May 31, 2002

Draft Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Environmental Protection Agency

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Rulemaking:

Draft Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Environmental Protection Agency

Stated Purpose:

"These guidelines describe EPA’s policy and procedures for reviewing and substantiating the quality of information before EPA disseminates it. They describe EPA’s administrative mechanisms allowing affected persons to seek and obtain, where appropriate, correction of information disseminated by EPA that they believe does not comply with these guidelines."

Summary of RSP Comment:

Data quality is of paramount importance for making sound policy decisions. Without assurances that agency decisions are based upon high quality data, the public will lack confidence in the legitimacy or efficacy of government action. Further, from a consequentialist perspective, the likelihood of success of a given policy is substantially reduced if it is constructed on the basis of questionable data. Effectively, garbage in leads to garbage out.

Even in those instances where government agencies simply act as the distributor of data, leaving the public to draw inferences and take action on the basis of that information, ensuring quality is still an important goal. Information disseminated by government agencies takes on a certain imprimatur. It carries with it a de facto agency seal of approval, whether the agency intends such a certification or not. Given this, there is a tremendous responsibility on the part of government agencies, in their roles as public servants, to make every effort to either warrant that the information they disseminate or act upon is of the highest quality, or to disclose fully the limitations of any suspect data.

It is with this in mind, that the Office of Management and Budget initially directed federal agencies to develop guidelines for assuring that the data and information they act on and disseminate meet some criterion of quality. It is indeed important that agencies examine and improve their data quality control procedures.

The Environmental Protection Agency asserts that it already has in place significant procedural mechanisms to guarantee the quality of the data it uses and disseminates. Repeatedly, EPA's guidelines refer the reader to extant guidelines that the agency has relied upon for years, suggesting that they meet or exceed any quality control concern suggested by OMB's directive. However, even accepting EPA's assertion that its policies are sufficient to ensure high quality data, its insistence on exempting numerous types of information from such rigorous procedures raises significant concerns and raises the question of whether or not EPA's guidelines truly fulfill the intention of OMB's directive.

It is the purpose of this comment to attempt to reconcile OMB's desire to ensure the quality of data used or disseminated by federal agencies and EPA's desire to maintain reasonable flexibility in its procedures.