Yesterday I sent a comments letter to the Environmental Protection Agency (EPA) detailing the U.S. Chamber's concerns with their Draft Guidance on the Development, Evaluation and Application of Environmental Models.  From the letter:

Specifically, the Chamber is concerned about EPA’s guidance concerning the development, evaluation, and application of proprietary environmental models. The public is not well served when EPA continues to use public funds to develop proprietary models, a practice that foments public skepticism and mistrust. This practice should be abandoned, and the Guidance Document should make this point unambiguously clear. If this is not done, EPA staff will be led to believe that it is okay to continue to fund the development (the original formulation or revision in part or in whole) of proprietary models with public funds and EPA staff will continue to do so, thereby perpetuating modeling secrecy that has caused so much public doubt about the integrity of the modeling process.
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In these comments, "proprietary models" means models as described by The National Academies Board on Environmental Studies and Toxicology (NA-BEST):

A model is proprietary if any component that is a fundamental part of the model’s structure or functionality is not available for free to the general public.

NA-BEST explains further:

The use of proprietary models in the regulatory process can produce distrust among regulated parties and other interested individuals and groups because their use might prevent those affected by a regulatory decision from having access to a model that may have affected the decision.

In the document we go into greater detail about the problems with proprietary modeling and request four modifications be made to the Guidance Document.  Here is the letter in full.

Transparency and accuracy in modeling is particularly important given the regulatory labyrinth which the EPA sets out in its Advance Notice of Proposed Rulemaking to regulate greenhouse gases under the existing Clean Air Act.

We are educating Congress and the American people on the expensive and expansive regulatory regime the EPA is trying to create, today we look at boats.

      

Tell Congress to take action today!