30 Day Comment 1

Document Metadata:DHS-2017-0036-DRAFT-0002

Document Details
Docket ID:

DHS-2017-0036

Docket Title:

DHS Industry Outreach Information Form

Document File:
Docket Phase:

Notice

Phase Sequence:

1

Original Document ID:

DHS-2017-0036-DRAFT-0002

Current Document ID:

DHS-2017-0036-DRAFT-0002

Title:

Unrelated Comment Submitted by Anonymous (c c)

Number of Attachments:

0

Document Type:

PUBLIC SUBMISSIONS

Document Subtype:

Comment(s)

Comment on Document ID:

DHS-2017-0036-0002

Comment on Document Title: Agency Information Collection Activities: Submission for
Review; Information Collection Request for the Department of
Homeland Security, Science and Technology, Research and
Development Partnerships Group, Office of Public- Private
Partnerships
Status:

DoNotPost

Received Date:

04/14/2018

Date Posted:
Posting Restriction:

No restrictions

Submission Type:

Web

Number of Submissions:

1

Document Optional Details
Status Set Date:

04/16/2018

Current Assignee:

Smith, Michelle DHS (DHS)

Status Set By:

Smith, Michelle DHS (DHS)

Tracking Number:

1k2-92l5-vwdi

Total Page Count
Including Attachments:

1

Submitter Info

Comment:

See attached file(s)

First Name:

Jorge

Middle Name:
Last Name:

Basile

Mailing Address:
Mailing Address 2:
City:
Country:
State or Province:
ZIP/Postal Code:
Email Address:
Phone Number:
Fax Number:
Organization Name:
Submitter's
Representative:
Government Agency Type:
Government Agency:
Cover Page:

Submitter Info
Comment:

2009 December EPA published its Endangerment and Cause or
Contribute Findings for Greenhouse Gases Under Section 202(a)
of the Clean Air Act. BUT scientific basis for EPAs finding,
assessments was conducted by other organizations. EPA reliance
on the IPCC is an international body outside the jurisdiction
and oversight of the United States Congress. is A VIOLATION of
the Data Quality Act. Flawed reports that created regulation
cost in the Billions on Middle Americas Children, the poor,
the Elderly, money that could have been spent on Healthcare,
schools, infrastructure, Dams, Roads. EPA Inspector Generals
investigating DATA QUALITY PROCESSES (2011), Conclusions the
endangerment finding Technical support document is a highly
influential scientific assessment that should have been peer
reviewed as outlined in Section III of Office of Management
and Budget Final Information Quality Bulletin for Peer Review.
EPA Office of Air and Radiation NEVER formally designated the
document as either influential scientific information or as a
highly influential scientific assessment in the preamble to
the proposed and final endangerment findings or in its
internal documentation. EPA did NOT consider the Technical
support document to be a highly influential scientific

assessment. EPA Office of Air and Radiation did not adhere to
some of its internal processes established to guide Tier 1
actions. EPA did NOT complete some of these key requirements
and recommended actions. EPA relied upon descriptions of other
organizations information quality processes. NO
contemporaneous documentation was available to show what
analyses EPA conducted prior to dissemination of the
information in its advance notice and proposed action. EPA
guidance for assessing outside sources of data does NOT
include procedures for conducting these assessments or require
the Agency to document its assessments. EPA document does NOT
identify specific steps or procedures EPA personnel should use
in determining whether scientific and technical information is
of acceptable quality, EPA does NOT identify the documentation
requirements for these determinations. EPA did not
contemporaneously document how it applied and considered the
assessment factors in determining whether the IPCC and other
assessment reports were of sufficient quality, objectivity,
utility, and integrity. EPA did NOT conduct any independent
evaluations of IPCCs compliance with IPCC procedures, EPA Did
NOT document any specific processes it employed to evaluate
the scientific and technical information included in IPCCs AR4
prior to EPA disseminating that information. With respect to
EPA accepting and disseminating data produced by other
organizations,; Office of Management and Budget SAID If an
agency uses another organizations data or analysis to support
their policy, they are disseminating that information. As
such, that information becomes subject to the Agencys
Information Quality Guidelines and the Bulletin for Peer
Review. Therefore, in evaluating whether to disseminate the
information; EPA MUST determine whether the information
complies with the Agencys Information Quality Guidelines. EPA
determined that the IPCC assessment and other outside reports
met EPAs information quality guidelines and were sufficiently
peer reviewed. EPAs reasoning was described in its response to
comments on the proposed rule. However; NO supporting
analytical information was available to show how EPA made its
determination PRIOR to disseminating the information. EPAs
guidance for assessing the quality of externally generated
information does NOT provide procedures or steps for assessing
outside data or requirements for documenting such analysis.
Since issuing its final findings in December 2009, EPA
received 10 petitions requesting that EPA reconsider its
findings. As part of their request for reconsideration,
petitioners claimed that IPCC suppressed dissenting views
during the development of its AR4, and some of the petitioners
provided e-mails from University of East Anglia Climatic
Research Unit (CRU) scientists as part of the evidence to
support this claim. EPA provided in its response to comments
document for the proposed findings, by referring to the IPCC
procedures as a means of ensuring that all scientific views
were considered during the development of the AR4. EPAs
response to petitions document: EPA Office of Air and
Radiation manager noted that a concern was raised about
improper edits being made to the second IPCC assessment report
in 1995.
First Name:
Middle Name:

c

Last Name:

c

Mailing Address:
Mailing Address 2:
City:
Country:
State or Province:
ZIP/Postal Code:
Email Address:
Phone Number:
Fax Number:
Organization Name:
Submitter's
Representative:
Government Agency Type:
Government Agency:
Cover Page:

Document Optional Details
Status Set Date:

04/16/2018

Current Assignee:

Smith, Michelle DHS (DHS)

Status Set By:

Hwang_DHS, BAH Randolph (DHS)

Tracking Number:

1k1-8ymp-ldob

Total Page Count
Including Attachments:

3

Submitter Info
Comment:

See attached file(s)

First Name:

Jorge

Middle Name:
Last Name:
Mailing Address:
Mailing Address 2:
City:

Basile

Country:
State or Province:
ZIP/Postal Code:
Email Address:
Phone Number:
Fax Number:
Organization Name:
Submitter's
Representative:
Government Agency Type:
Government Agency:
Cover Page:

Submitter Info
Comment:

2009 December EPA published its Endangerment and Cause or
Contribute Findings for Greenhouse Gases Under Section 202(a)
of the Clean Air Act. BUT scientific basis for EPAs finding,
assessments was conducted by other organizations. EPA reliance
on the IPCC is an international body outside the jurisdiction
and oversight of the United States Congress. is A VIOLATION of
the Data Quality Act. Flawed reports that created regulation
cost in the Billions on Middle Americas Children, the poor,
the Elderly, money that could have been spent on Healthcare,
schools, infrastructure, Dams, Roads. EPA Inspector Generals
investigating DATA QUALITY PROCESSES (2011), Conclusions the
endangerment finding Technical support document is a highly
influential scientific assessment that should have been peer
reviewed as outlined in Section III of Office of Management
and Budget Final Information Quality Bulletin for Peer Review.
EPA Office of Air and Radiation NEVER formally designated the
document as either influential scientific information or as a
highly influential scientific assessment in the preamble to
the proposed and final endangerment findings or in its
internal documentation. EPA did NOT consider the Technical
support document to be a highly influential scientific
assessment. EPA Office of Air and Radiation did not adhere to
some of its internal processes established to guide Tier 1
actions. EPA did NOT complete some of these key requirements
and recommended actions. EPA relied upon descriptions of other
organizations information quality processes. NO
contemporaneous documentation was available to show what
analyses EPA conducted prior to dissemination of the
information in its advance notice and proposed action. EPA
guidance for assessing outside sources of data does NOT
include procedures for conducting these assessments or require
the Agency to document its assessments. EPA document does NOT
identify specific steps or procedures EPA personnel should use
in determining whether scientific and technical information is
of acceptable quality, EPA does NOT identify the documentation

requirements for these determinations. EPA did not
contemporaneously document how it applied and considered the
assessment factors in determining whether the IPCC and other
assessment reports were of sufficient quality, objectivity,
utility, and integrity. EPA did NOT conduct any independent
evaluations of IPCCs compliance with IPCC procedures, EPA Did
NOT document any specific processes it employed to evaluate
the scientific and technical information included in IPCCs AR4
prior to EPA disseminating that information. With respect to
EPA accepting and disseminating data produced by other
organizations,; Office of Management and Budget SAID If an
agency uses another organizations data or analysis to support
their policy, they are disseminating that information. As
such, that information becomes subject to the Agencys
Information Quality Guidelines and the Bulletin for Peer
Review. Therefore, in evaluating whether to disseminate the
information; EPA MUST determine whether the information
complies with the Agencys Information Quality Guidelines. EPA
determined that the IPCC assessment and other outside reports
met EPAs information quality guidelines and were sufficiently
peer reviewed. EPAs reasoning was described in its response to
comments on the proposed rule. However; NO supporting
analytical information was available to show how EPA made its
determination PRIOR to disseminating the information. EPAs
guidance for assessing the quality of externally generated
information does NOT provide procedures or steps for assessing
outside data or requirements for documenting such analysis.
Since issuing its final findings in December 2009, EPA
received 10 petitions requesting that EPA reconsider its
findings. As part of their request for reconsideration,
petitioners claimed that IPCC suppressed dissenting views
during the development of its AR4, and some of the petitioners
provided e-mails from University of East Anglia Climatic
Research Unit (CRU) scientists as part of the evidence to
support this claim. EPA provided in its response to comments
document for the proposed findings, by referring to the IPCC
procedures as a means of ensuring that all scientific views
were considered during the development of the AR4. EPAs
response to petitions document: EPA Office of Air and
Radiation manager noted that a concern was raised about
improper edits being made to the second IPCC assessment report
in 1995.
First Name:

c

Middle Name:
Last Name:
Mailing Address:
Mailing Address 2:
City:
Country:
State or Province:
ZIP/Postal Code:

c

Email Address:
Phone Number:
Fax Number:
Organization Name:
Submitter's
Representative:
Government Agency Type:
Government Agency:
Cover Page: