1. The report is a historical look back to science at EPA anywhere from 5 to 20 years ago. (One case study deals with "regulatory reform" decisions made by early Reagan appointees in 1980 and 1981.) As such, it does not present, or reflect, the current state of science at EPA.



2. It is based on interviews with current and former EPA staff and political appointees (including several former EPA Administrators), and a number of people outside of EPA, and thus, reflects the differing recollections and subjective views that they have of events that occurred many years ago.



3. This Administration has taken a large number of steps to improve science, and the use of science at EPA, including:



4. Peer review policy, guidelines and handbook
5. Risk characterization guidance
6. Restructuring of ORD to enhance its ability to provide cross-disciplinary answers to environmental questions.
7. Development of a new strategic planning process and research planning process that explicitly provides for meeting the regulatory needs of the Agency.
8. Enhancing the ORD extramural program through the creation of the STAR program, thereby bringing thousands of scientists in academic institutions to focus on the science and research needs of EPA.

We are mystified why these many successful efforts were not highlighted in the report.

1. This study was partially funded by EPA as part of a continuing effort to identify and solve problems in the way in which science is planned, done and used at EPA.



2. We will continue to evaluate the issues and recommendations raised in the report, and will continue to build on the many steps we have already taken to ensure that science at EPA is always of the highest quality.

1. This report has basically three parts:



2. A summary section of evaluation, analysis and recommendations,
3. A brief overview of science in the different program offices and the major mandates that they implement,
4. A series of eight case studies in which Agency decisions were made from 4 to 20 years ago.



5. It is based on interviews with current and former EPA staff and political appointees (including several former EPA Administrators), and a number of people outside of EPA, and thus, reflects the differing recollections and subjective views that they have of events that occurred many years ago.



6. Each section has both positive and negative statements about science and people at EPA, including specific comments about people who have left the agency and some who are still here. The author's most critical words seem to relate to the Office of Drinking Water; OAR and OPPTS generally receive good marks, and remarks about OSWER are somewhat negative, though ambivalent.



7. In general, the issues that are raised in the report are largely of historical interest, in that this Administration has taken a large number of steps to improve science at EPA, -- steps which have, by and large, solved the problems raised.



8. The case studies in the report are:
9. The 1991 Lead/copper Drinking Water Rule
10. The 1995 Decision Not to Revise the Arsenic in Drinking Water Rule
11. The 1987 Revision of the NAAQS for Particulate Matter
12. The 1993 Decision Not to Revise the NAAQS for Ozone
13. The 1983-1984 Suspensions of Ethylene Dibromide under FIFRA
14. The 1989 Asbestos Ban and Phaseout Rule under TOSCA
15. Control of Dioxins and Other Organochlorines from the Pulp and Paper Industry under the CWA
16. Lead in Soil at Superfund Mining Sites

In each study an attempt is made by the author to reconstruct the science issues and to characterize the internal process that went on in reaching conclusions and making decisions. The author also discusses the role of external scientists and science advisors.