A couple of months ago, I posted on the EPA Endangerment Finding. In Canada, the government would just go ahead and pass the regulations without the long U.S. regulatory processes. In practical terms, some odd coalitions can form for specific policies between people who are worried about energy supply or the impact of energy imports on the U.S. economy and people who are worried about climate. I’m not opposed to governments making decisions, even if I don’t agree with the decision.
Contrary to what people on the one hand assume and contrary to urgings of people on the other hand, I don’t actually have an opinion on the merits of this particular policy. But there is an aspect to the process that annoys me – the implicit laundering of past stonewalling and obstruction.
EPA guidelines require that highly influential scientific assessments meet a variety of sensible standards for transparency, data availability and due diligence – policies that CA readers know not to have been implemented by the IPCC. I discussed these issues in my prior post and have amplified these arguments in my submission which is online here EPA submission 3951.1 here
In the submission, I included a consideration of some interesting clauses from the EPA Peer Review Handbook (which appears to be incorporated by reference into EPA Guidelines.)
EPA has to carry out some required processes in order to use a scientific assessment by an external party (mentioning international bodies). One of the requirements is that external party has to submit the assessment to EPA, together with the peer review record, following which EPA officials are obliged to evaluate the material to ensure that if complies with EPA standards (which in this case appear to me to be considerably more rigorous than IPCC standards.)
The IPCC Fourth Assessment Report is obviously a public document, but it doesn’t appear to me that anyone bothered to submit it to EPA (together with the peer review record.) Such a submission would create some interesting issues for ongoing FOI obstruction, e.g. the withholding of Mitchell’s Review Comments and Ammann’s “private” review comments.
Indeed, the various discussions that we’ve had over the past months over IPCC’s amorphous legal status – i.e. IPCC participants having dual status as government employees, with their IPCC affiliation being applied to yield a cone of darkness over activities which would be subject to FOI if they were “merely” government employees.
Evasion of transparency has been a long-running concern of this site and I’ve used this comment opportunity to place this and related concerns on the record.