CRE is not supportive of the EPA science initiative at this time because it creates a new regulatory regime without first exploiting to the fullest the existing regulatory regime which consists of the Data Access Act and the Data Quality Act. It has been nearly a month since CRE announced its opposition to the EPA Silent Science Initiative. During that time period we have examined the position of others and it appears that with the exception of NGOs, CRE is the only organization which has stated an outright opposition to the EPA proposal.
Here are CRE positions on this matter:
Press Coverage of CRE position:
With respect to a host of suggestions made to us, we appreciate and respect the views of those in support of the EPA proposal but CRE has no intention whatsoever of changing its position notwithstanding the source of recommendations to the contrary.
Kudos to EPA for asking the relevant question in its NPRM but a cursory review of comments to date appears that the request went over the heads of most if not all of the commentators.
EPA solicits comment on this proposal and how it can best be promulgated and implemented in light of existing law and prior Federal policies that already require increasing public access to data and influential scientific information used to inform federal regulation.
EPA is also to be commended for emphasizing that the Data Quality Act is one of the cornerstones of its proposed policy. Nonetheless it fails to advise the public that when it finds errors in the data made available by the NPRM that the DQA petition process is the mechanism to seek needed corrections. One reason for the aforementioned omission might be that no Administration has ever endorsed judicial review of DQA petitions. What is to be gained by having access to underlying information if there is no mechanism for using it? Consequently this is the time to confront this issue and that concerning the Data Access Act, not to bury them by hoping that activity in itself will lead to accomplishment.