Integrity of Science

With a calculator in one hand and a red pen in the other, the White House Office of Management and Budget is in an ugly light when it comes to scientific integrity and policymaking.

The calculator hit yesterday with a recess appointment that is directly related to January's OMB rule change (see "New Oversight Policy Bad for Science-based Decisionmaking"). With Congress out on Easter break, President Bush appointed Susan E. Dudley to serve as director of the Office of Information and Regulatory Affairs in OMB. Dudley is considered to be the main influence -- if not the author -- of the January amendments to Executive Order 12866. Those amendments greatly enhanced the regulatory oversight of political appointees in federal agencies. In other words, if the EPA wants to implement a new carbon dioxide regulation, they must not only clear the normal stretch of hurdles, but a new appointee and and Dudley, who is notably anti-regulation.

President Bush on Wednesday appointed as his top regulatory official a conservative academic who has written that markets do a better job of regulating than the government does and that it is more cost-effective for people who are sensitive to pollution to stay indoors on smoggy days than for the government to order polluters to clean up their emissions.

[...]In congressional testimony, Dudley has favored dispensing with costly air pollution controls and initiating a pollution warning system "so that sensitive individuals can take appropriate 'exposure avoidance' behavior" -- mostly by remaining inside.

She opposed stricter limits on arsenic in drinking water, in part because she argued that the Environmental Protection Agency's calculations of the costs and benefits overvalued some lives, particularly those of older people with a small life expectancy.

She has argued that air bags should not be required by government regulation but requested by automobile consumers willing to pay for them.

[...] Her nomination stalled because the Senate Homeland Security and Government Affairs Committee, which held the hearing (in November 2006), didn't vote on it.
Source

Her reliance over what she, by reputation, narrowly defines "market failure" and cost-benefit analysis means that efforts to regulate pollutants, no picnic for federal agencies in the first 6+ years of this administration, just got tougher. We don't know Dudley personally, but the tunnel-vision Microeconomics 101 thinking she expresses suggests that she has never gone jogging on a smoggy day, been involved in a car crash, or argued with a libertarian. It also assumes that everyone has ready access to air conditioning.

Cost-benefit analysis has its place in policymaking. But any notion that it is without bias is foolhardy. The definition and quantification of costs and benefits is inherently biased, and as such, should never prove to be a sole determination of a policy's viability -- regulatory or otherwise. Just as science can not and should not be the sole determinant of a policy decision.

With this appointment and its rule changes, the administration is changing the rules to devalue science in rulemaking.

OMB wields some serious power in the Executive Branch, acting in both advisory and oversight capacities. And while EPA, NASA, and FDA have been the agencies most noted in the chronicle of science abuse, OMB appears to have its own red pen and a track record of making unscientific edits to scientific documents:

On March 27, the Government Accountability Project (GAP), a public interest advocacy and watchdog organization, released a report detailing political interference in federal offices performing scientific research related to global climate change. The report, Redacting the Science of Climate Change, focuses on the manipulation of agency scientific communications to Congress and the media. The report is the product of a year-long investigation which included interviews and examinations of internal executive branch documents.

Examples in the report indicate OMB has been involved in political interference. OMB exerted political influence in responses to questions from Congress. OMB also plays an oversight role in a federal climate science clearinghouse.

For example, after an April 26, 2006, Senate committee hearing on the effects of climate change, two senators submitted questions for the record to the National Oceanic and Atmospheric Administration. A number of federal offices, including OMB, took the opportunity to comment on and edit the responses.

In one of its edits, OMB inserted text which "attributed global warming to increasing water vapor, in reliance on a quote taken out of context from a scientific paper," according to the GAP report. Before finalizing the response, one of the paper's authors intervened to correct OMB's assertion. Source

Between this chronicle of events and the Dudley appointment, OMB Watch is going to have its hands full. For anyone who believes that the science (from water pollution to diesel emissions) points to the need for greater regulation, a steep uphill battle will remain for at least two years. Despite Supreme Court decisions, Congressional sea changes, and public opinion, the regulatory landscape is not only uphill -- it's got trenches straight out of WWI.