A modified proposal from the Environmental Protection Agency (EPA) on “Strengthening Transparency in Regulatory Science” misses key opportunities to improve open data and evidence-building activities at the agency. The proposal, if implemented as drafted, could place restrictions on what studies and data the agency can consider when making decisions.
While EPA officials suggest the proposed rule promotes science and data transparency, experts outside EPA are concerned this new rule could limit the agency’s use of evidence when setting policy. Data Coalition CEO Nick Hart submitted comments on this proposed rule, outlining shortcomings in the proposal while also offering options that further the agency’s open data and open science capabilities.
As a longstanding leader in advancing transparency and evidence-based policymaking among federal agencies, EPA’s proposal omits opportunities to take advantage of new legal authorities established in the bipartisan Foundations for Evidence-Based Policymaking Act.
In order to build transparency and improve data access, government agencies, including EPA, must undertake a multi-pronged approach that builds a culture of openness, with appropriate privacy protections. In the near-term, EPA should focus on its obligations under the Evidence Act, such as strengthening EPA’s learning culture, improve its data governance, enhance EPA’s policy analysis and evaluation function, and bolster public trust.
More specifically, EPA should consider advancing bipartisan solutions that support meaningful transparency, including to
- Establish and Sufficiently Resource a Legally-Recognized Statistical Unit
- Establish or Identify a Partnership for a Secure Data Enclave
- Support International Environmental Systematic-Review Processes
- Establish an Advisory Body for Evidence-Building Activities.
Further details about each of these options, and other ideas, are offered in Nick Hart’s detailed written comments to EPA.
The Data Coalition strongly supports EPA’s efforts to promote open data and open science, when such efforts ensure the agency can promote meaningful transparency and continue to use the best scientific information available. The Data Coalition will be monitoring EPA’s progress on implementing the Evidence Act and realizing the promise of using high-quality data to support agency decision-making.