July 26, 2010

Ms. Vivian Daub
Director, Planning Staff
Office of Planning, Analysis, and Accountability
Office of the Chief Financial Officer
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, SW
Washington, DC 20460

Re: Draft FY 2011-2015 EPA Strategic Plan

Dear Ms. Daub,

Thank you for the opportunity to comment on the Draft FY 2011-2015 Environmental Protection Agency (EPA) Strategic Plan.

The American Institute of Biological Sciences (AIBS) is a nonprofit scientific association dedicated to advancing biological research and education for the welfare of society. Founded in 1947 as a part of the National Academy of Sciences, AIBS became an independent, member-governed organization in the 1950s. AIBS is sustained by a robust membership of individual biologists and nearly 200 professional societies and scientific organizations with a combined individual membership exceeding 250,000.

The draft strategic plan addresses many important issues facing the nation: climate change, water quality, pollution, and environmental stewardship. Meeting these challenges requires science. Research and monitoring conducted by EPA directly impacts the lives of every American every day. Whether monitoring drinking water quality, assessing impacts from climate change, or informing restoration of degraded environments, EPA science can and should play an important role in protecting and promoting public health and safety.

As outlined in the proposed plan, "advancing science, research, and technological innovation" is a second tier priority, included as a cross-cutting fundamental strategy. Although science is essential for achieving each of the five goals outlined in the plan, the need for science within EPA goes beyond these areas. In the new strategic plan, science should be a top tier, EPA-wide strategic goal: "Informing sound policy through research and monitoring."

When President Richard Nixon created the Environmental Protection Agency in 1970, he envisioned an independent agency that created and enforced environmental protection standards, and conducted research. In his message to Congress establishing the agency, President Nixon outlined the "principal roles and functions of the EPA." These were the establishment and enforcement of environmental protection standards, technical assistance to others to limit pollution, formulation of environmental policies for the nation, and the "conduct of research on the adverse effects of pollution and on methods and equipment for controlling it, the gathering of information on pollution, and the use of this information in strengthening environmental protection programs and recommending policy changes." As currently drafted, the strategic plan fails to completely reflect the roles laid out by President Nixon. The elevation of science to a strategic goal would help remedy this issue.

The EPA's Science Advisory Board (SAB) has also recommended the elevation of science within the agency. In letters dated May 2009 and November 2008, the SAB communicated the need for a broader science mission at EPA: "[I]t is clear that if the Agency is to truly protect the environment, it must undertake a larger program of research that goes beyond its immediate regulatory needs and address the broad array of environmental problems facing the nation." Some of the elements that the SAB called for in its Strategic Research Directions 2008 have already been incorporated into the draft strategic plan, including the promotion of interdisciplinary research and improved communication with stakeholders. Other elements are missing, such as the EPA's role in land-use decision making or the consideration of "emerging environmental disasters." Elevating science to an agency-wide strategic goal would help EPA to respond to the SAB's recommendations.

Within the new science strategic goal, several key areas should be addressed. Foremost is the need for scientific integrity and transparency; the plan does not currently address these issues as related to science. Additionally, environmental monitoring should be incorporated into the plan. Monitoring of ecosystems provides data that are necessary to inform environmental management decisions. Moreover, scientific monitoring of environmental conditions is the only way for the agency to know when it has met many of the performance metrics outlined in the areas of air, climate, water, and land.

The strategic plan should also address the curation of, and access to, scientific collections held by the agency. The directors of the Office of Management and Budget and the Office of Science and Technology Policy instructed agencies to do so in the annual Memorandum for the Heads of Executive Departments and Agencies (M-10-30) released on July 21, 2010: "Agencies should implement strategies for increasing the benefits for science and society derived from scientific collections by following the recommendations in the report by the Interagency Working Group on Scientific Collections and efforts outlined in the National R&D Strategy for Microbial Forensics."

Scientific collections, including tissue and cell cultures, biological specimens, and soil and water samples, offer a treasure trove of information about Earth systems and aid in regulation and management of the nation's natural resources. These collections, which are irreplaceable data, contribute to cutting edge research on environmental contamination, biodiversity, and climate change. For instance, two recent publications on the extent of pollution in National Parks utilized natural history collections to establish baselines of environmental contamination. Furthermore, an extensive collection of shells housed at Philadelphia's Academy of Natural Sciences is being used by scientists to better understand historical levels of environmental contamination in the Gulf of Mexico, information that is vital for restoration efforts in light of the BP oil spill.

Lastly, we commend EPA for increasing its emphasis on addressing climate change, both through mitigation strategies as well as adaptation to unavoidable climate impacts. Importantly, the plan also includes more attention to climate science, an essential part of informing climate policy decisions.

Thank you for your thoughtful consideration of these comments. If AIBS may be of further assistance on this or any other matter, please contact Dr. Robert Gropp, AIBS Director of Public Policy at 202-628-1500.

Richard T. O'Grady, Ph.D.
Executive Director

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