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EPA’s Challenges in Water Security Research

The Environmental Protection Agency (EPA) has been engaged in water security research for four years, and research management and technical issues specific to water security both guide and constrain its activities. A review of the EPA’s research efforts and suggestions for future research and programmatic directions (discussed in Chapters 4, 5, and 6) requires recognition of these challenges as important context for this report.

TECHNICAL CHALLENGES

The technical challenges facing the EPA water security research program are defined by the diversity and size of the water and wastewater sectors and the rapid evolution of water security research information.

Diversity and Number of Water and Wastewater Systems

The task of designing a research program that ultimately improves the security and response capabilities of the nation’s water or wastewater sector would be sufficiently challenging if only one or a few such systems needed to be protected. However, the nation’s “drinking water system” is in reality a large number of heterogeneous and separate systems, ranging in size from 15 connections up to many millions. While EPA regulations produce some technological commonalities, tremendous variety exists. The EPA estimates that the United States has some 160,000 public drinking water systems, each supplying at least 25 persons or 15 service connections on a regular basis (EPA, 2004c). About one-third of this total number (53,000) are “community water systems,” which serve cities, towns, mobile home parks, or residential developments. Most community systems are quite small, with 84 percent serving fewer than 3,300 persons each. “Noncommunity systems” are usually smaller, sup-



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Improving the Nation’s Water Security: Opportunities for Research 2 EPA’s Challenges in Water Security Research The Environmental Protection Agency (EPA) has been engaged in water security research for four years, and research management and technical issues specific to water security both guide and constrain its activities. A review of the EPA’s research efforts and suggestions for future research and programmatic directions (discussed in Chapters 4, 5, and 6) requires recognition of these challenges as important context for this report. TECHNICAL CHALLENGES The technical challenges facing the EPA water security research program are defined by the diversity and size of the water and wastewater sectors and the rapid evolution of water security research information. Diversity and Number of Water and Wastewater Systems The task of designing a research program that ultimately improves the security and response capabilities of the nation’s water or wastewater sector would be sufficiently challenging if only one or a few such systems needed to be protected. However, the nation’s “drinking water system” is in reality a large number of heterogeneous and separate systems, ranging in size from 15 connections up to many millions. While EPA regulations produce some technological commonalities, tremendous variety exists. The EPA estimates that the United States has some 160,000 public drinking water systems, each supplying at least 25 persons or 15 service connections on a regular basis (EPA, 2004c). About one-third of this total number (53,000) are “community water systems,” which serve cities, towns, mobile home parks, or residential developments. Most community systems are quite small, with 84 percent serving fewer than 3,300 persons each. “Noncommunity systems” are usually smaller, sup-

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Improving the Nation’s Water Security: Opportunities for Research plying individual schools, factories, campgrounds, or hotels, for example. The EPA estimates that about 107,000 noncommunity systems exist in the United States, although in aggregate, these small systems supply less than 10 percent of the U.S. population. Drinking water sources are also varied, from large surface water impoundments (reservoirs) or natural surface water bodies (e.g., lakes, rivers) to groundwater systems served by aquifers of varying complexity, interconnectedness, depth, and physical characteristics. The municipal wastewater industry has over 16,000 plants that are used to treat a total flow on the order of 32,000 billion gallons per day (Bgal/d). More than 92 percent of the total existing flow is handled by about 3,000 treatment plants that have a treatment capacity of 1 million gallons per day (Mgal/d) or greater, although more than 6,000 plants treat a flow of 100,000 gallons per day or less (EPA, 1997). Nearly all of the wastewater treatment plants provide some form of secondary treatment and more than half provide some form of advanced treatment using a diversity of treatment processes and configurations. Thus, crafting a wastewater security research strategy that is suitable for all wastewater treatment plants is difficult. Protecting a very large number of utilities against the consequences of the wide range of possible threats is a daunting, perhaps impossible, task. The development of a workable security system to prevent physical attacks against commercial airline flights is difficult and is still a work in progress, and the comparable problem for water systems is vastly more complex. Security technologies for one type of system might not work for another, and many systems might require custom designs. Further, no systems are immune from concern about an attack. A chemical or biological attack on a system that serves only a few thousand people would still be significant in terms of loss of life, economic damage, or the amount of fear and loss of confidence it would cause. In addition, smaller systems tend to be less protected and more vulnerable to a malicious attack. Approximately 160,000 drinking water systems and 16,000 wastewater systems operate simultaneously 24 hours a day, 7 days a week, with the largest systems each servicing millions of customers, and each is capable of being attacked by many different means requiring different methods of prevention. Expecting utilities to harden water and wastewater infrastructure to eliminate all vulnerabilities is unreasonable. The costs of security for the industry would be borne by the end users, and these users may not be willing to bear the costs of developing and implementing technologies that could prevent even a limited range of terrorist attacks over the entire nation’s water and wastewater systems.

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Improving the Nation’s Water Security: Opportunities for Research The diversity and number of water and wastewater systems pose specific problems for the development of workable and sustainable security technologies, such as chemical and biological agent detection and disease surveillance technology, which need to be considered in the development of a water security research agenda. These issues are discussed in detail below. Challenges for Detection Technology In most sectors, early detection is regarded as important to prevent or minimize damage from an intentional contamination attack. The detection might theoretically occur prior to any exposure, enabling preventive actions (“detect to protect”) or warnings to potential end users (“detect to warn”). Detection might also occur after exposure has occurred, possibly supplying sufficiently timely information to encourage exposed persons to seek appropriate treatment (“detect to treat”). Clearly, the earlier a contaminant is detected, the greater the likelihood that its public health impact can be reduced. Thus, an initial research interest has focused on developing early detection systems for chemical or biological agents that might intentionally be introduced into water or wastewater. Any such effort, however, will have to overcome some significant challenges to fashion advanced technologies into a workable system, considering the challenge of the number and diversity of water and wastewater systems and potential contaminants. The problem can be reduced to a matter of simple arithmetic. Every detector balances the ability to detect even the smallest and most transient of signals (i.e., sensitivity) against the need to avoid setting off an alarm erroneously. Ideally, extremely high sensitivity should be paired with an extraordinarily low false positive rate. However, even if the probability of attack on some water system were relatively high, the probability of attack on any particular one of the 160,000 water systems is still very low. Let us assume, for example, a very high rate of one such intentional attack per year among the largest 10,000 drinking water systems. To detect such an attack, sensors would have to be placed throughout the systems and take frequent measurements. If a generic intrusion detector samples once every 10 minutes and there are on average 20 detectors per system (a reasonable assumption for one of the 10,000 largest systems, although one might expect more for a very large system and fewer for a very small system), this adds up to a million sampling intervals per system per year. Assuming a false positive rate of one

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Improving the Nation’s Water Security: Opportunities for Research in 10 million measurements (an extraordinarily small rate if also maximizing sensitivity), this would still produce 1,000 false positives per year among these 10,000 water systems. If only one true positive in 10,000 is expected, this means that almost every time the alarm goes off (99.9 percent of the time), it is a false positive.1 As a result, operators are likely to disconnect, ignore, or simply choose not to install the detection system. If detectors are ignored or not maintained, they cannot practically serve their purpose, whether to prevent, warn, or treat. The problem is compounded when considering the installation of detectors for each of a large number of potential biothreat agents. Meinhardt (2005) published a table of 28 selected agents in 8 broad categories identified by multiple governmental, military, and medical sources as possible biowarfare agents that might present a public health threat if dispersed by water. Assuming success in constructing a 100 percent sensitive and extremely specific detector for the eight broad agent categories (e.g., viral pathogen, marine biotoxin) and assuming each broad category has an equal probability of being employed in an attack, the probability of a true alarm is reduced by almost another order of magnitude. In other words, the additional analysis of multiple categories of agents requires an order-of-magnitude reduction in the false positive rate of a detector just to get back to the unsatisfactory baseline of a system for a generic intrusion detector. The fundamental problem relates to the rarity of an attack on any particular system. Detectors can be made with high sensitivity and specificity (low false positive and false negative rates), but when applied in situations where the event to be detected is uncommon, the predictive value of an alarm can be very small. Positive predictive value is defined as the number of true positives divided by the total number of positive results (including both true and false positives). This predictive measure is improved if the likelihood of an event is higher. A false positive alarm every few years might conceivably be acceptable to some communities that consider themselves high-risk targets, assuming there is an agreed-upon response plan in place for a positive signal. An acceptable community response plan, which would include a protocol for confirmatory testing and public notification, requires joint 1 The calculations were conducted as follows: 10,000 water systems * 20 detectors/system * 6 measurements/detector/hour * 8760 hours/year = 10,512,000,000 measurements/year across all 10,000 systems. Given the assumptions in this scenario of a false positive rate of one in 10 million measurements and an attack rate of one per 10,000 drinking water systems, there will be approximately 1,000 false positives and only one is a true positive (one attack) per year.

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Improving the Nation’s Water Security: Opportunities for Research agreement between utility, health department, first responders, and politicians. Rigorous industry-wide employee training would be required to ensure timely response after a positive alarm. These challenges have practical implications for the EPA’s research program. Contaminant monitoring systems aim to detect a low-probability, high-consequence event. Therefore, suitable instruments need to be highly sensitive and specific for the agents they are intended to detect and ideally should be very low maintenance. Improved event detection architecture could possibly reduce the number of false positives. In this approach, a water system would install an array of sensors linked in a way that only triggers an alarm when a statistically significant number of sensors detect abnormal levels. This should reduce or eliminate the false positives caused by independent sensor malfunctions, but it would also increase the false negative rate (i.e., decrease specificity) and the cost of the detection system. The cost of purchasing and maintaining such detection instruments over a period of years needs to be considered in evaluating the likelihood of implementation. These sizeable technology requirements suggest that contaminant detection devices with a reasonable likelihood of widespread implementation and successful operation (even in a detect to treat capacity) remain a challenging long-term research goal. Research suggestions related to contaminant detection systems are discussed further in Chapter 6. Challenges for Disease Surveillance Systems Disease surveillance systems have been proposed as another method to detect a drinking water contamination event (Berger et al., 2006; Buehler et al., 2003; CDC, 2003a; 2006). The detection of a water-related event using a human-disease-based surveillance system with an appropriate epidemiologic follow-up investigation is insensitive to any but the largest outbreak events and would occur too late to prevent illness. However, disease surveillance systems could be used to mitigate further exposure and implement treatment or prophylaxis (detect to treat), especially if linked to contaminant monitoring systems. The problems associated with in situ detection systems, discussed in the previous section, apply with even more force to disease surveillance systems designed to detect specific syndromes related to bioterror agents, because disease surveillance systems have only modest sensitivities and specificities. The body’s immune system reacts generically to many in-

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Improving the Nation’s Water Security: Opportunities for Research fections in their initial stages to produce the ubiquitous “flu-like symptoms” seen in so many different diseases at first presentation. The implementation of enhanced disease surveillance systems is costly and has inherent false positive and negative rates. For example, not every case of waterborne disease will eventually be diagnosed as such. Therefore it has been argued (Stoto et al., 2004) that the benefits of such enhanced systems may not outweigh the costs in the general case. Public health researchers have argued that “it is challenging to develop sensible response protocols for syndromic surveillance systems because the likelihood of false alarms is so high, and because information is currently not specific enough to enable more timely outbreak detection or disease control activities” (Berger et al., 2006). Furthermore, implementation of a disease surveillance system for homeland security concerns alone would be difficult to maintain based on the overall likelihood of an event and the large number of utilities at risk. Rapid Evolution of Scientific Information Relevant to Water Security Since September 11, 2001, the federal government has substantially increased funding directed toward homeland security-related research, including research on biothreat agents (Altman et al., 2005). Although much of the research pertinent to water security is still in progress, the amount of scientific information has increased substantially, and this surge of information is expected to continue in the years ahead. Thus, current researchers and research managers will be hard pressed to stay abreast of the advances in technology and new information regarding specific agents, especially considering the additional security concerns that keep much of the new information out of the scientific literature. The volume of scientific information from a wide variety of fields that bear on the subject of water security (e.g., engineering, molecular biology, environmental science, social science) is also large and difficult to integrate. The subject matter is more than multidisciplinary but interdisciplinary. Researchers from disparate disciplines cannot simply work separately on the same problems but need to cross disciplines and consider problems in unaccustomed ways. Water security researchers also need to use information from fields far from their disciplinary home territories. The value of interdisciplinary approaches to complex scientific and technical problems is now well recognized, although educational and institutional structures have been slow to adapt. Not only do technical

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Improving the Nation’s Water Security: Opportunities for Research details and knowledge vary among disciplines, but attitudes, approaches, and language vary as well, sometimes leading to unrecognized difficulties in communication (Keller, 2002). These interdisciplinary challenges are complicated further with the addition of the social sciences. The problem of terrorism involves social science questions in a fundamental way (e.g., How will people respond in a time of crisis? How can water security risks be effectively communicated to the public?), and the social sciences cannot and should not be neglected even in setting what appears to be a purely technical research agenda (see Chapter 6). CHALLENGES FOR RESEARCH MANAGEMENT The EPA faces multiple research management challenges in its water security program. These challenges include the difficulties of interdisciplinary and interagency coordination, assuring stable leadership, balancing short-term and long-term research initiatives, allowing information sharing in the context of national security, balancing the needs of multiple constituencies, and building sufficient staff expertise. Interdisciplinary and Interagency Coordination Managing an interdisciplinary research program requires integrating a variety of disciplines that normally have not worked together and meeting the needs of each. The challenge is compounded for the EPA’s National Homeland Security Research Center (NHSRC) by the need to coordinate with different offices and divisions within EPA, numerous trade associations, and other federal and state agencies that may have overlapping and sometimes ambiguous jurisdictions. The challenge is well illustrated by the recent confusion as to which federal cabinet department would be the lead agency in the event of a pandemic from avian influenza. Both the Department of Homeland Security (DHS) and the Department of Health and Human Services claimed lead status, each citing the same National Response Plan and associated presidential directives as justification (Nesmith and McKenna, 2005). External mandates from presidential directives or requests from the DHS are unpredictable management constraints, independent of a planned research agenda, but cannot be ignored. Sometimes such mandates are sufficiently vague as to allow flexibility, but vague mandates

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Improving the Nation’s Water Security: Opportunities for Research can also cause confusion as agency managers may interpret them differently. Stable Leadership Frequent shifts in management personnel have become commonplace in federal service and represent a particular challenge to managing a long-term research agenda. Shifting demands and resources also put pressure on the desirable goal of continuity in management and personnel. Two possible consequences are a constantly shifting set of new goals and objectives or the ossification of an original and possibly out-of-date set of goals and objectives. Moreover, flexibility and adaptation require some kind of institutional memory and perspective, which is particularly difficult in the face of continual changes in management. This issue was raised in the National Research Council’s review of the EPA Action Plan (NRC, 2004), and so far, the changes that have occurred in the EPA’s water security research management have maintained good institutional continuity. Nevertheless, these management issues should be recognized as they will likely continue to raise serious challenges for implementing a long-term research agenda. Pressure for Rapid Results versus Long-Term Strategies Research agendas have inherent time scales, which can be roughly categorized as short-term (less than two years), medium-term (two to five years) and long-term (longer than five years). The EPA’s initial efforts in water security research and technical support appropriately emphasized the most urgent questions that could be addressed within a three- to four-year time frame, but now the agency is looking toward building a balance of short-term and longer-term research. As events evolve, there are pressures to turn research management attention from one area to another. Management pressures are often focused on the most immediate, urgent, and shortest-term questions. Sometimes those pressures are appropriate, but often they are the product of the moment. If efforts are expended continually in responding to immediate concerns, resources are reduced for the more sustained efforts that a mid- to long-term research agenda requires. Some of the continuing pressure toward short-term research comes from the interaction of newly developed information and external mandates. The result of such

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Improving the Nation’s Water Security: Opportunities for Research pressures can be a constantly shifting focus of attention, with a concomitant underresourcing of the mid- and longer-term efforts. Although understandable, the continual shifting focus presents a genuine management dilemma—a challenge that requires stable management if it is to be met. Information Sharing in the Context of National Security Balancing information security concerns versus operational need-to-know and the benefits of scientific and technical information sharing is among the most significant challenges in water security research management, especially as response time will be critical in minimizing consequences. Open exchange of information is preferred, where feasible, because it allows the most efficient progress to be made in solving difficult problems. The more people working on a complicated problem, the more likely that an innovative solution will be found. Yet, there is a widespread concern that some kinds of information cannot be shared, even with end users, because the information has the potential to be used in a way that might be harmful. The EPA faces risks in providing water security information and risks in withholding it, and there is no easy solution to a problem that involves risks on both sides. As an example, if research were to find an unforeseen but easy way to contaminate a system, this information might change how utilities protect themselves and improve their ability to recognize that an attack has taken place. At the same time, this information can be used for malicious purposes. As a result, there is a delicate balance between alerting a significant number of water operators of a danger, while minimizing the potential for suggesting a route of attack to a malefactor. Current approaches for distributing water security research information in a more secure manner to a limited number of people are described in Box 2-1. Multiple Constituencies The EPA has to be responsive to at least four separate constituencies with different needs and concerns: (1) DHS and cognate agencies with responsibility for national security; (2) the water industry; (3) state and local agencies involved with preparedness, emergency response, and environmental regulation; and (4) the public. Concerns about information

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Improving the Nation’s Water Security: Opportunities for Research BOX 2-1 Mechanisms for Disseminating Homeland Security Information The Water Information Sharing and Analysis Center (WaterISAC) was established as an outcome of Presidential Decision Directive 63 (see Box 1-1), calling for the establishment of ISACs for the sharing of security and sector-sensitive information within the private sector and with the federal government. The WaterISAC is a subscription-based service open to all drinking water and wastewater utilities within the United States, regardless of the size of the population served or the ownership. State administrators as well as certain EPA personnel also have access. The WaterISAC currently reaches 1,020 individuals at 512 water utilities that provide water services to 65 percent of the American population (D. VanDe Hei, WaterISAC, personal communication, 2006). The Water Security Channel (WaterSC) is managed by the WaterISAC and is designed to reach the drinking water and wastewater utilities that have not subscribed to the more comprehensive services of the WaterISAC. The WaterSC reaches 9,558 individuals at 8,447 organizations (D. VanDe Hei, WaterISAC, personal communication, 2006). WaterSC affiliates include utilities as well as state primacy organizations, government organizations, engineering firms, and researchers. The services of the WaterSC are free and available to all utilities and organizations concerned with water security. Both the WaterISAC and the WaterSC are partially funded through an EPA grant. WaterISAC and WaterSC security protocols require users to be authenticated before accepting and authorizing access to information. Because the WaterISAC handles highly sensitive information, its vetting sharing exemplify the challenge of multiple constituencies that the EPA faces in its water security research program. Federal agencies responsible for homeland security favor restrictions on information sharing to minimize potential risks. The water industry and state and local agencies need readily available information and tools that can be implemented practically and routinely, although the particulars can vary widely among utilities. The public needs enough information to have confidence in the safety of the water supply, the means to protect themselves in the event of an attack, and the ability to determine and understand when the supply is safe again. Adding to the complexity of these multiple constituencies, the water and wastewater industry is not only heterogeneous in size but also in ownership and management, with a mixture of public, private, and public-private models. The EPA, therefore, works with a variety of trade

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Improving the Nation’s Water Security: Opportunities for Research process is more rigorous. The WaterISAC also has a double authentication protocol in place to ensure that only authorized individuals access a designated document. When new and urgent information becomes available, WaterISAC and WaterSC participants are informed via e-mail and online notification databases. Participants can also be notified by text messages directly to their cell phones. The water-sector individual is informed of the location of the information including a link to its contents and a brief overview so that the individual can determine if the document would be of use in the particular circumstance. Additionally, WaterISAC and WaterSC Web sites host newly released information in file format. The Water Sector Coordinating Council (WSCC), a group representing the water sector that was organized to give advice to DHS, has recognized the WaterISAC, including its supplementary WaterSC, as the primary communication tool within the water sector (L. Stovall, Chair, WSCC, personal communication, 2006). An additional communication software platform exists in the Homeland Security Information Network (HSIN), which was launched by the DHS as a communications tool to make federal information available to a broad range of U.S. businesses and individuals. The HSIN is being offered to all critical infrastructure sectors, including the water sector. Because of the vast audience, sensitive data cannot be made available on the HSIN, as it can be on the WaterISAC. After an evaluation of the HSIN’s capabilities, a recommendation to integrate the HSIN into the suite of communication tools used by the WaterISAC was made and approved by both the WaterISAC Board and the WSCC. The HSIN, as well as the WaterSC, will be available at no cost to all utilities, state primacy organizations, government organizations, engineering firms, researchers, and other interested parties. associations and other interest groups (e.g., those representing rural water systems, municipal systems, investor-owned systems), each of which has its own set of incentives, disincentives, constraints, and relative financial sensitivities for various kinds of security investments and objectives. Research on protective methods might be directed differently if it were aimed at optimizing personnel costs, capital costs, maintenance costs, water rates, or some particular mixture of these. Thus, research products are of differential use to small or large systems, to urban or rural, or to those in certain competitive or public-sector financing environments. Decisions about a research agenda often do not explicitly acknowledge these differences, which are only recognized later if a significant sector of the industry has not been taken into account. Negotiating a research agenda through contradictory needs and constraints presented by such a heterogeneous industry and these multiple constituencies is a significant challenge. Research priorities may be

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Improving the Nation’s Water Security: Opportunities for Research more or less tailored to any or all of these constituencies, although institutional pressures may favor the needs of cognate agencies within the federal government. The usefulness of the EPA’s research agenda, however, will depend upon meeting the needs of the industry, and its ultimate success rests upon meeting the needs of the public. EPA’s Roles and Capabilities If the EPA’s water security research tasks combined with the above management issues were to be considered de novo, it would be an enormous challenge, but the tasks have been imposed on existing agency structure and expertise. The EPA cannot start afresh and is expected to use existing strengths and address gaps in a variety of ways. Today, the EPA is primarily a regulatory agency, not a research agency. Its strengths have traditionally related to understanding and controlling environmental and public health risks, including contamination, operational details of regulations, and cost-benefit assessments of proposed requirements. The Office of Research and Development (ORD) research facility in Cincinnati, where the NHSRC is housed, is an exception. The skills of the ORD and specifically the NHSRC have evolved to complement the regulatory portfolio of the agency as a whole, although many of these skills remain useful for large portions of the water security research portfolio. The agency’s regulatory emphasis, however, has shaped the current staff expertise, and several conspicuous gaps now exist within the NHSRC’s water security program. For example, the EPA lacks subject matter experts in issues such as cyber security and explosive attacks. Additionally, the EPA is only now beginning to acquire expertise in the social sciences needed for understanding public reaction to water security incidents, how information and misinformation spreads, and how to communicate effectively with the public and public officials. The EPA has recognized many of these weaknesses and has entered into research partnerships with the U.S. Army Corps of Engineers and other relevant agencies to obtain complementary expertise. Outside contracting, however, requires significant agency oversight to ensure the projects are planned and carried out in a way that best supports the needs of key stakeholders, including the water and wastewater industry. The EPA has been handed a task that is new to its historic mission, expertise, and mindset. Not unexpectedly in these fiscally austere times, it has also been asked to accomplish the task with relatively modest re-

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Improving the Nation’s Water Security: Opportunities for Research sources. A long-term water security research agenda could easily be envisioned that would require several times the budget of the EPA’s current program. Because such funding is not likely or reasonable considering the agency’s other obligations, a framework for evaluating and prioritizing the water security research enterprise is necessary for making the inevitable choices. The committee’s approach and general prioritizing criteria that shape its recommendations are presented in Chapter 3. SUMMARY The many challenges faced by the EPA’s water security program as it moves beyond the targeted short-term research and technical support objectives of the Action Plan are outlined in this chapter. These challenges range from the inherently technical to the managerial. The number and diversity of water and wastewater systems, for example, creates challenges for crafting a research agenda that is responsive to the needs of end users and also creates specific challenges for the development of water security technologies. Challenges for research management include the problems of multiple constituencies and disparate outside forces that constrain and sometimes redirect efforts. The EPA also faces challenges with information sharing and building a research program considering existing programmatic strengths and weaknesses. These challenges provide an important context for the findings and recommendations that follow.