Comments on: EPA Issues Its Own Scientific Integrity Memo http://cstpr.colorado.edu/prometheus/?p=5228 Wed, 29 Jul 2009 22:36:51 -0600 http://wordpress.org/?v=2.9.1 hourly 1 By: David Bruggeman http://cstpr.colorado.edu/prometheus/?p=5228&cpage=1#comment-13975 David Bruggeman Mon, 25 May 2009 16:05:37 +0000 http://sciencepolicy.colorado.edu/prometheus/?p=5228#comment-13975 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. 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.

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By: jae http://cstpr.colorado.edu/prometheus/?p=5228&cpage=1#comment-13967 jae Sat, 23 May 2009 01:56:38 +0000 http://sciencepolicy.colorado.edu/prometheus/?p=5228#comment-13967 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. 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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By: jae http://cstpr.colorado.edu/prometheus/?p=5228&cpage=1#comment-13966 jae Sat, 23 May 2009 01:53:16 +0000 http://sciencepolicy.colorado.edu/prometheus/?p=5228#comment-13966 "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. “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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By: David Bruggeman http://cstpr.colorado.edu/prometheus/?p=5228&cpage=1#comment-13965 David Bruggeman Sat, 23 May 2009 00:23:21 +0000 http://sciencepolicy.colorado.edu/prometheus/?p=5228#comment-13965 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. 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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By: jae http://cstpr.colorado.edu/prometheus/?p=5228&cpage=1#comment-13957 jae Fri, 22 May 2009 15:29:00 +0000 http://sciencepolicy.colorado.edu/prometheus/?p=5228#comment-13957 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. 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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By: jae http://cstpr.colorado.edu/prometheus/?p=5228&cpage=1#comment-13956 jae Fri, 22 May 2009 13:52:02 +0000 http://sciencepolicy.colorado.edu/prometheus/?p=5228#comment-13956 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. 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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By: David Bruggeman http://cstpr.colorado.edu/prometheus/?p=5228&cpage=1#comment-13952 David Bruggeman Fri, 22 May 2009 02:38:25 +0000 http://sciencepolicy.colorado.edu/prometheus/?p=5228#comment-13952 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. 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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By: jae http://cstpr.colorado.edu/prometheus/?p=5228&cpage=1#comment-13951 jae Thu, 21 May 2009 23:59:46 +0000 http://sciencepolicy.colorado.edu/prometheus/?p=5228#comment-13951 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. 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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By: David Bruggeman http://cstpr.colorado.edu/prometheus/?p=5228&cpage=1#comment-13950 David Bruggeman Thu, 21 May 2009 23:18:27 +0000 http://sciencepolicy.colorado.edu/prometheus/?p=5228#comment-13950 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. 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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By: jae http://cstpr.colorado.edu/prometheus/?p=5228&cpage=1#comment-13948 jae Thu, 21 May 2009 21:36:54 +0000 http://sciencepolicy.colorado.edu/prometheus/?p=5228#comment-13948 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. 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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