term consequences of 

these decisions. Rather than dealing with the consequences piecemeal and after the fact, 

it would be wise for the Agency to begin to more systematically think about how it might 

become more anticipatory in addressing such issues. 

4) Reinvigorate and modernize research on sensitive human and ecological 

populations including research on chemical mixtures.

The study and protection of sensitive populations (including plants, animal, and 

human) should continue to be a prime emphasis for the EPA. If the Agency 

protects those populations that may be the most susceptible to toxins and other 

stressors it will likely fulfill its primary mission of protecting the general 

population. While this has always been a key part of EPT’s mission, new 

advanced experimental methods hold the potential to dramatically strengthen and 

support this effort. 

 

Sensitive human groups include populations at various stages of life (fetus, 

pregnant females, children, elderly, etc) and populations of individuals with 

specific diseases (such as asthma), specific genotypes, or specific exposures. 

7 
Studies of these sensitive populations, not only provide critical data to protect the 

general population, but also provide insight into what chemicals are toxic, their 

mechanism of action or pathways of toxicity, and potentially help to identify

opportunities to protect these populations and the general population as a whole. 

Studies of effects on sensitive plant and animal populations, where these may be 

part of an interdependent ecological web, are also important. Such studies will 

also provide insight to mechanisms of action of environmental chemicals and 

possibly avenues of intervention (including nutrapharmaceuticals, nutrition, etc) 

when various species or ecosystems are at risk. The study of these sensitive plant 

and animal populations is also important in helping to understand the effects of 

population losses on the entire ecosystems. The study of sensitive populations 

must also consider how changes to sensitive ecosystems can affect the entire 

system. 

Often, environmental research and environmental protection actions focus on 

single pollutants, species, or stressors. While valuable, such work often fails to 

reflect the mixture of exposures that arise in the field. 

Mixtures pose an enormous research challenge. Developing general ways to 

determine what combinations and in what concentrations are of greatest concerns 

is still largely unresolved problems. While the Agency has made some progress 

on mixtures of agents whose health or other effects are produced by common 

mechanisms (organophosphate pesticides, dioxin), these represent only part of the 

problem. Many mixtures to which people and ecosystems are exposed do not 

have common causal mechanisms; also exposures typically occur within the 

context of other xenobiotic and endogenous chemical stressors as well as nonchemical risk modifiers that can also change the effects resulting from such 

environmental mixture exposures. While some brute force testing of specific 

mixtures is probably necessary, an expanded focus on developing more 

fundamental and generalizable strategies for addressing mixtures is clearly 

warranted. 

5) Improve the science foundation needed to respond to unexpected and 

emerging problems and environmental disasters. 

The science and technologies impinging on human health and environmental 

evaluations are exponentially expanding in terms of complexity and pace of 

development. Examples include the likely emergence of transforming sciences 

such as toxicogenomics and nanotechnology. EPA will be increasingly 

challenged to develop creative mechanisms to provide the Agency access to this 

science within the realistic constraints of EPA human and budget resources. 

The SAB has recently sent the Administrator a separate self initiated report, 

which includes a number of research recommendations that should allow the 

Agency to become better able to anticipate and respond to environmental 

8 
disasters. Rather than repeat those recommendations here readers are referred to 

the SAB report An SAB Advisory: Preparing for Environmental Disasters (EPA 

SAB, 2008). 

 

6) Expand policy relevant research on developing, testing and evaluating new

and innovative alternatives to conventional command and control regulation. 

 

Most of EPA's programs in environmental regulation and control operate under 

legislative mandates that stipulate specific strategies (use best available control 

technology; control to a specific emissions level per unit of activity; adopt a cap 

and trade regime; report all emissions to TRI; etc.). There is a modest research 

literature on the relative advantages and disadvantages of such different 

approaches in different contexts and on the development of new approaches. 

However, that literature is too small and insufficiently comprehensive given the 

importance of the issues that are at stake. Since existing programs are subject to 

review from time to time, and new problems such as control of the emissions of 

greenhouse gases will likely arise in the future, the Agency would be well advised 

to build a large and more vigorous research program that is focused on 

developing, testing and evaluating new alternative strategies that might be able to 

more effectively and efficiently achieve future environmental goals. 

7) Improve dramatically the integration of economics and the decision and 

behavioral social sciences into research and policy development across the 

Agency. 

 

The new research focus on ecosystem services is designed to provide inputs in a 

form that can be used in economic analysis and assessment of Agency programs. 

However, to be successful, evaluations of ecosystem services must build on an 

underpinning of solid ecological science, an area in which EPA has recently been 

dramatically reducing its research investments. The Agency will need to reverse 

this trend if the effort in ecosystem services is to meet its full potential. While the 

agency has reasonable staff resources in economics, and maintains some research 

on issues in environmental economics, its capability in the behavioral and 

decision sciences is so limited that it typically is not even in a position to ask the 

right questions. These are interdisciplinary fields of empirically based social 

science that have seen rapid development over the past few decades. They

provide both valuable insight into how people think about issues of risk and how 

they frame and make decisions in the face of uncertainty. At least as important, 

they offer guidance on how best to design programs and messages to aid citizens 

and others in decision making. At its core, EPA makes decisions to protect 

human health and the environment based on knowledge in several technical areas 

relevant to risk assessment and risk reduction. To be effective, these decisions 

need to be informed by science that studies various environmental issues (domain 

knowledge), decision sciences that identify factual information from these 

domains that are critical to considering what actions should be taken, and 

knowledge from the behavioral social sciences that helps EPA to understand what 

9 
people perceive about this factual basis and how that relates to their goals 

regarding the problem or issue being addressed by the EPA. 

Given that risk perceptions and the behavioral response of members of the public 

are central to the design of many of the Agency's most important programs, the 

lack of staff resources and the absence of a coherent research program is a 

deficiency in urgent need of attention. In the past, ORD teamed with the Decision 

and Management Science program at the National Science Foundation (NSF) to 

support some work in this area. In addition to hiring staff with expertise in this 

area, reestablishing that collaboration might be one strategy by which the Agency 

could move forward. 

8) Continue to work on improving the effective communication of research 

results to potential users both inside and outside the Agency. 

The Agency has a variety of formal and informal strategies to move the results of 

its research into the hands of government and private decision makers, research 

groups in universities, the private sector, and the general public. Clearly if the 

results of EPA research are to have maximum value in promoting good 

environmental understanding and informed decision making, these activities will 

require continued attention. 

Communicating research results to the public, links closely to the issues discussed 

under 7 above, since the effectiveness of such communication can be considerably 

enhanced through the application of good modern empirical methods in 

communication design and evaluation.

With a few exceptions, such as the new initiative in sustainability, most of EPA's 

current research programs are tied to specific media and their focus is driven by current 

regulatory strategies, statutory mandates and needs. The SAB understands the forces and 

budgetary limitations that have created this situation. However, in thinking about 2012 

and beyond the SAB believes that a broader and more systems-oriented approach to 

research will be needed. Many of the elements of such a program already exist, but in the 

words of Administrator Johnson, currently the work is much too "stove-piped." 

3.2 Human Resources for the Conduct of Science at EPA 

In addition to asking the SAB for its views on research needs, EPA expressed an 

interest in the implications of workforce changes on the quality and responsiveness of the 

Agency’s research programs. The question was primarily focused on strategic workforce 

planning, that is, how the skills available through the workforce might be adjusted to 

further evolve and improve the research program. 

While expanding expertise into new areas is important, it is also important to ensure 

that many areas of existing expertise do not undergo erosion as staff turnover occurs from

retirement and limited EPA investments in science staff, laboratory equipment, supplies, 

10 
travel and other things needed for researchers to be able to design and to carry out top 

flight research. 

The SAB has discussed new areas of expertise that will be needed in several of its 

recent reviews of EPA research budgets. Areas of need range from emerging fields such 

as nanotechnology to existing fields in which the agency has insufficient expertise such 

as behavioral and decision sciences. Solving our environmental problems will require

resources. However with many senior people in the existing workforce moving into 

retirement, there may also be opportunities to update the skill base with little increase in 

cost. 

 

The EPA has long enjoyed a remarkably dedicated and highly qualified scientific 

research staff. However, in our discussions with bench-level scientists during our 

October, 2007 visit to RTP, and in the individual interactions that members of the SAB 

have had in recent years with both junior and senior agency researchers, several issues

have emerged that deserve ongoing and expanded attention from EPA’s senior managers. 

These include: 

 

a) The erosion and/or disillusionment of senior staff. Continually shrinking research 

budgets have resulted in growing numbers of senior staff who are becoming 

disillusioned, and this risks loss of the high level of dedication that brought them

to the agency in the first place. 

b) Recruiting and retaining young talent. The agency has developed an outstanding 

program to attract postdoctoral scientists to the ORD labs, and an active program

to recruit new young scientific staff. However, the SAB is concerned that too 

many of the scientists who are participating in these programs are losing interest

when real opportunities and permanent, challenging jobs at the Agency do not 

become available or other more promising opportunities beckon from outside the 

Agency. 

c) Continuing Education and Training. The agency has long had formal and 

informal programs to support continued education, up to and including 

opportunities for MS-level scientists and engineers to pursue PhD studies. 

However, it is time to review and revitalize these activities. 

When the SAB has raised such concerns in the past we have been told that all is well,

and been given survey results to support this assertion. It is not our place to engage in an 

extended debate with Agency personnel on this matter. The SAB once again reports the 

impressions it has developed from its formal and informal interactions with staff at all 

levels across the EPA and with knowledgeable observers on the outside. With the 

exception of our recurrent recommendations to reverse the continued erosion of research 

budgets, the SAB is not close enough to the details of ORD operations to suggest specific 

strategies to address these issues. However we know enough about recent staffing trends 

to recommend that the issues of sustaining and strengthening ORD and the Agency's

scientific human resources deserves continued and expanded attention. 

11 
3.3 Comments on Research Effectiveness and Efficiency 

EPA asked the SAB for advice on whether it sees opportunities for improving the 

research program’s efficiency. Specifically, they asked the SAB to consider there are 

opportunities for greater coordination and synergy within ORD, across EPA, and across 

other organizations both inside and outside of government, and whether the SAB sees 

“themes” that could strengthen EPA’s research strategy. The SAB has discussed a 

number of such themes in the paragraphs above. 

The recent National Academy of Sciences’ report, Evaluating Research Efficiency 

in the US Environmental Protection Agency (NAS, 2008) offers valuable suggestions on 

evaluating both investment efficiency and process efficiency for US EPA research 

programs. The SAB supports the findings of the NRC report and notes that the role of 

expert review by SAB is most helpful in evaluating investment efficiency in research. In 

this regard, the SAB offers the following thoughts for consideration. 

a) Strategies by which the EPA might make greater use of results from its own 

research program (we offer examples in sustainability and in nanotechnology) and 

relevant research from other organizations. 

EPA should be the leader in using its own research results. The following are 

examples of current opportunities: 

i. The recent Agency and government-wide initiative on 

nanotechnology has provided significant research results 

demonstrating the properties of nanomaterials. Incorporation of 

these results in technology development activities into the water and 

air monitoring and treatment holds potential to yield significantly 

improved process performance. 

ii. The Technology for Sustainability Research Program has identified 

three interrelated ideas drawn from economics, social, and 

environmental realms. These have been translated into six program

themes. Integration of the ideas and themes into other research 

programs will yield program results that reflect EPA’s view of “... 

meeting basic environmental, economic, and social needs now and 

in the future without undermining the natural systems upon which 

life depends.” 

iii. The Ecosystem Research Program’s new direction on assessing 

ecosystem services needs to be integrated into Agency Program

offices and should help in prioritizing and evaluating the 

effectiveness of their activities. 

iv. ORD has passed the tools developed in EMAP to the Program and 

Regional offices, however, there is still an on-going need for the 

development of new monitoring strategies and tools. This parallels 

the opportunities in nanotechnology presented above. 

12 
The SAB has noted on many occasions that other governmental and nongovernmental organizations either fund or conduct research that can be useful in 

supporting EPA’s mission achievement. To its credit, EPA has a long history of 

using such results to the extent that they are relevant to EPA’s conduct of its own 

research and in considering the need for action on various environmental issues. 

EPA ORD should continue to actively look for and use the relevant research 

results from other governmental and nongovernmental organizations in ways 

similar to that noted above for its own research results. EPA should enhance and 

improve this effort by instituting a systematic process that ensures that such

research results are captured by EPA and used to support the Agency mission 

when it is appropriate for such uses. This systematic mining of others’ research 

results can also identify opportunities for EPA collaboration and partnerships to 

leverage the use of EPA’s own resources. 

Of course, as the SAB has remarked before, much of the research conducted by 

these outside organizations, though generally categorized as “environmental 

research” is not of the type that directly answers important questions that are 

relevant to EPA’s specific mission. 

b) Strategies to engage citizens for data collection, and for computational 

resources for advanced modeling and analysis.

Communications is shifting from a one-to-many paradigm (i.e., the approach that 

dominated radio and television for decades) to a many-to-many, net-centric 

paradigm. Nicholas Negroponte, the Director of MIT’s Media Lab, called this the 

move from “passive old media” to “interactive new media.” Interconnected 

people now have the technological tools that allow users to generate and distribute 

their own content -- everything from computer code (Linux) to course curriculum

(iTunes University). People can collaborate to make their content better (peer-topeer design and development) and they can apply their collective wisdom to 

solving important scientific challenges. 

To take advantage of these changes, ORD should explore the possibility of 

developing a strategy to engage a new generation of “citizen scientists” to help 

the agency collect, analyze, and apply the results of these activities to 

environmental issues. In this, EPA could consider the integration of citizens and 

outside organizations into their “macroscope”, possibly as a Citizen’s 

Environmental Science Corps. In this manner, EPA could create opportunities for 

citizens to work as observers and participants in a variety of efforts that would be 

useful to EPA’s achievement of its mission. Citizens could perform

measurements, analyze data, and support efforts to attain environmental 

improvements. In addition to making direct observations; such a “Science 

Environmental Corps” might participate in EPA websites to give their advice on 

what EPA should be doing on various issues following a collaborative model of 

the sort illustrated by Wikipedia; and they might analyze EPA’s data bases 

through competitions that reward the best ideas for new environmental science, 

13 
solutions, and technologies3

. The Agency might, with some imaginative effort, 

determine how it could turn a few million GPS-enabled cell phones with cameras 

into a participatory sensing system. EPA might consider using a virtual world 

like Second Life to test reactions to product labeling schemes or work on 

collaborative strategies to manage ecosystems. 

An example of a successful venture in this area is the effort to link together 

America’s 70 million bird watchers. Web-based systems like Bird Source and 

Journey North have allowed birders to share sitings and see new spatial patterns 

of migration never before possible. John Fitzpatrick, director of the Laboratory 

for Ornithology at Cornell, commented that, “We’ll be able to count them, 

monitor them, and observe their population crashes, on a continental scale.” 

In addition, a few years ago, NASA found that people with a bit of training could 

identify craters on the surface of Mars and classify them by age (humans can still 

beat computers on many pattern recognition tasks). Instead of just borrowing 

computer power (SETI project), NASA borrowed the brains of thousands of 

people in what was called the Clickworker’s Project. People did this for the 

challenge and learning experience, not for money. 

More recently, thousands of people poured over satellite images trying to find the 

downed plane of pilot Steve Fossett (Help find Steve Fossett with Google Earth). 

A similar technique was used to search for Jim Gray, a Microsoft scientist who 

went missing on his sailboat off the coast of California. 

c) Expansion and greater integration of behavioral and decision science into many 

ORD research programs

The SAB pointed out in point 7 of this advisory (see pages 9-10) that without a 

scientific understanding of human behavior and decision processes, the EPA 

cannot fulfill its responsibility to the American people. 

An element of human judgment is part of every analysis that the Agency 

conducts. It is present in the definition of fundamental terms, such as risk, 

benefit, exposure, discount rate, and equity. It is present in the selection and 

weighting of data. It is present in the selection of values for sensitivity analyses 

and the assessment of scientific uncertainties. The roles of judgment and their 

limits have been studied extensively for some forty years. If that science is not 

reflected in EPA's analytical processes, then the results of those analyses are less 

than they should be and they are conveyed with greater confidence than is 

warranted. These are the issues that, in part, motivated OMB's Risk Assessment 

Bulletin. Although that effort was faulted as fundamentally flawed by the 

 

3 See for example Don Tapscott and Anthony D. Williams, Wikinomics : how mass collaboration changes 

everything, Portfolio, New York, 351pp, 2008. 

14 
National Academy of Sciences and subsequently abandoned by OMB, the need 

for systematic treatment of scientific judgment remains. 

Many EPA analyses attempt to assess processes that depend on human behavior. 

For example, the risks from toxic chemicals depend on exposure processes shaped 

by human behavior (what people eat, whether they can use protective clothing, 

etc.). They may also depend on the behavior of people who must maintain 

equipment, interpret malfunctions, issue warnings, and respond to cautions or 

evacuation orders. In the publicly available reports from two consultations, the 

SAB's Homeland Security Advisory Committee raised serious questions about the 

behavioral realism of important programs that were sound in other ways. Unless 

EPA bases its analysis on social and behavioral science, its assumptions will be 

little more than guesswork. 

The value of much of EPA's work depends on its ability to convey research and 

analytical results to people who must make decisions informed by them. It is well 

established in the scientific literature that many technical issues are understood in 

different ways by expert and lay audiences. With scientifically sound 

communications, however, it is possible to make research results clear to those 

willing to attend to them. At one time, the Agency was a leader in scientifically 

sound communication. Today, however, EPA’s communications are almost all 

improvised, without any rigorous analytical identification of its audiences'

information needs or empirical evaluation of its effects. As a result, the Agency 

may not only fail to extract the full value of its research, but inadvertently 

misinform its audiences. 

The Agency is in urgent need of an ambitious program of scientific research in the 

behavioral and decision sciences. At the moment, its ranks are so depleted that it 

has difficulty commissioning sound work from the outside, lacking staff with the 

expertise needed to evaluate proposals and products. There is no substitute for 

aggressive hiring, investment in dedicated STAR graduate fellowships, and 

extramural research to fulfill the most pressing gaps until EPA has created 

adequate intramural research programs. As noted above, it may be wise for EPA 

to partner with an agency such as NSF that has social science expertise in order to 

build this program. 

d) An alternative organizational structure for EPA Research

The Agency may wish to consider alternative models for the management of the 

activities pursued within its laboratory system. Historically EPA research has 

been organized according to media-specific, pollutant-specific, and problemspecific areas as well as the risk management paradigm (air, radiation, 

assessment, effects, toxicology, exposure, risk management, homeland security, 

etc.). Such a model has served the regulatory side of the Agency well, but makes 

it difficult to respond to modern environmental problems which are increasingly 

cross-media, systemic, and complex. A focus that is finely tuned to the 

15 
regulatory side of the Agency also is vulnerable to changes in regulatory 

priorities. Over the years the SAB has observed a tendency for calls at EPA to 

shift away from existing research – research that may have taken several years to 

incorporate within plans and budgets – into new areas. This undermines the 

normal pursuit of research which almost always requires consistent attention over 

some protracted timeframe to reach successful conclusion. Alternative models 

that are more adaptive, multidisciplinary, and systems-oriented would allow the 

Agency to better anticipate new environmental challenges, and be less reactive. 

These would very likely permit cost and functional efficiencies to be gained, as 

well as create a more stable research environment within the research 

organization. The Board recognizes that a transition to an alternative model for 

management is a painstaking endeavor accompanied by a culture change and 

resistance by some. The long term rewards, however, might be best for the 

protection of human health and the environment. 

3.4 Moving Forward with the SAB – EPA Strategic Research Discussions 

EPA asked how future SAB-to-EPA interactions on strategic science planning 

might be improved. Since 2005, the annual review of the EPA research budget has been 

the responsibility of the Chartered Science Advisory Board. The SAB made the decision 

to move the review from an SAB subcommittee to the chartered Board because of its 

desire to reflect the importance of the review and because it allowed the Board to add to 

the number of individuals on the team that actually reviewed the report. It also arranged 

for the span of expertise used in the review to be increased. The SAB believes that 

retaining this activity as a Chartered SAB responsibility will allow the improvements 

already gained from this change to be preserved and it will also allow the benefits to be 

increased in the future. 

In its consideration of EPA’s overall research picture, largely through the window 

of a budget review, the SAB has explored a variety of approaches to conduct the actual 

review and considered a variety of types of information that would help it in the conduct 

of these reviews. EPA and the SAB continue to work to identify an optimal set of 

background documents to be given to the SAB so that it can carry out a meaningful 

review of EPA’s research budget. Over time the amount of documentation has 

decreased. The SAB believes that it should continue to work with EPA to refine the set 

of background documents necessary to allow a high quality review of EPA’s research

program portfolio. 

In addition, the SAB and EPA have varied the specific organizations involved in 

the review from having the SAB interact with just ORD to having all the client offices 

participate in the discussions of research needs. This is because the span of activities

conducted under the ORD research and development program overlaps with similar 

activities that are pursued by various program and regional offices. Thus, it has been the 

goal of the SAB and ORD to have regional and program offices all involved in the 

discussions so that the full science program would be a part of the discussions, not just 

that part carried out by ORD. At this point, the Program and Regional Offices are not 

participating in the interaction as fully as the SAB and ORD would like. The SAB 

16 
believes that EPA’s program and regional offices should be more involved in these 

discussions in the future. This is both so that the SAB can learn from programs and 

regions of how well their needs are being met by ORD and also because program and 

regional offices also conduct science activities that are of a similar nature to those 

conducted by ORD. To best provide advice to ORD on how its research efforts should 

evolve, it will be important to understand the full EPA science program and those 

components that are not under the direction of ORD. 

The SAB has long thought that engaging in discussions of the overall research 

program over the long term was not as successful when done in association with 

discussions on EPA’s research budget. Generally, open discussion is restricted when it 

occurs as a part of the budget process because of rules that constrain the Agency’s ability 

to thoroughly discuss how well a given budget meets the needs for conducting research 

that is identified in its long-term strategic planning. Thus, the SAB and ORD agreed to 

separate the two activities into a two-phased process in which the SAB and EPA are 

engaging in a continuing series of discussions of the strategic directions for EPA research 

so that the Board can better understand the overall directions of Agency research and how 

that might change. In addition, the SAB each February evaluates and advises the 

Administrator on the coming year’s research budget in terms of how that budget will 

contribute to the Agency’s accomplishment of the goals and objectives that are embodied 

in the longer term strategic directions for each research program. The SAB believes that 

continuing this separation, and pursuing discussions with EPA over time will contribute 

to better communications between the SAB and ORD on the overall research program. 

This will, in turn, provide a contextual basis for the SAB’s use in advising EPA, and the 

U.S. Congress, on each year’s budget. 

The topics which come to the SAB for consideration and advice differ from those 

sent to the ORD Board of Scientific Counselors (BOSC) and other advisory bodies. For 

example, SAB review topics tend more toward being peer reviews of scientific 

assessments or assessment methods than the actual conduct and progress on specific 

research programs – the latter usually being done by the BOSC. The SAB believes that 

deliberations on the adequacy and completeness of EPA research program strategies and 

budgets could be enhanced if it incorporates additional representation from other 

advisory bodies into its own reviews. The SAB will pursue this for future activities in 

these two areas. 

 

One of the difficulties in evaluating research budgets and strategies from year to 

year comes from changes that EPA makes to the structure, nomenclature, and 

organization of its research programs. Thus, from one year to the next, the location of 

specific research topics might fall within different categories. Further, when considering 

resource levels allocated to specific programs, and to the component activities within 

given programs, it is important to have information on what resource levels are actually 

associated with each component and program from year to year. Without this, it is quite 

difficult to know how a program is progressing over time. In addition, resource 

allocations rarely are given, when they are given, on a consistent basis over a series of 

years (e.g., some years show budget levels while some show appropriated levels) and 

17 
thus it is difficult to see resource trends over time. The SAB believes that its discussions 

on EPA research could be improved if it could be provided with a consistent set of 

resource numbers over a period of at least 5 years for specific programs and program

components. Further, if requirements change in a way that causes programs, and their 

components, to be renamed from one year to the next, information should be provided 

that makes those changes clear. 

Specific research programs carried out by or for EPA, typically, do have an actual 

beginning and end. Often the end of an activity within an ORD research program signals 

the need for a follow-on action by a Program or Regional Office. The SAB believes that 

improved consideration of EPA’s research programs conducted by ORD could be gained 

from participation of Regional and Program Office personnel who could indicate how 

specific completed research activities are to be implemented in their own offices (e.g., the 

continuation of the EMAP is such an issue since it is being indicated by ORD now as an 

area where research has completed the development of a method/approach and that the 

benefits gained from information coming from implementation of those methods will 

now be the responsibility of other EPA offices. Knowing that such things will happen is 

important to the SAB as it develops its advice on ORD’s research programs and budgets). 

18 
APPENDIX A 

SAB Comments on EPA’s Specific Research Areas

Contents 

Introduction................................................................................................................... A-2 

2. Comments on Specific EPA Research Programs................................................... A-2 

2.1 Technology Research Areas............................................................................... A-2 

2.1.1 Land Preservation & Restoration ............................................................. A-2 

2.1.2 Nanotechnology Research .......................................................................... A-3 

2.1.3 Global Earth Observation System of Systems (GEOSS)/Advanced 

Monitoring Initiative ............................................................................................ A-4 

2.2 Economics and Sustainability Research Areas ............................................... A-6 

2.2.1 Economics and Decision Sciences.............................................................. A-6 

2.2.2 Technology for Sustainability .................................................................... A-8 

2.3 Ecosystems, Water and Security Research Areas......................................... A-10 

2.3.1 Ecosystem Protection................................................................................. A-10 

2.3.2 Water Quality............................................................................................. A-12 

2.3.3 Drinking Water ......................................................................................... A-13 

2.3.4 Homeland Security.................................................................................... A-14 

2.4 Air and Global Change Research Area ......................................................... A-15 

2.4.1 Clean Air Research................................................................................... A-15 

2.4.2Global Change Research............................................................................ A-16 

2.5 Human Health Research Area........................................................................ A-17 

2.5.1 Human Health........................................................................................... A-18 

2.5.2 Computational Toxicology ....................................................................... A-20 

2.5.3 Endocrine Disruptors............................................................................... A-20 

2.5.4 Human Health Risk Assessment.............................................................. A-21 

2.5.5 Safe Pesticides and Products.................................................................... A-22 

ATTACHMENT 1: ADDITIONAL DISCUSSION............................................ A-24 

1. Detailed Recommendations Technology for Sustainability Research 

Program ............................................................................................................... A-24 

2. Additional Research Topics For the Human Health Area.......................... A-26 

A-1 
1. Introduction

This Appendix contains specific comments of members of the EPA Science 

Advisory Board (SAB) Subgroups that were established by the SAB to evaluate and 

comment on each of the Office of Research and Development’s (ORD) research program

areas. General comments are contained in the SAB Advisory to which this Appendix is 

attached. The comments in this Appendix are the interim responses of the review Teams 

that evaluated the EPA strategic directions research materials during the meetings from 

October 2007 through July 2008. Sections 2.1 through 2.5 of this Appendix discuss the 

research areas within each team’s primary purview, the key directions for the research in 

each of the specific research areas, and provide the SAB’s initial comments on each of 

the specific research areas. 

2. Comments on Specific EPA Research Programs 

2.1 Technology Research Areas

For the purposes of these discussions between the SAB and ORD, the 

Technology Research Area includes: i) Land Preservation and Restoration, ii) 

Nanotechnology, and the iii) Global Earth Observation System of 

Systems/Advanced Monitoring Initiative (GEOSS/AMI). Each of these programs 

has attributes the SAB believes represent the evolution and revolution of changes 

in the environmental arena. Research activities in the Land Preservation and 

Restoration Program have evolved from the traditional studies on hazardous waste 

treatment and management to Brownfields cleanup and revitalization. The 

Nanotechnology Research and GEOSS/AMI represent strategic research 

initiatives on the implications of modern technology and on innovative uses of 

data to support EPA’s mission. 

 

2.1.1 Land Preservation & Restoration research supports the needs of the 

Office of Solid Waste and Emergency Response (OSWER) as it 

implements provisions of the Resource Conservation and Recovery Act 

(RCRA), the Comprehensive Environmental Response, Compensation, and 

Liability Act (CERCLA), and the Superfund Amendments and 

Reauthorization Act (SARA) in the detection, assessment, and evaluation of 

the effects on and risks to human health of hazardous substances in the 

environment. The purpose of the research program is to provide more costeffective tools, models, and methods to support decisions on land 

restoration, materials management, and reuse/land revitalization (SAB, 

2007a). 

The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

 

• Development of sustainable planning criteria for land use plans, e.g., 

Brownfields. 

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• Evaluation of alternative remediation technologies for contaminated 

sediments. 

• In situ treatments and permeable reactive barriers for ground water 

protection, study of the operation of landfills as bioreactors, and 

assessment of asbestos risks. 

SAB Comments: The Agency’s Land Preservation area has historically 

focused on cleanup activities associated with contaminated sites, 

uncontrolled releases, spills, and leaking underground tanks. More 

recently efforts have been made to include waste minimization activities, 

mostly through the Resource Conservation Challenge (RCC), a voluntary 

partnering program aimed at helping companies and institutions overcome 

barriers to implementing waste minimization programs. This is a 

potentially valuable program, but it needs to be systematically evaluated to 

assess its efficacy or to develop plans for improvement. 

The Board recognizes that there are emerging environmental research 

needs that fall within the purview of this technology area that should be 

explored. Generally, these research needs fall within the well-recognized 

field of Land Use and include, but are not limited to, measuring the 

environmental and economic benefits of Brownfields cleanup and 

revitalization, documenting the multiple environmental challenges 

associated with urban sprawl and the built environment, clarifying the 

complex relationship between agriculture, biofuels, and environmental 

protection, and improvements in the rigor of Life Cycle Analysis (LCA) 

for use in land use remediation and protection. The Board urges the EPA 

to examine more closely the complimentary nature of an expanded Land 

Use program and its nascent, but important, research program in 

Sustainability with a view toward recognizing opportunities for crossdisciplinary collaboration. 

The EPA Environmental Technology Validation (ETV) and Superfund 

Innovative Technology Evaluation (SITE) programs are essential to 

moving technology to commercialization and have involved substantial 

leveraging of limited EPA funds. The National Advisory Council on 

Environmental Policy and Technology (NACEPT) and other studies view 

these evaluation activities as having high value to private environmental 

technology organizations, and to the accomplishment of EPA’s mission. 

2.1.2 Nanotechnology Research addresses the environmental protection 

challenge of ensuring “...that, as nanotechnology develops and engineered 

nanomaterials are manufactured and used, unintended consequences of 

exposures to humans and ecosystems are prevented or minimized. In 

addition, knowledge concerning how best to apply products of this 

emerging technology to detect, monitor, prevent, control, and clean up 

pollution is also needed.” In this regard, EPA has developed a research 

portfolio by working with others including federal agencies, industry, 

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academia, and non-governmental organizations to ensure research gaps are 

covered, critical issues are addressed, and information is communicated to 

all interested parties.” (SAB, 2007a). 

The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

• Understanding sources, fate, transport, and exposure throughout the 

life-cycle of nanomaterials. 

• Developing risk assessment and test methods. 

SAB Comments: The Agency’s Nanotechnology research program

appears to be well integrated into the broader National Nanotechnology 

Initiative, a positive development, and has shown that it can reach out to 

the broader international community as well as the manufacturing 

companies themselves. The ORD program on nanomaterials has been 

formulated strategically, considering EPA needs and with an eye towards 

leveraging and potential future regulatory decisions. There is involvement 

with many external groups. EPA has given careful attention to building on 

areas of internal expertise such as fate and transport, ecological assessment, 

and small particle inhalation. The program integrates activities at the 

international, national, and cross-agency levels. An important, 

unaddressed challenge is the implication of mixtures and environmental 

transformations of nanomaterials and other contaminants. 

2.1.3 Global Earth Observation System of Systems (GEOSS)/Advanced 

Monitoring Initiative (AMI). EPA’s GEOSS/AMI program grew from 

recognition that the goals of the US EPA’s 2006-2011 strategic plan (US 

EPA, 2006a) and those of the GEOSS were mutually reinforcing. GEOSS 

envisions a future in which “...decisions and actions are informed by 

information.” GEOSS intends to integrate “...multiple Earth observation

systems (networks, databases) and using computer modeling and decision 

support tools to help revolutionize our understanding of Earth’s complex 

processes.” EPA activity in this multi-agency program began with its 

participation in groups leading the effort to plan and support GEOSS and 

with its own Advanced Monitoring Initiative that is aimed at showing some

major tangible results by September 2008. EPA’s efforts involve 34 

projects in four areas (Air Quality Forecasting/Assessment and Decisionmaking for Human Health; Coastal/Source Water Quality and Decisionmaking for Human Health; Integrated Air-Water-Land-Biota Decisionmaking for Healthy Communities and Ecosystems; and Information 

Technology/Information Management (SAB, 2007a). 

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The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

• Transition from pilot projects to focusing on user needs, capacity 

building, and communities of practice. 

• Develop best practices guide to forecast air quality and inform decision 

making. 

SAB Comment: The GEOSS/AMI initiative is well-conceived and 

planned. It has a strong cross-media focus, especially for air and water, 

supports the goals of multiple Multi-Year Plans (MYPs), and has good 

cross-agency (e.g. National Science Foundation) connections. Some of the 

benefits of GEOSS are that it develops a technologically collaborative 

culture, creates an understanding of the need to plan for such collaboration, 

and, done right, it will work itself out of business. To accelerate and further 

the development of this technologically collaborative culture, the Agency 

should select a few high impact projects, such as the Chesapeake Bay and 

Mississippi River, for demonstration during the next phase of this program. 

At this early stage the Board supports GEOSS/AMI, but with two caveats: 

• There is a need to guard against moving toward a “datarich/information poor” state, and 

• Parallel concerns about the need for evaluating data quality and 

uncertainty exist. 

One potential application of GEOSS/AMI in relation to Homeland Security 

would be to organize the data from multiple labs from multiple samples 

from multiple field teams of the air, water, and land. However, without 

additional integration with economics and decision sciences, it would 

become just another store house of data, without much assessment. By 

adding the components of cost benefit analyses, compliance, and 

participation behavior, it would be possible to determine if allowing the 

public back into an contaminated area, but restricting their exposure 

through protective actions such as interdiction of crops would be 

adequately protective of public health and would be publicly acceptable. 

As a specific example, there are a number of protective actions which have 

been discussed involving milk which had been contaminated with a short 

lived radionuclide. Would it be acceptable to use the milk to make cheese

since the aging process would allow radioactive decay to take place? 

Could it be turned into powdered milk for consumption after 10 half-lives? 

What would the public's reaction to this milk be? By integrating 

economics and decision sciences with geo-mapped land use areas, it would 

be possible to make some better assumptions about public acceptance. 

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Another specific example would be to allow people to return to their homes 

following an incident involving deposition of a hazardous substance in 

their neighborhood, but not allow them to consume vegetables from their 

backyard garden, and require them to wipe their pet's feet every time the 

pet enters the house after running around on the lawn. Would people 

comply with this directive? 

2.2 Economics and Sustainability Research Areas

For the purposes of these discussions between the SAB and ORD, the 

Economics and Sustainability Research Area includes: i) Economics and Decision 

Sciences, and ii) Technology for Sustainability. 

Fundamentally, EPA makes decisions that are intended to protect human 

health and the environment from a suite of pollutants and behaviors that are 

addressed by nearly a dozen environmental laws. EPA makes choices about how 

to address a wide variety of environmentally linked risks based on knowledge and 

procedures in several areas. Choices inevitably call upon individuals to modify 

their behavior in regard to the issue. Informing EPA’s decision-making requires 

several types of knowledge, i.e., factual scientific and technical knowledge

about the risk issue and possible management approaches; decision sciences 

knowledge that identifies the scientific and technical information that is critical in 

evaluating possible actions to take to address the issue, and social sciences 

knowledge to determine people’s perspectives in relation to how they see the key 

science as well as their desired outcomes associated with actions that might be 

taken to respond to the issue. Further, it is important that this aspect be started in 

the beginning of EPA evaluation efforts in support of decision-making and that 

the capability to do this be available to and used by all EPA Program Offices. 

2.2.1 Economics and Decision Sciences. This research program area is

managed by the EPA National Center for Environmental Economics 

(NCEE) which plans the research component of its program in cooperation 

with the Office of Research and Development. This “...research is designed 

to improve our understanding of human and organizational environmental 

behavior and preferences, which is critical for improving EPA’s decisionmaking, cost-benefit analyses, and implementation strategies.”...This 

research program “...focuses on how people value their health and the 

environment; corporate and consumer environmental behavior; and market 

mechanisms and incentives (SAB, 2007a). 

The key directions of NCEE’s current research program in this area include 

(Teichman, 2007a): 

 

• Developing risk assessment metrics that can be used for valuation 

purposes; 

• Finding ways to transfer air market mechanisms to other environmental 

issues; and 

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• Developing advanced computational tools needed to support analytic 

models capable of evaluating policies on both micro- and macroeconomic scales. 

SAB Comments: The research plan for Economics and Decision Sciences 

follows closely the Environmental Economics Research Strategy. It 

identifies three major research areas (pp. 56-57): 

• health benefits valuation (both mortality and morbidity), 

• ecological benefits valuation, and 

• treatment of uncertainty. 

It also proposes research in three additional areas: environmental justice, 

costs and benefits of climate change, and compliance/participation 

behavior. 

The health valuation research is designed to improve the estimation of 

costs and benefits of EPA actions, primarily for use in Regulatory Impact 

Analyses (RIAs) and related assessments. An extensive literature exists on 

the valuation of mortality risks (i.e., estimating the value of a statistical life

(VSL)), and the proposed research appears to be aimed at refining those 

estimates to provide estimates that vary with factors such as income, age, 

and health status. While more information on this topic would clearly be 

valuable, before investing significant additional resources in VSL 

estimation by sub-group, the SAB urges the Agency to consider how the 

new information will be used in benefits assessment to ensure that the 

research results are policy-relevant. 

The SAB applauds the research direction related to ecological benefits 

valuation. Since this work requires extensive integration of ecological and 

economic analysis, the SAB urges the Agency to extend this research area 

to include participation from other program areas. Note that meaningful 

ecological benefits valuation requires more than applying an average value 

estimate (e.g., the “value of a hectare of wetlands”) to an estimate of 

environmental effect (e.g., hectares of wetlands preserved). Rather, it 

requires a meaningful assessment of the value of a policy-driven change in 

ecosystem services that reflects important bio-physical and socio-economic 

characteristics of the impacted ecosystem and population. Research in this 

area should build on results of the recent SAB project from its Committee 

on Valuing the Protection of Ecological Systems and Services (CVPESS).

The EDS strategy focuses almost exclusively on economics, particularly 

measuring costs and benefits, with little attention to other behavioral and 

decision science issues (other than the proposed work on 

compliance/participation in voluntary programs). Yet, behavior of firms 

and individuals drives environmental performance. This behavior is in 

response to policy-induced incentives, as well as cognitive and decisionA-7 
making processes employed by individuals. The SAB urges EPA to expand 

the EDS research strategy to include research focused on these issues. This 

could include work on the incentives and likely effectiveness of alternative 

policy approaches (evaluated relative to specific policy contexts), business 

management decisions, information processing, technology/product 

adoption (including consumer behavior), and risk and other communication 

strategies. 

As a practical example, with the growing emphasis on energy conservation, 

a market for compact fluorescent lamps (CFLs) has been stimulated. It is 

common to see CFLs in mass distribution markets, such as most major 

department stores. However, CFLs contain mercury which is released if the 

bulb is accidentally broken. It may be necessary to consider whether 

regulation is needed to require locations that sell CFLs to institute “takeback” programs. What incentives will inspire the public to return the bulbs 

rather than put them into the normal household waste stream? 

More generally, the EDS research strategy should be broadened to identify 

and include links with other program areas. The current strategy is defined 

more from a disciplinary than a problem-oriented perspective. For nearly 

all of the EDS research areas, closer interaction with other program areas 

would be fruitful. Specific examples include revitalization of contaminated 

lands (with land preservation), effectiveness of TMDLs (with water), and 

managing water quantity (with water and global change). 

Finally, the EDS research strategy seems to be driven to a large extent by 

short-term national assessment needs, most notably for RIAs. This is likely 

to become even more pronounced now that EDS has moved from ORD to

the EPA National Center for Environmental Economics and its budget has 

been sharply reduced. The SAB urges the Agency to broaden its research 

agenda to contribute to improvements in other decision contexts (e.g., 

regional planning applications and site-specific decisions) and to look 

beyond the short-term in identifying research priorities. 

2.2.2 Technology for Sustainability research has emerged as the new emphasis 

for programs that originated at EPA under the concepts of pollution 

prevention in the early 1990’s. According to EPA, in this context, 

“sustainability” refers to “...meeting the needs of the present without 

compromising the ability of future generations to meet their own needs. 

From a public policy perspective, sustainability means meeting basic 

environmental, economic, and social needs now, and in the future, without 

undermining the natural systems upon which life depends.” Sustainability 

goes “...beyond traditional end-of-pipe control strategies and embraces 

system-based, long-term solutions.” Early efforts under Pollution 

Prevention and New Technologies aimed to provide “...tools and 

technologies that advanced the idea of environmental systems management 

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while preventing and controlling pollution and reducing risks to human 

health and ecosystems originating from multiple economic sectors. 

Strategic directions for this research program begin with the notion that 

sustainability “...must combine interrelated ideas drawn from economic, 

social and environmental realms” – often thought of as the “Three Pillars of 

Sustainability.” Given EPA’s narrowly focused mission, the EPA 

sustainability research program is focused on environmental dimensions of 

sustainability while recognizing that sustainable environmental outcomes 

are best achieved in a systems-based context.” The resulting EPA research 

program is broader than the usual stove-piped media-focused program and 

it adopts a focus that is multimedia and systems wide. EPA’s sustainability 

research program has six themes: 1) Natural Resource Protection, 2) Nonrenewable Resource Conservation; 3) Long-term Chemical and Biological 

Impacts; 4) Human-built Systems and Land Use; 5) Economics and Human 

Behavior; and 6) Information and Decision-making (SAB, 2007a). 

The key directions of ORD’s current sustainability research program

include (Teichman, 2007a): 

 

• Development of sustainability metrics for use in EPA’s Report on the 

Environment, informing design and production, and evaluating 

innovative technologies. 

• Provide decision support tools to address energy and environmental 

impacts, e.g., water and land use. 

• Promote collaborative partnerships. 

SAB Comments: The ORD’s research initiative in the area of

sustainability is an important and timely step forward. The SAB supports 

ORD’s research efforts to develop metrics and tools to advance the 

Agency’s ability to achieve protection of human health and the environment 

through sustainable practices. The SAB believes the “6 Themes of 

Environmental Sustainability” identified as the framework for this research

are appropriate and important areas upon which to focus. Additionally, 

EPA’s intent to work on sustainability metrics, decision support tools and 

innovative technologies expressed in the long-term goals statements seems 

to capture the broad categories of tools and techniques in which the agency 

should be working. That said the review team felt that the written 

description provided to the SAB on the intended research actions under the 

long-term goals did not clearly link to the 6 themes for sustainability. The 

agency representatives did note that their forthcoming research strategy 

document will show this linkage. A post meeting, inspection of the June 

13, 2007 draft of the strategic research strategy draft contains a table (5.1) 

on page 43 which gives some indication of linkages between the 6 themes 

and the 3 long-term goals. A table such as this with some more details on 

research projects would have helped to clarify these linkages in the 

information provided for this current discussion. The SAB looks forward to 

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seeing those linkages further developed in the final Sustainability Research

Strategy. 

In conclusion, the SAB suggests that the agency allow itself wide latitude in 

the way it approaches sustainability research since this new systems-based 

approach to environmental protection will require a fundamental departure 

from the current stove-pipe single-media based regulatory framework. The 

SAB recommends the following (expanded details for each of these 

recommendations are included in Attachment 1 to this Appendix). 

Recommendations 

• Clearly define the intended audience(s) 

• Behavior and decision science research is needed 

• Establish (or clearly define) linkage to other Research areas and 

programs 

• Go beyond Technology – green chemistry and pollution prevention 

• LCA tools don’t incorporate directly what matters to people so they 

can’t incorporate value or benefits 

• Need for a clear definition of the sustainable condition or future state 

the agency desires to maintain or achieve. 

• Explore developing a bridge between risk and performance to achieve 

sustainability. 

2.3 Ecosystems, Water and Security Research Areas

For the purposes of these discussions between the SAB and ORD, the 

Ecosystems, Water and Security Research Area includes: a) Ecosystem

Protection, b) Water Quality, c) Drinking Water, and d) Homeland Security. 

 

2.3.1 Ecosystem Protection. The Ecological Research Program (ERP) is taking 

a new strategic direction that is intended to fill the need “... for better 

understanding the implications of human impacts on ecosystems and the 

resources they provide.” This new program direction recognizes that, even 

though “The nation’s health, security, economic potential, and much of its 

culture are directly and intimately tied to ecosystem characteristics and 

quality”, environmental policy “...decisions have failed to take these 

relationships into account.” The redirected ERP intends to build on past 

research efforts in ecosystem monitoring, restoration, and functions, to 

develop operational methods to incorporate quantitative information on 

ecosystems services into decision making routines. Using internal 

resources, and a suite of unique partnerships with outside organizations 

(academia, NGOs, other governmental agencies, etc.), the ERP will conduct 

research designed to “...answer multiple questions about ecosystem

services. ... and develop multiple measures of services, including 

biophysical and monetary measures, to estimate incremental changes to 

A-10 
ecosystem services, as well as suites of ‘bundled’ services associated with 

land, air, and water systems over explicitly defined spatial and temporal 

scales.” The “...goal is to inform a wide range of issues related to 

questions of social choice, with a special focus on informing trade-offs

among ecosystem services provided under alternative management and 

policy decisions.” ERP, through its own work and that of its partners, will 

create products in four categories: 1) measurements and dynamic maps of 

ecosystem services; 2) predictive models relating to the response of

stressors; 3) tools for analysis of management options; and 4) decision 

support tools (SAB, 2007a). Approaches developed by ORD to monitor 

ecosystem conditions (e.g., Environmental Monitoring and Assessment 

Program-EMAP) will now be passed to the Program and Regional Offices 

to implement. 

The key directions of ORD’s current ecosystems research program include 

(Teichman, 2007a): 

• Assessing the benefits of ecosystem services to human well-being, and 

• Understanding how policy and management choices affect the type, 

quality, and magnitude of services we receive from ecosystems. 

SAB Comments: The SAB noted the changes from the historically, 

diverse research program in this area to one that is refocused on ecosystem 

services. The SAB believes that ORD has a strong vision of where it is 

going in this area; however, that vision is not yet integrated across EPA 

Research and EPA Program Offices. Additionally, even though ORD has

passed the tools developed in EMAP to the Program and Regional Offices 

for implementation, the SAB believes that there continues to be a need to 

link ecological conditions to goals and that there is a need for additional 

development of monitoring systems, especially for some of the 

contemplated trading systems that involve ecosystem services. Success in 

this research area will depend greatly on adding expertise in economics to 

the program. Decision support tools are also critical to the aspirations of 

this program; however, current activity in this area does not seem

sufficient. ORD should invest in system support science more heavily in 

the future, given that it will benefit Ecosystems Research as well as several 

other programs. ORD has a history of taking the outcomes from their 

research and helping to infuse those results into EPA practice. This will be

very important for research on ecosystem services. An ecosystem services 

perspective will require staff with a holistic perspective and this 

perspective must be communicated to user communities. The opportunity 

to think at the strategic level instead of just focusing on the “issue of the 

week” is important to getting these new programs on a strong footing. 

Integrating across diverse scales is important. 

This new focus will also require support of the STAR grants program to be 

successful. ORD recognizes the importance of establishing research 

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partners in the broader research community to accomplish its challenging 

goals. The SAB believes that the elimination of the ERP-STAR program 

due to budget cuts is a strategic error. 

 

The ERP description reports that the EMAP program (a status and trend 

program) has been transferred to the Water Quality Program for technical 

support and to the Program Offices for survey monitoring and assessment. 

In light of the SAB’s criticism of the Report on the Environment 2007 for 

not including long-term trend information and little trend analysis for 

indicators questions arises in my mind 1) does the Water Quality Program 

have the capability to provide technical assistance needed, 2) and do the 

Program Offices have the capability to implement the survey monitoring 

and assessment need to generate indicator trend data and analysis for future 

Reports on the Environment. 

2.3.2 Water Quality research supports EPA’s Office of Water and Regional 

Offices in implementation of the Clean Water Act (CWA). The 

restructured water quality research program (WQRP) consolidates past 

work done under a separate goal into three remaining goals that focus on: 1) 

Water Quality Integrity Research - research in support of aquatic life 

guideline revisions, recreational water criteria, emerging contaminants, 

nutrients, biocriteria, stream biota, and biological condition gradients for 

Tiered Aquatic Life Uses; 2) Watershed Management Research - research

in support of Total Maximum Daily Load allocation processes; and 3) 

Infrastructure Research - research on innovative solutions to manage the 

nation’s aging water and wastewater infrastructure (SAB, 2007a). 

The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

• Supporting development of aquatic life guidelines and recreational 

water criteria, by studying the impact of stressors, including habitat 

alteration, nutrients, pathogens, and emerging contaminants. 

• Improving watershed management by applying diagnostic tools to 

assess impairment and guide mitigation efforts to manage both point 

and non-point sources. 

 

SAB Comments: Several National Program areas have responsibilities for 

water-related research areas, including Water Quality, Drinking Water, 

Ecosystems, Global Change, and Sustainability. While there are structures 

in place to encourage and facilitate interactions among the research 

programs and the program offices, these arrangements are not always 

effective in communicating when ORD’s effort is to end and OW’s effort 

is to begin. 

 

The SAB believes that EPA must begin to actively integrate its research 

and programs for water quality and drinking water. A holistic “Clean 

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Water” program should be pursued analogous to the way in which research 

is now pursued as a “one atmosphere” concept in the air medium. More 

work is needed in watershed management, infrastructure, and integrated 

criteria development (across biological, chemical and physical criteria). 

Research is also needed on modeling, monitoring, and measurement to 

support water quality decision making. Climate change, and the 

relationship of water quality to land use practices, must be incorporated 

throughout this research area.

2.3.3 Drinking Water research is “...an applied research program designed to 

develop new scientific data, models, innovative methods, and cost-effective 

technologies for characterizing and managing the quality and sustainability 

of drinking water resources in support of EPA’s goal of ‘Clean and Safe 

Water.’” “The Drinking Water Research Program (DWRP) is moving 

towards an integrated framework for addressing drinking water issues in the 

context of the water cycle.” Major themes in the DWRP are in the areas of

1) Assessment Tools; 2) Source Water/Water Resources; 3) Treatment/ 

Residuals; 4) Distribution/Storage/Infrastructure; and 5) Water Use/Health 

Outcomes. Increased emphasis is being placed on source water protection 

and sustainability; water distribution/storage systems/infra-structure; 

microbial risk associated with pathogen exposure; and health outcomes 

(SAB, 2007a). 

The key directions of ORD’s current research program in this area include 

(ORD, 2007a): 

 

• Develop sustainable source water protection approaches. 

• Assess exposure to contaminants from water storage and distribution 

systems. 

• Improve tools for characterizing and monitoring pathogens and 

biofilms, and develop methodologies for microbial risk assessment. 

• Develop methodologies to quantify the impacts of SDWA rule

implementation on public health outcomes. 

SAB Comments: Members noted that for Drinking Water Research most 

attention is on total coliform and CCL research with groundwater source 

protection getting some attention. It is understood that these priorities are 

driven by the regulatory drivers of the Total Coliform Rule, the Candidate 

Contaminant List (CCL), and Underground Injection Control (UIC, 

geologic carbon sequestration). While the regulatory drivers are important, 

the future strategic direction should focus on the most important risks 

which could be non-regulatory. A watershed focus may provide the 

greatest opportunity for public health protection via prevention. More 

attention is needed for surface source water protection and distribution 

systems. Research on the protection of surface water sources of drinking 

water is at the intersection of the SDWA and CWA. Again, the “One 

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Hydrosphere” approach is suggested for EPA use in integrating its research 

on a variety of water issues. 

2.3.4 Homeland Security responsibilities of EPA include: 1) the protection of 

water systems in general and for detecting and recovering from terrorist 

attacks affecting water systems; 2) decontaminating buildings and outdoor 

areas impacted by a terrorist attack; and 3) developing a nationwide 

laboratory network to support routine monitoring and response 

requirements. The EPA Homeland Security Research Program “...is 

currently conducting a year-long exercise to align the program more closely 

with these responsibilities. The original Homeland Security Research 

Program covered broad emergency response issues; however, the realigned 

research program will focus primarily on terrorist attacks. Even so, “...the 

program will continue to nurture research collaborations with the broader 

scientific community, seeking supplemental expertise, fostering valuable 

collaborations and leveraging of additional resources. In addition, although 

research products will be planned to meet the needs of Agency customers, 

ORD will conduct research that benefits multiple EPA programs and other 

Federal agencies as much as possible.” Goals focus on developing 1) 

“...products and expertise to improve protection from and the capability to

respond to terrorist attacks on the nation’s water and wastewater 

infrastructure” and 2) “...products and expertise to improve the capability 

to respond to terrorist attacks affecting buildings and the outdoor 

environment.” Behavioral research program requirements are still being 

explored in a white paper being developed by EPA on homeland securityrelated research needs in the behavioral sciences (e.g., risk communication 

and perception during crises) (SAB, 2007a). 

The key directions of ORD’s current homeland security research include 

(Teichman, 2007a): 

• Identifying and validating methods to detect and quantify biological 

agents. 

• Developing a methodology to assess microbial risks and risk-based 

advisory levels. 

• Developing decontamination and disposal approaches for chemical, 

biological, and radiation (CBR) agents in both large outdoor areas and 

in water infrastructure. 

• Improving the communication of risk and risk management options 

during a crisis. 

SAB Comments: The SAB recognizes that the Homeland Security 

Research program began in a crisis mode and focused on getting as much 

done as quickly as possible. The need now is to become more strategic and 

to define program boundaries so that this strategic focus has a goal. Even 

though the strategic directions state the intent to focus only on terrorism, 

EPA must think beyond terrorism and conduct research to enhance 

A-14 
responses to natural disasters as well. EPA also needs to think about how 

to increase collaborative research with other agencies and other 

stakeholders as well as to obtain more collaboration within EPA. A crosscutting issue is the need to coordinate with others to better define EPA’s 

niche in the response area and how that influences research needs. 

Important research areas identified include: risk communications; detection 

methods for contamination, decontamination, disposal and outdoor 

exposure. Issues such as determining “how much clean up is necessary” 

have social research needs beyond communications. 

EPA should ensure that it integrates the work and lessons learned from

others, including: 

• Other countries (UK, Canada, Australia) 

• Other federal agencies (DOD, USDA, CDC, DHS, DOE), 

• Multiple EPA offices (ORD, OW; other multi-year plans), 

• The States, and 

that it involves new areas/opportunities with new resources. 

2.4 Air and Global Change Research Areas

For the purposes of these discussions between the SAB and ORD, the Air 

and Global Change Research Area includes: a) Clean Air, and b) Global Change. 

2.4.1 Clean Air Research provides research results needed to develop and 

implement the National Ambient Air Quality Standards (NAAQS) – 

primarily particulate matter (PM) and ozone as high risk pollutants. 

Secondarily it also provides research for Hazardous Air Pollutant (HAP) 

management. Clean Air Research (CAR) has been restructured over the last 

several years into an integrated program in contrast to the previous research 

program that focused on individual pollutants. Ultimately the research 

program will provide information that allows EPA to adopt a multipollutant program that will lead to targeted control of emissions products

that most affect human health. Long-term goals for the CAR fall into five 

thematic areas. 

 

• Theme 1 supports the development of NAAQS and other air quality 

regulations; 

• Theme 2 supports implementation of air pollution regulations; 

• Theme 3 develops a multi-pollutant approach to research; 

• Theme 4 identifies specific source-to-health linkages using ‘near 

roadway’ as the prototype; and 

• Theme 5 assesses health and environmental improvements due to past 

regulatory actions (SAB, 2007a). 

A-15 
The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

 

•Support the development and implementation of the NAAQS and other air 

quality regulations. 

•Develop a multi-pollutant “one atmosphere” approach, focusing on 

identifying specific source-to-health-outcome linkages, e.g., near 

roadway exposures. 

•Assess health and environmental improvements from past actions 

SAB Comments: As noted above, the Clean Air Research Program

identified three key directions for their research agenda. The SAB agrees 

that all of these meet the criteria of being high priority research areas and 

are particularly supportive of the more holistic systems approach that the 

“one atmosphere” concept encompasses. In addition, we believe it is also 

important for ORD to maintain a robust research program on air toxics, and 

on air quality in indoor environments, which are critical for human 

exposure. In addition to these current focus areas, the SAB agrees that 

research on interactions of global change and air quality is an important 

new priority for both the Clean Air and Global Change programs. Further, 

the SAB believes significant societal benefits would result from increased 

research on the global mass balance of mercury and its fate and transport. 

Policy relevant research to support developing, testing and evaluating new 

and innovative alternative policy approaches (e.g., marketable permit 

systems for multimedia pollutants, effectiveness of various types of

voluntary instruments, etc.) would also yield high social returns.

 

2.4.2Global Change Research is a part of the interagency U.S. Climate Change

Science Program (CCSP) mandated by the Global Change Research Act of 

1990. “The primary focus of ORD’s Global Program is on the assessment 

of the potential consequences of global change (particularly climate 

variability and change) on air quality, water quality/aquatic ecosystems, and 

human health. Results of the program’s assessments are used to investigate 

adaptation options that improve society’s ability to effectively respond to 

the risks and opportunities presented by global change. The program

emphasis is shifting toward developing decision support tools to help 

managers consider global change during the decision making process (SAB, 

2007a). 

The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

• Continue to prepare the Synthesis and Assessment Products mandated 

by the Global Change Research Act. 

• Refine the assessment of climate change on air quality in the U.S. 

• Characterize the potential impacts of global change on water quality 

and aquatic ecosystems. 

A-16 
 

SAB Comments: The first key direction is largely driven by regulatory 

requirements whereas the second two areas are more anticipatory in 

nature. There seems to be very strong collaboration between the global 

change program and other research areas such as the water quality 

research, ecosystems protection, and clean air. There also appears to be a 

very healthy view concerning coordination of research efforts with other 

agencies. One area that could yield high returns from a focused research 

program is the development of guidance concerning mitigation and 

adaptation strategies, particularly with respect to the additional 

environmental benefits (or costs) these strategies might have (e.g., a 

practice that sequesters carbon in agricultural soils might also generate 

increased nutrient runoff). A second key direction of high importance is 

research on the design and development of policy instruments to 

implement greenhouse gas reductions cost-effectively. Greenhouse gases 

will inevitably become regulated. EPA should have a research portfolio 

now which assesses various policy actions and their cost-effectiveness for 

reducing greenhouse gas emissions (cap-and-trade, carbon tax, commandand-control, etc.). Various technologies could also be assessed for their 

cost-effectiveness. 

Relative to reducing the nation's greenhouse gas emissions, Carbon 

Capture and Sequestration (CCS) is thought to be mandatory for the use of

coal in the future. CCS is a major research area in which EPA will likely

be involved in regulating and permitting carbon dioxide geological 

sequestration, but also in encouraging and leading research and 

demonstration efforts (especially in view of the recent cancellation of the 

Future-Gen project, the only major CCS demonstration project in the 

country to date). At the present time, EPA has taken a rather narrow view

of its charge in this area to be limited to protection of groundwater quality 

under the Clean Water Act. SAB recommends that ORD begin partnering 

with DOE to provide risk assessments, encourage demonstration projects, 

and estimate leakages to the atmosphere. This should be a high national 

priority and EPA should play a prominent role. 

2.5 Human Health Research Area

For the purposes of these discussions between the SAB and ORD, the 

Human Health Research Area includes: a) Human Health, b) Computational 

Toxicology, c) Endocrine Disruptors, d) Human Health Risk Assessment, and the 

e) Safe Pesticides and Safe Products. 

SAB General Comments for this Research Area. Research directed at human 

health impacts should encompass a broad perspective to include public health 

approaches, exposure assessment, and epidemiology. Potential gene-environment 

interactions, including lifestyle, the built environment, diet, drug, and other 

xenobiotic exposures, and epigenetics should be included in assessment of human 

A-17 
health endpoints. This will require adequate numbers of individuals trained in 

epidemiology and public health.

The Agency has put forward an impressive array of research objectives to support 

long term needs in human health assessment, including an increased emphasis on 

research to support the new toxicity testing paradigm. The SAB notes that there 

are some important areas of research that were not included in the materials 

received by the Board for its October 2007 meeting. Still, the research portfolio 

presented had few items where efforts may be decreased, and these were already 

noted by the Agency. Therefore the additional research areas identified below and 

discussed in Appendix A would ideally be accomplished with the infusion of 

funding. Only one long term goal was identified as an objective that could be deemphasized. The Board did not have enough time to make any firm

recommendations on prioritizing this research. 

A critical evaluation of how new toxicological testing paradigm, including the in 

vitro and in vivo approaches, can support risk assessment and ultimately risk based 

decision-making should be conducted within the next five years. This dialogue 

should include industry, NGOs, the public, and international groups in making this 

evaluation. 

There are several research areas that the Board believed were in need of greater 

emphasis. Briefly, they include: 

• Long-term research to support the shift toward the new toxicity testing 

paradigm, such as the development of in silico methods to predict 

metabolism, addressing the issue of exposure duration in designing the 

high throughput tests, test strategies to ensure that novel agents from

poorly studies chemical classes are adequately characterized, and 

epidemiological surveillance to support data interpretation; 

• Research on methodologies for developing IRIS guidance levels (from

non-apical endpoints) for chemicals that have sparse data sets. 

• Work to evolve the Agency’s hazard identification and dose response 

practices and Guidance guidelines to keep pace with the emergence of 

data from new types of toxicity tests. 

• Epidemiological surveillance, particularly emphasizing the interactions

of genes, lifestyle and environmental chemicals to gain a better 

understanding of “background additivity” and how to interpret results 

of the emerging high throughput tests. 

These are further described in Attachment 1 to this Appendix. 

 

2.5.1 Human Health research provides fundamental information to improve our 

understanding of and to predict levels of human health effects associated 

with environmental agents that are managed through a variety of statutory 

mandates. Research themes in this program focus on: 1) developing data, 

methods and models for risk assessment; 2) research to characterize 

A-18 
aggregate and cumulative risk; 3) research on susceptible subpopulations; 

and 4) research to evaluate the public health impact of environmental 

decisions. Historically, Human health research focused on biological 

mechanism of toxicity, cumulative effects associated with exposures, 

understanding susceptible subpopulations, the internal factors associated 

with vulnerability, life stages in relation to vulnerability, and the evaluation 

of public health outcomes. A recent NAS report (NAS, 2007) has made it 

clear that additional emphasis is needed on the development of new ways to 

characterize and predict toxicity. In addition, EPA’s desire to continue to 

improve its “Report on the Environment” requires research for evaluating 

the effectiveness of decisions targeting public health (SAB, 2007a). 

The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

 

• Establish relationships between environmental decisions and changes in 

health indicators. 

• Focus on characterizing toxicity pathways for dose-response and 

extrapolation models for risk assessment. 

SAB Comments: Long term research focused on both of the key research 

directions is needed but should not sacrifice critical research efforts 

addressing sensitive populations and understanding their vulnerability. The 

main goals for the new initiative in toxicity testing approach are expected 

to achieve results in the 10 to 20 year time frame. Nearer term, research 

outputs are needed to support program office needs in cumulative and 

aggregate risk assessment, and to support characterizations of human 

susceptibility and variability to develop more scientific approaches for 

modeling dose response relationships. Also, methods are needed to take 

existing test data to the next step to enable better predictions especially for 

chemicals with non-apical endpoint data or limited data sets, as discussed 

in Attachment 1 to this Appendix. Community level risk assessment can 

better direct regulatory focus and depending on the nature of the 

assessment tool provide a conduit for stakeholder involvement in decisionmaking. There is an increasing need for tools that can be used by 

communities. On the ground for particular problems, collaborations 

between an EPA Region and local authorities in both risk assessment and 

risk management aspects can be important, but on a research level tools 

developed by agency would help facilitate efforts in the field. 

To the extent that the program is continuing to support methods to 

characterize variability, susceptibility and cumulative risk, this should be 

stated explicitly for the sake of transparency and clarity. This should be 

done both internally for organizing EPA efforts and during external 

evaluations. It is not clear whether the repackaging of the research 

portfolio presented by the Agency represents a shift in program focus away 

from some of the critical nearer term objectives. 

A-19 
2.5.2 Computational Toxicology research develops enhanced tools for 

prioritization of hazards, and improved methods for quantitative risk 

assessment. Traditional methods can not keep pace with the current 

demands for hazard and risk evaluations, thus methods employing modern 

tools of molecular biology, information management, and computational 

models are being developed to identify, characterize hazard and risk 

quicker, cheaper and in a more scientifically robust way. Objectives of the 

program are to improve our understanding of the link between chemical 

sources and adverse health outcomes; to provide predictive models for 

screening and testing; and to improve quantitative risk assessment by 

providing a better understanding of basic mechanisms and their underlying 

biology (SAB, 2007a). 

The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

 

• Provide predictive models for screening and testing of chemicals to 

improve source-to-outcome linkages. 

• Develop new approaches and technologies to better predict a 

chemical’s hazard, and identify toxicity testing priorities. 

• Develop new systems biology models, such as the virtual liver. 

SAB Comments: The SAB believes that this program continues to be 

headed in the right direction. The objectives of providing predictive 

models for screening and testing chemicals, developing new approaches 

and technologies for predicting chemical hazard and testing priorities and 

developing new systems biology models such as the virtual liver are 

reasonable objectives to advance toxicity testing and predictive biology 

within the agency. Ultimately, a large research effort will be needed to 

fully realize the NAS toxicity testing vision so that the testing strategy can 

serve as the basis for most agency assessments. This can not be 

accomplished by elements reflected in the current research strategy. The 

Computational Toxicology Research Program is taking the first steps to 

build capacity and collaborations and to lay down initial work for proof of 

concept. The Board heard about the Agency’s efforts to ensure that data 

supporting the work of the Program was publicly available on-line and the 

SAB compliments the Program for overcoming the obstacles to make this 

happen. 

 

2.5.3 Endocrine Disruptors research improves our understanding of chemicals 

that interact with the endocrine system. Research has been conducted to: 1) 

develop methods, models and measures for understanding and managing 

risks from endocrine disrupting chemicals (EDCs); 2) apply these methods 

to determine the extent of endocrine disruptor impacts to humans and 

wildlife; and 3) support the EPA screening and testing program on EDCs 

mandated by the Food Quality Protection Act and the Safe Drinking Water 

A-20 
Act Amendments. Over the last five years, the program has increased its 

emphasis on research to characterize sources and occurrences of EDCs 

(SAB, 2007a). 

The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

• Complete development of protocols for EDC screening and testing 

assays. 

• Improve understanding of EDCs’ mechanisms of action, dose response, 

and cumulative risk issues. 

• Develop exposure assessment and risk management tools to 

characterize and reduce exposure to EDCs. 

SAB Comments: This program has been focused on completing the 

screening and testing assays, and is well along in this effort. The SAB 

agrees with the phase down for Tier I test development and suggests a 

greater attention to support hazard identification and explore how dose 

response can be characterized based on less than ideal data sets. The SAB 

also suggests exploring methods for estrogen and androgen compounds 

considering “background” exposures and exploring cumulative risk 

assessment approaches given background levels. The Agency might 

explore developing TEF approaches for several classes of compounds. 

 

2.5.4 Human Health Risk Assessment. This research program is at the 

forefront of applying quantitative methods advances to risk assessments 

(e.g., use of physiological based pharmacokinetic (PBPK) models to reduce 

uncertainty in risk extrapolations or to replace default uncertainty factors). 

The program maintains its leadership role in incorporating mode of action 

evaluations to support decision-making. Products of the program include 

IRIS assessments, Integrated Science Assessments (ISAs), and other 

assessments that respond directly to Program Office needs and are primary 

considerations in Agency actions to protect human health and the 

environment. Human Health Risk Assessment (HHRA) also incorporates 

contemporary science advances into agency practice to improve risk 

assessment methods, models, and guidance for other EPA offices (SAB, 

2007a). 

 

The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

• Continue to support IRIS profiles, PPRTVs, and other priority 

assessments. 

• Develop methods, models, and guidance for improved health risk 

assessments. 

• Conduct integrated science assessments for ambient air pollutants. 

A-21 
SAB Comments: The SAB recognizes that this as one of EPA’s “bread 

and butter” research programs. The SAB supports the three objectives in 

this research area and notes that there is an opportunity for developing and 

incorporating new approaches for sparse data sets to expand the capacity to 

develop guidance values. Staff in this research program should therefore 

collaborate closely with those in the Human Health Research program in 

these efforts. In addition, to have better assurance that sensitive populations 

are adequately addressed, collaboration between these programs is also 

needed to develop a better understanding of how to approach the use of 

variability assumptions in risk assessment. EPA should also consider 

better integration of HHRA with its Endocrine Disruptor Program to 

develop Reference Doses (RfDs) for chemicals with less than optimal data

sets. 

The SAB notes its concern with delays and challenges posed by OMB 

reviews. The SAB encourages the EPA to make use of suggestions 

provided in the recent NAS document (NAS 2008) on reviewing research 

efficiencies to improve their ability to work with OMB in a more efficient 

manner. The SAB sense is that OMB has a very limited scientific review

capacity and EPA needs to find improved ways of addressing these delays. 

One way is to work with OMB to develop a sufficient level of comfort so 

that OMB will increasingly rely on EPA’s own document review 

processes. 

 

2.5.5 Safe Pesticides and Products research supports the problem-driven 

science needs of EPA’s Pesticides and Toxic Substances programs. Safe

Pesticides and Safe Products research tends to focus on high priority 

science needs that are not addressed by other research programs and work 

on both human health issues and ecological issues. The program’s longterm goals focus on: 1) developing methods, models and data as the 

scientific foundation for prioritizing test requirements, enhancing data 

interpretation, and improving decision-making; 2) developing probabilistic 

risk assessments focused on natural populations of birds, fish, other 

wildlife, and plants; and 3) conducting research to provide the scientific 

foundations for decision-making on biotechnology products (SAB, 2007a). 

The key directions of ORD’s current research program in this area include 

(Teichman, 2007a): 

 

• Develop predictive tools for chemical prioritization and testing 

requirements, and enhanced interpretation of exposure and toxicity 

studies. 

• Develop mathematical models for integrating dose-response and habitat 

relationships for wildlife population and plant communities. 

• Develop approaches to assess allergenicity potential from GM crops 

and to assess the risks of gene flow from GM crops. 

 

A-22 
SAB Comment: The SAB believes that this research area has reasonable 

objectives. However, there is a need for greater emphasis on toxicity tools 

to enable migration to safer products based on human, as well as ecological 

systems, health protection. 

A-23 
ATTACHMENT 1: ADDITIONAL DISCUSSION 

1. Detailed Recommendations Technology for Sustainability Research Program 

(See Appendix A, Subsection 2.2.2, Page A-8) 

a) Clearly define the intended audience(s): It appeared to the review team that 

the ultimate objective of this research is to develop improved information, tools 

and approaches that will lead to changes in behavior. The intended audience or 

audiences (e.g., Agency, firms, and individuals) from which such behavior change 

is expected is not clear and needs to be more explicit. For example, who are 

EPA’s “clients” as mentioned in paragraph 5 under section “Making a 

Difference”? 

b) Behavior and decision science research is needed: The concept of 

sustainable development has an implicit element of people or organizations 

making decisions that lead to behaving in a manor such that their actions do not 

diminish environmental conditions resulting in either current impacts to human 

health or the environment nor reduce opportunities for use of that environment by 

future generations. Therefore, the area of behavioral and decision sciences should 

play an important role in helping EPA develop tools and information to aid such 

sustainable practice by individuals and organizations. The current research 

strategy does not reflect a focus on behavioral or decision science and the 

designers should revisit this area for research opportunities. Although the agency 

is planning to work on decision support tools such as life-cycle assessment (LCA) 

this is not the same as research on how and why people or organizations make 

decisions with regard to sustainability. Such behavioral research should not only 

address whether behavior is elicited but also if once elicited it is leads to positive 

improvements. 

c) Establish (or clearly define) linkage to other Research areas and 

programs: Sustainability as a research area is truly cross-cutting at it core. 

Although the research strategy overview provided to the SAB indicates a degree 

of cross linkage in planning with other ORD areas, the SAB recommends a 

systematic and thorough planning effort that cross-links sustainability research 

with other programs. Examples of opportunities for such cross planning include: 

• Revitalization of contaminated lands (economics and Land restoration) 

• Effectiveness of TMDLs (economics and water) 

• Managing water quantity (water-Global change- sustainability) 

In addition, the agency should be taking a fresh page on this research. Don’t just 

repackage former areas such as “land preservation” go beyond land contamination 

to management to avoid reduction in ecological services and or other human 

health services. 

A-24 
d) Go beyond Technology – green chemistry and pollution prevention: E.g. 

Research on Smart growth; sustainable cities. 

e) LCA tools don’t incorporate directly what matters to people so they can’t 

incorporate value or benefits. The review team also supports EPA’s move 

towards taking a “systems” approach to environmental management. To this we 

note ORD’s interest in focusing on tools based on LCA techniques. The review 

group cautions that the typical system boundaries and the inputs and out-puts of 

such analysis do not include any consideration of the benefits or the costs 

associated with the process or system under review. LCA as currently practiced is 

an excellent planning and design aid to manage raw material consumption, 

energy, hazard and waste production but it should not be relied on for integrated 

management decisions or balancing trade-offs among benefits without further 

development. It would be exciting and important if the agency can identify 

opportunities to integrate or couple LCA, and similar tools, with economic or 

valuation techniques. 

f) Need for a clear definition of the sustainable condition or future state the 

agency desires to maintain or achieve. Sustainability, or its stated operational 

objective, sustainable development, has a variety of meanings depending on the 

audience that considers the term. Therefore, it seems essential that the agency 

start its sustainability effort by defining in specific systems terms the operating 

condition it plans to protect or restore. For example, water quality is generally 

defined in terms of expected or designated uses such as fishable, swimable or 

drinkable. If such conditions were attained, would EPA deem these systems to be 

sustainable? If so, what metric would the agency use to track sustainability? To 

the degree that the agency can specifically define the acceptable operating 

conditions for any specific environmental regime, it will assist itself in identifying 

sustainable metrics and designing sustainability tools to support sustainable 

practice for that regime. The definition of an environmental regime is itself in 

question. Historically one might that appropriate regimes are air, water and land, 

but if one attempts to manage a river or a lake, sustainable outcomes will not be 

achieved if the interfaces of land and air with that water body are not part of the 

management strategy and design of sustainable practices. The SAB does not 

suggest that this will be easy, or even how this might be done, but EPA should 

work diligently to do a conceptual mapping or otherwise the breakthrough 

expected from the sustainability research will not yield the needed behavioral 

changes that achieve sustainable conditions. 

There may be value for EPA if it were to develop a vision of sustainable 

conditions in collaboration with other agencies that have complimentary 

responsibilities for land (e.g. USDA/NRCS), and water (e.g. USGS and ACOE). 

g) Explore developing a bridge between risk and performance to achieve 

sustainability: The risk assessment paradigm is a core management 

conceptualization for EPA, and for that matter most of the entities it regulates. If

A-25 
the Agency plans to lead the nation to a higher state of environmental 

management performance, then it must build a bridge of understanding between 

the risks associated with the stressors it manages and how they link to functional 

process and the benefits associated with those processes. So in ecological terms 

this would mean linking chemical, physical or biological stressor loads to 

predicted adverse ecological responses in functional ecological processes which 

are ultimately linked to the ecological services humans enjoy from a landscape. If 

the agency succeeds in establishing this analytical chain then it can test and 

understand the implications of risk management to ecological performance 

sustainability. This would suggest the agency should be trying to move beyond 

the management of individual agents to the management of environmental 

regimes or landscapes (e.g. lakes, rivers, forests, cities etc.) based on their actual 

condition or performance. 

The Agency should test the assumption that following a risk assessment/risk 

reduction strategy can lead to defining sustainability tools and achieve sustainable 

practices. The SAB believes that sustainability is tied to an expected set of

performance criteria and the absence of unacceptable risk or risk reduction to 

acceptable levels is no guarantee of a sustainable outcome. The extreme but very 

real example of controlling ecological risks by removing the forest to get to the 

underlying contaminated soil highlights a use of risk assessment that is not framed 

in a sustainability context. If the Agency wants to achieve sustainable 

management of contaminated sites it will need to put risk projections into the 

context of actual ecological conditions which should be held up against a 

definition or set of design criteria of sustainable condition for the ecological 

habitat in question. Clearly, this means that data collected on sites must include 

data on ecological conditions and not just levels of contamination. This example 

is intended to illustrate the need to understand how the risk paradigm aligns with 

the type of decisions to be made, and that the current practice used to conduct 

regulatory reviews and reach decisions (e.g. data we collect) may need to evolve 

within the policy context of sustainability rather than risk control. 

 

2. Additional Research Topics For the Human Health Area

(See Appendix A, Subsection 2.5, Page A-17 forward) 

What follows outlines important areas of research that could be given increased emphasis 

in the general research area of human health, and then briefly comments on research by 

individual groups or laboratories as described in the October 2 Compilation and captured 

in bullets in Deputy Assistant Administrator Teichman’s presentation. 

a) Long-Term Research to Support Toxicity Testing Paradigm Shift. In 

support of the new toxicity testing initiative, various areas for increased 

emphasis were noted. These include: 

• Predicting metabolism: Development of strategies to support identification 

and characterization of possible active metabolites in humans and breakdown 

products. This is a critical area for research because failure to miss important 

A-26 
metabolites can lead to missing toxic activities and under-predicting human 

risk. 

• Addressing exposure duration: Rapid high throughput tests of exposed cells 

and cell components will eventually be used to shed light on the consequence 

of complex, long term human exposures – by their nature reflecting real life 

exposure of cells at various ages to a wide spectrum of various endogenous 

and exogenous chemicals. 

• Addressing novel agents: An understanding of the extent that the tests capture 

the behavior of agents that fall outside the chemical sets used to develop the 

assays, and approaches to address novel agents will be needed. 

• Epidemiologic surveillance: A critical piece for predicting human toxicity 

from high throughput test results for a chemical exposure will be an 

understanding of other exogeneous and endogenous exposures that perturb the 

same toxicological process, the degree of human exposures to them, and the 

variable human responses to such exposures. Research is needed to support 

the development of human surveillance strategies to provide the needed 

human data to interpret high throughput findings. 

The NAS (2007) Toxicity Testing report notes these and a variety of other 

research areas that require attention in order to support the development of 

toxicity test batteries for wide use - to address the large number of environmental 

chemicals that are not now tested for lack of resources and rapid methods. The 

NAS envisioned a large scale research venture over many years to bring the 

testing vision to fruition, involving an NTP-like effort in terms of scale. The 

Agency’s impressive but necessarily modest effort to move forward and gain 

experience and capacity in the area is noted. As the Agency by itself and in 

collaboration with other Federal agencies and institutions makes progress in its 

research, it is encouraged to turn frequently to the scientific community through 

the SAB and other scientific expert groups to optimize its research effort in this 

area. 

b) Research to Develop Numerical (IRIS) Guidance Levels for Chemicals 

with Limited Apical Endpoint Test Data. Chemicals go uncharacterized 

because data from classical toxicity test results (e.g., long term bioassays) are not 

available. In some cases, in vitro and metabolic studies and other data would 

enable the prediction of toxicity endpoints and levels. One example where the 

Agency does make quantitative activity estimates and estimates risk in the

absence of full bioassay data is dioxin-like compounds based on toxic 

equivalency factors. Research is needed to support the application of this 

approach to other chemical classes. In the long term approaches will be needed to 

develop guidance levels based on data emerging from the toxicity testing vision 

discussed above. Nearer term research can enable the Agency to move forward 

on chemicals using short term in vivo and in vitro data and structure activity 

A-27 
relationships. This kind of information can be quite valuable in supporting green 

chemistry and other initiatives aimed at moving toward using less toxic materials. 

c) Evolving Agency Hazard Identification and Dose Response Practice and 

Guidance as New Test Data Emerge. Clearly there is a need to evolve risk 

assessment techniques and practice as the practice of toxicity testing changes. 

With the exception of pesticides, there are significantly fewer chronic studies 

being performed today than twenty years ago. REACH promises to produce large 

volumes of toxicity data, but many chemicals are likely to have non-classical 

toxicity tests, particularly given the REACH guidance to where possible minimize 

the use of animals. Agency guidance and practice needs to evolve to take 

advantage of the available toxicity data, particular in cases where chemicals go 

uncharacterized. While the Carcinogen Guidelines and Supplemental Guidance

did advance over previous versions, they were long in coming, and the 

International Agency for Research in Cancer has now developed guidance that is 

considered by some to be more up to date. There is a research component to 

develop new practice – new methods need to be developed to capitalize on 

findings, and sensitivity and specificity of the new approaches need to be 

understood in a general sense. It is recognized that development and incorporation 

of new approaches to chemical hazard and dose response prediction are 

challenges for a variety of practical reasons. Predictability of agency response to 

particular types of test data, consistency across chemicals in methods of analysis, 

and the need for researchers to have the skill set and understanding to replicate 

analyses all come into play in maintaining the status quo. On the other hand when 

there are exposures to apparently toxic agents that go uncharacterized and are not 

included in risk assessments, or better replacement chemicals are harder to

identify, or agency assessments appear out of step with the science, opportunities 

for better decision-making are lost and agency credibility suffers. 

d) Epidemiological Research: Surveillance, Understanding Gene-LifestyleEnvironment Interactions. The SAB saw in-house capacity in the area of 

epidemiologic research limited to a few specialized areas. Most of the long term

research is “bottom up” in nature, with the long term goal of inferring risks and 

effects in individuals from mechanistic understanding and data. “Top down” look 

at exposures and disease can be used to quantitatively generate as well as check 

hypotheses. It can also help to develop more scientifically rigorous basis for 

individual variability assumptions used in dose response analyses. Also, 

epidemiologic understanding of endogenous and exogenous exposures and health 

status should prove critical in applying the results of high throughput screening to 

individuals and populations. Molecular epidemiology is key to identifying 

relationships between specific diseases and genes. Disease pathways can be 

discovered through associations between genes in susceptible individuals and 

diseases. An understanding of background processes and exposures is also 

critical to understanding the potential for linear dose response relationships due to 

“background” additivity. The Board supports the partnerships EPA has 

developed with agencies such as CDC in health tracking and biomonitoring, as 

A-28 
well as the extramural research conducted to support the assessment of the criteria 

air pollutants and cumulative risk assessment. Still, greater in-house capacity 

including at a senior level could provide a public health and epidemiologic 

perspective to the research program and potentially synergize activities in the 

toxicity testing initiative.

A-29 
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R-1 
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