EPA: the Endangerment Finding was not a “highly influential scientific assessment”
by Steve McIntyre
The recent report of the EPA Office of Inspector General(OIG) contains a remarkable dispute between the OIG on the one hand and EPA and the Office of Management and Budget (OMB) on the other as to whether the Technical Support Document (TSD) for the Endangerment Finding was a “highly influential scientific assessment”, a defined category under OMB peer review policy. It would doubtless seem self-evident to most readers that, if any scientific assessment were to meet any criteria of being “highly influential”, the TSD for the Endangerment Finding would meet such criteria.
But readers should never under-estimate the capacity for institutional mendacity. The EPA and OMB have both vigorously argued that the TSD was NOT a “highly influential scientific assessment”. The OIG report includes a fascinating series of appendices in which EPA and OMB gradually articulate this seemingly improbable doctrine – a doctrine rejected by the OIG.
The dispute arises because the EPA peer review procedures did not meet U.S. standards for a “highly influential scientific assessment” – as clearly stated in the recent OIG report. Thus EPA and OMB have resorted to the improbable argument that the Endangerment Finding was not a “highly influential scientific assessment”.
I remind CA readers that the issue of whether EPA peer review procedures complied with federal policies for a “highly influential” scientific assessment (and with related EPA handbook policies) was first raised at CA shortly after the release of the Endangerment Finding – see tag and here. My submission to EPA directly addressed this topic and included a review of relevant authorities.