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151. U.S. Environmental Protection Agency	11-P-0702
Office of Inspector General	September 26, 2011
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At a Glance
Why We Did This Review
The Ranking Member, Senate
Committee on Environment
and Public Works, requested
that we determine whether the
U.S. Environmental
Protection Agency (EPA)
followed key federal and
Agency regulations and
policies in developing and
reviewing the technical data
used to make and support its
greenhouse gases
endangerment finding.
Background
On December 15, 2009, EPA
published its Endangerment
and Cause or Contribute
Findings for Greenhouse
Gases Under Section 202(a)
of the Clean Air Act. As the
primary scientific basis for
EPA's finding, the Agency
relied upon assessments
conducted by other
organizations. EPA
summarized the results of
these and other scientific
assessments in a technical
support document (TSD).
For further information,
contact our Office of
Congressional and Public
Affairs at (202) 566-2391.
The full report is at:
www.epa.aov/oia/reports/2011/
20110926-11 -P-0702.pdf
Catalyst for Improving the Environment
Procedural Review of EPA's Greenhouse Gases
Endangerment Finding Data Quality Processes
What We Found
EPA met statutory requirements for rulemaking and generally followed
requirements and guidance related to ensuring the quality of the supporting
technical information. Whether EPA's review of its endangerment finding TSD
met Office of Management and Budget (OMB) requirements for peer review
depends on whether the TSD is considered a highly influential scientific
assessment. In our opinion, the TSD was a highly influential scientific assessment
because EPA weighed the strength of the available science by its choices of
information, data, studies, and conclusions included in and excluded from the TSD.
EPA officials told us they did not consider the TSD a highly influential scientific
assessment. EPA noted that the TSD consisted only of science that was previously
peer reviewed, and that these reviews were deemed adequate under the Agency's
policy. EPA had the TSD reviewed by a panel of 12 federal climate change
scientists. This review did not meet all OMB requirements for peer review of a
highly influential scientific assessment primarily because the review results and
EPA's response were not publicly reported, and because 1 of the 12 reviewers was
an EPA employee.
EPA's guidance for assessing data generated by other organizations does not
include procedures for conducting such assessments or require EPA to document
its assessment. EPA provided statements in its final findings notice and supporting
TSD that generally addressed the Agency's assessment factors for evaluating
scientific and technical information, and explained its rationale for accepting other
organizations' data. However, no supporting documentation was available to show
what analyses the Agency conducted prior to disseminating the information.
Our evaluation examined the data quality procedures EPA used in developing the
endangerment finding. We did not assess whether the scientific information and
data supported the endangerment finding.
What We Recommend
We recommend that EPA (1) revise its Peer Review Handbook to accurately reflect
OMB requirements for peer review of highly influential scientific assessments,
(2) instruct program offices to state in proposed and final rules whether the action
is supported by influential scientific information or a highly influential scientific
assessment, and (3) revise its assessment factors guidance to establish minimum
review and documentation requirements for assessing and accepting data from
other organizations. EPA stated that its response to the final report will address our
recommendations.

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