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Response Letter from EPA's Office of Environmental Information (OEI)
Ms. Dorothy Bowers, Chair
National Advisory Council for Environmental Policy
and Technology
111 Aberdeen Road
Matawan, NJ 07747
Dear Ms. Bowers:
On behalf of Administrator Leavitt, I thank the National Advisory Council for Environmental Policy and Technology (NACEPT) and the NACEPT Report on the Environment Working Group for the thoughtful and comprehensive recommendations provided to U.S. Environmental Protection Agency Administrator Leavitt on November 6, 2003. The NACEPT recommendations regarding the EPA Draft Report on the Environment 2003 (DROE), as well as our discussion on July 8, 2004, have been helpful in shaping the development of the next report. Administrator Leavitt is committed to continuing and refining our efforts to measure results and inform the public about trends in environmental conditions.
As you know, EPA recently concluded its year-long national dialogue about the DROE with a web cast to stakeholders and advisory group members to address the comments and guidance we received. Your recommendations shaped the overall thinking about the next steps in the Environmental Indicators Initiative and will influence the development of the next report, which is planned for release in spring 2006. As EPA builds upon its experience with the DROE, we plan to develop reports on the environment at regular intervals.
EPA's next report will include two publications and a Web site with interactive content to help us reach a broader audience base. The two publications include a technical document, intended for environmental professionals, and a shorter public report for the informed public. These two documents will share a common set of indicators and analytic results, but will have different levels of detail and explanation. To further foster public access to the indicators and the analysis relied upon in both documents, EPA will provide an electronic Report on the Environment (e-ROE) on EPA's Web site. The e-ROE will serve as a means for accessing both publications and will allow people to navigate across topics to find the underlying indicator data.
The enclosure to this letter contains responses to the comments you provided us in your letter. The enclosure is organized by the categories of recommendations the Committee provided:
- The indicators themselves;
- The public consultation process; and
- Next steps in the EPA Environmental Indicators Initiative.
EPA has made significant progress since releasing the DROE last June. We have received considerable feedback from many parties and this is informing our plans for developing and using indicators at EPA. Your recommendations and our responses were shared with the other EPA offices that are contributing to indicator projects. We will continue to work with them to institute the working group's recommendations.
We look forward to working with the NACEPT in future phases of the Environmental Indicators Initiative. If you have any questions or would like to discuss any of this further, please contact me at (202) 564-6665 or Mike Flynn, Director of OEI's Office of Information Analysis and Access at (202) 566-0600.
Sincerely,
Kimberly T. Nelson
Assistant Administrator and
Chief Information Officer
Enclosure
cc: Ms. Carolyn Green
Chair, Report on the Environment Working Group
Report on the Environment Working Group Members
Enclosure
Response to the NACEPT Report on the Environment Working
Group's Comments and Recommendations
1. THE INDICATORS
EPA agrees that a hierarchy of indicators is useful for understanding the relationships between different indicators. In the next report, EPA is planning to more systematically pose questions that reflect the levels of the hierarchy to frame each environmental issue in each chapter. In doing so, there will be a corresponding broader focus on indicators that reflect emissions, ambient conditions, exposures, or effects rather than outputs (e.g., number of permits issued). In addition, the ability to link indicators along the hierarchy will become more apparent.
EPA agrees that environmental conditions are often the result of multiple factors, both anthropogenic and natural. In the next technical document, various contributing factors will be addressed as "context" to the indicator presentations. However, it must be acknowledged that it is difficult to quantitatively parse out the relative contribution of EPA activities, societal trends, natural events, and other factors.
EPA agrees that, ideally, indicator trends should reflect consistent time periods. This is a great challenge for an EPA report on the environment because numerous statutory mandates often direct the frequency of reporting. This problem is further compounded by the heavy reliance on other federal agency information (greater than 50%) in the last report. EPA is aware of the issue and will strive to present information using comparable baselines where it is feasible.
Finally, EPA chose to focus the scope of this first report on U.S. environmental conditions, recognizing that the U.S. environment both influences and is influenced by environmental conditions in other countries. In the next report, EPA will take steps to address additional global environmental issues like trans-boundary air pollution, oceans, stratospheric ozone, and climate change.
RESPONSE TO CHAPTER RECOMMENDATIONS
EPA is appreciative of the breadth and depth of the NACEPT recommendations by chapter. Three themes emerged from your chapter recommendations as well as from other National Dialogue participants. These themes deserve discussion and may serve as the basis for future NACEPT activity.
The first theme is the degree to which EPA program activities and goals are addressed in the DROE. For this first report, EPA intentionally chose to minimize the use of output measures and not include discussions of policies, programs, and goals. This was done largely to focus the report on indicators of environmental conditions; however, there were also practical reasons, such as the publication of EPA Annual Performance
Reports that address these topics, and the DROE reliance on indicators from other federal data sources. The reliance on other federal data sources makes it difficult to adequately address all of EPA's policies and programs. EPA is working to build an environmental indicator reporting process that supports and informs Agency strategic planning.
Second, the Committee noted the need for greater transparency in how indicators were selected for inclusion in the public report. Based on feedback from the National Dialogue, EPA plans to develop a much shorter public report in 2006, which will necessitate sound, well-documented criteria for selecting indicators from the technical document.
Finally, related to the issue of transparency is the degree to which EPA interprets the indicator information in future reports. Some of the Committee recommendations point to the need to interpret the indicator data. For the DROE, EPA attempted to be as factual and objective as possible in reporting on conditions and trends. Over the last year, EPA received feedback that public audiences need summary assessments of "what it all means." In addition, the EPA Science Advisory Board recommended that the public report be an "interpretation of the technical report, not a distillation." EPA is considering ways to interpret the information while at the same time retain scientific accuracy.
The following is EPA's response to the chapter-by-chapter comments provided by the Committee. We provided responses to comments that EPA has incorporated or are under consideration.
CLEANER AIR CHAPTER
EPA is working to improve the use of the Air Quality Index (AQI) as an indicator in the Agency's next report. As the NACEPT correctly indicated, the description of the current indicator in the DROE needs to better explain the derivation of the number of days with AQI values greater than 100 and the calculations used to determine the percentage of these days as well as the significance of these reported figures. To eliminate the influence of changes in monitoring networks over time for all the indicators used to characterize air quality, EPA only uses data from monitoring sites that have sufficient operating history and data completeness to allow that assessment of trends. Similarly, as suggested by the NACEPT, EPA is improving the description of the indicator in Exhibit 1-2 (page 1-4) to better describe and explain the methodology employed. Despite the observed limitations, the AQI is a premier environmental indicator that is widely used and easily understood both in the U.S. and internationally. EPA continues to refine and improve the AQI consistent with its present solid scientific and technical basis, and ease of implementation.
EPA acknowledges the dearth of information about indoor air quality, and intends to provide a more robust presentation using available information. However, there
remain significant data gaps that need to be filled before EPA can provide a comprehensive picture. This is likely to be highlighted in our current effort to identify data gaps. Filling these gaps with statistically valid results would require significant resources due to the variability of indoor environments. EPA will evaluate various data gaps and provide information on current efforts to fill them. EPA received many comments on the issue of climate change. EPA plans to address climate change in the next report consistent with the Agency's Strategic Plan.
PURER WATER CHAPTER
EPA acknowledges that the public report did not contain thorough coverage of water consumption statistics or all of the National Coastal Condition Report indicators. In both cases a decision was made to present in the public report a subset of indicators presented in the technical document. Water consumption statistics were presented in the technical document, and EPA intends to include them in the next technical document. NACEPT's comments will be helpful to us as we develop the public report and the e-ROE.
EPA presented the summary analysis of the condition of U.S. coasts in the public report. Some, but not all, of the indicators were presented as examples of the kinds of indicators that went into creating the summary analysis. NACEPT's comments will be helpful to us as we consider how to present information from the next technical document in the next public report.
EPA is gathering new data about several indicators that potentially could be used in future reports (2006 and beyond). For example, we are currently working with states in conducting a National Wadeable Stream Survey to improve the quality, comparability and representativeness of the nation's water quality data. In addition, EPA is conducting a national, statistically-based study of contaminant levels in freshwater fish. This study covers the largest set of chemicals (268) studied in fish and is the largest effort under the persistent, bio-accumulative, toxic (PBT) pollutants program. Its objective is to estimate the national distribution of mean levels of selected PBT chemical residues in fish tissue from lakes and reservoirs in the contiguous U.S. Unfortunately, the data from this study will not be available in time for the 2006 publication.
The intent of the section on fish and shellfish consumption capacity was to highlight areas where consumption is cautioned or restricted because of the potential to impact human health and to describe the geographic spread of contaminants.
BETTER PROTECTED LAND CHAPTER
Your comments on including state data for the National Priorities List (NPL), waste, and contaminated lands are being considered. EPA is evaluating the use of state and regional data in preparation for the next report.
The National Priorities List (NPL) does not include the entire universe of potential sites for NPL and is therefore under-reported. EPA agrees and will evaluate how to strengthen this indicator.
ECOLOGICAL CONDITION CHAPTER
EPA agrees that "progress toward defining and monitoring ecological conditions will require significant coordination among agencies and will require, as well, development of many new approaches to systematic data collection to define effectively the ecological condition of the nation." Given the lack of high quality, long term ecological indicator data, it is imperative that any current data be utilized to the fullest extent possible. This requires much better coordination than has occurred in the past.
To address the concern regarding both data compilation and indicator development, the Council on Environmental Quality (CEQ) and the Sustainable Resources Roundtable (SRR) are in the process of developing an entity (perhaps within EPA as suggested by the NACEPT) for compiling quality data for selected indicators.
In response to the following NACEPT comment, "for an indicator or index to be useful for decision-makers, thresholds or criteria distinguishing acceptable from unacceptable conditions are needed," EPA's perspective is that indicator data should be reliable, scientifically sound, and defensible. However, the ultimate responsibility for deciding what is acceptable or unacceptable must lie with well-informed decision makers.
HUMAN HEALTH CHAPTER
EPA recognizes that the issue of using biomonitoring data as a surrogate for environmental exposure and health outcomes indicators needs a clearer explanation. Presenting the health risk paradigm (as shown in Exhibit 4-1 in the technical document) is one potential solution.
EPA is considering structuring the next report to better highlight the state of human and environmental health today. While it is recognized that human health is influenced by the interaction among exposures to environmental contaminants, genetics, and lifestyle factors, it is not always clear what contribution is from environmental chemicals. Until adequate scientific information is available to define and quantify how these factors contribute to disease, indicators of environmentally-related health effects remain difficult to develop. Increased efforts will be made to correlate the detection of certain chemical contaminants in blood and other human tissues with environmental exposures. For many environmental pollution-related health effects, susceptibility is a key consideration and should be discussed in the context of linkages. Where appropriate, susceptibility factors such as age, gender, and socio-economic status need to be acknowledged.
The NACEPT noted that the DROE did not mention the role of emerging technologies such as toxicogenomics or other monitoring technologies that might be useful as measures of health indicators. EPA agrees that emerging technologies such as toxicogenetics, new scientific knowledge, and new analytical capabilities may serve to improve existing indicators, and plans to update future indicators as they become available.
2. THE PUBLIC CONSULTATION PROCESS
EPA consulted with the public in several ways over the last year. Six day-long National Dialogue sessions were held at locations around the country. Each session was attended by approximately 30 to 50 participants. A summary of participant comments, including the NACEPT's, is available at: http://www.epa.gov/indicators/docs/National_Dialogue_Summary_Report.pdf. In addition to these comments, EPA received over 400 comments through EPA's E-DOCKET system, and received advisory recommendations from EPA's Science Advisory Board and the Local Government Advisory Committee.
EPA is engaging partners at many levels to develop the next set of reports, build the electronic Report on the Environment, and improve indicators by filling gaps through data partnerships and other collection strategies. EPA is participating in forums organized by the Council on Environmental Quality to develop environmental indicators across the federal government. EPA setup an Environmental Indicators Workgroup so states and tribes can contribute to the development of the next report, and EPA is evaluating how to engage local governments.
Finally, EPA is clarifying the customer for the public report, including how they would use environmental indicator information. During the National Dialogue, many parties commented that the customer and uses for the DROE were unclear. We hope the EPA indicator web site, www.epa.gov/indicators, will be used by various stakeholders and the interested public to follow the development of the next report.
3. NEXT STEPS IN THE EPA ENVIRONMENTAL INDICATORS INITIATIVE
A common feedback theme heard during the National Dialogue was that decision-makers need information at a resolution that is relevant to them and that national indicators (and averages) mask "hot spots" across the country. EPA will include regional indicators in the next report as a step toward the long-term goal of providing indicator information at the national, regional, state, and local levels. These regional indicators have been proposed by EPA's regional offices in consultation with the states.
EPA is working to better align indicator reporting to inform strategic planning. The next technical document will focus on indicators of emissions, ambient conditions, exposure, and health and ecological condition and will be written for the environmental professional. As previously mentioned, further thinking is needed on the best set, analysis, and presentation of indicator information to inform strategic planning. Similarly, EPA is identifying data gaps in the DROE and is developing criteria for prioritizing which gaps to fill first.
As mentioned, EPA is developing an electronic Report on the Environment (e-ROE) that will be accessible from the Internet and allow people to view indicator information at different levels of detail. The first phase of the e-ROE is to place the indicators on the Internet in a format that allows for easy presentation and navigation. The second phase will allow people to access the underlying indicator data.