"EPA undertook a thorough and deliberate process in the development of this finding, including a careful review of the wide range of peer-reviewed science. Since EPA finalized the endangerment finding in December of 2009, the vast body of peer reviewed science that EPA relied on to make its determination has undergone further examination by a wide range of independent scientific bodies. All of those reviews have upheld the validity of the science."
- EPA met statutory requirements for rulemakings.
- We did not test the validity of the scientific or technical information used by EPA to support its endangerment finding.
- We did not make conclusions regarding the impact that EPA's information quality control systems may have had on the scientific information used to support the endangerment finding.
- EPA fulfilled the statutory requirements for notice and comment rulemakings mandated in the Administrative Procedure Act and in Section 307 of the CAA, and employed several of its processes designed to ensure data quality.
- OMB in response to our draft report stated that OMB believes that EPA reasonably interpreted the OMB bulletin in concluding that the TSD did not meet the bulletin's definition of a highly influential scientific assessment.
"Sound process is critical to sound outcomes, and the credibility of federal policy and regulations is compromised when agencies cut corners. EPA's controversial greenhouse gas regulations are projected to cost tens of billions of dollars and could eliminate up to 1.4 million jobs by 2014. Clearly the stakes are high, and the notion that the Obama administration took regulatory shortcuts in pursuit of their preferred policy outcome is deeply troubling."
"Putting aside the fact that OMB agrees with EPA's call, it is still reasonable to ask what peer review process was used for the document. In preparing the technical support document, EPA organized a panel of 12 federal agency climate experts (including one from EPA) to review the document. The document also underwent extensive interagency and OMB review before being published in the Federal Register for public review in July 2008 as part of the agency's Advance Notice of Proposed Rulemaking. It was revised in response to public comments and reissued for a second round of public comments as part of the proposed endangerment finding in April 2009. The agency held public hearings on its proposed action and prepared 11 volumes of responses to public comments before issuing the final document and endangerment finding in December 2009.
"The endangerment finding has been challenged in the courts, and they ultimately will decide its fate. Given the extensive body of peer reviewed scientific assessments that formed the basis for the finding and EPA's thorough review process for the finding itself, it is highly unlikely that any such challenges will prevail."
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