Laura Grant asks:
@willwheels can you tell me more about this #hr4012 "secret science" bill and how it might affect @EPA?
— Laura Grant (@c0ntributary) November 21, 2014
Sure!
Before I start, I should mention that while I am free to express personal opinions as long as I put in the disclaimer below, this is awfully close to stuff I work on. So, I'm going to go with the interpretation of the non-partisan Congressional Budget Office (CBO), in their cost estimate of the bill, which would:
prohibit the Environmental Protection Agency (EPA) from proposing, finalizing, or disseminating a “covered action” unless all scientific and technical information used to support that action is publicly available in a manner that is sufficient for independent analysis and substantial reproduction of research results. Covered actions would include assessments of risks, exposure, or hazards; documents specifying criteria, guidance, standards, or limitations; or regulations and regulatory impact statements.
According to the CBO, EPA relies on 50,000 scientific studies each year and would have to incur costs to make each study available. CBO "expects that EPA would modify its practices, at least to some extent, and would base its future work on fewer scientific studies, and especially those studies that have easily accessible or transparent data." This makes sense, some studies would not be able to be made publicly available at any cost (e.g., PACE or other confidential Census data; or many health studies that rely on personal medical data) while others would be very costly to make available. They assume that EPA would cut the relied-upon number of studies by about half--focusing on using the least costly studies to make available--and spend $250 million a year initially, although this cost would decline over time as EPA gets more efficient. The costs could go up or down (perhaps nonlinearly) if EPA decided to rely on more or fewer studies than CBO's central estimate, and of course the quality of the resulting analysess could go down if EPA has to rely on fewer studies to reach scientific conclusions.
One example, in particular, to consider is the use of the Census of Fatal Occupational Injuries (CFOI) data, which is generally considered to be superior for calculating the Value of a Statistical Life (VSL) (e.g., Viscusi 2012) because the CFOI data are a census and allow for detailed category refinements. However, every study I'm aware of that uses CFOI data to calculate a VSL does so under a confidentiality agreement, so it's not clear to me that any CFOI studies could be used in an EPA RIA if this act were to pass.
This work is not a product of the United States Government or the United States Environmental Protection Agency, and the author is not doing this work in any governmental capacity. The views expressed are those of the author only and do not necessarily represent those of the United States or the US EPA.
