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4 Building Science for Environmental Protection in the 21st Century Since its formation in 1970, the US Environmental Protection Agency (EPA) has had a leadership role in developing the many fields of environmental science and engineering. From ecology to health sciences, environmental engi- neering to analytic chemistry, EPA has stimulated and supported academic re- search, developed environmental education programs, supported regional sci- ence initiatives, supported and promoted the development of safer and more cost-effective technologies, and provided a firm scientific basis of regulatory decisions and prepared the agency to address emerging environmental problems. The broad reach of EPA science has also influenced international policies and guided state and local actions. The nation has made great progress in addressing environmental challenges and improving environmental quality in the 40 years since the first Earth Day. As a regulatory agency, EPA applies many of its resources to implement- ing complex regulatory statutes, including substantial commitments of scientific and technical resources to environmental monitoring, applied health and envi- ronmental science and engineering, risk assessment, benefitcost analysis, and other activities that form the foundation of regulatory actions. The primary focus on its regulatory mission can engender controversy and place strains on the con- duct of EPA's scientific work in ways that do not affect most other government science agencies (such as the National Institute of Environmental Health Sci- ences and the National Science Foundation). Amid this inherent tension, re- search in EPA generally, and in the Office of Research and Development (ORD) in particular, strives to meet the following objectives: Support the needs of the agency's present regulatory mandates and timetables. Identify and lay the intellectual foundations that will allow the agency to meet environmental challenges that it faces and will face over the course of the next several decades. 107
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108 Science For Environmental Protection: The Road Ahead Determine the main environmental research problems on the US envi- ronmental-research landscape. Sustain and continually rejuvenate a diverse inhouse scientific research staff--with the necessary laboratories and field capabilities--that can support the agency in its present and future missions and in its active collaboration with other agencies. Strike a balance between inhouse and extramural research investment. The latter can often bring new ideas and methods to the agency, stimulate a flow of new people into it, and support the continued health of environmental re- search in the nation. Those multiple objectives can lead to conflict. For example, ORD re- sources that are applied to expanding staff and expediting science reviews and risk assessment in the National Center for Environmental Assessment may di- vert resources from longer-term program development and research. However, the agency has shown itself capable of maintaining a longer-term perspective in several instances, such as the establishment and maintenance of the Science to Achieve Results (STAR) grant program for extramural research, anticipatory moves to develop capability in computational toxicology, and the development and sustained implementation of multiyear research plans, for example, for re- search on airborne particulate matter (now the Air Quality, Climate, and Energy multiyear plan). In each of those cases, EPA identified ways both to give longer- term goals higher priority and to identify and commit resources to them. How- ever, the tension between the near-term and longer-term science goals for the agency is likely to increase as more and more contentious rules are brought for- ward and as continuing budget pressures constrain and reduce science resources overall. In light of the inherent tension, the emerging environmental issues and challenges identified in Chapter 2, and the emerging science and technologies described in Chapter 3, this chapter attempts to identify key strategies for build- ing science for environmental protection in the 21st century in EPA and beyond. Specifically, the chapter lays out a path for EPA to retain and expand its leader- ship in science and engineering by establishing a 21st century framework that embraces systems thinking to produce science to inform decisions. That path includes staying at the leading edge by engaging in science that anticipates, in- novates, is long term, and is collaborative; using enhanced systems-analysis tools and expertise; and using synthesis research to support decisions. In sup- porting environmental science and engineering for the 21st century, EPA will need to continue to evolve from an agency that focuses on using science to char- acterize risks so that it can respond to problems to an agency that applies science to anticipate and characterize both problems and solutions at the earliest point possible. Anticipating and characterizing problems and solutions should opti- mize social, economic, and environmental factors.
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Building Science for Environmental Protection in the 21st Century 109 EMBRACING SYSTEMS THINKING FOR PRODUCING AND APPLYING SCIENCE FOR DECISIONS: A 21ST CENTURY FRAMEWORK FOR SCIENCE TO INFORM DECISIONS The continued emergence of major new and complex challenges described in Chapter 2--and the need to deal with the inevitable uncertainty that accom- panies major environmental, technologic, and health issues--will necessitate a new way to make decisions. As described in Chapter 3, systems thinking has begun to take root in biology and other fields as a means of considering the whole rather than the sum of its parts; this will be essential as increasingly com- plex problems and the challenges described in Chapter 2 present themselves. The emergence of "wicked problems", the increasing need to address exposures of humans and the ecosystem to multiple pollutants through multiple pathways (some of which are global), and the continuing challenges for the analysis and characterization of uncertainty throughout science and decision-making combine to make the adoption of systems thinking critical. The systems-thinking perspective is useful not only for characterizing complex effects but for designing sustainable solutions, whether they are inno- vative technologies or behavioral changes. Understanding systems is also impor- tant for determining where leverage points exist for the prevention of health and environmental effects (Meadows 1999). To successfully inform future environ- mental protection decisions in an increasingly complex world, systems thinking must, at a minimum, include consideration of cumulative effects of multiple stressors, evaluation of a wide range of alternatives to the activity of concern, analysis of the upstream and downstream life-cycle implications of current and alternative activities, involvement of a broad range of stakeholders in decisions (particularly where uncertainty is significant), and use of interdisciplinary scien- tific approaches that characterize and communicate uncertainties as clearly as possible. As part of a systems perspective, it will be important for the agency to engage in "systems mapping" to comprehensively understand the way in which interacting stressors (such as environmental, human, technologic, socioeco- nomic, and political stressors) map to health and environmental impacts and to identify where intervention points can result in primary prevention solutions. Although EPA has made efforts over the years to attempt to bring systems concepts into its work, most recently in its efforts to reorganize its activities under a sustainability framework (Anastas 2012), these efforts have rarely been integrated throughout the agency, nor sustained from one set of leaders to an- other. To begin to address the lack of a sustained systems perspective, the com- mittee has developed a 21st century framework for decisions (Figure 4-1) and recommends a set of organizational changes to implement that framework (see Chapter 5). The framework features four elements that will be critical for in- forming the complex decisions that EPA faces: To stay at the leading edge, EPA science will need to o Anticipate.
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110 Science For Environmental Protection: The Road Ahead o Innovate. o Take the long view. o Be collaborative. EPA will need to continue to evaluate and apply the new tools for data acquisition, modeling, and knowledge development described in Chapter 3. EPA will need to continue to develop and apply new systems-level tools and expertise for systematic analysis of the health, environmental, social, and economic implications of individual decisions. EPA will need to continue to develop tools and methods for synthesiz- ing science and characterizing uncertainties, and will need to integrate methods for tracking and assessing the outcomes of actions (that is, for being account- able) into its decision process from the outset. STAYING AT THE LEADING EDGE OF SCIENCE EPA can maintain its global position in environmental protection by staying at the leading edge of science and engineering research. Staying at the edge of science knowledge requires staying at the edge of science practice. In addition to understanding the latest advances in the science and practice of environmental protection, EPA will need to continue to engage actively in the identification of emerging scientific and technologic developments, respond to advances in science and technology, and use its knowledge, capacity, and experience to direct those advances. That is consistent with the two principal goals for science in the agency: to safeguard human health and the environment and to foster the development and use of innovative technologies (EPA 2012). For EPA to stay at the leading edge, the committee presents a set of over- arching principles for research and policy that begins to address the challenges of wicked problems. To be able to predict and adequately address existing chal- lenges and prevent on-the-horizon challenges, EPA's science will need to Anticipate. Be deliberate and systematic in anticipating scientific, technology, and regulatory challenges. Innovate. Support innovation in scientific approaches to characterize and prevent problems and to support solutions through more sustainable tech- nologies and practices. Take the long view. Track progress in ecosystem quality and human health over the medium term and the long term and identify needs for midcourse corrections. Be collaborative. Support interdisciplinary collaboration in and outside the agency, across the United States, and globally. Those four principles support the flow of science information (from data to knowledge) in EPA to inform environmental decision-making and strategies for inducing desirable environmental behaviors.
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Complex Challenges for the Future Problem Formulation Hypothesis Generation Needs Assessment Technical Approaches Analysis of Key Measures to Advance Knowledge Knowledge Data Acquisition Environmental Fate Impacts Ecologic Population Health Biologic Data Modeling, Exposure and Dose Physical Analysis, and Mechanism and Mode of Action Chemical Synthesis Implications Epidemiologic Costs Socioeconomic Feedback Outcomes Behavioral Behaviors Balanced Informed Decisions Informatics Decision Options Improved Health Cleaner Environment Lower Costs Systems Thinking to Assess Implications of Decisions Translation and Applying Science that Anticipates, Innovates, Takes the Long View, Is Collaborative Communication Applications, Decisions, Synthesis and Evaluation Systems Tools and Skills and Actions Sustainability Analysis Life-Cycle Assessment Policy Solution-Oriented Approaches Cumulative Risk Assessment Regulation Multiple-Criteria and Social, Economic, Behavioral, Social Change Multidimensional Tools and Decision Sciences Uncertainty Synthesis Research FIGURE 4-1 The iterative process of science-informed environmental decision-making and policy. Leading-edge science will produce large amounts of new information about the state of human health and ecologic systems and the likely effects of introducing a variety of pollutants or other perturbations into the systems. In particular, many multifactorial problems require systems thinking that can be readily integrated into other analytic approaches. This framework relies on science that anticipates, innovates, takes the long view, and is collaborative to solve envi- ronmental and human health problems. It also supports decision-making and ensures that leading-edge science is developed and applied to in- form assessments of the system-wide implications of alternatives for key policy decisions. 111
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112 Science For Environmental Protection: The Road Ahead Science That Anticipates Continually striving to more effectively anticipate challenges and emerg- ing environmental issues will help EPA to stay at the leading edge of science. That involves two main sets of activities: anticipating concerns and developing guidance to avoid problems with new or emerging technologies, and establish- ing key indicators and tracking trends in human health and ecosystem quality to identify and dedicate resources to emerging environmental problems. Further- more, continuing to anticipate (and direct resources to) targeted science and technology developments will allow EPA to enhance its ability to identify early warnings and prevent effects before they occur. Fulfilling the anticipatory func- tion can be difficult when the day-to-day pressures to respond to regulatory deadlines can take most of, if not all, an EPA leader's time and attention. Hence, anticipatory activities will need to be pursued in collaboration with other gov- ernment agencies, the private sector, and academic engineers and scientists. Anticipating Environmental and Health Effects of New Technologies One example of EPA's efforts to identify emerging challenges has been the engagement of its National Advisory Council for Environmental Policy and Technology (NACEPT). NACEPT is an external advisory board established in 1988 to provide independent advice to the agency on a variety of policy, tech- nology, and management issues. The advisory council recently identified several challenges that EPA will need to focus on in the future (EPA NACEPT 2009). The most important challenges identified included climate change, biodiversity losses, and the quality and quantity of water resources. NACEPT also identified corresponding organizational needs for EPA to meet existing and emerging en- vironmental challenges, including improving its ability to use technology more effectively, to transfer technology for commercial uses, and to enhance commu- nication in and outside the agency. The committee concurs with the advisory council's observations that although EPA has demonstrated the ability to create and implement solutions to new challenges in some cases, emerging challenges need to be approached in a more integrated and multidisciplinary way. The committee also concurs with NACEPT's recommendation that EPA include "environmental foresight" or "futures analysis" activities as a regular component of its operations. Some of EPA programs, including its New Chemicals program and De- sign for the Environment program (see Chapter 3), already demonstrate strate- gies for anticipating and mitigating future problems (Tickner et al. 2005). In those programs, EPA has used information on what is known about chemical hazards to develop a series of models so that chemical manufacturers and formu- lators can predict potential hazards and exposures in the design phase of chemi- cals. The models are updated as new knowledge emerges. The Design for the Environment example demonstrates that EPA will be best able to address
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Building Science for Environmental Protection in the 21st Century 113 emerging issues through enhanced interdisciplinary collaboration and by using systems thinking and enhanced analysis tools to understand the human health and ecologic implications of important trends. Addressing emerging issues should include consideration of the full life cycle of products, establishment of large-scale surveillance systems to address relevant technologies and indicators, and the analytic ability to detect historical trends rapidly. Although EPA has engaged NACEPT and its Science Advisory Board (SAB) to help in anticipating trends and has individual programs designed to address concerns about existing and emerging technologies and identify promis- ing new technologies (see, for example, EPA 2011a), the agency does not ap- pear to have a systematic and integrated process for anticipating emerging is- sues. The example of engineered nanomaterials (discussed below and described in Chapter 3) illustrates some of the problems and pitfalls of current approaches to emerging technologies. A better understanding of such technologies can help to identify and avert ecosystem and health effects and in some cases to avoid unwarranted concern about new technologies that pose little risk. In principle, early consideration of environmental effects in the design of emerging chemicals, materials, and products offers advantages to businesses, regulatory agencies, and the public, including lower development and compli- ance costs, opportunities for innovations, and greater protection of public health and the environment. Yet, despite nearly 15 years of investment in engineered nanotechnology and the use of nanomaterials in thousands of products, recogni- tion of potential health and ecosystem effects and design changes that might mitigate the effects have been slow to arrive. Indeed, a December 2011 report by the EPA Office of Inspector General (EPA 2011b) found several limitations in EPA's evaluation and management of engineered nanomaterials and stated the following: "Program offices do not have a formal process to coordinate the dis- semination and utilization of the potentially mandated information. "EPA is not communicating an overall message to external stake- holders regarding policy changes and the risks of nanomaterials. "EPA proposes to regulate nanomaterials as chemicals and its success in managing nanomaterials will be linked to the existing limitations of those applicable statutes. "EPA's management of nanomaterials is limited by lack of risk infor- mation and reliance on industry-submitted data." The Office of Inspector General concluded that "these issues present significant barriers to effective nanomaterial management when combined with existing resource challenges. If EPA does not improve its internal processes and develop a clear and consistent stakeholder communication process, the Agency will not be able to assure that it is effectively managing nanomaterial risks."
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114 Science For Environmental Protection: The Road Ahead How EPA arrived at that situation provides important information for the design and evaluation of new and emerging technologies. EPA was actively working with other agencies to make large investments in nanotechnology dur- ing implementation of the 21st Century Nanotechnology Research and Devel- opment Act. In particular, the agency saw the opportunity to use nanotechnology in remediation and funded this type of research. However, it missed the oppor- tunity to support research that addressed proactively the environmental health and safety of nanomaterials, pollution prevention in the production of nanomate- rials, and the use of nanotechnology to prevent pollution. In early years, the agency focused primarily on the applications of nanomaterials and not on the environmental and health implications. When it did begin to address implica- tions, the agency focused its attention on defining nanomaterials and whether they are subject to new policy structures because of size-specific hazards (an issue that is still discussed) and on cataloging and redirecting existing research and resources toward assessing exposure, hazard, and risk. The private sector has been left looking for signals from the agency about how it should develop and commercialize nanoscale products. There were several reasons for the delay in early intervention in the case of nanotechnology. One reason was that materials innovators were focused on discovering new materials and promoting applications of them. Another reason is that materials innovators often have little expertise or formal training in envi- ronmental, health, and safety issues. Some of these innovators assumed that nothing about nanomaterials presented new challenges for environmental health and safety and that these were secondary matters to be considered only after commercial products are developed. A third reason was that there was insuffi- cient federal agency leadership, emphasis, and policy regarding proactive rather than reactive approaches to safer design. Even with increasing knowledge about the design of environmentally benign engineered nanomaterials, progress toward incorporating greater consideration of health and safety in nanomaterial design has been limited for a variety of reasons, including the lack of design rules or other guidance for designers in developing safer technologies, the lack of exper- tise in solutions-oriented research in EPA, and the lack of collaboration between material innovators and toxicologists and environmental scientists. The case of engineered nanomaterials indicates the need for EPA to estab- lish more coherent technology-assessment structures to identify early warnings of potential problems associated with a wide range of emerging technologies. If EPA is going to play a major role in promoting and guiding early intervention in the design and production of emerging chemicals (through green chemistry), materials, and products, it will need to commit to this effort beyond its regula- tory role. Many new chemicals and technologies hold considerable potential to im- prove environmental quality, and it may prove useful for EPA to take some spe- cific steps to anticipate and manage new technologies that emerge from the pri- vate sector. Some of these specific steps can be done in collaboration with other agencies, industries, and research organizations when possible. They include:
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Building Science for Environmental Protection in the 21st Century 115 Develop baseline design guidelines for new chemicals and technolo- gies and fund research that can anticipate potential effects as part of technology development. Balance near-term research that is focused on understanding the poten- tial risks posed by chemicals and technologies that are closer to commercializa- tion with substantial development of longer-term predictive, anticipatory ap- proaches for understanding the potential effects of the technologies. Establish processes to collaborate with external partners in academe and industry to attain needed expertise in the development of common metrics for evaluation of emerging technologies. Establish opportunities that educate and bring together chemical and materials innovators and environmental health and safety experts (and other stakeholders) to collaborate in understanding and intervening in chemical and materials design. Support efforts to amass and disseminate data, models, and design guidelines for safer design to guide emerging technologies. Embrace imperfect or incomplete information to guide actions. Uncer- tainty will always exist in the case of emerging technologies, and identifying alternative paths for action would allow EPA to act or provide guidance for de- velopment and commercialization in the face of incomplete data. Anticipating Emerging Challenges, Scientific Tools, and Scientific Approaches In recent years, EPA has had to make decisions on several headline- grabbing environmental issues with underdeveloped scientific and technical information or short timelines to gather critical new information, for example, during natural disasters. EPA will always need the capacity to respond quickly to surprises, in part by maintaining a strong cadre of technical staff who are firmly grounded in the fundamentals of their disciplines and able to adapt and respond as new situations arise. But the agency also needs to scan the horizon actively and systematically to enhance its preparedness and to avoid being caught by surprise. Anticipating new scientific tools and approaches will allow EPA to fulfill its mission more effectively. Collaboration is critical for identifying and addressing many of the topics discussed in Chapter 2, such as trends in energy and climate change and "emerg- ing" environmental concerns that are not new but are the result of improvements in detection capabilities. For example, critics have suggested that the agency's slow response to growing scientific concern about effects of pharmaceutical and personal-care products in surface waters was due in part to its lack of infrastruc- ture or collaboration to address problems that span media and jurisdictions (Daughton 2001). EPA's efforts to anticipate science needs and emerging tools to meet these needs cannot succeed in a vacuum. As it focuses on organizing and catalyzing its internal efforts better, it will need to continue to look outside
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116 Science For Environmental Protection: The Road Ahead itself--to other agencies, states, other countries, academe, and the private sec- tor--to identify relevant scientific advances and opportunities where collabora- tion that relies on others' efforts can be the best (sometimes the only) means of making progress in protecting health and the environment. Finding: Although EPA has periodically attempted to scan for and anticipate new scientific, technology, and policy developments, these efforts have not been systematic and sustained. The establishment of deliberate and systematic proc- esses for anticipating human health and ecosystem challenges and new scientific and technical opportunities would allow EPA to stay at the leading edge of emerging science. Recommendation: The committee recommends that EPA engage in a delib- erate and systematic "scanning" capability involving staff from ORD, other program offices, and the regions. Such a dedicated and sustained "futures network" (as EPA called groups with a similar function in the past), with time and modest resources, would be able to interact with other federal agencies, academe, and industry to identify emerging issues and bring the newest scientific approaches into EPA. Science That Innovates Given EPA's mission and stature as the leading government environ- mental science and engineering organization, it is imperative that it innovate and support innovation elsewhere in technologies, scientific methods, approaches, tools, and policy instruments. "Innovation" can be challenging to define for a regulatory agency, but one component involves advancing the ability of the agency to discover and characterize problems at a systems level and to provide decision-makers with solutions that are effective and that balance the multiple objectives relevant to the agency and society. Spinoffs from innovation within the agency and activities to promote innovation outside the agency can help en- vironmental authorities in states and other countries to solve their problems and can encourage the regulated community to discover less expensive, faster, and better ways to meet or exceed mandated compliance. Based on the above per- spective and using analogies to the typical business definition of innovation, the section below considers processes by which EPA can incorporate and promote innovation. Identifying Opportunities and Meeting Desired Customer Outcomes Innovations typically begin with two processes: the identification of op- portunity and the understanding of desired "customer" outcomes. An opportu- nity is simply a "gap" between the current state and a more desirable situation as envisioned by customers. The gaps can be technologic in nature (for example,
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Building Science for Environmental Protection in the 21st Century 117 the need for the design of a new sensor to measure something of interest) or re- lated to a process or business (for example, the need for an approach to obtain up-to-date information from stakeholders). Once an opportunity has been identi- fied and analyzed, an understanding of desired customer outcomes is needed to create innovative solutions. Understanding desired outcomes goes well beyond simply talking to cus- tomers; it includes putting oneself in the clients' shoes to separate what they say they want from what they want. A common mistake in trying to innovate is to substitute desired producer outcomes for desired customer outcomes. While EPA is in a different position from product manufacturers, only by understand- ing why customers are purchasing products can the agency help promote crea- tive solutions. One example is the development of alternative plasticizers for polyvinyl chloride plastics rather than alternative materials that do not require plasticizers. Another example is the creation of less toxic flame retardants rather than creation of an inherently flame-retardant fabric or even consideration of whether flame retardancy is needed for a particular part or product. Insightful, unbiased determination of desired customer outcomes is crucial for proper sup- port of innovation. An innovative means of defining desired customer outcomes is ethnogra- phy, hypothesis-free observation of customers in their "natural habitats". The technique, pioneered by such design firms as IDEO (Palo Alto, CA), has pro- duced a number of insights into consumer behavior that have been translated into successful products. For EPA, the analogue of ethnography is the willing- ness of staff to visit their "customers" (for example, industry, the general public, or even specific EPA regional offices or laboratories) to see technology or sci- ence needs, to see where current regulations or prescribed methods cause people to struggle to conform, or to see where regulations create perverse results. An example of the benefits of observing customer needs is the design of the copying machine. In the 1970s, Xerox used anthropology graduate student Lucy Such- man to observe how users interacted with their copying machines. Suchman created a video showing senior computer scientists at Xerox struggling to make double-sided copies with their own machines. Surprising ethnographic results like that have led to a host of innovative alterations in office equipment that ren- der the user experience much more productive (Suchman 1983). While direct observation of this sort may be unusual for a regulatory agency, similar observa- tional activities by EPA might lead to insights regarding how consumer products are actually used (informing exposure models) or whether responses to specific regulations have unintended consequences that could be readily addressed. In business, innovation is a catalyst for growth. Business innovation in- volves the development of ideas or inventions and their translation to the com- mercial sphere. Innovation results in rapid (favorable) change in market size, market share, sales, or profit through the introduction of new products, proc- esses, or services. Those are clear outcomes that are relatively easy to measure. In an agency like EPA, innovation plays a different role but one that is no less important for the success of the agency in achieving its mission, adapting to
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150 Science For Environmental Protection: The Road Ahead innovation, or change in ecology or human health. The preference index then leads to a partial ranking of the policy options under consideration and recom- mendation of an "optimal" set of choices or competitive choices (Brans and Vincke 1985). MCDM has been applied successfully in environmental decision- making (Moffett and Sarkar 2006; Hajkowicz and Collins 2007); however, crite- rion-specific constituents of the preference index for each policy option are af- fected by the quality of the science and evidence, scaling, and other factors that can limit validity (Hajkowicz and Collins 2007). An alternative to single-objective formulations is to provide decision- makers with the Pareto optimal set of nondominated candidate solutions. Essen- tially, the Pareto optimal set is constructed by identifying decisions that can im- prove one or more objectives without harming any other. Use of the Pareto op- timal set does not determine a single preferred approach but presents decision- makers with a smaller set of options from which to choose. The concept of Pareto optimal sets is not new, but the capacity to apply it in decision-making has been greatly expanded by recent methodologic advances in optimization techniques (most notably multiobjective evolutionary algorithms) and computa- tion of Pareto sets for large complex problems, and this has increased the scope of environmental and other applications (Coello et al. 2007; Nicklow et al. 2010). Rabotyagov et al. (2010) give an example of evolutionary computation for the analysis of tradeoffs between pollution-control costs and nutrient- pollution reductions. Optimal sets of air pollution control measures have been developed that consider aggregate health benefits and inequality in the distribu- tion of those benefits as separate dimensions (Levy et al. 2007). Kasprzyk et al. (2009) demonstrate how multiobjective methods can be used to inform policies for the management of urban water-supply risks that are caused by growing population demands and droughts. Multiobjective optimization in support of environmental-management decisions is especially compelling given the emerg- ing paradigm of managing for multiple ecosystem services and consideration of cumulative risks for human health. Tradeoffs and complementarities can exist between alternative services and between other relevant performance metrics (for example, public and private costs and distribution outcomes by location or income class). Applications of multiobjective optimization methods would pro- mote the explicit specification of preference indices relevant to environmental decision-making and science to quantify outcomes and evaluate tradeoffs; all this would serve to improve the transparency and scientific soundness of deci- sions. Addressing Uncertainty in Complex Systems With any of the solutions-oriented approaches delineated above, regard- less of which analytic tools or indicators are used by EPA to support decisions in the future, uncertainty will be an overriding concern. With increasingly complex multifactorial problems and a push for tools that are sufficiently timely and
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Building Science for Environmental Protection in the 21st Century 151 flexible to inform risk-management decisions (NRC 2009), the importance of uncertainty characterization and analysis will only increase. It should be noted that the increasing importance of uncertainty analysis does not necessarily imply increasing sophistication of computational methods or even increasing necessity of quantitative uncertainty analysis. As discussed in Science and Decisions: Ad- vancing Risk Assessment (NRC 2009), uncertainty analysis is a component to be planned for with the rest of an assessment, and a simple bounding analysis or qualitative elucidation of different types of uncertainties may be adequate if it shows that a given risk-management decision is robust compared with compet- ing options (NRC 2009). Consistent and holistic approaches are necessary for characterizing and recognizing uncertainty (in particular the various types of uncertainty, including unquantifiable systems-level uncertainties, indeterminacy, and ignorance). Such approaches would allow EPA to articulate the importance of uncertainty in light of pending decisions and not become paralyzed by the need for increasingly complex computational analysis. In addition, applying uncertainty analysis co- herently in all EPA's arenas would ensure that a policy or decision is both ten- able and robust (van der Sluijs et al. 2008) and would ensure that uncertainty analysis is a means to an end and is designed with the end use in mind. Simi- larly, uncertainty analyses that are billed as comprehensive but omit key sources of uncertainty have the potential to be misleading or to lead to inappropriate decisions about research priorities and interventions. Finally, EPA would benefit from communicating uncertainty more effectively. Uncertainty is often mistak- enly viewed as a negative form of knowledge, an indicator of poor-quality sci- ence (Funtowicz and Ravetz 1992). There is therefore a perception that ac- knowledging uncertainty can weaken agency authority by creating an image of the agency as unknowledgeable, by threatening the objectivity of "science- based" standards, and by making it more difficult to defend itself in the face of political and court challenges. However, reluctance to acknowledge uncertainty can lead EPA to rely on tools and methods that cannot provide timely answers, can push the agency to use point estimates to defend what are policy decisions (see Brickman et al. 1985), and runs counter to the value of uncertainty analysis in informing research and decision priorities. OVERARCHING RECOMMENDATION The committee has described the important emerging environmental issues and complex challenges in Chapter 2 and the many types of emerging scientific information, tools, techniques, and technologies in Chapter 3 and Appendixes C and D. It is clear that if EPA is to meet those challenges and to make the greatest possible use of the new scientific tools, its problems will need to be approached from a systems perspective. Although improved science is important for EPA's future, it is not sufficient for fully improving EPA's capabilities for dealing with health and environmental challenges. Better economic analysis, policy ap-
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152 Science For Environmental Protection: The Road Ahead proaches, stakeholder involvement, communication, policy, and integration for systems thinking are also vital. In the present chapter, the committee has recommended ways in which the agency can integrate systems thinking techniques into a 21st century framework for science to inform decisions. For EPA to stay at the leading edge, it will need to produce science that is anticipatory, innovative, long-term, and collaborative; to evaluate and apply new tools for data acquisition, modeling, and knowledge development; to continue to develop and apply new systems-level tools and ex- pertise; and to develop tools and methods to synthesize science, characterize uncertainties, and integrate, track, and assess the outcomes of actions. If effec- tively implemented, such a framework would help to break the silos of the agency and promote collaboration among research related to different media, time scales, and disciplines. In supporting environmental science and engineer- ing for the 21st century, EPA will need to continue to evolve from an agency that focuses on using science to characterize risks so that it can respond to prob- lems to an agency that applies science holistically to characterize both problems and solutions at the earliest point possible. Finding: Environmental problems are increasingly interconnected. EPA can no longer address just one environmental hazard at a time without considering how that problem interacts with, is influenced by, and influences other aspects of the environment. Recommendation: The committee recommends that EPA substantially en- hance the integration of systems thinking into its work and enhance its ca- pacity to apply systems thinking to all aspects of how it approaches complex decisions. The following paragraphs provide examples of some of strategies that EPA could use to help it set its own priorities and to enhance its use of systems thinking. Even if formal quantitative LCA is not feasible, increased use of a life- cycle perspective would help EPA to assess activities, regulatory strategies, and associated environmental consequences. Placing more of a focus on life-cycle thinking would likely include increasing EPA's investment in the development of LCA tools that reflect the most recent knowledge in LCA and risk assessment (both human health and ecologic). In addition, it may be more cost effective for EPA to provide incentives and resources to increase collaborations between LCA practitioners in the agency and those working on related analytic tools (such as risk assessment, exposure modeling, alternatives assessment, and green chemistry). EPA has some internal capacity for LCA, but could benefit from a more systematic use of such an assessment across the agency's mission. Continuing to invest intramural and extramural resources in cumulative risk assessment and the underlying multistressor data, including coordinated bench science and community-based components, would give EPA a broader
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Building Science for Environmental Protection in the 21st Century 153 and more comprehensive understanding of the complex interactions between chemicals, humans, and the environment. A challenge before the agency is the characterization of cumulative effects using complex, incomplete, or missing data. Even as EPA seeks to improve its understanding of risks, some prevention- based decisions may need to be made in the face of uncertainty. In EPA's science programs, environmental decisions will only be effective if they consider the social and behavioral contexts in which they will play out. Such decisions can substantially affect societal interests beyond those that are specifically environmental. Tradeoffs among environmental and other societal outcomes need to be anticipated and made explicit if decision-making is to be fully informed and transparent. Predicting economic and societal responses at various points in the decision-making process is necessary to achieve desirable environmental and societal outcomes. For these reasons, developing mecha- nisms to integrate social, economic, behavioral, and decision sciences would lead to more comprehensive environmental-management decisions. EPA can engage the social, economic, behavioral, and decision sciences as part of a sys- tems-thinking perspective rather than as consumers and evaluators of others' science. Human behavior is a major determinant of the state of the environment and, as such, should be an integral part of systems thinking regarding environ- mental risk and risk mitigation alternatives. In addition, EPA would benefit from a long-term commitment to advancing research in a number of related fields, including valuation of health and ecosystem benefits. Research centers that focus on synthesis research have demonstrated the power and cost effectiveness of bringing together multidisciplinary collaborative groups to integrate and analyze data to generate new scientific knowledge. De- liberately introducing synthesis research into EPA's activities would contribute to accelerating its progress in sustainability science. A specific area where knowledge from systems thinking could be applied is in the design of safe chemicals, products, and materials. REFERENCES Abbott, J.K., and H.A. Klaiber. 2011. An embarrassment of riches: Confronting omitted variable bias and multi-scale capitalization in hedonic price models. Rev. Econ. Stat. 93(4):1331-1342. Ackerman, F., and L. Heinzerling. 2004. Priceless: On Knowing the Price of Everything and the Value of Nothing. New York: The New Press. Anastas, P. 2012. Fundamental changes to EPA's research enterprise: The path forward. Environ. Sci. Technol. 46(2):580-586. Ashford, N.A. 2000. An Innovation-Based Strategy for a Sustainable Environment. Pp. 67-107 in Innovation-Oriented Environmental Regulation: Theoretical Approach and Empirical Analysis, J. Hemmelskamp, K. Rennings, and F. Leone, eds. Hei- delberg: Springer Verlag [online]. Available: http://184.108.40.206/bitstream/handle/ 1721.1/1590/Potsdam.pdf?sequence=1 [accessed Apr. 17, 2012]. Bare, J.C. 2011. TRACI 2.0: The tool for the reduction and assessment of chemical and other environmental impacts 2.0. Clean Technol. Environ. Policy 13(5):687-696.
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