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News & Comment r Counting On Science at EPA William Reilly is trying to give science a bigger role in EPA policy and wants to focus on the worst environmental problems, not just the most visible. It may be an uphill struggle W ILLIAM REILLY, THE ADMINISTRATOR Of the Environmental Protection Agency, and his top advisers are plotting a quiet revolu- tion. They have embarked on a process that could fundamentalh• change the way EPA does business: an attempt to focus the agen- ca's resources on the environmental prob- kms that pose the biggest risks rather than those that have attracted the most political attention. "It's an effort to inject science more prominenth• into the policy process," savs Hank Habicht, deputy administrator of the agency and Reilly's right-hand man. That may not sound revolutionary, but Reilly is trying to reverse ncarhy 20 years of piecemeal environmental policy-making. Congress, reflecting public concerns, has written numerous laws instructing EPA to deal with individual environmental prob- lems-hazardous waste one year. toxic sub- sta.•ues or pesticides another, and medical Eoolopicas Risks Global climate chanpe Stratospheric ozone depletion Habitat alteration Species extinction and biodiversrty loss Health Risks Cdteria air pollutants (e.g. smog) Toxic air pollutants (e.g. benzene) Radon Indoor air pollution Drinkinp wam contamination Occupational ettposure to chemicals AppGcation of pesticides Stratospheric ozone depletion ScientisLSand the public dnw diladeru oonchdJdns aDout the seriousrKSS ot wrious envirpnrmrbl Qrpp(G7ts. Abm : the wDrst envirorurrntal prop/ems, as ideruilied oy EPA's Scientilic AdwSpry Bpard RiplK fAe puDGC's tOP cOrNxlns. as relkcted in a MarcA . 1990 Roper Poll (F,pures in parenf,heses are . JDe AerceAlaW tlal rateO W prOD/em 'Nery serious:' AipAlipl)fey ilerrtS also appear on fPAS li.~l) 616 wastes still another. The result: EPA's bud- get and priorities have been shaped more by "what the last phone call from Capitol Hill or the last public opinion poll had to sae than by a scientific assessment of risk, says Frederick Allen of EPA's office of policy anah•sis. Now, Reilh• has asked his Scientific Ad.•i- sory Board to tell him which problems pose the biggest crt7ronmental or public health threats. The board's analysis, a draft of which has been obtained by Scirna. reveals that the environmental problems that domi- natc public conccros-and EPA's budget- are often not those that Reilly's scientific advisers dcem the biggest threats (see table below). Radon and dimate change, for ex- ample. are at the top of the Gst for EPA but near the bottom in the public's view. But turning the agency around would be no mean feat, and even within EPA, opinion 1. 2. 3. 4. 5. 6. 7. e. 9. 10. 11. 12. 13. 14. 1s. 16. 17. 16. Active hazardous waste sites (67%) Abandoned tnardous tvaste sites (65%) Water pollution from tndustrial wastes (63%) Occupational exposure to toxic chemicals (63%) Oi spills (60%) Destruction of the ozone layer (60%) Nuclear power plant acddents (60%) Industrial accidents releasing pollutants (58%) Radiatlon from radioactlve wastes (58%) Air pollution from factories (56%) leakinp underground storage taMcs (55%) Coastal water ctintamination (54%) Solid waste ind litter (53%) Pesticide risks to farm workers (52'r.) _ Water pollution from agricultural runoH (51 %) Water podutbn from sewage plants (50%) Air pollution from vehicles (50%) Pesticide re"a In foods (49%) 19. 6reenhouse effect (48%)_ __ _- 20. Drinking water contamination (46%) ~ 21. 22. 23. 24. 25. 26. 27. 26. 29. Destruction of wetlands (42%) Acid rain (40%) Water pollution from city runoff (35%) Nonhanrdous waste sites (31%) Biotechnology (30%) Indoor air pollution (22%) Radiation from x-rays (21%) Radon in homes f tN) Radiation lrom microwave ovens (13%) t is divided on whether Reilly can pull it off. Without question, he starts with several strikes against him. For one thing, the EPA administrator has very little discretion in alloating funds: most of the agency's bud- get is needed just to implement the major environmental laws, like Supetfund, already on the books. And for another, Reilly faces inertia from within EPA, a bureaucracy that has a vested interest in maintaining the status quo. And then there is the public, which EPA is beholden to, whether or not it agrees with the latest scientific study. Rcil- h's new effort is "laudable," says Richard Morgenstcrn, director of the office of policy analvsis and an old hand at EPA. "I am bullish on it. But I wouldn't bet the store on it " But Tcrn• Davies. assistant administrator for polic~•, planning and evaluation and one of the architects of the new plan, voices no doubts. "We're already doing it," he ex- daims. "We are changing the way the agen- cv thinks." But not even the optimists expect major shifts overnight. Deputy administra- tor Habicht, for instance, talks about "a rapid evolutionary changc, not a rc.•olution- arv one," but he is convinced that it w•ill be a different agena•-if thn• can pull it off. The new effort actually had its origins before Reilh• came to EPA, in a much discussed 1987 report, Urtlinished Business. In that tome, EPA staff tricd, for the first time, to take a broad look at all the en.•iron- mental problems the agency deals with and figure out which pose the greatest risk to human health and the environment. Risk ranking, per se. was nothing ne..•-people often ranked one air pollutant against anoth- er, for example. And EPA had even attempt- ed to rank the cancer risks within small geographic areas, like Philadelphia and Sili- con Valley. But this was different: it was an attempt to look at toxic air pollutants versus pesticides versus global warming. The task proved to be a methodological nightmare, given the paltry data, uncertain techniques, and value-laden questions such as how to rank loss of wetlands against, say, ••isibility degradation. But Morgenstern, who directed the study, and 75 senior staff plunged in nonetheless, using whatever data thev could mustcr and falling back on pro- SCIENCE, VOL. 249 I

k kssional judgment when they couldn't. They ended up with a list of 31 problems, essentially in rank order. To their credit, they never pretended scientific rigor; thev never claimed, for instance, that problem number 2 was definitely worse than prob- km 3, but said that it was certainlv worse than 13, and 13 in tum was worse than 26. Their list showed that the old assump- tions were wrong. Many of the things that the public was most conccmed about-and that EPA was devoting vast resources to- like hazardous waste and underground stor- age ranks, posed relatively small risks, while the biggest problems, like radon and climate chan¢e, were being virtually ignored. In 1987 the agency was spending several bil- lion dollars for waste cleanup, for example, as opposed to several million for indoor air pollution and climate change. "(,'nfinished Biuuness revolutionized how people thought," says Jonathan Lash, a for- mer environmental activist with the Natural Resources Defense Council who is now the secrecarv of natural resources in Vermont. But while Oipnis/ied Business may have changed thinking, it didn't change practice much at EPA, mosth• becausc "vou don't rum a tanker on a dime," says .Vlorgenstern. Its impact was also limited by the fact rhat Ranking the Risks Proves Contentious If the deliberations of EPA's Scientific Adv isorv Board commit- tee are anv indication, then ranking environmental risks, as William Reilly is proposing to do, will not be easy. Indeed, the committee members almost came to academic blows over just how far they were willing to go on admittedly squishy data. The scientists fell out basically along subcommittee lines, with the ecological group taking a bolder or more foolhardy stance, depending on your perspective. But this says as much, if not more, about the person- alities of the two subcommittee chair- men as it does about the nature of the problems thev were wrestling with. William Cooper, an ecologist at Michigan State who headed the sub- committee looking into ecological ef- fects, do.e right in. His group dis- carded the methodology of the earlier report, Unfsnis/red Busiruss, as unscien- tific and divided up the universe in a new way, and then promptly ranked 'l many in the agency saw the studv as an "unscienti6c" first cut-not the kind of hard analysis on which to force a change in environmental policy. But the study did influence Reilh•. Soon after he was appointed but before he was confirmed as EPA administrator, Reilly was sitting around the World Wildlife Fund/ Conservation Foundation hcadquarten with his colleagues, including Terry Davies and Dan Beardsley, a deputv assistant ad- ministrator for policy at EPA who was then on loan to the conservation group, talking about what he should do at EPA, and how. All were frustrated with the "chemical of the would go about ranking risks in a scientifically defensible way, if one had the time and monev to do so. And central to that, they say, is separating out individual agents, like lead, instead of lumping it in with other "criteria air pollutants." Their cautious stance was immensely frustrating to some committee members, like Jonathan Lash, secretary of natural resources in Vermont, and Fred Han- sen of Oregon's Depattnent of Envi- ronmental Quality, who pointed out that EPA and state agencies do not have the luxury of waiting for the definidve studv but have to make decisions now. But Upton sticks to his guns. "In many cases, we simply don't have the data, either on human ecposure to various agents or their toricitv." Upton recently chaired the National Academy of Sciences report, known as BIER V, which wrestled over the effects of ionizing radiation. "When you rum to chemicals, the Bold and cautious. William Cooper (righr) was willing to rank problrnu. but Arrhur (.'pron wasn't. the problems. His group came up with a complex set of matrices for evaluating risk, but the bottom line, savs Cooper, is that problems are worse if they atFeet a broad area and have a long "time horizon =in Cooper's words, a measure of how long it takes, once vou shut off the stress, fbr the ecosystem to recover. According to their new scheme, global dimate change and stratospheric ozone depletion came out way on top, as they did in Urifinished Business, and so did two other problems the earlier commiaee did not even consider: habitat alteration and destruc- tion, such as deforestation, and species extinction and loss of biodiversity. Second rank, or relatively high ecological risks, werc airborne ooxics, toxics in surface water, and pesticides and herbicides. While Cooper's group bulldozed through the uncetiainties, a subcommittce on health effecis, headed b,v Arthur Upton of the Institute for Envirommennt Medicine at New York Universitv Medical Center, got bogged down early on in the problems of missing data and inconsistent assumptions. The upshot was they declined to rank anything. "It was not scientificallv feasibic. It was more than a committee of scientists could do on a part-time basis over a few montFu," says Upton, especially since they were given the unenviable task of somehow combining cancer and noncancer risks. Instead, they laid out in great detail how one 10 AUGUST 1990 information is even more incomplete," says Upton. "Unless one gets more data, these assessments will remain highly uncertain. Sure, one can rank risks, but the confidence one has in the rankings will not be great." And though Upton thinks compara- tive risk assessment is a good tool for setting priorities, he cautions that "you can carry it to absurd extremes." The committee reached a compromise of sorts, with Upton's group identifying seven problems that would rank high by almost any reckoning: criteria air pollutants (for example, smog), toxic air pollutants (for example, benxene), radon, odter indoor air pollutants, drinking water, worker =posure to chemicals, and worker application of pesticides. And though the data were "less robust," they threw in stratospheric ozone depletion as well, because it looms so large compared with other problems. For all of these high-risk problems, the common denominator was direct exposure, says Upoon, not something passed up through the food chain. Upton cautions that this is not the final word; other prob- lems-such as pesticide residues in food or exposure to consumer products, which were described as high risk in the earlier report-might also rank high if more data were available. But until they are, Upton's committee has "no problem" with Reilly giving extra attention to tlx seven they have identified.  L.R- NEWS 8c COM.NENT 617

month" phenomenon and the sense that EPA was not spending its money as wisely as it could, recalls Davies. They wanted to find a way to focus the agencys resources Where they would get the biggest payoff- which means, as Davies savs, factoring in not only how risky a problem is but how feasible and costly the various "fixes" are. They decided upon a two-part strategy: take another look at Unftnislud Business and the whole issue of comparative risk; and at the samc time, get the senior managers at EPA to start thinhing about what actions would have the biggest payoff in terms of reducing the most significant problems. Reilly wasted littk time. Soon after he arrived at EPA he asked the agency's Scien- tific Advisory Board (SAB) to essentially pea review Unfinished Bwsiness-to go over the data again, see whether they agreed with the methodology and rankings, and, if not, to come up with their own. The board set up a committee of 45 ezpcrts, mainly scien- tists but a few people from state government as well, like Vermont's Jonathan Lash and Fred Hansen, director of Oregon's Depart- ment of Environmental Quality, to keep the effort focused on political reality. Lash and Raymond Loehr, an environmental engi- tteer at the University of Texu, Austin, cochair the committee. That catunittee, in turn, divided itself into three subcommittees: one headed by William Cooper, an ecologist at Michigan State University, to look at ecological, eco- nomic, and aesthetic effecss; another, head- ed by Arthur Upton, director of the Insci- tute for Environmental Medicine at New York University Medical Center, to look at health risks; and a third, chaired by Alvin Alm, director and senior vice president of Science Applications International and a for- mer deputy administrator of EPA under William Ruckelshaus, to look at strategies for reducing the major risks. The SAB committee spent more than a year sifting through studies, all the while bcawaning the scanty data and uncertain analytical techniques, which make acctuately characterirutg a risk, much less ranking it against another, a tenuous business at best. Though they applauded Unfinished Business for its pioneering work, the committee had lots of problems with it, from the fact that the EPA staff had divided up the universe into problem areas that essentially reflect the agency's eusttng programs-which "makes no damn scientific sense," says Cooper-to some of its aottclusions, which they call "provisional." But for all their complaints, the SAB eommittee concluded that Unfinished BNsi- ness was not that far off in its conclusions. Most of the "baddics" identified in the 618 repon-like climate change, stratospheric ozionc dcpletion, air pollution, and radon- still looked bad. The earlier group had, however, overlooked a couple of big ones, habitat destruction and species extinction, which the S.AB committee added. And once again, the things the public cares the most about, like hazardous waste, ended up in the middle or at the bottom of the heap. Not evcrvone in the group, however, was willing to follow their predecessors out ontb a scientific limb and actually rank the prob- lems. Cooper's ecological effecis group was perfecth• willing to rank tliem, but Upton's health effects group wasn't, which led to some tussles on the committee (box, p. Focusing on risk. If William Reilly has his way. EPA will sprnd its money differently. 617). In the end, they agreed to simply list the 11 problems that everyone agreed were high risk-with the caveat that this is not an inclusive list. Some of these problems, like the loss of biodiversirv, do not fit handily into EPA's statutory mandate, but the committee urged EPA to exert leadership anyway. The com- mittee also urged EPA to give greater weight to ecological risks, which they uy have been given short shrift while EPA has concentnted on combating pollutants that pose a threat to public health. And perhaps most important, in terms of the agency's overall direction, the SAB committee gave its scientific seal of approval to comparative risk assessment, flawed as it is, as the best way to set priorities. They recommended that EPA set up a permanent process for comparing risks and then make its policy and budgctart• dccisions, as much as possi- ble. on the basis of those risks. And, they said. EPA should move beyond the com•en- tional "cnd-of-the-pipe" approaches and use alternatives, such as pollution prevention - and market incentives. The committee's final report will go to Reilly in late September. At this stage, it is not at all dear how the public and the environmental community will receive it because in the Reagan era, at least, "setting priorities was a euphemism for cutting," says Jonathan Lash. "I don't see that hap- pening hcre," he adds. But Reilly and his aides have already embraced the report; in fact, they arc using it in shaping the agenWs 1992 budget. Their problem, of course, is that 80% of the budget is essentially cast in stone, estimates Dan Beardslry of the policy office. EPA must spend thae dollars implementing the laws, paying salaries and rent, and so on. The administrator technically has discretion over perhaps 15% of the budget, but in reality, that too is sacrosanct. "You would be out of your political mind to exercise it," says Bcardslcy, since Congress has dearly indicated, if not insisted on, how that mon- ey ought to be spent. That leaves only 5% of the budget that is tn,tly 8exible. While working to wrest more discretion and more 9aribility from Con- gress, Reilly's aides are concentrating on .that 5%. Last November, Reilly and Ha- bicht asked the heads of the various pro- grams to submit 4-year plans, describing where they want to go and how they are going to get there. The guiding principle, they were told, should be risk reduction- and not, say, how to meet the latest court- ordered deadline. In identifying the big risks, the program heads were to take direc- tion first from Unfinished Business, and then, when it became available, the SAB report. By all accounts, the first round "engen- dcred grave suspicions," as Don Barnes, director of the SAB, puts it. "Any time a program is challenged, people wonder if the real goal is to take money away," he says. The plan did cause some resentment, con- cedes Habicht. But after some initial grnm- bling most, if not all, have come around. jV But if this new thinking is really going to Q make a diffcrrnce-if Reilly is reallFv to get N the greater flexibility and discretion he (~,J wants-then he and his aides will have to ~ change the culture not only at EPA but in ~ ~ Congress and the Office of Management and Budget. Proponents of the effor, point ~ to some encouraging signs from Congress, ~ such as rising budgets for global climate ~ change and radon, while funding for hazard- ous waste has remained relatively steady. t ' "It is a big agenda, but you have to start somewhere," savs Habicht. "We are planting sceds, most of which won't bear fnut until after we have left." • LESisB RoBEItrs SCIENCE, VOL 249