CEI Submits Appeal of Lack of Peer Review for EPA’s Greenhouse Gas Endangerment Finding
The Competitive Enterprise Institute is challenging the Environmental Protection Agency’s Endangerment Finding for Greenhouse Gases on procedural grounds. This is the document which supposedly laid out the scientific basis for the claim that greenhouse gases are an existential threat. This challenge that is on the procedural error in failing to follow the Office of Management and Budget Peer Review requirements under the Information Quality Act.
We submitted our correction request in May 2019. OMB says it should take no more than four months, but it took 33 months for the EPA to deny our correction request in January 2022. We filed our appeal today, March 11, 2022.
The most interesting part of the EPA response was this on page 7:
The charge to the reviewers of the TSD was to determine whether the TSD [Technical Support Document] was a fair reflection of the major assessment reports rather than to peer review a new scientific assessment. OIG report at p. 83. For that reason, the authors of those underlying reports were well-positioned to evaluate the charge question and ensure that EPA did not modify or misstate key findings of the major scientific assessment products. [Emphasis added]
So, essentially, the EPA is claiming that the proper peer reviewers were the people who had actually written the reports on which the Endangerment Finding was based. It didn’t need independent, disinterested peer reviewers because the original authors knew their work better than anyone else! It’s amazing to me that this is the foundation upon which all of the EPA global warming regulations are built. Our appeal discusses this issue in Part IV, on page 5.