Geoscience Reference
In-Depth Information
used to support regulations. The Office of Management and Budget (OMB) cir-
cular that contains the requirement exempts preliminary analyses, drafts of pa-
pers, plans for future research, peer reviews, and communications with col-
leagues. It also exempts trade secrets, commercial information, and information
that must be withheld to protect the privacy of research subjects. The Data Ac-
cess Act is consistent with an interest in providing greater access to scientific
information that underlies regulatory efforts but is limited in applying only to
federally funded research (Wagner 2003; Wagner and Michaels 2004 ). It would
be useful to extend requirements for data access to privately supported research
that is submitted for regulatory purposes. As with publicly supported research,
exemptions could be provided as necessary to protect the privacy of research
subjects and legitimate proprietary interests.
Access to EPA internal research. Concerns about access apply not
only to externally sourced scientific information but to research data and find-
ings that are developed through EPA's internal research programs (Grifo 2009).
Publication of EPA science not only helps to bolster the agency's influence, it
also provides legitimacy in the scientific community. EPA needs to encourage
its own scientists to communicate and publish their results and to do so in a
timely manner. Institutional barriers to the publication of results, particularly
bureaucratic delays related to internal approvals and concerns about policy im-
plications, should be addressed.
Ensuring the Quality of Scientific Information
In rule-making processes that rely on extensive reviews of scientific in-
formation, EPA generally imposes a strong preference for reliance on published,
peer-reviewed studies. The agency's peer review policy states that “peer review
of all scientific and technical information that is intended to inform or support
Agency decisions is encouraged and expected” (EPA 2006). The OMB Final
Information Quality Bulletin for Peer Review (OMB 2004) and EPA's internal
Peer Review Handbook (EPA 2000) guide the peer-review process for internally
generated scientific studies and tools. However, when EPA needs to go beyond
peer-reviewed literature to fill information gaps, it may need to be more active
in initiating external peer review to ensure that the identified externally gener-
ated information is reliable and to provide quality assurance for stakeholders.
EPA has used advisory groups both to review scientific research and to
provide advice and expertise from outside the agency. For example, EPA's Na-
tional Advisory Council for Environmental Policy and Technology (NACEPT)
was established in 1988 to use environmental-policy expertise outside the
agency. The advisory council is an independent group of experts that has pro-
vided advice to EPA on a broad variety of topics, including workforce capacity,
strategic planning, promotion of environmental stewardship, and strategies for
improving access to environmental information (EPA 2012d). Various other
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