◼ (W)ithout the TSD ((Technical Support Document), the Endangerment Finding is toast - and so is regulation of carbon dioxide - S. Fred Singer/American Thinker
...(T)he EPA's Inspector General (IG) released a report in September 2011, finding that EPA did not meet applicable federal Information (or Data) Quality Act (IQA) standards when developing the TSD. The IG argued that the TSD is a "highly influential scientific assessment," and therefore should have been subjected to the most rigorous form of peer review. EPA fell short of the mark by not publishing the comments of the agency's 12-member peer-review panel, and by placing an EPA employee on the panel, compromising its independence.
EPA claims it met all IQA standards because the TSD, far from being a "highly influential scientific assessment," is not a "scientific assessment" at all. According to EPA, the TSD did not involve any weighing of data, information, or studies. Rather, the TSD simply summarizes assessments of other authorities, principally the UN's Intergovernmental Panel on Climate Change (IPCC), the US National Academy's National Research Council (NRC), and the US Global Change Research Program (USGCRP). [Note that neither NRC and USGCRP are "independent;" both reports are based on the IPCC, whose own Assessment has been compromised by the revelations of the Climategate e-mails.]
But in so saying, EPA may have leapt from the frying pan into the fire, because in the ongoing litigation over EPA's greenhouse gas regulations, a key claim made by the petitioners Coalition for Responsible Regulation is that when EPA developed its TSD and associated EF, it unlawfully outsourced its "judgment" to the IPCC and other non-agency experts.... Read The Rest.
...(T)he EPA's Inspector General (IG) released a report in September 2011, finding that EPA did not meet applicable federal Information (or Data) Quality Act (IQA) standards when developing the TSD. The IG argued that the TSD is a "highly influential scientific assessment," and therefore should have been subjected to the most rigorous form of peer review. EPA fell short of the mark by not publishing the comments of the agency's 12-member peer-review panel, and by placing an EPA employee on the panel, compromising its independence.
EPA claims it met all IQA standards because the TSD, far from being a "highly influential scientific assessment," is not a "scientific assessment" at all. According to EPA, the TSD did not involve any weighing of data, information, or studies. Rather, the TSD simply summarizes assessments of other authorities, principally the UN's Intergovernmental Panel on Climate Change (IPCC), the US National Academy's National Research Council (NRC), and the US Global Change Research Program (USGCRP). [Note that neither NRC and USGCRP are "independent;" both reports are based on the IPCC, whose own Assessment has been compromised by the revelations of the Climategate e-mails.]
But in so saying, EPA may have leapt from the frying pan into the fire, because in the ongoing litigation over EPA's greenhouse gas regulations, a key claim made by the petitioners Coalition for Responsible Regulation is that when EPA developed its TSD and associated EF, it unlawfully outsourced its "judgment" to the IPCC and other non-agency experts.... Read The Rest.
