Milloy & Dunn testimony to EPA on science transparency

This afternoon, I delivered the following remarks on EPA’s proposed science transparency rule at the public hearing. I commented on behalf of myself and Dr. John Dunn. We are trying to open the black box.

Open Black Box

My name is Steve Milloy. I publish

I am speaking on behalf of myself and Dr. John Dunn, an emergency physician in Texas.

We are commenting in support the proposed transparency initiative.

Science transparency in EPA regulatory action is long past overdue.

When I first started working on EPA issues in 1990, the main controversy with EPA science was the use of science policy and default assumptions – like the linear no-threshold model of carcinogenesis.

The problem wasn’t necessarily the use of science policy and default assumptions. The problem was, rather, EPA’s failure to disclose the nature of those default assumptions.

In other words: what part was science; what part was guesswork and; what part was politics.

When I first reported on this problem for the Department of Energy in 1994, the Clinton administration tried to censor my report. But they couldn’t and so here we are so many years later finally making progress on this important issue.

More recently, the major problem with EPA science has been what has become known as “secret science.”

Since 1990s, EPA grantees like Harvard’s Doug Dockery and Brigham Young University’s Arden Pope have refused to make available to the public the raw data used in their epidemiologic studies.

And this is true despite the fact that these studies were cited by EPA as the principal scientific bases for major air quality rules like those that were the Obama administration’s war-on-coal.

Worse, prior EPA administrations have actually aided and abetted Dockery and Pope hiding their data from public review. Prior EPA administrations have ignored the requests of the EPA’s own independent science advisors and Congress to release the data.

I can only conclude this is because independent review of the Harvard Six City and American Cancer Society line of studies would prove them to be highly problematic, embarrassing or even fraudulent.

Desperate to defend the indefensible, supporters of Dockery and Pope have wrongly maintained that making the data in question public would violate medial and personal privacy rights.

Nothing could be further from the truth.

For the most part, the data is electronic. Scrubbed files with the key data needed for independent review can easily be made available. No one is interested in any personal and medical data. It has no value.

The state of California has made such data files available for use for years. I know. I have obtained this data (over 2 million death certificates to be precise) and with it enabled research to be published that completely debunks the secret science of Dockery and Pope.

Fear of exposure of their research as faulty, if not fake, is why Dockery and Pope are so scared of producing their data for independent review.

To make these comments current, efforts have been made this month to obtain the Dockery and Pope data. But they continue to keep their data secret.

Given that the Dockery and Pope research and the related PM2.5 research has been funded by taxpayers – to the tune of more than $600 million dollars, and then this research is used to regulate the public, costing untold billions more dollars without providing any public health benefit — the conspiratorial hiding of this secret data is more akin to crime than science.

If EPA wants to regulate, that is fine. But the basis of and reasons for that regulation must be clearly laid out so their can be full and fair debate.

Harvard’s Doug Dockery and Brigham Young’s Arden Pope don’t want independent scientists to check their work for some reason. Dockery and Pope’s supporters may offer whatever excuses they like. But we all know what the reality is – fear of exposure.

But thanks to the Trump EPA, the days of secret science are coming to an end.


For more on EPA’s secret science, read: “Scare Pollution: Why and How to Fix the EPA.”

Dunn’s written comments to the rulemaking docket are here.