The Triangulation of the CCS Issue

Triangulate:  “Triangulation is a powerful technique that facilitates validation of data through cross verification from two or more sources”.

N. B.  Subsequent to the publication  of the following  post EPA did respond to CRE; we appreciate their doing so in a comprehensive manner.

DQA:  The Data Quality Act requires that EPA conduct a structured peer review of CCS  pursuant to the Data Quality Act.

OIRA:  OIRA has the statutory mandate to enforce the DQA.

GPRA:  GPRA directs EPA and OMB to disclose actions they have taken to ensure regulations are science based.

The EPA Inspector General has investigated this issue and his  resultant report provides documentation for requiring that statements regarding  the  “availability” of  CCS  be subjected to a DQA structured peer review for Highly Influential Scientific Information.

The Data Quality Act requires EPA to conduct a structured peer review of the availability of CCS as a commercially available control technology.

The Data Quality Act also requires OMB to enforce the requirement for a DQA structured peer review.

The Government Performance Results Act requires EPA and OMB to disclose to the Congress and the public compliance or non-compliance on the part of EPA  with respect to its science related performance goals under GPRA.

Conclusion

As of March 2013 neither EPA, OIRA nor OMB have fulfilled their statutory responsibility to ensure that a DQA structured peer review be conducted to determine whether CCS is a commercially available technology.  Accordingly CRE  has requested that the EPA Inspector General review this matter.

Leave a Reply