EPA Issues Its Own Scientific Integrity Memo

May 19th, 2009

Posted by: admin

On May 9, EPA Administrator Jackson issued a memo to all EPA employees about scientific integrity in the agency (H/T OSTP Blog).  Keeping in line with the Obama Administration’s scientific integrity memo, scientific integrity is not defined in this memo.  While referencing the agencies previous efforts in this area, including whistleblower protections, Administrator Jackson notes that she has asked the EPA Science Council to assess EPA efforts and gaps in this area:

“The SPC at my request is inventorying all our guidelines and policies that relate to scientific integrity to look for gaps and possible areas for improvement. One SPC focus, for example, will be updating and reaffirming EPA’s Peer Review Handbook and recommending how we can improve implementation of our peer review policies across our programs and regions. I also have asked the SPC to work the National Partnership Council to reaffirm the Agency’s Principles of Scientific Integrity and update the Principles of Scientific Integrity online training.”

It’s also important to note the parts of this memo that are open to misleading interpretation.  Some will read them and think the EPA will only accept policy outcomes dictated by science (whatever that means).  What the language means is that the desired policy outcomes of the EPA will be supported by science that is conducted under current accepted community standards.

“While the laws that EPA implements leave room for policy judgments, the scientific findings on which these judgments are based should be arrived at independently using well-established scientific methods, including peer review, to assure rigor, accuracy, and impartiality. This means that policymakers must respect the expertise and independence of the Agency’s career scientists and independent advisors while insisting that the Agency’s scientific processes meet the highest standards of rigor, quality, and integrity.”

The most important part of the above paragraph is the language that understands the science is the support of policy decisions, not the determinant of those decisions.  Judgment is still king, and judgments will be made on many criteria, not just science.  The EPA Administrator recognizes that there will be conflicts:

“Able scientists may not always agree on what methodologies should be employed or how studies should be interpreted. I am committed to fostering a culture of robust scientific debate and discussion within the Agency, recognizing that in the end senior scientists must take responsibility for resolving differences of opinions using established science policies and their best professional judgment. I intend to work with our science leadership, unions, and career staff to make sure that we respect and encourage free and honest discussion among our scientists while bringing to closure issues that we must resolve to support decision making.”

Now this will not stop anyone, on any side of any issue, from trying to close off debates by appealing to the science.  Those that would suggest new standards of scientific integrity support such actions aren’t reading memos like this closely enough.

14 Responses to “EPA Issues Its Own Scientific Integrity Memo”

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  1. jae Says:

    Oh, brother. All this, just after the horrible unbelievably one-sided, unscientific “finding of endangerment.” At least she’s just like the boss: say one thing, do another. LOL.

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  3. David Bruggeman Says:

    Please point out the conflict. The finding is a policy judgment, not a scientific conclusion.

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  5. jae Says:

    “I am committed to fostering a culture of robust scientific debate and discussion within the Agency, recognizing that in the end senior scientists must take responsibility for resolving differences of opinions using established science policies and their best professional judgment. I intend to work with our science leadership, unions, and career staff to make sure that we respect and encourage free and honest discussion among our scientists while bringing to closure issues that we must resolve to support decision making.”

    IMHO, this did not take place as part of the “finding.” If it did, I see no record of it.

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  7. David Bruggeman Says:

    Internal agency discussions may not necessarily be a matter of public record, so there may not be a record of it.

    The scientific debate and discussion can take place, be free and honest, and still overruled by other considerations.

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  9. jae Says:

    David B:

    “Internal agency discussions may not necessarily be a matter of public record, so there may not be a record of it.

    The scientific debate and discussion can take place, be free and honest, and still overruled by other considerations.”

    How absolutely LAME! The regulated community lives by the rule that if it is not recorded, it never happened. The regulators should be held to their own standard, at least.

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  11. David Bruggeman Says:

    You seem to be asking for a level of disclosure (which is different from recording) equivalent to extensive document discovery in a court case – every document of every meeting on every action taken by an agency.

    If there is dispute over whether something should be disclosed, there are measures like FOiA to address those concerns. Not everything that is recorded is made public.

    The memo is about how scientific discussions should be handled within a larger context of making a policy decision. It does not address many of the non-scientific factors that inform regulatory decisions. It does not give specific instruction on how disagreements over scientific practices or findings should be resolved. It does not say that science trumps other issues in regulatory decisions.

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  13. jae Says:

    David: I don’t think we are communicating. I am NOT asking for a high level of disclosure, concerning political concerns, just enough disclosure to determine if all the important scientific issues were considered. Without some records, how will we ever know if the following occurred?

    ““I am committed to fostering a culture of robust scientific debate and discussion within the Agency, recognizing that in the end senior scientists must take responsibility for resolving differences of opinions using established science policies and their best professional judgment. ”

    IMHO, there is no evidence of any “robust scientific debate” during the EPA deliberations on whether CO2 is a pollutant that causes endangerment. This is obvious because the final product is egregious to the point of sick humor. It lacks ANY considertation of the positive effects of CO2. It lacks any explanation for the lack of temperature rise over the past 12 years. ETC. It reveals NO scientific debate. It is a piece of political CRAP.

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  15. David Bruggeman Says:

    You seem to believe that a robust scientific debate would automatically lead to your preferred policy option. That’s a bit presumptuous, and hints at some stealth advocacy on your part.

    It’s not obvious that the finding is egregious to the point of sick humor. The EPA wants to control CO2 emissions, and thinks this particular way of doing so is within their authority.

    You also assume that a robust scientific debate would dictate any particular policy option. There are no guarantees of that, even with the new memo.

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  17. jae Says:

    David:

    “You seem to believe that a robust scientific debate would automatically lead to your preferred policy option. That’s a bit presumptuous, and hints at some stealth advocacy on your part.”

    “You also assume that a robust scientific debate would dictate any particular policy option. There are no guarantees of that, even with the new memo.”

    NO, you are not understanding me at all. I never said this and don’t believe it. ALL I’m trying to say is that there should be clear evidence that the Agency has looked at all “sides” of the issue, if they are going to claim that they have looked at the “science.” In the case of the “finding,” there is no such evidence. In fact, it is very obvious to me that the conclusion preceeded all the “scientific pursuit.” The process appears identical to that of IPPC’s, where the SPM was produced BEFORE the main AR4 document. EPA did not go back to the science to produce their finding; they relied on other “findings,” (like AR4) which are not scientific documents, IMHO. If you think that is “science,” then you and I truly are on different wavelengthts.

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  19. jae Says:

    David: I agree entirely with Roger Pielke, Sr. For example:

    “This report is a clearly biased presentation of the science which continues to use the same reports (IPCC and CCSP) to promote a particular political viewpoint on climate (and energy) policy).”

    If this is true, it is NOT consistent with Jackson’s statements, which are just more Democratic Doublespeak.

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  21. David Bruggeman Says:

    Yeah, we’ve been talking past each other.

    “ALL I’m trying to say is that there should be clear evidence that the Agency has looked at all “sides” of the issue, if they are going to claim that they have looked at the “science.”

    Putting aside the question about the presence of “sides” on scientific questions (with or without policy implications), there is nothing in the scientific integrity memo that promises that all “sides” will be considered. The only promise is for robust scientific discussion and debate. There is no guarantee that viewpoints in opposition to those expressed by agency scientists will be sought out, especially if the differences within the agency are on matters of degree rather than what the conclusions are.

    Keep in mind what these measures are in response to – the claims by the Union of Concerned Scientists and other groups that scientists in federal agencies were misrepresented, muzzled, or otherwise restricted from discussing their research. This document, and the one the OSTP will inform, are not making claims that all scientific viewpoints will be considered in the ultimate policy judgment. Unless the finding violated the law (and I’m sure there will be a suit to address that question), or the laws mandated an outcome based on the results of scientific assessments, then there is nothing wrong with the professional judgment of an agency making policy choices based on things besides “the science”.

    The doublespeak you believe is happening is not unique to any particular party or ideology. Frequent readers of this blog will have seen this before, but the notion that political viewpoints will be absent from policy decisions related to science harkens to some mystical uber-objectivity that never existed.

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  23. jae Says:

    “there is nothing in the scientific integrity memo that promises that all “sides” will be considered. The only promise is for robust scientific discussion and debate. ”

    Then the memo is absolutely worthless doublespeak, right? Otherwise, please tell me how you have a “robust (god, I hate that word) scientific discussion and debate.” You are not making much sense to this simple scientist.

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  25. jae Says:

    IOW, how the HELL do you have a “robust scientific discussion,” if all “sides” are not considered? Do you have a “robust” circle jerk, where everyone cheers everyone else, as is common when the great BO speaks and when the IPCC meets? I seriously don’t understand your point.

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  27. David Bruggeman Says:

    Not all viewpoints are considered in robust scientific discussions, because not all relevant viewpoints relate to the science. For instance, scientific propositions that cannot gain acceptance with other scientists (can’t get published or funded, perhaps), would not be considered essential to having a robust scientific discussion.