Compare & Contrast

President Obama, Inaugural Address, January 20, 2009:

We'll restore science to its rightful place.

President Obama, Memorandum for the Heads of Executive Departments and Agencies, April 9, 2009:

The public must be able to trust the science and scientific process informing public policy decisions. Political officials should not suppress or alter scientific or technological findings and conclusions. If scientific and technological information is developed and used by the Federal Government, it should ordinarily be made available to the public. To the extent permitted by law, there should be transparency in the preparation, identification, and use of scientific and technological information in policymaking.

EPA Administrator Lisa Jackson, Memorandum to EPA Employees, April 23, 2009:

The success of our environmental efforts depends on earning and maintaining the trust of the public we serve. The American people will not trust us to protect their health or their environment if they do not trust us to be transparent and inclusive in our decision-making. To earn this trust, we must conduct business with the public openly and fairly. . .

I believe this will enhance the credibility of the Agency, boost public trust in our actions and improve the quality of our decisions.

John Holdren, Assistant to the President for Science and Technology and Director of the Office of Science and Technology Policy, Memorandum on Scientific Integrity, December 17, 2010:

[I]t is important that policymakers involve science and technology experts where appropriate and that the scientific and technological information and processes relied upon in policymaking be of the highest integrity. Successful application of science in public policy depends on the integrity of the scientific process both to ensure the validity of the information itself and to engender public trust in Government [including] ensuring that data and research used to support policy decisions undergo independent peer review by qualified experts.

EPA, Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act, December 15, 2009:

The Administrator finds that six greenhouse gases taken in combination endanger both the public health and the public welfare of current and future generations. . .

EPA’s approach to evaluating the evidence before it was entirely reasonable, and did not require a formal hearing. EPA relied primarily on robust synthesis reports that have undergone peer review and comment. The Agency also carefully considered the comments received on the Proposed Findings and TSD [Technical Support Document], including review of attached studies and documents. The public has had ample opportunity to provide its views on the science, and the record supporting these final findings indicates that EPA carefully considered and responded to significant public comments.

EPA, Office of the Inspector General, Procedural Review of EPA’s Greenhouse Gases Endangerment Finding Data Quality Processes, September 26, 2011:

EPA’s peer review did not meet all OMB requirements for such documents. EPA had the TSD reviewed by a panel of 12 federal climate change scientists. However, the panel’s findings and EPA’s disposition of the findings were not made available to the public as would be required for reviews of highly influential scientific assessments. Also, this panel did not fully meet the independence requirements for reviews of highly influential scientific assessments because one of the panelists was an EPA employee. Further, in developing its endangerment finding, we found that OAR did not: Include language in its proposed action, final action, or internal memoranda that identified whether the Agency used influential scientific information or highly influential scientific assessments to support the action. OAR also did not certify that the supporting technical information was peer reviewed in accordance with EPA’s peer review policy. (at 13)

Additionally, EPA’s Peer Review Handbook directs the Agency to include a statement in its action memorandum that the Agency followed its peer review policy with respect to the influential scientific information or highly influential scientific assessments supporting the action. (at 19)

In our opinion, the endangerment finding TSD is a highly influential scientific assessment that should have been peer reviewed as outlined in Section III of OMB’s Final Information Quality Bulletin for Peer Review. OAR never formally designated the document as either influential scientific information or as a highly influential scientific assessment in the preamble to the proposed and final endangerment findings or in its internal documentation. EPA did not consider the TSD to be a highly influential scientific assessment. Additionally, OAR did not adhere to some of its internal processes established to guide Tier 1 actions. We noted that OAR had completed many of the processes and steps outlined in its guidance to ensure the quality of the information the Administrator used in making her determination. Those processes are intended to help ensure EPA develops quality actions and to provide assurance on data quality. We concluded that the Agency did not complete some of these key requirements and recommended actions. We did not analyze the quality of the scientific information and data used to support the Administrator’s decision. (at 22)

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. (at 27)

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. (at 28)

Conclusion: As the Wall Street Journal editorializes:

Here's one good way to consider the vote in 2012: It's about whether to re-elect President Lisa Jackson, the head of the Environmental Protection Agency, which these days runs most the U.S. economy.

That is to say, she's trying to kill most of the economy.