1 Summary Minutes of the United States Environmental Protection Agency (U.S. EPA) of the Science Advisory Board (SAB)

March 22

- 23 , 201 2

Date and Time : March 22 , 201 2

, 10:00 a .m. to 6:30 p.m.; March 23 , 201 2

, 9:00 a.m.

- 1 : 0 0 p.m.

Eastern Time

Location: The Washington Plaza Hotel, 10 Thomas Circle, NW, Washington, DC

Purpose : To conduct quality reviews of a draft report on the President’s requested FY 2013 budget for EPA research and a draft report on science integration at EPA; to discuss a joint mee ting of the SAB and Office of Research and Development’s (ORD’s) Board of Scientific Counselors (BOSC); to receive a briefing on ORD and sustainability science; and to discuss the scientific and technical bases for four proposed agency

actions.

SAB and BO SC Members :

SAB Members

Dr. Deborah Swackhamer, Chair Dr. George Alexeeff

Dr. David Allen

Dr. Pedro Alvarez

Dr. Joseph Arvai Dr. Ingrid Burke

Dr. Thomas Burke

Dr. Terry Daniel Dr. George Daston

Dr. Costel Denson

Dr. Michael Dourson

Dr. David Dzombak

D r. Taylor Eighmy Dr. Elaine Faustman, Dr. John Giesy Dr. Barbara Harper (by telephone) Dr. Kimberly Jones

Dr. Bernd Kahn Dr. Agnes Kane Dr. Nancy Kim Dr. Cecil Lue

- Hing Dr. Judith Meyer

Dr. James Mihelcic

Dr. Christine Moe

Dr. H. Keith Moo

- Young

Dr. Eilee n Murphy (by telephone

, March 22, 2012 only ) Dr. James Opaluch

Dr. Duncan Patten

Dr. Stephen Roberts

Dr. Amanda Rodewald

Dr. James Sanders

Dr. Jerald Schnoor (by telephone , March 23, 2012 only )

Dr. Peter Thorne Dr. Paige Tolbert

Dr. John Vena

Dr. Roberts W atts
Dr. Thomas Zoeller

Liaisons to the SAB : Dr. James Johnson

Dr. Kenneth Portier

Dr. Pamela Shubat Dr. Katherine van Stackleberg (by telephone, March 23, 2012 only)2 EPA p resenters : Dr. Robert Kavlock , Deputy Assistant Administrator for Science, O RD Dr. Peter Preuss, Chief Innovation Officer, ORD Dr. Alan D. Hecht, Director for Sustainable Development, ORD Dr. Joseph Fiksel, Sustainability Advisor, ORD

SAB Staff Office : Dr. Angela Nugent, SAB Staff Office , Designated Federal Officer for the Chart ered SAB Dr. Vanessa Vu, SAB Staff Office Mr. Thomas Brennan, SAB Staff Office

Meeting Summary March 22

- 23, 2012

The meeting g enerally followed the issues and tim ing as presented in the agenda

. 1

Convene the meeting

Dr. Nugent formally opened the meeting and noted that the meeting had been announced in the Federal Register. 2 She noted that participating SAB members had met the requirements of the

Ethics in Government Act and the SAB Staff Office had reviewed these materials to determine that they had no conflict of interest or appearance of lack of impartiality. She noted that the Federal Register notice meeting announcement had provided the public with an opportunity to provide written and oral comment. There was one request for oral comment and no written comments had been provided by the public

. Attachment A contains a list of other attendees

.

Goals and agenda for the meeting

Dr. Vanessa Vu review ed the agenda, thanked the agency and the public for participation, and

thanked SAB members and l iaisons and SAB staff for the meeting preparations.

Dr. Deborah Swackhamer, the SAB Chair, welcomed the group and asked advisory members and

liaisons and members of the public to introduce themselves

. She r eviewed the agenda

.

Discussion of draft report f rom the SAB Research Budget Work Group

Before the chartered SAB’s discussion of the draft report 3

, Dr. Robert Kavlock, ORD Deputy

Assistant A dministrator for Science , extended greetings from Acting Deputy Assistant

Admininistration Lek Kadeli and from for mer ORD Deputy Assistant Administrator for Science Dr. Kevin Teichman, who had taken a n EPA research post addressing indoor air issues at the National Institute of Standards and Technology. In response to a question from Dr. Swackhamer,

Dr. Kavlock undersc ored ORD’s commitment to implement the “Path Forward” vision previously articulated by then

- ORD Deputy Administrator Paul Anastas.

Dr. Kavlock noted that the SAB’s draft report on the President’s FY 2013 requested research budget affirmed support for fun ding ORD’s six research programs and identifi ed needs for strengthening support for several priority areas, including climate and energy, sustainability, and3 molecular design. ORD will make efforts to factor these recommendations into future research plann ing. He noted that the SAB called for budget items to strengthen integration across ORD’s

six research areas. He suggested that this concern was more properly addressed as an implementation, rather than a budget

, issue, and that this implementation concern might better be addressed at the July 10

- 12, 2013 meeting of the SAB and ORD Board of Scientific Councilors (BOSC)

. He noted that ORD has just announced that five or six new postdoctoral fellows would be added to focus on integration issues.

He also note d that the distribution of resources across ORD’s six major pro grams resulted from ORD’s 2011 program restructuring. ORD did not anticipate major shifts in resources across these

programs.

After Dr. Kavlock concluded his remarks, Dr. Taylor Eighmy, Chair of the SAB Research Budget Work Group summarized the major points in the draft report and thanked members for

their comments

. 4 The President’s requested budget provides a modest increase in funding for ORD overall, with increases in four program areas and modest decline s in two areas. Although

some topics merit more funding, the budget was reasonable in the context of a declining budget

for EPA

. Dr. Eighmy also noted that the report was prepared on an accelerated schedule and acknowledged the contributions of work group members, the DFO, and agency staff who addressed work group members’ questions.

Dr. Swackhamer asked SAB members who had been asked to serve as lead discussants to

summarize their written comments. The first lead reviewer, Dr. David Allen

, summarized brief comments to address the draft report’s comments on the FY 2013 requested funding for the Air, Climate, and Energy program. He considered the draft report very well done. It addresse d the charge questions and was clear and logical. He sugge sted that the report would be improved by adding a conclusion to address cross

- cutting themes and adequacy of resources.

The second lead reviewer, Dr. David Dzombak

, summarized comments on the report, with special attention to the section addressing the r equested budget for the Safe and Sustainable Water program

. He found the draft to be a v ery well written, well organized report. He suggested that the Board consider areas to disinvest, rather than only call for increased resources for ORD

programs . He als o suggested that the Board consider how ORD resources compared with investments in related EPA programs . He suggested that the report could be improved by making

the tone of the letter more consistent with the neutral language of the report and by avoiding

verbs such as “ troubled .”

The third lead reviewer, Dr. Amanda Rodewald

, focused her comments on the draft report’s text addressing funding for the Safe and Healthy Communities program. She noted that the Board had identified this program previously as th e most visionary, integrative, and potentially most
transformative ORD program . She observed that the program had received the largest percentage

cut. The report’s language describing the cut is very neutral. She advocated that the Board take a position on whether the program will be able to meet its goals with the requested resources. The language should be clearer on this point.4 The fourth lead reviewer, Dr. Thomas Zoeller, noted that the draft report was clear and well organized. He suggested that the l etter to the Admi nistrator should provide additional detail about the major recommendations in the report. He also stated that the letter should highlight the limited information available to assess the budget’s adequacy for ORD programs. He had no

issue w ith points raised regarding the requested funding for the Che mical Safety for Sustainability research program and agreed that the small proposed reductions in funding for the

Human Health Risk Assessment will make it difficult for that program to integrate new types of

scientific information into risk assessments.

The fifth lead reviewer, Dr. James Johnson, provided comments on the section addressing funding for ORD’s Homeland Security program. He found the section well written and asked

whether more resou rces were needed for the water security program . He also suggested that the report more strongly endorse the Homeland Security program ’s efforts to collaborate with other programs to leverage resources.

The sixth lead reviewer, Dr. Joseph Arvai

, commented on the section of the report addressing

Economics and Decision Science

. He noted that the charge questions were handled well but that the mission statement did not clearly identify strategic research that reflected current work in

decision science. The la ck of clear objectives gave the impression of a research program “floundering without research directions.”

The SAB Chair asked members to restrict their comments to budget

- related topics and to defer discussions of strategic research directions to the S AB

- BOSC meeting in July.

Dr. Eighmy responded to lead reviewer comments. He endorsed the idea of adding a conclusion

section to address cross

- cutting integration issues. He noted that the work group didn’t identify

additional cuts. One option for FY 2014 might be to request additional information about one or two programs for a more detailed e xamination of resource needs or for an examination of budget allocations at EPA outside ORD. He agreed to revise the report to make language consistent to

address th e appropriate degree of concern.

Regarding funding for the Safe and Health Community program, Dr. Taylor noted that the program was to receive nearly 40 percent of ORD’s budget and that the reduction of 2.5 percent

should be viewed in that context. He agr eed that it was appropriate to acknowledge the success of the Homeland Security program in collaborations and successful product development.

Other members of the work group provided their comments. One member noted that the budget

exercise was structured in terms of six research silos and provided no obvious accountability for integration across research programs. Another member expressed appreciation for the strategic research action plans made available to the work group for ORD’s six research programs. These plans identified outputs but did not identify milestones for multi

- year outputs. Several members

voiced frustration with the “ mismatch ” of charge questions and the amount and type of information provided to the SAB. Both EPA and the SAB should consi der the appropriate level of detailed advice that would be useful and the amount and nature of information that would help the SAB address those questions. There is a need in the future to better map information in the strategic research action plans to th e budget and to briefing materials provided to the Board. The5 SAB Chair noted that these questions were not new ones . T he key question for the SAB to

address is “ how does the requested budget line up with the research needs of the a gency ?” Dr.

Kavlock note d that the SAB’s report informs Congress as it considers EPA’s budget for the upcoming fiscal year and also informs ORD as it plans for budgets in future years. SAB

members agreed that the issue of how best to conduct future budget reviews would be a good topic to address during the July meeting.

Other Board Members and Liaison made the following additional comments related to revising the report:

**•** The report should consider whether to include exposure assessment as a cross

- cutting issue. Have budget cuts d isproportionately hit exposure science, a topic being emphasized in a current National Academy of Sciences report? Some areas being cut are new exposure tools in the Chemical Safety for Sustainability program, Beach Monitoring

in the Safe and Sustainable W ater Program, and exposure science in the Air Climate and Energy programs. The report should clarify whether the Beaches program had a dual use (supporting regulatory development and ongoing exposure monitoring)

.

**•** The report should r evise the discussion of the beaches program to frame comment about reductions narrowly. Do not say reductions are appropriate unless that is thoroughly

evaluated.

**•** The report should e liminate specific references to programs (e.g., new estuarine center) if not needed)

.

**•** The report should suggest that ORD use the Federal Technology Transfer Act more actively to sa v e resources and to work more collaboratively with the Food and Drug Administration, Centers for Disease Control on risk assessment, perhaps using Toxnet as a starting point for risk assessment. ORD might consider how to share information about

chemical assessments between ORD’s National Center for Environmental Assessment and Homeland Security program.

**•** ORD had provided a sample table showing where different ORD programs had the lead

for cross

- cutting activities. The Sustainable and Healthy Communities had the lead for

some activities. It might be useful to showcase these tables more clearly or discuss these examples.

**•** The report should c larify language about Dashboard and Eva luation on page 18 to communicate that ORD has responded to the SAB’s recommendation for closer coordination between the Chemical Safety for Sustainability program and users of its science products

.

**•** The letter should c ommunicate more clearly that a 29 perc ent decrease in real dollars over a decade for research is not appropriate when there are tremendous needs to understand climate change, unusual events, and exposure issues. Programs and regions have significant science needs. It is important to invest in research to prevent future problems.

**•** Overarching findings on page 3 line 16 of the report can be incorporated in the cover

letter. The report should incorporate discussion of science integration page 4, line 13

- 19

and language on decision science from pag e 25 in the letter.

SAB members also noted that some content taken from the strategic research action plans

merited SAB review and comment. One member noted that the vision statement of the6 Sustainable and Health Communities program was very vague. Member s agreed that this topic was appropriate for discussion in July.

After the Board concluded its discussion, the Chair requested a motion to determine whether the report was appropriate to transmit to the Administrator and under what conditions. Dr. George Daston made a motion to accept the report with changes identified in written comments and in the Board’s discussion and to have the revised report sent to the Board chair. Dr. Peter Thorne

seconded the motion. The Board discussed the motion. One member not ed that if decadal research funding trends were discussed, it should be stated factually without a policy judgment. The SAB chair and the workgroup chair agreed. The motion passed by voice vote with no members opposed and no abstentions

.

SAB members then discussed mechanisms for providing the report to Congress. One member expressed concern that Congress had not requested written or oral testimony from the SAB on the President’s requested research budget this year. The SAB Director noted that the SAB Staff will brief Hill Staff about the report when it is complete and enquire whether the House Science, Space and Technology Committee would like additional information.

Planning for the July 2012 Meeting of the SAB and the Office of Research and Development’s (ORD’s) Board of Scientific Counselors

Dr. Robert Kavlock , Deputy Assistant Administrator for Science, ORD, provided a presentation

entitled “ Planning for July 2012 SAB/BOSC Meeting .” 5 He underscored ORD’s commitment to integrated transdisciplinary rese arch and welcomed the opportunity for joint advice from the SAB and the BOSC. He identified three topics for possible discussion: 1) progress in developing the six research programs; 2) integrating across the six programs; and 3) stimulating innovative

res earch. He envisioned the meeting as offering an opportunity for each of ORD’s six programs to provide an overview of progress in the past year, describe the impact of SAB/BOSC comments (Oct. 2011) on program development, and raise specific questions to SA B/BOSC for advice. There would be an opportunity to d iscuss case studies that demonstrate integration at different stages of development. Three possible case studies to explore integration might be

cl imate change, nitrogen, and integration of results from Chemical Safety for Sustainability into

Human Health Risk Assessment

.

Dr. Peter Preuss, the ORD Chief Innovation Officer, provided a presentation on ORD

innovation. 6 He described ORD’s innovation strategy, which aims to support innovation at the

bench in ORD laboratories, demonstrate the power of transdisciplinary research, use open innovation to broaden the network of environmental problem solvers (building on the strong federal government program showcased at the website challeng e .gov) , and showcase res earch that exemplifies the principles of the “Path Forward” described by former Assistant Administrator Paul Anastas (i.e., by expanding an understanding of innovative research and sustainability). He suggested that it would be helpful to get SAB and BOSC advice about how to encourage innovation in the labs , how to apply design thinking in ORD to diverge from present approaches to identify creative choices and creative solutions, and how to measure/evaluate

innovations.7 After both presentations, SAB member s and liaisons engaged in discussion with Drs. Kavlock and Preuss. They touched on the following points relating to the July meeting :

**•** It may be helpful to discuss one or more case stud ies where success has been difficult to achieve, such as the integration of economics and environmental justice.

**•** In July breakout groups, National Program Directors can discuss how sustainability is addressed in each of their programs.

**•** It would be useful to discuss the strategy and structural basis for integration of research programs, and identify where ORD needs integration vs. better coordination. Discussion of specific activities or case studies would be helpful.

**•** ORD should describe how its “communities of practice” described in EPA’s 2012 Budget in Brief, will operate.

**•** It would be helpful to hear how ORD plans to update the strategic research action plans (e.g., timing for updates, content of updates, especially related to milestones)

.

**•** There is a need for ORD to address how it will involve decision sciences in

consideratio ns of sustainability, tradeoffs, problem formulation, evaluation, and adaptive management, key issues for ORD’s six new programs.

**•** Evaluation is important for the innovation program; ORD is planning to work with the program evaluation group in EPA’s Office of Policy. Issues of timing and how to measure success are important to understand. Sometimes an innovation may not be successful for its intended purpose and is successful for other purposes, a difficult

situation to evaluation.

**•** It may be useful to talk about innovation in terms of innovative problem formulation and possible use of futures scenarios.

**•** The July discussion should also include how to foster innovation across ORD and not only for recipients of Pathfinder Innovation grants.

SAB members spo k e of the desirability of break

- out groups to discuss OR D’s research programs

in detail and also noted the importance of plenary presentations to break down stove pipes and feature discussions of how ORD research programs interact and fit together. The SAB Staff Office Director noted the importance of logistics. A full two

- day meeting will be necessary to address the topics discussed and she asked members to commit to a two

- day meeting

.

ORD and Sustainability Science

Dr. Alan D. Hecht, Director for Sust ainable Development, ORD and Dr. Joseph Fiksel, Sustainability Advisor , ORD, provided an “Update on EPA Response to NRC Report and ORD Sustainability Science.” 7 Dr. Hecht described how EPA’s commitment to Dr. Paul Anastas ’

“Path Forward” and awareness of t he need to meet future environmental challenges led to EPA’s request for the National Academy of Science s (NAS) 2011 report, Sustainability and the U.S.

EPA , informally called the “Green Book

. ” In response to the report, ORD prepared a draft inventory of s ustainability tools and approaches for EPA’s Science and Technology Policy Council. The goal is to provide guidance on how tools and approaches can be integrated to facilitate sustainability assessment. He also noted that EPA is participating in a wider fe deral government sustainability effort, where the White House National Science and Technology

Council Committee on Environment

, and Natural Resources had been renamed as the Committee on Environment, Natural Resources, and Sustainability . He also noted tha t EPA has participated8 in several months of listening sessions with stakeholders (November 2011

- April 2012), where the role of science was identified as critical for sustainability.

Dr. Joseph Fiksel introduced himself as the Director of the C enter for R e silience at Ohio State University and explained that he had taken the temporary post of Sustainability Advisor to ORD to seek opportunities to introduce systems thinking to the EPA. He focused his presentation on an ORD collaboration with Region 1 to addre ss nutrient pollution in Narragansett Bay. ORD collaborates with stakeholders to address sustainability goals to explore integrated (i.e., regulatory and voluntary) strategies for nutrient mitigation. The project used the “Triple Value (3V) Model,” a conce ptual model linking the environment, economy and society, which gave scientists and stakeholders a common framework and language and offered an opportunity to identify opportunities for intervention, knowledge gaps, and research needs. He noted that the

Sa fe and Sustainable Water Resources program and the Sustainable and Healthy Communities

program s have used the model

. The Narragansett research team populated the model with data to develop a working systems

- dynamics simulation model. He described this mode l as a “c rude

model approximation of reality” that captured key trends and drivers. He described the “Dashboard” human interface that allows a nontechnical user to change variables and project implications.

He concluded his comments with a brief discussio n of indicators and metrics

, since the NAS “Green Book” emphasized the importance of sustainability metrics and the public listening

sessions reiterated this theme . ORD has introduced several sustainability indicators for the 2012 Report on the Environment

.

After the ORD presenters concluded their presentation, SAB members and l iaisons engaged them in a question and answer session. In response to questions, Dr. Fiksel clarified that the graphical interface had been used to support discussions at stakeholde r meetings. The model is transferable and would take a month to populate with different data. Dr. Hecht responded to a question about ORD’s Homeland Security program by noting he was working with that program to broaden its efforts related to resilience, b uilding on a National Council on Environment and Security conference held in January 2012. Dr. Fiksel clarified that resilience is not a well

understood concept across ORD.

An SAB member asked about ORD’s definition of sustainability. Dr. Hecht responded that the Green Book defined sustainability as both a goal and a process and that the NAS relied on the definition of sustainability from the National Environmental Policy Act, i.e., “to create and maintain conditions, under which humans and nature can exis t in productive harmony, that permit fulfilling the social, economic, and other requirements of present and future generations.”

An SAB member noted that the “Triple Value (3V) Model” did not show benefits from industries that invest in protection and inn ovation. Dr. Fiksel responded that the “benefit arrow” properly belonged in the model and had been eliminated for simplicity in this presentation. In response to another SAB member, he noted that the model could be used to help stakeholders

better understa nd tradeoffs involved in choices. Modeling involves educating decision makers,

the community, and sometimes states to understand trade

- offs.9 An SAB member and a liaison noted that the term” resilience” did not make sense in a public

health context. Childr en may be resilient, but that may not mean they are healthy. She asked for a presentation focused on sustainability and public health. Dr. Fiksel responded that another example could show the application of the model in a public health context. Health is a driver of resilience, but resilience doesn’t equal health. EPA has discussed these issues in the context of environmental justice and children’s health and is sensitive to these concerns. The model might also be used in integrating social impact assessmen ts and community vulnerability

considerations that affect children’s health.

Yet another SAB member stated that the “Triple Value (3V) Model” is useful but requires true investment in decision science to reap benefits. Simply showing info rmation and tools to people

is not the same as studying the alignment of the outcome of decisions with people’s priorities. Dr. Fiksel agreed that people need more than data to make decision

- support tools such as his model operational. ORD has “n ot crossed the threshold ” i nto decision science that would make

the model most useful. He noted that the tool is primarily being used within EPA and not generally currently being used in program offices. ORD potentially envisions the tool being used to help develop regulations and/o r policies promoting green infrastructure for treatment of wastewater and storm water. It may also be used for policies related to greenhouse g ases and biofuels, where there are complex considerations and a variety of regulatory and voluntary

management ap proaches that could be used.

An SAB member asked how ORD is identifying problems at different scales that would be most appropriate for using the “Triple Value (3V) Model.” Dr. Fiksel responded that ORD has not yet

identified where there are decisions at the national scale that would be appropriate to the use of

the model.

Dr. James Johnson, SAB Liaison and Chair of the National Advisory Committee on Environmental Policy and Technology (NACEPT), noted that NACEPT was meeting to provide

advice to the Admin istrator regarding EPA actions in response to the NAS report , especially as they relate to sustainability objectives, metrics, and fostering an agency culture related to sustainability.

The SAB Chair noted that the language chosen to describe the model wi ll be very important to promote the interdisciplinary collaboration that will be needed. She also noted that the July SAB

BOSC meeting might benefit from a discussion of sustainability and resilience and ORD’s role in developing science to support EPA’s wo rk in these areas.

Discussion of draft report from the SAB Committee on Science Integration for Decision Making

Dr. Thomas Burke, Chair of the SAB Committee on Science Integration for Decision Making

, described the ambitious efforts undertaken by the com mittee to talk with hundreds of EPA scientists, managers, and leaders in all 10 EPA regional offices and major program offices. The

SAB conducted its fact

- finding efforts at a time when EPA was experiencing great changes since 2008. The report 8 has had to adapt to the changing science environment at a time when EPA science was under great scrutiny. The committee developed the report to reflect major themes10 heard during the interviews and to make the report relevant to current EPA science. The field

work co nducted by committee members offers the SAB an opportunity to provide advice to change the culture of science in ways that will be important to EPA’s future success integrating science for decision making . Although EPA regions and program offices develop a nd use their science in very different ways, common themes emerged fro m the discussions regarding the need for science integration. He acknowledged the contributions of chartered SAB members Drs. Terry Daniel, Taylor Eighmy, and John Giesy, as well as the NACEPT l iaison, Dr. James

Johnson

, and many other committee members.

The advisory activity was prompted by a request from then

- Admin istrator Stephen Johnson , who

asked for advice on how EPA could better integrate science into agency decisions. This reque st
had “ some of its origins ” in the 2009 NAS report, Science and Decisions: Advancing Risk

Assessment (sometimes called the “Silver Book”) , which emphasized the importance of problem

formulation.

The SAB’s science integration report repeats this theme. E PA has no consistent process for problem formulation, a step that helps EPA “ask the right scientific questions” and get the right expertise. In some cases at EPA, problem formulation is not done; in other cases, it is “ hit or

miss. ”

Although EPA might em phasize the importance of science integration, the necessary implementation steps are not in place and very often EPA program offices’ “silo” ap proach to environmental problem

- solving is a barrier to science integration. Managers are not accountable

for sc ience integration.

Significantly, regions and program offices are isolated from ORD. Two thirds of EPA’s scientific staff are located in program and regional offices. Scientists outside ORD are responsible for translating science into decisions and voic ed frustrations about accessing and using ORD science to solve their specific problems. To obtain needed science , program and regional scientists developed their own networks, drawing on science at the state or local level, colleges and universities, other federal agencies, or non

- governmental organizations where

science was available to them. The SAB committee concluded that there is a need for EPA to have a stronger community of science to encourage cross

- silo communication, mentoring and outreach, and c ollaboration. There is a need for new measures of success for EPA science. Science should be measured in terms of science integration for decision making and not just in

terms of publication s uccess. EPA needs to develop an approach for attracting, trai ning, retraining and mentoring scientists that addresses the importance of transdisciplinary science.

Dr. Thomas Burke acknowledged the written quality review comments from chartered SAB

members and liaisons. 9 He noted that many commenters asked for more examples but that the committee found that there were no examples of science integration that did n ot have some problematic aspect.

Dr. Elaine Faustman , the first lead reviewer, commended the committee for extensive fact

finding and supported the three re commendations in the report. She suggested that the report mention the 1992 ecological risk assessment framework’s emphasis on problem formulation and11 explore whether that framework informed decisions or resulted in lessons learned. She suggested

that it may have been more useful to use the science integration diagram from the Silver Book, which emphasized problem formulation. She suggested that the revised figure be shown or an explanation be provided for omitting it.

She suggested that the report provi de more support for discussion of sustainability and its link to science integration. She also called for the report to provide a definition of science not just as an “enterprise” that builds knowledge, but also the knowledge itself. She also asked that t he description of EPA’s mission be expanded to include protection of human health.

Dr. Ingrid Burke commended the report for its important focus and message. She suggested that the letter to the Administrator be strengthened to convey more clearly that pr ogram and regional science is separate and somewhat disconnected from ORD research and that science integration was not happening consistently.

Dr. Ingrid Burke supported the three major recommendations. She suggested that the more

detailed recommendatio ns in Appendix D should be nested, if possible

, in the discussion of the three major recommendations. She also suggested that the report also make a recommendation regarding translation of science, drawing on literature and study of “metrics for translatio n ” developed by extension scientists, who study how their science is used.

She suggested that the report refer to “Science Integration Councils,” r ather than “Science Policy

Council s .” She also suggested that the report refer to science to “inform” decisi on making, rather than to “support” decision making.

Dr. George Daston, the third le ad reviewer, found the report a “ bit vague and generalized ” and called for more specifics. He suggested that the report more clearly communicate the charge questions

. If t he report diverged from the questions originally provided by Administrator Johnson, the report should better explain how the questions evolved. He called for additional details and findings from the interviews beyond the description of the National Ambient Air Quality Standard (NAAQS) review, which is unusual because the NAAQS review is a major, mandated review process. He suggested that the scientific response to the Gulf Oil Spill and the work conducted by the National Center for Computational Toxicology might provide good examples. He called for the report to provide stronger recommendations and to highlight changes that can be made immediately

. The conclusions generally are reasonable but should be more

detailed. He took issue with the second recommen dation, which seemed to recommend rewarding managers for integrating more science. He argued

, instead

, that managers should be rewarded for outcomes where science integration was instrumental. He took issue with the third

recommendation , which included s upport for exchanges of scientists between program or regional offices and ORD for developmental details. He argued that ORD’s depth of expertise would be diluted by such exchanges.

Dr. Otto Doering, the fourth lead reviewer suggested that information in the conclusion drawing from the Ash Commission be moved to the introduction. He suggested that clearer charge questions, based on the committee’s experience with the EPA interviews, be presented in the12 scoping section, even if these questions diverged fro m the charge questions in the letter from

Administrator Johnson.

Dr. Doering suggested that the report drop figure 1 because it contained outdated terms. He suggested that the report use the figure from the Silver Book or create a new figure. He

recommen ded that the definition of integrated science be simplified.

Dr. James Sanders found the report a short, clear ly written and straight

- forward report. He would have liked more support for the findings and recommendations. He asked that the report

communi cate more clearly that the interviews were available as a stand

- alone document. He suggested that the letter provide additional explanation for each finding and recommendations so that the reader can more easily understand the findings and major recommenda tions.

After the lead reviewers finished their remarks, Dr. Thomas Burke noted that the committee grappled with these i ssues. It should be feasible to m ove recommendations in A ppendix D into the body of the report. He committed to considering possible cas e examples, such as science supporting the Gulf Oil Spill, Region 3’s use of the Multi

- criteria Integrated Resource Assessment (MIRA) , or the estuary program. He also noted the call to provide more support for

the recommendations , to consider using the Si lver Book diagram or redrawing figure 1 and to provide additional support for the sustainability references.

After Dr. Burke finished his brief response, other members of the committee provided

comments. Dr. Johnson noted that the committee had found it d ifficult to use examples, because different members of the committee made objection, on different grounds, to the use of every example chosen. Dr. Terry Daniel supported the idea of crafting fresh charge questions without being tied directly to the origina l language provided by Administrator Johnson.

Dr. John Giesy noted that the impetus for this report resulted from criticism of EPA past practices that generally are no longer a problem. Rather than criticize those past practices, the

committee chose to make positive recommendations to strengthen EPA science. Recommendations for this report were especially tricky. The committee found EPA scientists to resourceful and innovative in solving their problems, often in unexpected ways. The committee

did not ha ve grounds to criticize regions or program offices for these strategies nor did it have grounds to criticize ORD for not providing all the science required by the Agency , because ORD cannot conduct all the research and science needed by program and region a l offices . As a result

, it became difficult to develop recommendations that were clear and pointed at the high level of this report, which addressed an overview of EPA science. The messages from the interviews

cannot be neatly diagramed; “they were all ov er the map” addressing how program and regional

offices were “ doing things and not doing things.” The committee decided to keep the message simple and address only a few key points.

After members of the Committee on Science Integration for Decision Making who were also

members of the chartered SAB concluded their remarks, other members provided comment. One member noted that the report is important because it addresses science beyond ORD, the SAB’s usual customer. The committee has engaged EPA’s scientific community outside ORD and has an important message to communicate to the Administrator. It should communicate that message13 clearly to help the agency strengthen its use of science. The recommendations are systematic and

fundamental. The SAB should compl ete this report and follow

- up to see that recommendations

receive attention and are addressed. The recommendations are important to decisions m ade in program offices, regions and states that look to EPA as a model. Other SAB members supported

this view an d suggested that the SAB consider how to continue efforts to better understand science outside ORD and how to provide advice to support science in program and regional

offices

.

Members made the following additional suggestions to consider in strengthening the report:

**•** Consider commenting on how to communicate uncertainties in science assessments. The report might emphasize the importance of “getting the science right” and communicating it effectively.

**•** Highlight any findings related to states.

**•** Edit the repor t with consideration to where text can be pulled out of context to be misconstrued and cause problems for EPA.

**•** Highlight EPA institutions that foster integration: the Science Policy Council, Risk Assessment Forum, and historical Integrated Risk Information System consensus work

groups. Dr. Thomas Burke responded that the committee found all these topics complex and had not reached agreement on conclusions to include them in the report.

**•** Make it clearer that the type and level of integration can depend on the type and significance of the decision to be made.

Members discussed the importance of clarifying the nature of the committee’s fact

- finding. Members of the Committee on Science Integration for Decision Making explained that

, although

there was an ambitio us interview protocol, the dynamics of the discussion depended on the

“ dynamic of who was in the room .” The interview summaries are available and are cited in the report, but they do not provide an objective data set. The committee used the interview

summ aries as a base set of information to extract themes. One theme that came across in many interviews is that that science integration played little or no part in interviewees’ work. Those interviewees reported that the law prescribed what was necessary, o r that they didn’t have time for science integration, or that they were following precedent. Other interviewees made different kinds of efforts to integrat e science. The major “ take

- home message ” is that there is no single

way to integrat e science to supp ort EPA’s decisions. “ It’s all over the map. There are a lot of really dedicated people. T hey don’t have resources they need for science. There isn’t time for them to get training and learn and get ready for all the decisions they need to make. Approaches

differ at every level of organization and across programs.” The Committee decided to distill a few key findings and recommendations. The available interview materials defy deeper analysis.

Members agreed that the report would be strengthened by a descr iption of the “messy” nature of the interviews and the “incredible group of EPA scientists” meeting challenges in different ways. The report should explain that it distilled only a few clear themes relating to the need for education, networking, data shar ing, and convening the right people.

After the discussion had concluded, Dr. Swackhamer asked for a motio n to dispose of the report. Dr. Ingrid Burke made a motion to accept the report with changes discussed during the quality

review and to have the revis ed report sent to the Board C hair. Dr. Duncan Patten seconded the14 motion. The Board discussed the motion. The motion passed by voice vote with no members opposed and with one abstention from Dr. Michael Dourson.

The DFO recessed the meeting at 6:30 p.m.

Friday, March 23, 2011

The DFO reconvened the meeting at 9:00 a.m.

Discussion of the scientific and technical bases for several rules proposed by the Office of

Air and Radiation

Dr. Deborah Swackhamer provided background about a pilot activity undertak en by the SAB in response to a new EPA initiative to strengthen coordination with the SAB by providing the SAB with information about proposed agency actions. This initiative was described in a January 2012 memo from Office of Policy Associate Administrato r Michael Goo, as provided to the SAB in Attachment A of the meeting material entitled “Screening Consideration of Four EPA Proposed Regulatory Actions and Supporting Science.” 10 She noted that this new process is intended to provide the SAB a meaningful op portunity to provide advice and comment, where appropriate, on the science supporting proposed agency actions, even when there isn’t an explicit request for

SAB advice. The initiative is consistent with language of the Environmental Research and Developme nt Demonstration Authorization Act of 1978.

As the SAB develops an implementation process for this initiative, the Board conducted a pilot exercise to evaluate four proposed rules to determine the information needed to provide advice

and comment on the su pporting science. The pilot exercise focused on two sets of proposed regulations. On December 23, 2011, the SAB Staff Office was informed by EPA’s Office of Air and Radiation of proposed rules relating to : 1) standards for air toxics from boilers and

incin erators and 2) greenhouse gas emissions and fuel economy standards for light

- duty vehicles

.

To assist the SAB deliberations, SAB members Drs. David Allen, Peter Thorne and Jerry Schnoor agreed to serve as lead discussants. In that capacity, they worked w ith SAB staff to

conduct fact

- finding and de veloped initial recommendations to the chartered SAB on information needed to evaluate if the SAB should develop advice and comment relating to the OAR proposed rules.

After Dr. Swackhamer’s introduction, SAB m embers briefly discussed the nature of this new activity. There are 164 actions identified in EPA’s most recent semi

- annual regulatory agenda that the SAB might consider. The SAB Staff Office Director noted that the SAB DFO, Dr. Angela Nugent, was leading an agency work group to identify a process for screening actions for SAB attention and to identify the supporting information that would be publicly available.

Chartered SAB members would decide which agency actions had supporting scientific and

technica l documents that would be the focus of SAB review

. Review of the science supporting

these actions would be conducted by an appropriate panel of experts . The SAB Staff Office

would follow its standard process for identifying the appropriate type of panel to conduct the

review , and, if a new panel of experts were needed, the SAB Staff Office would follow its established panel formation process . SAB members agreed that the process would need to take15 account of EPA’s time constraints and still meet the requir ements of the Federal Advisory

Committee Act. They also noted that although the effort would be time

- intensive, it might offer

the SAB a new opportunity to provide science advice to strengthen EPA decision making.

EPA’s proposed rule addressing 2017 and Later Model Year Light

- duty Vehicle

Greenhouse Gas Emissions and CAFE Standards

Dr. Jerald Schnoor, the lead discussant of the science supporting EPA’s proposal related to the 2017 and Later Model Year Light

- duty Vehicle Greenhouse Gas Emissions and CAFE

Standards

, participated via teleconference. Dr. Schnoor summarized the background for this proposed rule and his major findings, documented in Attachment G of the meeting material entitled “Screening Consideration of Four EPA Proposed Regulatory Actions an d Supporting

Science 11 .” He noted that the proposed rule under consideration amended EPA’s rule promulgated on April 1, 2010. To evaluate the science issues, he considered the historical evaluation criteria for determining whether science issues merited SA B attention (Attachment

D 12 ), the proposed rule, public comments, Agency fact s heets and technical documents, and information gathered through agency fact

- finding conducted 13 with the assistance of SAB DFO

Ms. Stephanie Sanzone.

Dr. Schnoor n oted that the proposed rule is mostly an extension of the previous rule (April 1, 2010) establishing standards for 2012

- 2016 model year vehicles. There are no new scien tific or technical issues with the possible exception of the advanced technical credits for electric v ehicles and (partially) plug

- in electric vehicles (PHEVs) . These proposed credits are intended to provide

incentives to facilitate market penetration of the most advanced vehicle technologies as rapidly as possible . He concluded that there is not a major n ew scientific issue associated with these regulations, and recommended that it should not be a high priority for SAB action.

After Dr. Schnoor concluded his remarks, SAB members asked several questions. In response to a query, Dr. Schnoor noted that he mi ght have made a different recommendation if he were reviewing the April 2010 rule, where there was a new major regulatory initiative. He noted that he spent approximately six hours considering information related to the pilot. Mr. William Charmley, from E PA’s Office of Air and Radiation, Office of Transportation and Air Quality, responded to a question about EPA’s lifecycle analysis for electric vehicles. He noted that the

cost

- benefit analysis included upstream emissions , including projected increased ele ctricity use, as compared with previous tailpipe analyses.

SAB members discussed the pilot’s significance for future SAB activities. One member noted

that i t may be more appropriate for the SAB to focus on new science issues, rather than whether

EPA is a pplying existing science correctly. Another member noted that t he economic analysis supporting the rulemaking may raise science issues; how consumers value fuel economy is a complex top ic that may merit SAB attention

.

EPA’s proposed air toxic rules for b oilers and incinerators

Drs. David Allen and Peter Thorne, the l ead d iscussants for SAB pilot examination of the science underlying EPA’s proposed air toxic rul es for boilers and incinerators, summarized their16 findings and experience with the pilot. Dr. D avid Allen provided comments on proposed rules published in December 2011 that amended four final rules issued in March 2011 that set national emission standards for control of hazardous air pollutants from industrial, commercial and

institutional boilers at major and area source facilities, revised the definition of no n

- hazardous secondary material to clarify the scope of biomass and other solid wastes used as fuels, and

emissions from commercial and industrial solid waste incineration units. The December 2011 rules were major rules because they had estimated costs of $1.5 billion; affected a large number

of boilers ; and were estimated to result in major risk reductions.

For both lead reviewers, the most significant science issue was the proposal to replac e numerical

dioxin limit s with workplace standards. EPA assumed that di o xin emissions would scale with

reductions of fuel burned. Dr. Allen considered this rule “fel l squarely in the middle ”

– it might merit SAB attention because of the significance of the rulemaking and the novel science issue. More information would be needed to determine whether workplace standards involving tuning up boilers and changing flame temperatures would necess arily result in changed emission of

dioxin.

Drs. Allen and Thorne reported that they had participated in a very useful fact

- finding session with senior EPA staff organized by Ms. Sanzone 14

. Dr. Allen concluded that historical SAB

evaluation criteria are not well suited to evaluating the significance of science supporting rulemaking. The SAB will need more focused criteria that will allow the SAB to rank order different proposed agency actions and their related science in terms of relative significance for

SAB attention. For him the key questions were: 1) whether the scie nce was new; 2) whether the right science was done; and 3) whether the science was done right.

Dr. Thorne commented on the proposed rule addressing commercial and industrial solid waste

incineration units

. He noted that these regulations generally impose d more restrictive limits for a wide variety of incineration units, from very large to small units that might operate in a laboratory and would also affect Portland cement kilns

.

Drs. Allen and Thorne each spent approximately 12 hours reviewing documents for the pilot and

“ felt fairly confident ” in concluding that the proposed changes did not involve much new science that should be examined by the SAB.

After the lead discussants concluded their remarks, Mr. Timothy H unt from the American Forest

and P a per As sociation provided public comment, supported by a factsheet on dioxin workplace

standards 15 and a bar chart comparing d ioxin l imits in various U.S. r egulations

. 16 The American Forest and Paper Association supports EPA’s December 2011 proposal to use workplace standards, rather than a numeric standard because dioxin levels from these units are below the limits of detection given current measurement protocols. Drs. Allen and Thorne questioned whether EPA might use a longer, 24

- hour sample , rather than a one

- hou r sample, and noted that costs of such sampling might be the barrier to such a requirement.

In response to other questions from SAB members , Mr. Hunt noted that many industry stakeholders supported the December proposal because it made the more standard achievable and affordable. He also noted that the rule was highly technical. Public comment was difficult17 because EPA’s accelerated schedule made it impossible for stakeholders to develop test data as part of their public comment. If the SAB were to prov ide comment on such issues, “timing would be critical,” and the SAB would need to set priorities to focus on the most significant issues within the complex context of the regulatory decisions to be made. He noted that the

Maximum Achievable Control Technol ogy rules were not based on health effects and were technology

- based standards. An SAB member noted that science integration issues relate to whether technology

- based standards meet health

- based concerns.

Another SAB member expressed the view that the reg ulated industry and public interest groups

often have a good sense of the scientific issues related to regulations

. Comments from these groups can help inform SAB decisions about whether to review the science associated with a proposed rule.

Discussion of lessons learned from the pilots

Chartered SAB m embers and l iaisons addressed the following points in discussing the future

evaluat ion of the science supporting proposed Agency actions:

**•** Members discussed the need to know answers to key questions:

o What ar e the science issues?

o Is EPA’s evaluation of the literature sufficient ?

o What was the methodology used?

o Was the analysis well done?

o What was the problem formulation associated with the action (e.g., why the proposed action is needed, what methodology /scie nce/data is needed; how will the data be gathered and assessed to support the action)

.

**•** Refining/updating SAB’s historical evaluation criteria would be useful

**•** Members discussed how the evaluation should be done

o One option

– a subgroup of approximately six c hartered SAB members could evaluate the set of proposed rules and propose a ranking or triage

o Another option: the full chartered SAB could evaluate the entire list and delegate more detailed exploration of high priority actions to a small group that would work with the SAB Staff to do fact finding and then return to the chartered SAB

with recommendations.

o Another option : SAB would develops criteria and EPA could do initial screening

. The SAB and SAB staff could focus attention on EPA offices that typically do not

seek review or advice from the SAB.

**•** Members generally agreed it would be desirable to engage in the early stage of reg ulatory development.

**•** The SAB should keep in mind that the goal is to identify a small (e.g., two or three)

numb er of actions for SAB attention each year

.

**•** There might be a “checklist” of questions that EPA staff could address to provide background on the science supporting a planned a gency action.

**•** EPA could provide the SAB with its Data Quality Objectives to help the Board to screen

f

or appropriate actions for attention.

**•** EPA could provide information about key technical documents and associated peer review plans/history and summary of science issues identified by public comment ers.18 **•** Both EPA and stakeholders can provide the SAB with inf ormation about whether new or controversial science is associated with the proposed action.

**•** The output or work product of the SAB’s screening would be a letter to the Administrator identifying the proposed action (s) and related science the SAB has elected to review/provide comment on

**•** The SAB should examine how the FIFRA Scientific Advisory Panel provides advice on science supporting rulemaking.

**•** The SAB will need to develop a process for : 1) evaluating the backlog of planned and proposed agency actions (164 actions) and 2) examining actions on a semi

- annual basis,

as EPA releases its semi

- annual regulatory agenda.

The SAB Chair noted that the Board had reached several areas of agreement: 1) involvement is appropriate early in the process; 2) a three

- stage ev aluation process is appropriate (the full Board sees the whole list and screens actions down to 10; a subgroup looks in depth at those 10 to make recommendations on a few actions for SAB attention; the full Board decides the actions to take

on as SAB advis ory activities); and 3) there is a need to further develop/refine criteria.

She also noted that the Board had not agreed on how to conduct the initial screening and how to meet the many concerns about resources, time, and staff needed to address this new activity. She called for formation of a small group to focus on how best to conduct the initial screening. The following SAB members were identified to participate in a work group on this issue : Drs. David Allen, Michael Dourson; Elaine Faustman; David Dz omback; Duncan Patten; Jerry Schnoor; Deborah Swackhamer; and Peter Thorne

.

Action Items/Next Steps

Dr. Deborah Swackhamer thanked participants for the successful meeting and expressed appreciation for ORD and EPA staff involvement.

The DFO adjourned the meeting at 12 : 3 0 p.m.

Respectfully Submitted: Certified as Accurate :

/Signed/ /Signed/

_______________________ _____________________________ Dr. Angela Nugent Dr. Deborah Swackhamer

SAB DFO SAB Chair

NOTE AND DISCLAIMER: The min utes of this public meeting reflect diverse ideas and suggestions offered by committee members during the course of deliberations within the meeting. Such ideas, suggestions, and deliberations do not necessarily reflect definitive

consensus advice from the panel members. The reader is cautioned to not rely on the minutes represent final, approved, consensus advice and recommendations offered to the Agency. Such advice and recommendations may be found in the final advisories, commentaries, letters, or report s prepared and transmitted to the EPA Administrator following the public meetings.19 Attachment A: Other attendees

Thomas Armitage,EPA Amy Battaglia, EPA James Berlow, EPA Thomas Carpenter

Dan Costa , EPA Bill Charmley, EPA Bob Wayland, EPA David Cozzie, E PA Ed Hanlon, EPA Jenny Hopkinson, Inside EPA Michael Loughran, EPA
Steve Potts, EPA Alexandra Reyes, CQ Transcriptions Stacy Rabkin, EPA Matt Richards, EPA Gail Robarge, EPA Chris Saint, EPA Stephanie Sanzone, EPA Phil Sayre , EPA Greg Susanke, EPA

Kevin T eichman , EPA Marilyn Tenbrick, EPA Tim Watkins, EPA Larke Williams, EPA20 Materials Cited

The following meeting materials are available on the SAB Web site, http://www.epa.gov/sab , at the page for the March 22

- 23, 2012 meeting : http://yosemite.epa.gov/sab/sabproduct.nsf/a84bfee16cc358ad85256ccd006b0b4b/b7520f11667e df858525795600699ba9!OpenDocument&Date =2012

- 03

- 22

1 Agenda

2 Federal Register Notice Announcing the Meeting

3 Science Advisory Board Comments on the President's Requested FY 12 2013 Research Budget (March 13, 2012 Draft)

4 Comments from Board Members and Liaisons on the drart report "SAB Comments on the President's Requested FY 2013 Research Budget (March 13, 2012 Draft) as of noon 03/21/12.

5 Planning for July 2012 SAB/BOSC Meeting, Presentation by Robert Kavlock

6 ORD Innovation, Presentation by Peter Preuss

7 Update on EPA Response to NRC Report and ORD Sustainability Science, Presentation by Alan Hecht and Joseph Fiksel

8 Science Integration for Decision Making at the U.S. Environmental Protection Agency (Draft 03/05/12)

9 Commen ts from Board Members and Liaisons on the draft report entitled "Science Integration for Decision Making at the U.S. Environmental Protection Agency (Draft 03/05/12)" (rec'd as of 03/22/12). .

10 Attachment A, Coordination with the Science Advisory Board Re garding Proposed Criteria Documents, Standards, Limitations and Regulations (Memorandum from Michael Goo, Associate Administrator for Policy) , page 2 of the Screening Consideration of Four EPA Proposed Regulatory Actions and Supporting Science

11 Attachment G, Science Topics Raised by Commenters at Public Hearings for Light

- Duty 2017

- 2025 GHG and CAFE Standards NPRM (EPA Staff Draft Summary), page 20 of the Screening Consideration of Four EPA Proposed Regulatory Actions and Supporting Science.

12 Attachment D

, SAB Evaluation Criteria, page 11 of the Screening Consideration of Four EPA Proposed Regulatory Actions and Supporting Science.

13 Attachment H , Peer Reviewed EPA Studies Utilized in the LD 2017

- 2025 GHG and CAFE Standards NPRM (EPA Staff Summary), page 1 1 of the Screening Consideration of Four EPA Proposed Regulatory Actions and Supporting Science.

14 Attachment F

, Summary of Fact

- Finding Meeting on Scientific and Technical Issues for EPA Proposed Rules Relating to HAPs Emission Standards for Boilers and I ncinerators (SAB Staff Office Summary) , page 16 of the Screening Consideration of Four EPA Proposed Regulatory Actions and Supporting Science.

15 American Forest and Paper, Why EPA’s Work Practices for Dioxin/Furan in the Industrial

Boiler MACT Are Scienti fically Justified (March 23, 2012)

16 Comparison of Dioxin Limits in Various U.S. Regulations, bar chart provided by Tim Hunt, American Forest and Paper