Organization and management of EPA's Office of Research and Development


Material Information

Organization and management of EPA's Office of Research and Development
Series Title:
Serial - House, Committee on Science and Technology ; no. 94-LL
Physical Description:
v, 40 p. : ; 24 cm.
United States -- Congress. -- House. -- Committee on Science and Technology
U.S. Govt. Print. Off.
Place of Publication:
Publication Date:


federal government publication   ( marcgt )
non-fiction   ( marcgt )


Statement of Responsibility:
prepared by the Subcommittee on the Environment and the Atmosphere of the Committee on Science and Technology, U.S. House of Representatives, Ninety-fourth Congress, second session ... June 1976.
General Note:
At head of title: Committee print.

Record Information

Source Institution:
University of Florida
Rights Management:
All applicable rights reserved by the source institution and holding location.
Resource Identifier:
aleph - 025927553
oclc - 02517032
System ID:

Full Text
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OLIN E. TEAGUE, Texas, Chairman KEN HGLR, Wetsigii CHARLES A. MO8SHER, Ohio
ROBERT A. ROE, New Jersey LO UIS F RE Y, Ja., Florida MIKE McCORMACK, Washington BARR.Y M. GOLDWATERj, Ji., Calift GEORGE E. BROWN, JR., California 3XARVIN L. ESCH, Michigan DALE MILFORD, Texas JOHN B. CONLAN, Arizons RAY THRNTON, Arkansas GARY A. MYER$,. Pennsylvania JAMES H. SCHEUER, New York DAVID F. EMERY, Maine
HENRY A. WAXMN CalorniaL PHILIP H3. HAYES, -iin TOM HARKIN, Iowa JIM LLO YD, Califorila JEROME A. AMBRO, New York CHRISTOPHER J. DODD, Connecticut MICHAEL T. BLOU-IN, Iowa TIM L. HALL, Illinals ROBERT (BOB) KRUEGER, Texas MARILYN LLOYD, Tennessee JAMES J. BLANCHARD, Michigam TIMOTHY E. WIRTH,, eloriaeo 70EN L. SWIGERT, Jr., Executive Director HAaoLDA. GovLD, Deputy Director
1 FlPHIur B. YEAGER, Counsel ,FRANK R. HTAmmTT.T, Jr., Counsel !AMES E9. WIHsoN, Technical Conisitand L.TNAuS RacaORon, Science Consuant Jb~ D. HOLMFELD, &*deC COSIsilsnt RAHN. READ, Tchnical Opstaffas O0BERT C. KEacuAx, Counsel EIAA. DAVos, Chief Clerk r- E A. SUPERATA, Misority Cousead

GEORGE E. BROWN, Jig., California, Chairmss
KEN HECHLER, West Virginia :MARVIN L. ESCH, Michigan
MIKE McCO RMACK, Washington LARRY WINN, Jr., Kansa DALE MILFORD, Tea GARY A. MYERS, Pennsylvania



Washington, D.C., June 30, 1976. Iton. OuNE. TE.&GUE,
Chairman, Committee on Science and Technology, U.S. House of Representatives, Washington, D.C.
Dvmt MR. CHAIRMAN: In the exercise of its oversight responsibilities, the Subcommittee on the Environment and the Atmosphere has held extensive hearings on the or an ation and management of the Office of Rese ic_ J Development of the Environmental Protection Agency. A major reorganization of that Office was announced about one year sgp, and the reasons for, and results of, that reorganization have been reviewed in detail during both authorization and oversight hearm*gs, as well as visits to EPA laboratories I am transmitting herewith a report which summarizes the organization and management deficiencies of the past, assesses the efficacy of the re- organization, and includes findings and conclusions on the ma, or issues bearing upon the vital work of EPA's Office of Research
Development as perceived by the Subcommittee.
CUirman, Subcommittee on the Environment and the Atmosphere-


Introduction ------------------------------------------------ I
Committee interest ------------------------------------------------------ 3
Organization and management changes ------------------------------- 5
Wpact of reorganization ------------------------------------------- 7
ve authority ---------- ------------------------------------ 9
= ct'h modes --------------------------------------------------- 13
Rasearch program emphasiB ----------------------------------------- 19
teragency coordination ------------------------------------------- 23
5-year research plan ----------------------------------------------- 29
Porsonnel problems ------------------------------------------------ 31
Findints and conclusions ------------------------------------------- .33


Thw National Environmental-Policy Act (NEPA) P.L. 91-196 which vw signed i4to law on Januaxy.1, 1970, established a national pqlky of: encour" productive %and enjoyable harmony between man and his environment, promoting efforts to prevent or eliminate do4we to, :the environment, enriching the ui&derstanding of the 6_01ogieal_ 4"tems. and natural resources important to the nation, 0". ftuiring all Federal Agencies to consider the environmental coimbe.qubnces of their activiti&s.
ollowing this statement of nationa.policy, a Presidential comknown as the ASH Council, noted the dispersion of authority for environmental regulation among a large number of Federal agencies, and recommended establishment of a new agency with broad regulatory powers. In December 1970, under the terms of Executive Reorganization Plan #3, the Environmental Protection Agency (EPA) came into existence to consolidate the functions and responsibilities of 15 separate organizational units scattered around the Federal government, and was given the mandate to respond to the nation's environmental problems.
The ASH Council recommended establishment of a research arm in the -new agency, and the research components of the 15 separate organizations brought tpgether to form EPA were therefore combined to form the Office of Research and Monitoring, which was later r.ftamed the Oflice of Research and Development.
no 42 separate field installations which made up the Office of Research and Monitoring had been conducting research in areas in'duding air and water pollution, solid waste management, pesticides, and radiation. According to Dr. Wilson K. Talley, EPA's A&4 stant Administrator for Research and Development, each group of installations had a distinct and different type of ing from
ashhrtoi _M a to quasi independent, ex:tramur
oriented field opearsations. Dr. Gordon MacDonald, a former member of the Council on Environmental Quality, observed that the varied dhj ter and wide geographical distribution of the various research laboratories and field stations made management problems particulady severe.
In the initial orgam ation, the number of sepamte research units was reduced through comsolidation of activities, and three large field units (National Environmental Research Centers, or NERCs) were created. Two of these, in Research Triangle Park, North Carolina and Cincinnati, Ohio, consisted of an administrative office and a senes of labomtories; the third, in Corvallis, Oregon, had laboratories reporting to it from locations across the United States. Later, a fourth NERC was created in Las Vegas, Nevada all of whose components were local. Each of these NERCs was given a "theme," or program area, in which to concentrate. Some groups were geographically relocated to consolidate the themes of each NtRc, but the movement of pro-


grams and people was never completed. As a result, the thematic specialization of the NERCs was never fully implemented, and the laboratories associated with each NERC continued to be involved in a wide ranLre of environmental research and development activities.
Molding the activities of such a conglomeration of geographically dispersed laboratories and personnel -with their different orientations, varied mix of skills, and different modus operandi into a coherent and cohesive research effort posed extraordinary obstaclesfor top management. The response of the first Assistant Administrator far Research, Dr. Stanley Greenfield, wg;s to establish a highly centrafized Washington-based system.
With the passage of time, it became clear that severe management problems existed in the Office of Research and Development, and several studies, some internal to EPA and others external, were undertaken. Highly critical reports were issued in 1974 which cub.ifinated in a major reorganization of the Office in 1975 under n ew management.

As a consequence of a ma or revision-of the Rules of the House of RePresentatives which took effect at the beginning of the 94th ConVoss. in January 1975, the Committee on Science and Technology ANuired 'unisdiction over, among other things, environmental redevelopment.
The Subcommittee structure was revised to reflect the newly icquired jurisdiction of the full Committee, and a new Subcommittee an -the Environment and the Atmosphere was established. The several critical reports on the oTganization and management of
PIPA's Office of Reseaxch and Development lent emphasis to the 6ed for the Subcommittee toexercise substantial legislative oversight of.1he accomplishments, plans, and goals of EPA's research program
a whole through the annu al authorization process, a comprehensive review that had been impossible previously due to the f act that j : trisdiction over various as;cts of the program had been divided Qmnng three, Committees of the House of Representatives and four &fiate: Committees.
During the initial R&D authorization hearings in March 1975, EPA's newly appointed Assistant AdMIT11strator for Research and Development, Dr. Wilson K. Talley, testified to the effect that he had undertaken a thorough study of the organizational structure, T"Wam management, pl un-ing d conduct o? research by his office In light of the several critical7reports that had been issued durmig the previous year or so. He stated he had personally visited 23 of ORD's field units since taldng office some four months earlier, and had talked to more than 300 ORD personnel.
During his testimony before the Subcomm ttee, Dr. Talley provided the general outlines of the major reorganization of ORD which he had in mind. Washington headquarters henceforth would focus on long-range, objective-oriented planning and broad-scope program review and oversight; greater resource management and program implementation responsibilities would be delegated to ORD's network of field laboratories; the mission of the ORD laboratories would be clarified; and the planning and management system would be simplified.
The promised reorganization was announced some -three months later in June 1975.
In December, 1975, after the ORD reorganization had been in place for about six months, the Subcommittee scheduled five days of hearings in order to provide Dr. Talley an opportunity to des4 &the nature and p oses of his reforms, and to make a preliminary
assessment of the 12(ectiveness of the reorganization.
The following witnesses, in the order of their appeaxance, were heaxd:
Dr. Wilson Talley Assi tant Administrator for Research and Development, Enviio'iimental Protection Agency, accompanied by

Dwir. Balepne, D.iraec, EuvirmalMntrgad u!pt Dabr Thn~ia a urh Depty BrhAt ircoEvr
lonialtoring andhia Support, 0aoaoy,1asVgs hms Vaunze Fa.; oneil M.D.e, Director, elhEfcsRsat Laord oy Heealth DiisoniExngl Cor .C Dr. Milton Harrisaformer Vienr resihirofE mentl Gtitte Co iyDrmuhClee
Dr. RE lr, Chnellor Emern Amnsiaorfie fl avis Ecgalf etOfc f.&DEA Dr. Joehn ukae, BelDeept ho Ldiitrtrfo:E
Mr Abrt raoskDei& sssan dmnitatriii

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an Halh iision, Exxon Corp.
Dr itnH .s omeiiePeietfrieexhadDvlj
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Dr. John Tukey, Bell Telephone, Laboratories, Linden, N.J. @iii

at efc encies noted in the various critical reports on EPA's
biC of Co .hand Development can be'summarized as follows:
14- ij ieOice of "garch and Development had become tanged up in n, labrate a u '"smn teai that created a lot of paper, and iluch.dlope intoi a cumbersome management tool. Tis detailplanmo ptan wea based upon a "vacunm-cleaner"
,the ddliaheSe of ideas from the field without an effective
metho:ofe.Nabislhng priorities, and it was unrelated to an overall
4 As the report of the National Academy.oSiecsfud
paramount of paperwork and excessive bureaucratic review
-(Onstithd) a wasteft cartsumption of time and energy."
Anthri tomange the finanWa and other resources o h
P ffieo Reseiaveh and Derlopment was not clearly delegated, and
a..iahortyand responsibility between headquarters and the APT m we.cnu Several groups at headquarters level provided proramiretion and resource allocation to the laboratories. NERO
trs. were sometimes by-passed. Timely, responsive research was threly knpeded, and mothle was adversely affected. "Accountiy (wa) made impossible by the parallel but separate management gatyinubitmefo housekeeping and the others for program ,ntat-atia by -the hopethasly complex .. system which obfuscates
pagement respansibility," according to the report of the National Acdemy of Sciences.
9() Headquarters staff had become too large and too much involved in thdetails of research done in the laboratories. ]Instead of establish%ro &-aii goals and an overall research strategy, headquarters had al1vope a management system based upon the detail-intensive
ifeve r anyone had a mandate to change the structure and managementI an orgsolzedon, the newly appointed Assistant Administrator for 1dearch and Development, Dr. Wilson K. Talley, had such a mandate.
Dr. Ta11ey took alfice late in 1974, after the position had remained o .pen for some six months. He immediatel y undertook a detailed Teview of the organization, and about six months after taking office he annuDnced a comprehensive reorganization of the Office of Resea rch and Development. His stated goals: were to be accomplished within the followmg constraints: there should be an absolute minimum of disupion of the ongoing research and deveoment programs; gcographic displacement of individuals should be kept to- a mimum; ad clear lines of authority and responsibility should be established. Working group ]e, consisting of individuals from headquarters, the NERCs, and laboratories, were etbihdto analyze and make recommendations reading both program and management structure.
Unde thereo. anzaton, he pogrms adin
rg geent f th
Offie o.Reearh~adDevlopentwer comle estuctred


It was decided that ORD's activities should be organized in such a way as to group the research programs according to problems being addressed and to.type of output needed. Consequently, ORD's shortterm activities, including analytic responses to the needs of the Agency's regulatory and enforcement offices, were grouped together under the heading of monitoring and technical support. While specific problems cannot always be foreseen, Dr. Talley states that a level. of effort for work of this type can be anticipated and planned for based on historical information.
The relatively longer-term research activities relating to the deteration of the human and ecological effects of pollutants sometimes require several years in order to obtain the necessary results, and consequently must be supported with a relatively stable level of resources. Dr. Talley has organized these activities into a health and ecological effects program.
The third component of ORD's mission, designed to meet legislative and Agency Tandates for control or abatement technology, was, because of its size, organized into two groups. The first group-energy, minerals, and industrr-focuses on I point, or basically industrial, sources; while the second-air, land, and water use-includes work in the nonpomt source and public sector areas. The latter program also includes research on the transformation and physical transport of pollutants in theenvironment.
These four new groups-monitoring and technical support; health and ecological effects; energy, minerals, and industry; and air, land, and water use--have been"placed under the direction of four new Deputy Assistant Administrators at Washington Headquarters.
The National Environmental Research Centers were abolished under the reorganization, and their functions and personnel were transferred to the laboratories.
The laboratories were consolidated, based upon mission and geographic proximity, from 24 units to 15, and the work of each laboratory is concentrated in one of the four new research areas.
Program regrouping was designed to give each of the resulting 1.5 laboratories a clear focus for its mission. Most of these laboratories accomplish their mission with a mixture of in-house and extramural research. However, according to Dr. Talley, a few do all their work by contract and grant and axe therefore research managers; and a few others accomplish their missions essentially with in-house staff.
In addition to the new organizational structure, Dr. Talley established several new management concepts which included defining the responsibilities of Washington headquarters and the 15 field laboratories in such a way as to create a single line of authority between them. This required a major reorientation of headquarters staff.
Headquarters staff have been removed from the day-to-day management of the on-gomg research program and given responsibility for longer range program planning; for coordination within the Agel cy and with other Government and industrial groups; and for review and integration of the laboratories' outputs.
Under the new management scheme, the laboratories are now charged with detailed program planning and implementation. Each laboratory relates through a clear and accountable direct line authority to a specific Deputy Assistant Administrator (DAA), who directs both headquarters and laboratory efforts in one of the four major


geogram offices. The DAA's, along with the Assistant Administrator,
Associate Assistant Administrator, and the Directors of two support offices (the Office of Financial and Administrative Services, and the Office of Planning and Review) make up the senior staff
f up which serves as the top level management at Washington erioaldquaxters.
Dr. Talley notes that central to any management system is how and who controls resources, both funds and personnel. Under his reorganization, resource control flows from Dr. Talley to the four Deputy Assistant Administrators, and from them to the laboratory directors under their supervision. Consequently, says Dr. Talley, those who have the responsibility for carrying out ORD's programs now have cleax control of the resources which axe available for these programs.

najsiyof the witnesses before the Suboommittee tended tol
VW~a ihreorganisation. of the Office of .Research and Development
atekh ligt'hth n..ean~ofsimplifying the planning and
awgment .system, and establishing, clearer lines of authority and
pi1e 1r Tah. sttdga of minimizing the adverse effects
ouiployees of the Office of Research and Development,. some disatbn, .inevitably has .aoccursed-. Overall, 39 employees have been.
noaest to other geographicst sites. In an organization employing spirx'P800 personnel however, *relocation of so few people appears anbea minimal. Aeberdingt i Dr. Talley, 10 proposed georgraphic reocations of personnel were decided against because undue. hard-. WbPe winald ha een imposed on the individuals involved. 11iP Mahi relocation weinly one factor he gearing upon morale of
p41ael A more nebulous impact, ssys Dr. 'Talley, but perhaps a anba ...:-- on is the concern felt by a number of individuals over chaes in the tyeof work they are doing, and. their responsiInes -hefly affaed .were headquarters professional personnel
to sr .aboratorypronl Because Dr. Talley's purpose was tW &4 moere tong-%terin* program planning and coordination at headqttwt, sas well as to tidathlke periodic reviews, the headquarters
-now expected to 'handle broader, policy-related matters.
11 &~uaters personnel whe -preferred. to continue to manage research dn. a say-to-day basis, or to implement research programs, were given me 6prtunity to transfer toi a laboratory, ad 20 elected to do so. MI as,.ae..,,me who did not wish to,- relocate to. the field reportedly Ihave found it dilicult to. work in the new mode at headquarters with
and.broader responsibilities, Headquarters staff has been
redped fom more than 300 personnel to fewer than 250 under the
r...~ ........ion

tansfor of. additional authority to 'the laboratories has placed a resposbilities on the senior laboratory staffs, particularly mn the MaA pgexent ,area.: Dr. Talley notes that:
,.Pwithk any effort that: involves possible changes in personnel and organisaticial relationships, the uncertainty created by, not knowing how one will fit' into the new structure impAgts the morale df the stha. . once it becomes clear b. iRMOdlils will fit into the new sweueture, morale should: not be a significant pambexn.
Ti~etthe circumstances of reorganisation, it is n'toral for some f ', to' perceive that their positions have unproved, while others e tha their relative, positions and status in the organization have declined.
AsDeputy Assistant Administrator Ro Albert has observedAny reorganization is disruptive thing. t -is -similar to surgery. It is traumatic and requires a recuperative period., It is not done for fun. it is done to produce a beneficial effebt and let us hope this regoranization does have a beneficial effect.
Dr. iltn Hrri, e'membekr.of the EPA.Sciece Advisory Board concludes that:
1%ne+ at +Lcharanna that Tr. TaHley has nstiuedfk harms tLA pneatimal, giAdvn
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Wag 0 Drovi e a p e approach to
t& R Yet sdwral ibiess:es noted' the lack of
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M")?Pn#ld,,ha&, obeyed, managemerA of longer-term research is
:L=porqi because PA ag ii6cessarilj, focused on separate; media, (t"a"D J j.7 air and 'Water) iiild individual environftientat threats, (p(sstiCid, t,' oie and radfatiol which are subject tovayifts
llvw l i6d at i ereAt tiniog'but axe now t6 bl administered totetho. According td MhelYwiald, these legislated'bits and pieces ar 'in
d*ept opposition to the holiAic View whidh is ess tial to effective
iviroTgpiental maiiageMent. Dr. MacDonald cites as an' examp
r gulqti6ii of the disposiff of sTudg6 6oiit sewage treatment plants;- it may U.iiioke-fated put into, a, fah4fill or dumped into the ocean, each Sol" U rembd'uy separate laws alid each having broad and lately
O.Wh jin"P60ts on the environment as a whole. He concludes that
d izadon of RPA, d e- from a non-c
ogq= an organ eriv slu
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of '64' 6oja control legWation, runsco mter to the: comprehensive fWs, D&I.s.-Of the enviLronniedt in virtdall e, &y iTistance.
ij 13A .ZeuWd adds that the research thinking which- preceded r6rr"tion .. of EPA, And to soine extent stiR pe'r'Ists in, EPA today, *as Imke -oriented t o 4 large extent eng-ondered'by legislative authority
oug media lines. in th' nm h ar
e eA o e tal 'etta Dr. Neuhold j'' ihat a pollutant kriows no boulid6rifes ihtermedia

19 aches necessary.
he'reis6akch ptogram of the Envir'OhnieAtal Piotectibh- Agency is
i-I 10 ; ..
carried out uv&r the following statutory authority,:
T,4e Clean Alr'Act, as amended, Public Law 89-206, directs EPAI to
t r' seax ch on thb causes, effects extent, and'waysto control air y is charged with tlie duty of providing tech Mtal an jancial assistance to'StAte:and 16ca;l air pollution control: agencies
spepial'ih*,ditigations by EPA may.b6institutiod at the request of t tjtm qQv6r1n'- dAts%- Fed:eral Interagetey coloPeraltion is onp(suragbd and "ZkXs,'dwn f6se"Arch is directed ifiW specific' s4 6as, in hiding hoidth
uel c6iiibustibtL, afttrgR.ejifti9si6ns -- dogt-behtfit studies, dnd con& i i 601(59y. Uiidef t46 Mkfi-Air Ac ,'th6 toxiedlogi6ak(as *efl
0 *ects of air, pollutdnt 'c6fistifuth, a jfiiij6r're86IAXbh- focus!
T 'e. 0 2 9 moftdments tb the-Fo6ml"Watef PollutiotiVontibI Act
U gic AW: OLSOO, establish f6s -.aich-pt6gr-aijas for* th61 *e*eli6on, 0 ilQG011 and Oiniiiiation'' of 1*91ftioii. ity xiAvigAbI6'm ter-8-',6f, the fa g. The a 7ehey14 directed tb'estlblish' iii, eobo rafw6 with 51 "tiji' P di 91-State, aVid, pri vate ptrlddg, cothOk(ehdnsi+,4'16cal
auc[j 46hia alhs r water pdMitio-A donta dl. SpeOWAII the
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establish advisory committees to evaluate research progress and proposals; establish a water quality surveillance system to monitor the quality of navigable waters, and initiate and promote studies measuring the social and economic costs and benefits of water pollution control activities. The Administrator is also required to investigate the harmful effects of pollutants on the health and W'elfare- of persons. The Administrator must establish field -laboratories and research facilities, make a comprehensive study of the pollution of the Great Lake and Anaiace, pilot treatment works programs. Problems of pollution by eutrophication, oil spill, pesticides in water, and thermal discharge m ust be investigated.
Under the Safe Drinking Water Act, Public Law 92-523, the'Administrator may conduct research, studies, and demonstrations relating to the causes, diagnosis, treatment, control, and prevention of physical and mental diseases and other impairments of man resulting directly or indirectly from contaminants in water, or to the provision of a dependably safe supply of drinking water.
The Solid Waste Disposal Act, as amended, title II of Public Law 89-272, directs the Administrator to conduct and cooperate with research efforts relating to any adverse health and welfare effects of the release into the environment of material present in solid waste, and methods to eliminate such effects; the operation and financing of solid waste disposal programs; the reduction of the amount of -such waste and unsalvageable materials; the development and application of new and improved methods of collecting and disposing of solid waste; processing and recovering materials and energy from solid waste; and the identification of solid waste components and potential materials and energy recoverable from such waste components.
Under the Federal Insecticide, Fungicide, and Rodenticide Act, as amended, Public Law 92-516, the Administrator shall undertake research to carry out the purposes of the act, giving priority to the development of biologically integrated alternatives for pest colitrol. The Administrator shall formulate a national plan for monitoring pesticides, and undertake activities in support of it.
The Administrator, under the Public Health Service Act, as amended, Public Law 78-410, has broad research powers to develop accurate estimates on levels of radiation in the environment, their pathways to man, and the health risks from these doses.
The Noise Control Act of 1972, Public Law 92-574, authorizes the Administrator to establish a comprehensive research program relating to noise. Such a program enables EPA to undertake the necessary investigations into the health effects of noise under varying conditions of magnitude, duration, background, etc.
The National Environmental Policy Act (NEPA) Public Law 91190, requires Federal agencies to prepare environmental impact statements (EIS) for legislative proposals and for other "major federal actions that significantly affect the quality of the human environment." In preparing these ElSs, a Federal agency must consult with other agencies having jurisdiction by law or special expertise over such environmental considerations. Since EPA's purview is the total environment, it must be consulted for most ElSs.


Under the Maxine Protection, Research and Sanctuaries Act, Public Law 92-532, the Administrator, in coordination with the Secretary of Com e and the Coast Guard, shall initiate a comprehensive and
continuing program of monitoring and research regarding the effects of the dumping of material into the ocean water or waters which ebb or flow into the Great Lakes and report the effects not less frequently than Amiually. The Administrator is responsible for offering consultation to the Secretary of Commerce on the possible long-range effects of pollution, overfishing and man-induced changes of ocean ecosystems.
Inasmuch as the statutory basis for the conduct of research is piecemeal and fragmentary, the Committee on Science and Technology hopes to assist in the achievement of a more balanced, integrated, a d coherent research program by reviewing, on an annual basis, the accomplishments and goals of EPA's Office of Research and Develop ment, using the vehicle of an annual authorization.

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Moreover, after many years during which both research and regulstion were carried out by the Atomic Energy Commission (AEC), a recent decision to separate the two functions led to the establishment of two distinct agencies, the Energy Research and Developmmt Administration (ERDA) and the Nuclear Regulatory CommU91104.. (NRC).
As Dr. John Tukey has testified,
Over the past few decades, we have come to recognize the need for separatier of the regulatory function from the promotional function. Responsibilities once.,. in USDA are now in EPA, others once in AEC are now in the new Nuclear Regg-' latory Commission.
Combining the two functions in a single agency raises the questi6h: of bias in some minds. As the Office of Technology Assessment h noted,
When a regulatory agency conducts its own research to evaluate and support.:, regulations that it must enforce, there is a danger that a strong regulatory orientation will permeate the research program. If this occurs, the efficiency, conten .' and quality of the research being performed may be seriously degraded. Itis.a matter of special concern when the research program is not only supposedto establish regulatory support data but also promote the development of baeic. science in the affected areas.
Another reason for separatincr research from regulation has to do with allocation of resources. During his testimony on atmophieric: sulfates research on-July 11, 1975. Dr. Talley's predecessor in EPA, Dr. Stanley Greenfield had this to say about the difficulties of reconciling the two functions under a single management and one ovemll budget.
Research in an operational agency is always a difficult and uncomfortable* activity. This is primarily because in the yearly competition for funds the opera, tional arm of the agency always views itself as carrying out a clearly defined
-near-term mandate within that budget period.
In contrast to this, the research function, with its more distant, less clear goals, 4s always viewed as an unnecessary drain on limited resources and in many ways: a hinderance to the accomplishment of the "more important" agency functions.
-This conflict is even further amplified in an operational regulatory agency, where
-the political measurement of its effectiveness is very closely tied to the day-to-day,::
-public view of its enforcement activities. In this case, the research function is not only viewed as utilizing needed current resources in order to accomplish future goals, but in addition it is seen as being constantly in the position of posing uncertainties and constraints in the technical base which underlies the desire d regulatory action. The result is a constant battle in which the research function is continuously put in the position of having to request sufficient time and resources to provide an information base that is adequate to permit defensible, rational regulatory activities. From the regulatory side of this conflict emerges a resentment of the need to "waste" funds on nonregulatory activities and a frustration over the inability of the research activity to provide the needed and required information on demand.
The accomplished compromise to these opposing viewpoints is a research function that is never sufficiently funded nor given adequate time to acquire the required knowledge and a regulatory function that never had adequate information to make the decisions on which it acts. I should hasten to add at this point that this condition is too often not the complete fault of the regulatory agency, but rather may be due to the fact that unreachable or unreasonable implementation dvttes are legislated in an understandable attempt to produce quick positive results. While laudatory in intent, such action tends always to produce a chaotic response, and frequently can result in a counterproductive effort. I .
This conflict that classically exists between research and regulation, or research and any operational activity, was experienced by me during my entire tenure as Director of Researeh and DevelopmiBnt for the Envircom al Protection


-A third reason for separating research from regulation is that it is diffwdt) 4aome think impossible, for the research arm of a regulatory,

l moy, tQ 4adertake patient, uninterrupted long-term basic researche t" "Of'fwtivity that is characterized b stability and continuity.
EPA s research program has tended to Ze driven by urgent needs percolating up from the EPA regions which reflect the exigencies of the remilatory and enforcement functions of the agency. ORD's reaction has been described as "firefighting" and has led to the "pollutant ot the mouth" syndrome which characterizes much of ORD's research. Dr. Talley makes it quite clear that he accepts ORD's support role f6r the rest of the a"ney, and he comes close to saying that relatively unfocused basic environmental research of -the type recommended by otbm is not a realistic goal for his organi ation.- He claims that,
Fint and foremost is the full recognition that research serves a support function within the regulatory Agency. Our strategy, specific objectives and priorities should not.and cannot stand as entities in and of themselves. Rather they must derive from those of the Agency in the accomplishment of its to ii legislative mandate.
The program then, is one of 'on-oriented research and not one of so-called basie research. !i7Ms is not to say that some very fundamental research is not, in fact, aA integral part of our program. It is and must continue to be so because of our responsibility to provide the best scientific data and to develop control systems for pollution problems that are beyond the present state-of-the-art. Further, a mA3s:t:importaat researiph function is to anticipate the problems that will emerge in the future aud-if we cannot prevent them-tag them so that they will not arrive unhearalded.
".1t its review of ORD's initial publication of its five year research plan,, the, Office of Technology Assessment (OTA) was rather critical of Dr. Talley's approach to basic research. It found that as an organization, EPA dKe of Research and Development (ORD):
Lacks a clearly defined commitment to research addressing long-range environmental concerns; it appears to be preoccupied or overwhelmed with the day-to-day domands Of the regulatory process. Short-term research in support of the regulatory process is necessary, to be sure; but this should not preclude a strong commitment by ORD to long-range reseaxch.

Where long range research is mentioned in the Plan, in most cases the development of techniques is addressed rather than a clear definition of what long-range Issues are considered important.

Ie knowledge gained from pursuing research on long-range environmental issues is essential to the regulatory and legislative processes.

ORD's preoccupation with the short-term, prevents it from exercising national scientific leadership and becoming a forum for scientific knowledge reflecting the broadest input from the scientific community and the public.

The report of the Office of Technology Assessment acknowledges the merits of Dr. Talley's contention that, although ORD performs mis P on-onented; research, as opposed to basic researchproviding the best scientific data and anticipating future problems is an integral
t of ORD's research program.
Thus, OTA concludes. that:
Lack of a well defined commitment to research addressing long-range environmental concerns may reflect the dedication of this Office to its primary job of supporting the regulatory role of EPA. Indeed, ORD was strongly urged to do

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The research on the longer term problems requires an approach vastly different. The longer term research programs such as the epidemiology of air pollutants, the Im acts of PCB's on man, and the effects of nitrogen-based fertilizer on the ozone er, cannot be completely divorced from the ongoing day-to-day operations of the Agency.
But to be successful, these efforts must be provided with the stability and resources that will permit the very best scientists to commit themselves for several years to research in these largely neglected fields.
In considering the alternatives, one could organize a program of grants and contracts with existing institutions, including universities carrying out these loxigei term programs.
. Such a policy would insure that some of the best scientists in the country
would be involved.
However, universities and related institutions have a variety of missions, not necessarily compatible with the long-range stability required if we are going to, anticipate problems before they overwhelm us.
I believe the importance of longer term environmental research is of such magnitude that a new institutional mechanism with a high degree of visibility is required.
In particular, I would argue that an Environmental Science Institution should be established to carry out the longer term research activities supporting EPA. The new institution should be modeled along those institutes now constituting the National Institutes of Health.
Such an organization could attract the very best talents. Further, the combination of high visibility and adequate resources would encourage the younger and most creative scientists to become involved in the difficult and at present unrewarding task of assessing future environmental problems and developing ways of dealing with them. .
I recognize in making this recommendation the difficulties of creating new organizations. However, the success of environmental management requires taking unusual measures.
Duri his testimony on the costs and effects of chronic exposure to low leve pollutants in the environment on November 7, 1975, Prof. Lester B. Lave of Carnegie-Mellon University stated he would place the responsibility for longer-term environmental research in another existing Government agency, viz. the National Science Foundation.
EPA's task is a difficult one, being performed under what are impossible time constraints. It is not likely that responsible EPA officials are going to find the time and money to commission research with an horizon of more than one year. Thus, I would advocate that the Congress appropriate funds for longer term environmental research and that these funds be overseen by the NSF rather than EPA.
My comments should not be interpreted to mean that all research funds should be taken from EPA. Indeed, the great bulk of research funds should remain there, since most of the tasks confronted by EPA require short-term research. Advocating that some funds go to NSF is a way of attempting to insure that these funds will be allocated for research with a longer time perspective than that of the funds administered by the EPA.

One of the more pressm.g questions is the overall balance of the EPA research program. Historically, EPA has emphasized research and development of control technology-hardware and techniques designed for the abatement of pollution of air and water due to the activities of industry and the utilities. An example is the development and retrofitting of flue gas scrubbers at electric utility power plants.
.. Reseoxch on processes and effects, by contrast, deals with identifying
and describing pollutants, understanding and monitoring their production, their transport through media such as air or water, their transformation through chemical reactions, their effects on the health and well-being of humans and othek living organisms, and their ultimate fate in the biosphere.
Dr. Talley observes that:
As a regulatory agency, EPA requires credible scientific and engineering information in order to promulgate and enforce standards and regulations. Certainly health and ecological effects data on dose-response relationships of harmful materials in the environment are required to determine tolerable pollutant levels. However, effective and economically feasible control technology must also be assessed, and where necessary, developed and demonstrated to ensure that
-human health and environmental values are protected. Both the Clean Air and Federal Water Pollution Control Acts require the setting of some emission or effluent standards based primarily on technological and economic considerations. Examples are New Source Performance Standards and Best Practicable Technology Standards. The 1972 amendments to the FWPCA emphasized this approach, and some proposed amendments to the CAA would do the same.
While it seems clear that EPA cannot, and should not, withdraw from further research on control technology, there are those who believe that there should be a shift of emphasis in EPA's research program away from large and expensive demonstration projects to .exploratory research.
For example, in its report on EPA's five year research plan, the Office of Technology Assessment notes that,
EPA efforts in the development of control and abatement technologies appear to favor demonstration over exploratory research projects. EPA's efforts in this area need to be planned with due regard for ERDA!s specific mandate to develop enviro-nme ally sound energy technologies and the efforts of private companies 'with the capability and economic incentive to continue control technology development. Additionally, because EPA is both regulator and developer, it could be put in the position of promoting its own technology. Others behove that the time has come for ORD to shift its research
emphasis from control technology to processes and effects. In appraismg EPA's research budget, Dr. Gordon MacDonald states that:
The distribution of funding leaves very much to be desired. Approximately 60 percent of the funding goes into the Office of Air, Land, and Water Use and the Office of Energy, Minerals and Industry. These offices are primarily concerned with the development of pollution abatement technology.
Much of that work, in my view, should be the responsibility of private industry, APO Government participation in this research is not as necessary nor as approOriate as research on such questions as pollution emission, pollutant transfer,


pollutant transformation and pollutant effects, particularly health effects that in so many ways influence the way in which people Eve.
Currently about 27 percent of the R. & D. budget supports the Office of Health and Ecological Effects. . .
Resources currently available to EPA are certainly sufficient to carry out a broad and strong program, but they need to be redirected with less emphasis on pollutant abatement technology and greater emphasis on the long-term health and ecological effects. . .
I would say that much of (control) technology is'well in'-hand today. Developments in the private sector have proceeded quite rapidly. Greater emphasis should now be placed on having the Federal Government look into areas not being dealt with in the private sector-health effects, psychological, effects-ana emphasizing those as opposed to continuing to conduct research on S02scrubbers. That kind of activity quite properly belongs in industry, and industry, private industry, is doing a great deal.
Dr. John Neuhold concurs with Dr. MacDonald's assessment:
The continued expenditure of funds in EPA R. & D. for the development of control technologies seems to me to be past the stage of usefulness. I think that industry is quite capable of control technology development. They have been given a start in this area. A number of specific industries have been created over the past 10 years in this area, and they are fully capable of developing -their technology. I fully agree with Dr. MacDonald that industry, the private sector,, can in fact not undertake support of research in such areas as ecological and: health effects and are the ones which EPA should be concentrating on.
ORD's Deputv Assistant Administrator for Energy, Minerals, and Industry, Dr. Siephen Gage, perceives some practical problems in, looking to industry to pursue control technology research, and he. cites the historical record:
The general impression that indust ry can be left to carry out its research and development for pollution control technology given a regulatory requirement has been a notion that has been tried out now, and we have some experience to draw on.
I think that 5 years ago, before the Clean Air Act Amendments came in and theFederal Water Pollution Control Act was passed that the thesis had not been tested. It has be-n tested in the last 5 years.
Frankly, the thesis does not hold up.
Industry may or may not have the wherewithal to carry out the pollution control research that it needs. The fundamental point, in order to protect the environment, is not whether industry has the resources to do it, but whether it will in fae't carry out the pollution control R. & D.
In too many instances, the industry has not carried this out.
You mentioned one excellent example, of flue gas desulfurization. Most of the investment in flue gas desulfurization R. & D. has been made by the Federal government, and unfortunately at this point we are unable to show that the stack gas scrubbers can operate, can operate reliably, can operate with a minimal amount of secondary environmental impact, and can meet the control requirements that we have for sulfur dioxide across the country.
The Industry's initial position of several years ago was that such scrubbers did not work, they could not make them work, and it was only through pollution control R. & D. carried out by the OfFice of Research and Development that such scrubbers were made to work within the United States.
The fact that they were working in Japan is really quite another subject, but they were made to work here in the United States, and American industry isnow beginning to accept that fact.
The point remains, Mr. Brown, that in many instances when faced with an environmental regulation for emission control, the industry finds it much Riore cost-effective to litigate than to control, and before they can even control, they have to carry out the research and development.
If the industry does not have the capable technicalskillsto do that themselves, they must rely on vendors of pollution control equipment, but -the vendors of pollution control equipment axe not going to carry out that reseArch unlm they' have some degree of certainty that a market will develop for that research. When the regulations are under litigation, the. future is clouded and risk capital will not move in.


What the very small amount of pollution control R. & D. dollars that we have really does is to provide that extra incentive, that carrot, rather than the stick, to try to leave more innovative and more risk taking vendors in industry in moving ahead the state of the art of pollution control technology. . And I just thinifthat the record really should indicate at this point that someone making a statement that industry can do it and therefore, why, let industry do the work in the pollution control area really has to be examined against the record in the lut 5 years, where we have had real operating experiences with some fairly stringent sticks and we have had very few carrots at that time.


EPA's research program is- currently funded at approximatelv $260 miDion. This represents less than 20 percent of the total annual Federal budget of some $1.3 billion supporting environmental R. & D. in it dozen or so agencies of the government. Coordination among these Vanous Programs to avoid major gaps in the total effort as well as widwakable duplication of effort has been a matter of continuing concernto the Committee on Science and Technology.
Expressions of Congressional intent bearing on the question of 00orAination of environmental R. & D. also appear in a number of statutes which seem to give primary responsibility to th-e Administrator of EPA:,
SEC. 104. (a) The Administrator shall establish national programs for the preV41.44on, reduction, and elimination of pollution and as part of such programs Shall(1) incooporation' with other Federal, State, and local agencies, conduct
and promote -the coordination and acceleration of, research, investigations, experiments, training, demonstrations, surveys, and studies relating to the causesY effects, extent, prevention, reduction, and elimination of pollution;
(2) encourage, cooperate with, and render technical services to pollution
control agencies and Other appropriate public or private agencies, institutions, and organizations, and individuals, including the general public, in the conduct of activities referred to in paragraph (1) of this subsection;
CLEAN AIR ACT (P.L. 88-206)
SEC. 103. (a) The Administrator shall establish a national research and development program for the prevention and control of air pollution and as part of such program shall(1) conduct and promote the coordination and acceleration of, research,
investigations,: experiments, training, demonstrations, surveys, and studies relating to the causes, effects, extent, prevention, and control of air pollution;
(b) In carrying'out the provisions of the preceding subsection the Administrator is authorized to(2) cooperate with other Federal departments and agencies, with air pollution control agencies, with other public and private agencies, institutions, and organizations, and with any industries involved, in the preparation and
conduct of such research and other activities;
SEC. 20. Research and Monitoring.
(a) RESEARcn.-The Administrator shall undertake research, including research by grant or contract with other Federal agencies, universities, or others as may be necessary to carry out the purposes of this Act, and he shall give priority to research to develop biologically integrated alternatives for pest control. The Administrator shall also take care to insure that such research does not duplicate research being undertaken by any other Federal agency.
(b) NATIONA-L MOMITORING PLAN.-The Administrator shall formulate and periodically revise, in cooperntion with other Federal, State, or local agencies, a national plan for monitoring pesticides.,

(C) MoNIom.-The Adminiarator shall undertake sue
tivities, including but not limited to monitoring in air, soil, watemn lns and animals, ns may be necessary for the implementation of tisAtadoth national pesticide monitoring plan. Such activities shall be card tion with other Federal, State and local agencies.

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(2) the operation andi ig sold wate
(3) the reduction of the amount ofsuch wato and8
(4) the development? and, application 6-eP ffM imd ~ ( ixdft4 o
collecting and disposing oftsolid wastesagroeselgad-recoen utra
and energy from solid wastes; and
(5) the identification of solid waste components and potnfdmt'il
and energy recoverable from such waste components.
NOIE CONRtOL AdT OF 1972 (hare a 2
SE~C. 4. (a) Th1e Congre88 allth1rizes 8,'dRet t0 a Feea A66Ahat
the fullest extent consistent with their authority unde aFederal as d~see by them, carry out the progrm within their aontrol in suish a mnerastfuhr the policy declared in section 2b.
(c) (1) 'The Admigh9,trator salcoordinate te ogaso lltdrf ece relating to noise resin arah and noise eonirol. ahFdrlaec hluo
request, furnish to the Administrator suchinfotio as he a esribyrq to determine the nature, scope, and result othno ise eerhadnie oto programs of the agency.
According to Dr. Talley,
It was not envisaged that EPA's research arm need do every
it needed to be aware what whs going on- outstat tthd I believe this original view was, and remains, correct. We in (R ree P cannot perform all the needed research ourselves. First of all, i sateomu effort and our funding is limited. Second, and nmore impbrtantly, ohr ~ led doing a major part of it. The challenge is: that all these other rese: hatvte Federal, State, industrial, -academic-must be puled- together, oriae n focused on particular EPA problems, in order to, meet legislatiemnasad time frames.
Dr. Talley has explained how Federal interagencycoriaonf environmental research is accomplished under: pres~tent ~jatac
Our interagency contacts fall into three principal categories; fomlitmey Agreements,. which involve about 23 percent of our RAD bu programs with other agencies;, and coordinating activitica Thislt cegrin cludes membership, of our staff on various committees and inionl-dyt-a working level contact among, Federal scientists.,,.1
To be more specific, what I have termed formal interagency agrees ivle an identification of -a major pool of talent and expertise ianotherFdrlaec
1Sec. 2 (b) states "...purpose of this A:ct to-etablish a meaner for fetv'~rfa tion of Federal research and activities In noise control . .

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However, I wonder what technical expertise is brought to bear to help them with this process. It is my sincere belief that there should be a formal coordination function for environmental health research and that it should be at a level in the Federal Government above the actual agencies involved in the research.
This is difficult because Cabinet-rank persons actually head some of the agencies involved. Even so, perhaps this is a role that can be assigned to or accepted by the about-to-be-reformed Office of Science and Technology.
Everything that supports the environmental health effort supports the regulatory proqam. What we do not have is any internal coordination. There are hwge gaps in information. They have to be recognized. There are duplications within these progr These need to be recognized. In factY this need for coordination was one of the reasons I referred to the ad hoe committee report on environmental health research done under the aegis of OST and CEQ.
is the Office of Technology Assessment satisfied With the way interagency coordination of environmental R. & D. is pursued. In its apprafsal of ORD's five year research plan, OTA concludes that:
The ORD Plan fails to recognize and delineate the actual function of EPA in coordinating Federal environmental programs, including programs related to research and development. Though mention is made that such a role exists, the Plan proposes no method to achieve it. The Executive initiative which created EPA and numerous subsequent legislative acts mandating environmental provl-ft seem clearly to place this responsibility with EPA.
*Z;ause there are numerous government agencies conducting environmental rmearcb leadership in determining the environmental research goals and priorities among these agencies is essential; ORD is the logical center for such leadereMp.

Among the perceived weaknesses in the manag nient of EPA's research program was a lack of long-range plannin5, a probable eonsequence of ORD's preoccupation with the day-to- av exigencies generated by the Agency's basic regulatory mission. The Subcombecame convinced that some type of long-range strategy should be developed to guide the research program, and to provide a sense of mission continuity to the research peiFsonnel. As the National Academy of Sciences noted in its report on EPA's Office of Research and Development, "a long-term program designed to meet stated goals is missing, and this is vital for any scientific venture2y
For these reasons, the Subcommittee amended the initial (fiscal year 1976) EPA Reseaxch and Development authorization bill to include a provision requiring that a comprehensive five-yeax plan for environmental research, development, and demonstration be transmitted to Congress, and that the plan be appropriately revised annually.
Dr. Emil Mrak, Chancellor Emeritus, University of California at Davis is a member of EPA's Science Advisory Board. Regarding the desirability of a five-year reseaxch plan for EPA's Office of Research and Development, Dr. Mrak testified,
I commend the subcommittee for its decision to press EPA for a long-term research plan. Such a plan has been too long in coming and will be a great help to the Agency. . I think, however, that two points need to be made here: (1) The elements of any such plan can cleaxly benefit from input offered by the scientific community. Provision should be made for gathering and incorporating such views: (2) any such plan should not be viewed as inflexible.
I think that it is very important to make a 5-year plan and then come back and look at it. . .
New information or situations can often create a need for reseaxch not before perceived.
Dr. Talley responded quickly to the Coneressional intent expressed in Section 5 of the EPA Research and Erevelopment Authorization Bill for FiscaJ Year 1976 which mandated a five-year reseaxch plan, and in December 1975, the first draft of the plan was submitted. Dr. Talley explained that, in this initial effort at a five-year research overviewp an effort was being made to raise issues and identify environmental problems and priorities. He added that: I recognize that this is a first attempt and that as such, suffers from the usual weaknesses or deficiencies that are associated with being a first. In addition to substantive criticisms of the projected research program, I invite your comments and suggestions to improve subsequent versions of this document.
Since ORD's five-yeax research plan represented a new departure in the Agency's manacrement system in the sense that it was a first attempt to structurehPA's future research program so as to anticipate, to the extent possible, future environmental problems, the Chairman of the full Committee on Science and Technology, Honorable Olin E.

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There axe problems in managing a research laboratory under the Civil Service System. As Dr. Talley has testified, a number of constramits, completely outside his control, pose major obstacles:
Our severe limitation is in the area, of personnel. The moan problem here is not ehiefly one of numbers, but rather one of skills and salaries. A low attrition rate, ;Woverall reduction in personnel ceiling, certain inflexibilities in the personnel system, and an inherited skill mix have severely restricted our ability to modify or change the type of activities we undertake in our own laboratories.
Developing and retainmig a well-qualified professional staff is difficult for several reasons, according to Dr. Vaun Newill:
&dary levels in the Federal Government for those below the professional level are competitive. At the professional level the salaries tend to be less than topuotch'professionals can draw in other quarters.
This does not make the task of building a research organization impossible but means that rewards other than salary have to be important to the individual to accept a Federal job.
Such a limitation tends to make the Government professional staff younger, less experienced, and consist of persons who derive other than economic satisfaction from the job they have.
Dr. Newill further notes the difficulty in altering the mix of disciplines in a laboratory that should accompany a change in program emphasis, particularly when the laboratory is under a no growth or reduction mandate.
WM a no growth order and with no empty positions, there can be no shift in the discipline mix. If the order were to reduce staff, as happened on several occasions during my tenure, it usually came with other provisions, for example, no personnel can be fired and the reduction will be by attrition. Attrition is a very bad way to alter the size of an organization. One, it does not
allow the manager to get rid of his nonproductive personnel; two, the most reemployable and thus most desirable employees are the ones who recognize the situation and move out; and three, the manager has no control over the discipline mix within the organization because the all important position count mentioned earlier does not distinguish between professional and non-professional positions. I Finally, a Civil Service laboratory has difficulty hiring research
personnel because of rules rescribing the "average grade" of persODnel at the installation. Accorying to Dr. Newill:
Quality personnel can only be hired at the higher grade levels and thus a good research organization heavy with professional personnel always win be above the
ed average grade.
ng the latter yeaxs I was a laboratory manager, the in-house dollars were
spent about 75 percent for personnel and 25 percent for maintaining the ongoing reseanh effort. 'When the order for a 10-percent reduction in budget came, as it frequently did, we were in trouble.
The only place the in-house 10 percent could come from would be the research qport budget, thus the money to maintain the research effort was reduced from 25 reent to 15 percent, a 40 percent reduction. The level of operation funding % rnot keep a viable program underway and guarantees loss of qualified professioual. research employees.
Rather than destroy the in-house program and lose hard to come by staff, the total dollar reduction was usually taken out of the support for research grants and contracts. This meant a reduction in purchased research. Such a loss was also a bad one.


Hard to come by, and this is really true in the mid to late 1960s, grantees and contractors became disgruntled with our support, lost their knowledgeable supporting staff to do this work, and turned their interests to other areas.
Whether our decision to maintain this in-house effort rather than the extramural one was the best decision was not considered because we had to maintain our tenured employees.
I continue to be amazed that the Government laboratories retain as competent staffs as they do and that they are as productive as they are. Certainly the system under which they work is fax from optimum.

The, Subcommittee takes cognizance of a number of considerations, .0s9me unique to EPA, which have influenced and shaped the orgawation and management of the Office of Research and -Development.
(1) EPA was created from an affgregation of existing agencies with optablished research components. f ch of the several units of Govern1970 to form EPA had different orientations "pt brought together in
i44 ": stitutionJ biases, different methods of operation, different traditions and customs, and are understood to have been staffed with personnel of uneven sldfls and talents. As Dr. John Neuhold observed, "TJUe task of molding these into a cohesive and coherent R. & D. diiisiou forEPA was not a simple task." In fact, pullin together 42 geographically dispersed research institutions of widely differing 6haracter would have challenged the finest management talent.
(2) EPA's regulations frequently involve social and economic considerations that affect la ge_ segments of our population. In other words, environmental decision-making is often highly political and subject to intense political pressures. Since environmental standards abnost, always require balancing of economic considerations, usually in the form of *increased costs as against the public health and welfare, the reactions of the public and of interest groups are, and should be, asiessed and given appropriate- weight. Perhaps no other regulatory agency has such widespread and intimate imp ct on the individual lives of citizens, and on modem American society in general. Business and industry understandably resist any regulation of their activities which may require changes in est 6blisl ed methods of production aiad distribution. Such changes can be expensive and inconvenient. .1. With powerful economic interests arrayed against change, EPA has found it cannot rely upon presumptions or inferences of risk to the public health or welfare. The Agency must have scientific facts to support defensible standards, since the burden of proof rests with those
P change. They are required to produce persuasive evidenceSipeo conclusive evidence-that proposed new regulations axe
indeed needed in the terest of the blic health and welfare.
To the extent that scientific evidence can remove uncertainties, resistance to proposed environmental standards can be overcome. Such evidence is generated by EPA's Office of Research and Development. Thus, the purpose of EPA's research program a is to remove uncertainty. For this reason, the work of ORD is crucial to the adoption of rational public policy. The success of EPA depends upon the extent to which the Agency's standards and regulations are based upon sound scientific analyses.
: The more we learn about the social and economic consequences of environmental pollution, 'the greater is our realization pf the truly staggering costs to our society, both in terms of adverse effects upon

human health and uponi the ecology in general. Our knowledge 4~a understanding of these casts ax bae upo th reut o' - -* and the Subcommittee concludes that the nation's investment ai such research does not reflect its true potential economic value.
Given EPA's enormous statutory responsibilities for polltio control and a........a.... th c..x a... ... la a aR m
program has not been adequately funded. Resources. requested b Administration for support of EPA's research progranttoigthi hta fallen far short of funding levels authorized -by kg6"(%ki The Stubommittee believes that the annual bud get fdr mi af*M ORD's program should be substantially increased in_ thefte n, 9
(3) The original organization and managenieds I t Research and Development, as noted elsewhere in- this E~i-i-I
mhuch to be desired. The changes brought about by, Dr. WTN reorganizationt appear to be. responsive to the major critmelsg lf8f past, adseem well conceived to achieve .a more e: 6ighqt"' responiv, more effective research program. Msfer,: p 3i
ave beerfaccomplished in simplifying the lines of responsibility, eliminating undesirable layers ofM'et replacing the earlier paper-intensive planning anad el 8m system with a ibre streamlined orgaizational frarnmao
While somei dislocations and moae problems are inevitable%
major reorganization, and this one is no exception, the impaW.dts": ORD personnel appear to the Subcommittee to. have been' rM& to a reasonable minimum and reflect a thoughtful and esatiO approach on the part of Dr. Talley.
The Subcommrttee takes the position that Dr. Thilefsa redi M& tion should be allowed a chance to work. Thus, while theta Obshi finds Dr. Mae~oniald's recommendation for -establishmenqt:a-f &t aw Environmental Science Institute attractive, and ackn1owled40 Ei it may well be the best course for the future, serious ctsidefai0-V suich a proposal should be postponed. Ailother -major reorgania M6ti would be extremely disruptive to an Agency that. is still in the pr666AR of making a difficult adjustment to new circumstaticbs. Mariby Bsf a praetidal matter, the current economic and political climate does tot appear congenial to the establishment of a new researchch institot6H regardless of the merits of the proposal.
Finally, for the same reasons, suggestions to the effect thM iB6 research fuinetion might be separated from EPA's regard .A enforcement mission, follow the ERDA-NRO and NIOSH*)H pcedents, do not appear re istic or timely. While the Subeoment* acknwlegesthere may be certain advantages in the sepairation& of research frmregulation, a strong case can also be made fort hah9 0 research arm responsive to, and under the direct supervsiott i aB@ head of an agretcy charged with a specific mission. In short, there Maf be no "ideal" management model for research, and, varios.A M~e can be made to work efficiently and effectively. Dr. TalleyW.4 n&#* organization should be given a reasonable opportunity- to dd 104 strate its effectiveness.
(4) EPA carries out its mission under the legislative mandate of nine statutes. These acts of Congr ess, products of several diffs int Committees of both Houses, passed -at different times and a id4 different historical influences, form the major basis for, and constraints on, the research program.

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and EPA was expected to make heroic efforts to reverse the destructive trend, and to restore the environment. Under difficult circumstances marked bX strong resistance from powerful economic interests, EPA has made impressive strides in bringing about a steady improvement in the quality of the nation's environment.
The time may have arrived, however, when ORD's research and development of control technology, and particularly the larger demonstration projects, should be given somewhat less emphasis in the total program. In light of expanded efforts by industry and by the Energy Research and Development Administration, the Subcommi e, would prefer, during the next few years, to see a larger and increasing portion of ORD's resources devoted to research on pollution processes, their transport, their transformation, and their health and ecological effects.
While much remains to be done in control technology, much more needs to be done to understand the processes by which pollutants are produced and enter the various media, what happens to them, and how they affect human health and the ecology generally. A more comprehensive understanding of environmental conditions and trends is essential to support EPA's future decision-making process, and this research effort should be steadily increased.
(7) Interagency coordination of environmental research and development activities continues to be a matter of concern to the Subcommittee. The present system is considered inadequate to achieve an integrated and coherent national program from the various elements dispersed among the dozen or so mission-oriented Federal agencies engaged in environmental R. & D. Without intending to disparage the work of the various Committees of the Federal Council for Science and Technology which address the technical aspects of environmental R. & D. but have no management responsibilities, or the contributions of the Office of Management and Budget which is responsible for allocation of resources, the Subcommittee believes some other method or vehicle must be brought into play iia order to avoid undesirable duplication of effort as well as major gaps 'in the total research program. At the very least, a continuing inventory of on-going environmental research and development programs should be kept so that the details of research being conducted elsewhere within the Federal establishment would be readily available to all interested parties. In addition, an
mediate effort should be made at the highest level, preferably by the newly established Science Advisor to the President, or by the Council on Environmental Quality, to establish clearly defined agqncy roles and goals for achieving a well-coordinated total national environmental R. & D. program.
EPA was established to bring together much of the environmental work in the Federal government. According to Dr. Talley, Reorganization Plan No. 3 of 1970 envisioned EPA not as an agency which would perform all environmental research, but one which would insure that all necessary research would be done. Dr. Talley concludes that "close cooperation with other agencies is not only desirable, it is mandatory."
Furthermore, the several statutes under which ORD conducts its research program, noted elsewhere in this report, give EPA a special responsibility for coordinating environmental research throughout the Federal Government.

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thea& itgenges'is essential.- ORD is the logical center for such leaderK @he'Subcommittee commends Dr. Talley for a good faith effort
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