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Climate Change Endangerment Report and the EPA’s National Center for Environmental Economics

Rating: Foothill

The Charge

The Environmental Protection Agency (EPA) was accused of suppressing science during its intra-agency review of its proposed finding that heat-trapping gases endanger public health and welfare.1 The EPA announced its decision on April 17, 2009.2 The finding relied upon rigorous and peer-reviewed scientific literature.3 Alan Carlin, an economist in the EPA's National Center for Environmental Economics (NCEE), attempted to submit an analysis challenging the endangerment finding's scientific basis a few days before the March 16, 2009 deadline for internal agency review.

A series of emails from March 12-17 demonstrate that Al McGartland, the director of NCEE, told Carlin that "in light of the tight schedule and the turn of events, please do not have any direct communication with anyone outside of NCEE on endangerment."4 On March 17, McGartland informed Carlin that he did not submit Carlin's comments as part of the intra-agency review because "the time for such discussions of fundamental issues has passed for this round. The administrator…has decided to move forward on endangerment, and your comments do not help the legal or policy case for this decision….I can only see one impact of your comments given where we are in the process, and that would be a very negative impact on our office."5

Because Carlin's comments were not forwarded on at the EPA, lawmakers and climate skeptics have condemned the EPA and accused the Obama administration of suppressing science.6

Is it political interference in science?

Yes and No. Some aspects of the Carlin controversy represent political interference in science while others do not. It seems that Carlin attempted to push through a report that was not peer-reviewed internally by the EPA only a few days before the intra-agency review deadline. His report indicated that his comments represented the views of the NCEE and not Carlin as an individual.7 The EPA has discretion to require that official studies and reports be peer reviewed before they are released to the public or become part of an official agency document or rule making. In addition, the substance of Carlin's report is outside of the scientific consensus on climate change8, and thus it is understandable that the director of the NCEE would be reluctant to forward Carlin's non-peer-reviewed document significantly outside the mainstream at such short notice.

What is the best way to ensure scientific integrity?

The EPA should have acted more appropriately with respect to Carlin's free speech rights.  Although the EPA does have the right to refuse to consider information it does not deem credible, the EPA should have informed Carlin that he could submit comments on the endangerment finding as a private citizen as part of a public comment period. In addition, Carlin should not have been prohibited from speaking publicly about his opinions. NCEE Director McGartland should have informed Carlin of his right to speak freely and publicly about his opinions so long as he makes it clear that he doing so as a private citizen, not as a representative of the EPA. The EPA needs to institute transparency reforms that would end confusion and clarify employees' rights as employees and as private citizens.


For more analysis of scientific integrity charges against the Obama administration, see the Mountain or Molehill feature.

1. U.S. Environmental Protection Agency. 2009. "EPA Finds Greenhouse Gases Pose Threat to Public Health, Welfare / Proposed Finding Comes in Response to 2007 Supreme Court Ruling." April 17.
2. Ibid.
3. Ibid.
4. McGartland, A. 2009. Email to Alan Carlin, titled "endangerment." March 12.
5. Ibid.
6. Bravender, R. 2009. "Two EPA Staffers Question Science Behind Climate 'Endangerment' Proposal." The New York Times, June 26.
7. Carlin, A. 2009. Report titled "Proposed NCEE Comments on Draft Technical Support Document for Endangerment Analysis for Greenhouse Gas Emissions under the Clean Air Act." March 16.
8. Ibid.

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