EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency's Office of Research and Development (ORD) conducts a program ofintramural and extramural research and provides technical servicesin support of the agency's regulatory and regional offices. ORD has1,830 staff members at its 12 geographically dispersed laboratories,three field stations, four assessment centers, and the Washington,D.C. headquarters office. Its fiscal year 1995 extramural budgetis $378 million for research grants, cooperative and interagencyagreements, and contracts.
In the 25 years since the Environmental Protection Agency (EPA) wascreated, its research programs and overall scientific credibilityhave been assessed many times by independent expert groups, includingcommittees of the National Research Council (NRC), the Carnegie Commission,the National Academy of Public Administration, and EPA's own ScienceAdvisory Board (SAB). EPA has made and currently is making many changesin the ORD program in response to recommendations from those groups.
In EPA's budget appropriations for fiscal year 1995, Congress requestedthat the NRC perform an independent assessment of several aspectsof EPA's research program and peer-review procedures. The NRC's 2-year study will produce two reports: this interim reportand a comprehensive final report in 1996. Congress requested thatthis interim report be provided at a very early stage in the study;it presents some initial observations on the overall research programand peer-review practices within it. The final report in 1996 willassess agencywide scientific practices and ORD's strategic plans,and against that background it will review ORD's intramural and extramuralprogram structure, funding levels, funding mechanisms, balance amongactivities, grants program, cooperative and interagency programs,and procedures for scientific peer review and quality assurance ofplans, proposals, reports, laboratory programs, and research staff.
As this study began, some of the most important changes in the historyof ORD, a so-called “New Beginning,” were already under way:
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A new strategic-research planning process has been initiated incollaboration with other offices of EPA;
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Long-term fundamental and anticipatory research is being increasedfrom approximately 30% to at least 50% of ORD's program resources,with a corresponding reduction in applied projects and technicalservices for the agency's regulatory and regional offices;
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ORD's laboratories and assessment centers are being functionally consolidated,and some management responsibility is being decentralized from headquartersto the laboratories;
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Annual funding for extramural, investigator-initiated, peer-reviewed,competitive research grants and centers is being increased from $21million to $100 million;
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Peer-review practices are being strengthened and expanded; and
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A national program of 300 graduate fellowships is being created.
In this interim report, the NRC's Committee on Research and Peer Review in EPA presents its initialobservations on the overall ORD program and the changes being made:
Strategic Planning—The lack of a clear, agreed-upon mission statement and coherent research-planningprocess has been one of the most frequently expressed concerns ofprevious independent groups evaluating EPA's research program. Thepresent committee strongly concurs in those concerns. Most sorelyneeded are a coherent scientific-strategy statement for EPA; a robustmission statement, vision statement, and strategic plan for ORD;and mission statements, vision statements, and strategic plans foreach new ORD national laboratory and center (consistent with theagency and ORD plans). The present committee believes that ORD'scurrent efforts to develop such statements and strategic plans areof crucial importance. The committee eagerly awaits them and willassess them in its final report.
The Role(s) of ORD—Historically, ORD has struggled to balance two primary roles: a researchrole involving fundamental and anticipatory research and a technical-assistancerole involving applied projects and directed support to EPA's regulatoryoffices. In the past, ORD has predominantly engaged in the supportactivities. But the fundamental and anticipatory research role isvery important. This longer-term research must enable EPA to anticipatefuture problems and to develop the knowledge base needed to movebeyond yesterday's approaches of controlling individual pollutantproblems into complex new concepts, such as sustainable developmentand industrial ecology. A sustained program of long-term, anticipatoryresearch can generally be expected to reduce the need for short-term,reactive projects. An effective research program directed towardover-the-horizon questions seeks to anticipate and address EPA'sfuture needs for scientific and technical information, thereby reducingfuture short-fused needs.
The committee endorses ORD's decision to increase its emphasis on long-term fundamental andanticipatory research, despite the resulting reduction in short-termregulatory assistance. At this early point in its study, the committeecannot offer judgment on the optimal proportions for ORD, but itdoes conclude that the past predominance of regulatory support activitiesmay have been excessive, and ORD's contemplated increase appearsto be a change in the right direction. However, as ORD moves to increaseits long-term research and its grants program, safeguards are neededto ensure that the important scientific needs of EPA's regulatory and
regional offices are not compromised. A great burden will be placedupon the new cross-agency strategic-planning process to ensure thatthis does not occur. The committee recommends that ORD review itstechnical assistance role with respect to the goals of such interactions,the appropriate degree of interaction between the staff of ORD andthe regulatory offices (especially at senior levels), the timingof such interactions, and the administrative channels for such interactions.The committee also recommends that EPA examine several completedrulemakings to determine the types, degree, and timing of scientificinteractions between regulatory offices and ORD staff, and the effectsof such interactions (or lack of them) in shaping agency decisions.From there, and taking into account the varying needs and constraintsof the regulatory processes, more concrete and effective guidancefor future interactions could emerge.
The committee further recommends that EPA's budget-development process be reconsidered with a view toward ensuringthat ORD has sufficient autonomy to conduct the expanded long-termresearch program. There is also a critical need for the researchbudgeting process to be made more understandable to persons withinand outside the agency, so it can become more useful for managing,tracking, and explaining the ORD program.
The committee has concerns about agencywide scientific quality andORD's role, or lack of role, in it. No EPA official below the levelof the administrator has the overall responsibility for EPA's scientificperformance or credibility, and no scientist has ever served as EPAadministrator. Although improving science in EPA has been a priorityof some administrators, including the current one, that cannot alwaysbe assumed.
The 1992 report Safeguarding the Future: Credible Science, Credible Decisions recommended that EPA appoint a distinguished scientist or engineerto function as the agency's science adviser. The report presentedstrong justification for such an appointment, and it defined theroles that such an individual would perform in the agency. It alsoassessed arguments for and against three organizational alternatives:appointing a new staff member in the administrator's immediate office;assigning the additional responsibilities to the assistant administratorfor research and development; or assigning them to a subordinateofficial in ORD. In response to the report, EPA appointed a scienceadviser on the immediate staff of the administrator, but lackingsubstantial managerial authority, that individual has generally lackedthe means to perform effectively the agencywide role envisioned bythe 1992 panel.
The present committee strongly concurs with the assessment and recommendationsof the 1992 report concerning a science adviser and believes thatsuch a role is vital to EPA. In essence, the senior science advisershould serve as the chief scientific and technical officer of theagency with overall responsibility for coordinating and overseeingEPA's scientific and technical activities. Based upon
the 1992 report and subsequent related developments, this committeerecommends that EPA adopt an alternative recommendation from the1992 Credible Science report; EPA should broaden and strengthen therole of the assistant administrator for research and developmentto include the agencywide aspects of the science adviser positionenvisaged by the Credible Science panel.
Specifically, the committee recommends that the assistant administratorfor research and development be designated as EPA's chief scientificand technical officer, responsible not only for ORD, but also forcoordinating and overseeing agencywide scientific policy, peer review,and quality assurance, as well as EPA's outreach to the broader domesticand international scientific community for scientific knowledge relevantto the agency's mission.
ORD's Laboratories—The committee believes that the main immediate impact of ORD's current consolidation of its laboratories and centers will be thedecentralization of laboratory management responsibility from headquartersto the laboratories. This consolidation will streamline operationsby giving more responsibility to laboratory managers and eliminatinga layer of headquarters staff. Another important aspect of the reorganizationis that the names and overall themes of the new national laboratoriesemphasize the goal of reducing uncertainty in risk assessment andrisk management. The committee recognizes that this is an importantcore research area for EPA's in-house laboratories, and it endorsesthis aspect of the reorganization.
Partnerships and Outreach—ORD by itself can never meet all of EPA's needs for scientific knowledge. It must realistically recognizeits limits, specialize in core areas, foster greater awareness andutilization of research findings obtained elsewhere, and build moreand better research partnerships with other agencies, academia, andindustry in this country and abroad. To accomplish this, ORD willneed a more structured approach to maintaining thorough awarenessof research conducted by scientists not affiliated with or sponsoredby EPA, as well as a cadre of in-house scientists responsible forthis function. To further such awareness, the committee also recommendsthat ORD consider increasing sabbatical assignments for EPA scientiststo work at other research organizations and visiting appointmentsfor outside scientists to work at EPA.
The Research Grants Program—EPA's research grants program is one of the most important ways by whichORD can expand and strengthen its partnerships with academic scientists.The committee welcomes ORD's decision to increase the program substantiallyabove its fiscal year 1994 funding level of $21 million. However,it is important that this redirection of support not critically injure other
key research programs. To help justify the increases in the grantsprogram, the committee recommends that ORD endeavor to do a muchbetter job of disseminating the results of its grant-funded research,critically assess the relevance and usefulness of such research tothe rest of EPA, and demonstrate the beneficial impact of such researchon agency decisions and actions.
The committee believes that ORD is deriving some value from its collaborationwith the National Science Foundation (NSF) in the fiscal year 1995grants program. However, ORD faces some impediments to adopting aprocess more like that of NSF. The NSF grants process generally ismuch more labor-intensive than ORD's has been. In addition, the NSFgrants process emphasizes quality but not program relevance; ORD's grants process must address both.
The committee strongly concurs with ORD's stated intent to streamline the administration of grants and toimprove the reliability of multiyear funding. The committee alsorecommends that ORD look to decrease its contracting budget as theprimary means to increase the grants program budget. The committeedoes not recommend substantial decreases in ORD's budgets for cooperativeagreements, interagency agreements, or multidisciplinary institutionalgrants, because those mechanisms are very important to ORD's researchpartnerships and outreach efforts.
Peer Review—The committee endorses ORD's plans to expand and strengthen peer-review practices for researchprogram plans, research proposals, interim stages of long-term research,and completed research products. The committee makes this endorsementbecause it believes that wider and more effective use of peer review,as well as greater emphasis on publication of EPA research resultsin the open and readily accessible, peer-reviewed scientific literaturewill increase the quality of EPA science and the credibility of EPAdecisions. The committee further recommends that peer review be appliedessentially to all intramural and extramural scientific projectsand programs. Notwithstanding the deadlines and other factors involvedin determining when peer review is appropriate and practicable, anddetermining what levels and types of peer review should be conducted,there should in all cases be strong presumptions in favor of conductingpeer review, involving external experts in such reviews, and havingsuch experts nominated by independent referees instead of projectmanagers.
The Fellowships Program—The committee commends ORD for initiating this national competitiveprogram of graduate student fellowships and recommends that the programgive special emphasis to scientific subdisciplines in which the limitedavailability of qualified personnel is impeding, or is anticipatedto impede, efforts to meet the scientific and technical needs ofenvironmental programs.
