The USEPA Office of Inspector General (OIG) has issued a review questioning the procedures used in preparing the Technical Support Document (TSD) on which EPA’s Endangerment Finding for greenhouse gases (GHGs) was based. The review argues that the TSD was a “highly influential scientific assessment” but that EPA did not follow the Office of Management and Budget (OMB) requirements for such assessments. EPA argues that it was not a “highly influential scientific assessment” and that they therefore did not have to meet the OMB requirements; I could not disagree more.
My comments on the draft TSD strongly advocated an independent EPA review of the science rather then relying on the science presented in reports prepared by the UN Intergovernmental Panel on Climate Change. The OIG review does not deal with the validity of the science–only the procedures used in preparing the TSD. But among the OIG conclusions were the following that appear to be related to my recommendation:
“We found that EPA did not contemporaneously document how it applied and considered the assessment factors in determining whether the IPCC and other assessment reports were of sufficient quality, objectivity, utility, and integrity. EPA described the IPCC review procedures and how they met EPA data quality requirements in the proposed and final rulemakings. However, the Agency did not conduct any independent evaluations of IPCC’s compliance with IPCC procedures, nor did EPA document any specific processes it employed to evaluate the scientific and technical information included in IPCC’s AR4 prior to EPA disseminating that information.”
“Because EPA used information from other organizations to support its findings, EPA, in evaluating whether to disseminate that information, should have determined whether the assessments referenced in the TSD (e.g., IPCC’s AR4) complied with EPA’s information quality guidelines, and whether the peer reviews of these assessments met OMB’s requirements for peer review of scientific assessments. U.S. government acceptance of the documents did not relieve EPA of its responsibility to determine whether the data met EPA’s information quality guidelines before disseminating the information.”
For more information and a link to the OIG review see here.
During the period for public comment on the EPA’s proposed Endangerment finding, I submitted a comment by following the EPA’s own procedure. In this comment, I pointed out that the IPCC’s conjecture of anthropogenic global warming (AGW) lacked refutability by reference to instrument readings, thus lying outside science. Subsequently, the EPA published a response which (allegedly) addressed each one of the public comments it had received. In this response, the EPA failed to acknowledge receipt of or refute my contention that the AGW conjecture lacked refutability thus lying outside science. I responded to this inaccuracy with a letter to the EPA’s administrator, Lisa Jackson. In my letter to Jackson, I pointed out that the EPA’s response to public comments was materially inaccurate. Year later, I’ve not heard from Jackson.
[…] CARLIN ECONOMICS & SCIENCE EPA Inspector General Finds Procedures Used in Preparing GHG Endangerment Finding Did Not Follow OMB Requirements Alan Carlin| September 28, 2011 http://www.carlineconomics.com/archives/1363 […]
Congratulations, Dr. Carlin!
Based on past performance, response from the IPCC movers and shakers (e.g. Trenberth) was entirely predictable.
It would have been nice if the OIG had pointed out that – notwithstanding the inclusion of a lengthy recitation of IPCC’s “policies and procedures” – the 2010 IAC review of these policies and procedures (which did not include any examination of “the science”) concluded that the IPCC wasn’t following its own rules.
So in effect, the EPA – which didn’t follow its own rules -relied on the increasingly disputed “findings” of yet another group which didn’t follow its own rules!
And they expect the general public to “trust” them?!
Amazing.
It is heartening to see sanity coming back. Your efforts helped big time. Thank you.
So, nice guys don’t always finish last.
Congrats and here’s hoping this gives you at least some vindication and personal satisfaction.
Yes, at last!
Congratulations!