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Re: EPA's Draft Guide To Analyzing Environmental Innovations Out For Comment



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In her EvalTalk post of 27 Oct 2004, Katherine Dawes (2004), Director of
Evaluation Support Division for the US EPA, wrote:

" 'Innovation Analysis' is one of EPA's major drivers for program evaluation,
and so we're working to develop sound approaches to data collection and
analysis. Our "Guide to Analyzing Environmental Innovations" is one
tool that we hope will improve EPA's evaluation capacity. Please see
the description below for more details. We welcome any comments and
perspectives you might care to share."

In the "description below" it is stated that [bracketed by lines
"EPA-EPA-EPA. . . "]:

EPA-EPA-EPA-EPA-EPA-EPA-EPA-EPA-EPA-EPA-EPA-EPA
The U.S. Environmental Protection Agency's National Center for
Environmental Innovation (NCEI) promotes the use of innovative
approaches to environmental problem-solving efforts that deliver
improved environmental results. As part of this process, the
Evaluation Support Division (ESD) within NCEI promotes and conducts
rigorous evaluations to determine whether innovations deliver
environmental results that surpass the traditional way of doing
business and to identify lessons that can be applied more broadly.

On October 25, 2004, ESD announced in the Federal Register the availability
of a Guide To Analyzing Environmental Innovations. Because the field of
environmental program evaluation is fairly young, and EPA did not have one
comprehensive method for evaluating innovation projects, ESD produced a
"Companion User's Guide" and corresponding questions in a modular format
called, "Modular Approach to Analyzing Environmental Innovation," to help
innovation practitioners analyze environmental innovations. The analysis
modules include a series of questions that encourage critical thinking and
assessment of successes, obstacles and lessons learned. The modules can be
applied in a variety of scenarios, including developing an innovative
project, informing future evaluation efforts, assessing environmental
outcomes, and evaluating the potential transferability of an
innovation. The modules and user's guide are available on EPA's
website
<http://www.epa.gov/evaluate/module.htm>:

1. Innovation Analysis Modules - 16 pages
<http://www.epa.gov/evaluate/modules1.pdf> (244 kB),

2. Companion User's Guide - 38 pages
<http://www.epa.gov/evaluate/moduleguide.pdf> (624 kB),

3. Innovation Analysis Module Fact Sheet - 3 pages
<http://www.epa.gov/evaluate/evalmodules.pdf> (77 kB).

ESD is looking for comments on the applicability of the tool and
whether it is flexible enough to meet performance measurement and
analytical needs of a variety of environmental innovations. Please
note that the notice does not solicit applications nor mandates the
use of the guide or module questions in innovative projects and
programs.

OUR DEADLINE FOR COMMENTS IS NOVEMBER 30, 2004.
EPA-EPA-EPA-EPA-EPA-EPA-EPA-EPA-EPA-EPA-EPA-EPA

In addition to soliciting comments on the "Innovation Analysis
Modules," I suggest that the EPA and other interested parties
consider evaluating the Modules by using them to assess recent EPA
actions, such as, e.g.:

1. The EPA study that concluded that there was no evidence that
hydraulic fracturing posed a threat to drinking water [Hamburger &
Miller (2004a,b); Hake (2004a); GMRS (2004b)].

2. EPA's decision to delete any mention of global warming from its
draft Report on the Environment [UCS (2004c), OMB Watch (2004), CGRMS
(2004c.]

3. The EPA' use of industry drafted language in its latest ruling on
mercury emissions [UCS (2004d)].

4. EPA's decision to withold publication of its study showing that
the Carper/Gregg/ Alexander/Chafee Senate bill would reduce sulfur
dioxide, nitrogen oxides, and mercury pollutants earlier and in
larger quantities than the Clear Skies Act, result in 17,800 fewer
expected deaths by 2020, and reduce carbon dioxide emissions at
"negligible" cost to industry. [UCS (2004e)].

5. EPA's report stating that "hormone disruption cannot be considered
a 'legitimate regulatory endpoint at this time'" and is not an
acceptable reason to restrict a chemical's use, evidently the result
of a petition by a Washington consultant working with atrazine's
primary manufacturer, Syngenta Crop Protection. That petition was
filed under the OMB's "Data Quality Act." [Wiess (2004), Hake
(2004b)].

Richard Hake, Emeritus Professor of Physics, Indiana University
24245 Hatteras Street, Woodland Hills, CA 91367
<rrhake@earthlink.net>
<http://www.physics.indiana.edu/~hake>
<http://www.physics.indiana.edu/~sdi>

REFERENCES
Dawes, K. 2004. "EPA's Draft Guide To Analyzing Environmental
Innovations Out For Comment," EvalTalk post of 27 Oct 2004
16:00:41-0500; online at
<http://bama.ua.edu/cgi-bin/wa?A2=ind0410d&L=evaltalk&T=0&O=D&X=7717F2499A742C860C&Y=rrhake@earthlink.net&P=5485>.
The encyclopedic URL indicates that EvalTalk is one of the few
discussion lists whose archives are closed to non subscribers :-( -
WHY ??. However, it takes only a few minutes to subscribe by
following the simple directions at
<http://bama.ua.edu/archives/evaltalk.html> / "Join or leave the list
(or change settings)" where "/" means "click on." If you're busy,
then subscribe using the "NOMAIL" option under "Miscellaneous." Then,
as a subscriber, you may access the archives and/or post messages at
any time, while receiving NO MAIL from the list!

CGRMS. 2004a. Committee on Government Reform - Minority Staff (Special
Investigations Division) <http://www.house.gov/reform/min/>, U.S.
House of Representatives, "Politics and Science: Investigating the
State of Science Under the Bush Administration," online at
<http://democrats.reform.house.gov/features/politics_and_science/index.htm>,
see especially topics under "Environment" in the left hand column:
Yellowstone, Agricultural Polution, Artic Drilling, Environmental
Committees, Oil and Gas Practices, Protecting Wetlands, and Global
Warming Sciences."

CGRMS. 2004b. "Research on Oil and Gas Practices," online at
<http://democrats.reform.house.gov/features/politics_and_science/example_oil_and_gas.htm>.
This is part of CGRMS (2004a).

CGRMS. 2004c. "The Science on Global Warming, online at
<http://democrats.reform.house.gov/features/politics_and_science/example_global_warming.htm>.
This is part of CGRMS (2004a).

Hake, R.R. 2004a. "The Hydraulic Fracturing Fracas," PHYSOC post of
15 Oct 2004 15:20:36-0700; online at
<http://listserv.uark.edu/scripts/wa.exe?A2=ind0410&L=physoc&O=D&X=4FB314066B2B6DCD11&Y=rrhake@earthlink.net&P=1021>.Copies
part of Hamburger & Miller (2004a). The encyclopedic URL indicates
that PHYSOC is one of the few discussion lists whose archives are
closed to non subscribers :-( - WHY ??. However, it takes only a few
minutes to subscribe by following the simple directions at
<http://listserv.uark.edu/archives/physoc.html>/ "Join or leave the
list (or change settings)" where "/" means "click on." If you're
busy, then subscribe using the "NOMAIL" option under "Miscellaneous."
Then, as a subscriber, you may access the archives and/or post
messages at any time, while receiving NO MAIL from the list!

Hake, R.R. 2004b. "Re: Data Quality Act," PhysLrnR/EvalTalk/PHYSOC
post of 17 Aug 2004 17:38:06-0700; online at
<http://listserv.uark.edu/scripts/wa.exe?A2=ind0408&L=physoc&P=R1989&X=43B3A96A72042760CB&Y=rrhake@earthlink.net>.
The appendix contains a copy of Weiss (2004).

Hamburger, T. & A.C. Miller. 2004a. Hamburger & Miller write: The
administration has lent support to a lucrative drilling technique.
Some in the EPA consider it an environmental concern," Los Angeles
Times, 14 October; freely online (for a few days) at
<http://www.latimes.com/news/politics/la-na-frac14oct14%2C1%2C33390.story?coll=la-home-headlines>.
See also Hamburger & Miller (2004b) and Hake (2004a).

Hamburger, T. & A.C. Miller. 2004b. "Investigation of Drilling
Regulations Is Urged: Lawmakers want an explanation for EPA's stance
on hydraulic fracturing, used widely by former Cheney employer
Halliburton. Los Angeles Times, 15 October; formerly freely online at
<http://www.latimes.com/news/nationworld/nation/la-na-frac15oct15,1
5831880.story>; abstract only is now freely available by searching
for "Hamburger" at <http://pqasb.pqarchiver.com/latimes/search.html>.

OMB Watch. 2003. "Multi-Agency Data Quality Challenge on Global
Warming Includes the EPA," online at
<http://www.thecre.com/misc/20040606_multiagency.htm>: "The
Competitive Enterprise Institute (CEI) submitted a data quality
petition Feb. 10 to the Environmental Protection Agency (EPA)
challenging global climate change information. The CEI petition seeks
withdrawal of the Climate Action Report 2002 (CAR) which relies on
the National Assessment on Climate Change (NACC), the inter-agency
technical document that underlies most of the federal government's
recent statements about global climate change. . . . A troubling
aspect of this data quality challenge is that CEI seeks to "correct"
this information by prohibiting the government from disseminating the
NACC."

UCS 2004a. "Scientific Integrity in Policy Making: An Investigation
into the Bush Administration's Misuse of Science," online at
<http://www.ucsusa.org/global_environment/rsi/page.cfm?pageID=1322>.
See especially the right hand column "Cases - Environment": Deleting
Scientific Advice on Endangered Salmon; Endangered Species: Florida
Panther, Bull Trout, Trumpter Swans; Mountaintop Removal Mining;
Climate Change; Mercury Emissions; Multiple Air Pollutants; The
Endangered Species Act; Forest Management. The full report is
available as a pdf at this site. See also UCS (2004b).

UCS. 2004b. "New Cases of Scientific Abuse by Administration Emerge:
Thousands More Scientists Join Protest," News from the Union of
Concerned Scientists, 8 July; online at
<http://www.ucsusa.org/news/press_release.cfm?newsID=405>.

UCS. 2004c. "Climate Change Research Distorted and Suppressed," online at
<http://www.ucsusa.org/global_environment/rsi/page.cfm?pageID=1363>.
This is part of UCS (2004a).

UCS. 2004d. "Information on Power Plant Mercury Emissions Censored," online at
<http://www.ucsusa.org/global_environment/rsi/page.cfm?pageID=1364>.
This is part of UCS (2004a).

UCS. 2004e. "Multiple Air Pollutants Information Censored," online at
<http://www.ucsusa.org/global_environment/rsi/page.cfm?pageID=1365>.
This is part of UCS (2004a).

Weiss, R. 2004." 'Data Quality' law is nemesis of regulation,"
Washington Post, Aug. 16, online at
<http://www.washingtonpost.com/ac2/wp-dyn/A3733-2004Aug15?language=printer>
This article was also copied into the Appendix of Hake (2004b).