OIG Report – Procedural Review of EPA’s Greenhouse Gases Endangerment Finding Data Quality Processes
Statement of Inspector General Arthur A. Elkins, Jr., on the Office of Inspector General (OIG) report Procedural Review of EPA’s Greenhouse Gases Endangerment Finding Data Quality Processes:
“The OIG evaluated EPA’s compliance with established policy and procedures in the development of the endangerment finding, including processes for ensuring information quality. We concluded that the technical support document that accompanied EPA’s endangerment finding is a highly influential scientific assessment and thus required a more rigorous EPA peer review than occurred. EPA did not certify whether it complied with OMB’s or its own peer review policies in either the proposed or final endangerment findings as required. While it may be debatable what impact, if any, this had on EPA’s finding, it is clear that EPA did not follow all required steps for a highly influential scientific assessment. We also noted that documentation of events and analyses could be improved.
We made no determination regarding the impact that EPA’s information quality control systems may have had on the scientific information used to support the finding. We did not test the validity of the scientific or technical information used to support the endangerment finding, nor did we evaluate the merit of EPA’s conclusions or analyses.
We make recommendations that we think will strengthen EPA’s control over data quality processes. EPA disagreed with our conclusions and did not agree to take any corrective actions in response to this report. All the report’s recommendations are unresolved.”
To view the complete OIG Report: http://www.epa.gov/oig/reports/2011/20110926-11-P-0702.pdf
EPA’s Response to Inspector General’s Report on Endangerment Finding
The Office of Inspector General (OIG) released a report on EPA’s process as it relates to the greenhouse gas endangerment finding. The following is EPA’s statement in response to the OIG report to correct any mischaracterizations and some excerpts from that report:
We appreciate the important role played by the Inspector General’s Office and will give the recommendations in this report the utmost consideration.
Most importantly, the report does not question or even address the science used or the conclusions reached – by EPA under this and the previous administration – that greenhouse gas pollution poses a threat to the health and welfare of the American people. Instead, the report is focused on questions of process and procedure. While EPA will consider the specific recommendations, we disagree strongly with the Inspector General’s findings and followed all the appropriate guidance in preparing this finding.
EPA undertook a thorough and deliberate process in the development of this finding, including a careful review of the wide range of peer-reviewed science. Since EPA finalized the endangerment finding in December of 2009, the vast body of peer reviewed science that EPA relied on to make its determination has undergone further examination by a wide range of independent scientific bodies. All of those reviews have upheld the validity of the science.
EXCERPTS FROM OIG REPORT:
EPA met statutory requirements for rulemakings.
We did not test the validity of the scientific or technical information used by EPA to support its endangerment finding.
We did not make conclusions regarding the impact that EPA’s information quality control systems may have had on the scientific information used to support the endangerment finding.
EPA fulfilled the statutory requirements for notice and comment rulemakings mandated in the Administrative Procedure Act and in Section 307 of the CAA, and employed several of its processes designed to ensure data quality.
OMB in response to our draft report stated that OMB believes that EPA reasonably interpreted the OMB bulletin in concluding that the TSD did not meet the bulletin’s definition of a highly influential scientific assessment.