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Government Republicans Science Politics

House Approves Bill To Force Public Release of EPA Science (ap.org) 422

schwit1 quotes a report from Associated Press: House Republicans are taking aim at the Environmental Protection Agency, targeting the way officials use science to develop new regulations. A bill approved Wednesday by the GOP-controlled House would require that data used to support new regulations to protect human health and the environment be released to the public. Rep. Lamar Smith, R-Texas, said "the days of 'trust me' science are over," adding that the House bill would restore confidence in the EPA's decision-making process. Connecticut Rep. Elizabeth Esty and other Democrats said the bill would cripple EPA's ability to conduct scientific research based on confidential medical information and risks privacy violations by exposing sensitive patient data. The bill was approved 228-194 and now goes to the Senate. According to The Hill, "The bill would also require that any scientific studies be replicable, and allow anyone who signs a confidentiality agreement to view redacted personal or trade information in data."
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House Approves Bill To Force Public Release of EPA Science

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  • Sounds great! (Score:4, Insightful)

    by Anonymous Coward on Thursday March 30, 2017 @08:33PM (#54147911)

    Or should people be opposed to this because its a Republican administration?

    • Re:Sounds great! (Score:4, Informative)

      by Anonymous Coward on Thursday March 30, 2017 @08:49PM (#54147995)

      Sound Great when you just Post the Republican that pushed the Law side of the story.
      It means a lot of Common Science can not be used.
      Corporate Reports.
      Medical Research unless all the Patients are named.
      And the Congress limits what can be researched on the Public's Money.
      That leaves them controlling the outcome of certain research.

      So No it is Not that good.

      • Re:Sounds great! (Score:5, Informative)

        by Anonymous Coward on Thursday March 30, 2017 @10:50PM (#54148413)

        That is not what the bill does (read it here [congress.gov]). It is actually refreshingly concise and readable for a federal bill.

        In fact, the bill specifically does not require disclosure of personally-identifiable confidential information and allows that kind of information to be redacted. While there is a provision on allowing people who sign a NDA via a yet-to-be-developed EPA process to gain access to redacted data, the bill also clarifies that it does not and is not intended to supersede nondiscretionary statutory requirements (i.e. even the NDA process it describes cannot circumvent HIPAA privacy protections).

        The EPA can use "Common Science", reports from private parties, and medical research, but only if sufficient data is provided that the conclusions of the reports can be independently verified. Note that without this information, even the EPA cannot validate the conclusions of the reports it was using. The problem, therefore, is that without some kind of requirement like this, who and what EPA chooses to use as the basis for decision making is incredibly discretionary.

        There is nothing inherently wrong in providing an agency discretion, but this bill can be seen as blowback against EPA's efforts to brand itself as a science-based regulator, despite an incredible lack of scientific rigor within the agency. It is common to run into the sentiment that "X is too urgent/important to wait for the science to catch up" or "While we may lack the data/resource to collect the data to prove it scientifically, I know X is true". That would be perfectly understandable except you cannot run the agency on that level of discretion and simultaneously claim to be a science-based regulator with any expectation of credibility and legitimacy.

        They claim to be scientific. They're being held to a fundamentally basic standard of science. If they don't want to be held to basic standards of science, don't claim to be a science-based regulator. Nothing to see here.

        • Re:Sounds great! (Score:5, Insightful)

          by SandorZoo ( 2318398 ) on Friday March 31, 2017 @05:07AM (#54149493)

          The EPA can use "Common Science", reports from private parties, and medical research, but only if sufficient data is provided that the conclusions of the reports can be independently verified. Note that without this information, even the EPA cannot validate the conclusions of the reports it was using. The problem, therefore, is that without some kind of requirement like this, who and what EPA chooses to use as the basis for decision making is incredibly discretionary.

          Thanks for the link to the bill. The actual text for the bill reads "publicly available online in a manner that is sufficient for independent analysis and substantial reproduction of research results". How about things like ESA's Copernicus Programme [wikipedia.org] of Earth observation satellites? The data access requirements [esa.int] say that public online access is only available to a "rolling on-line archive covering the last month(s) of selected Sentinels core products". You need at least an "International Agreement" (whatever that is) to access the full data set. Does that mean the EPA can't use any science based on Copernicus/Sentinel data?

        • Re:Sounds great! (Score:4, Informative)

          by Stephan Schulz ( 948 ) <schulz@eprover.org> on Friday March 31, 2017 @07:52AM (#54150085) Homepage

          That is not what the bill does (read it here [congress.gov]). [...]Nothing to see here.

          What can be seen is “(5) The Administrator shall carry out this subsection in a manner that does not exceed $1,000,000 per fiscal year, to be derived from amounts otherwise authorized to be appropriated." In words, that is One Million Dollars [youtube.com], or, with overheads, maybe around 5 qualified employees. How much vetting of science and handling of NDAs do you think 5 people can do? Assuming you get someone qualified for such a mind-numbing job...

        • Re:Sounds great! (Score:4, Interesting)

          by rgbatduke ( 1231380 ) <.ude.ekud.yhp. .ta. .bgr.> on Friday March 31, 2017 @10:22AM (#54151283) Homepage

          If only I had mod points, I'd add to your +5 still further, sir AC. If only people who ranted above noted that no, it doesn't supercede HIPAA before making absurd allegations that it did, or that the EPA would itself be required to reproduce every piece of science it uses to arrive at its conclusions and rules, starting by reproducing Brahe's observations of planetary motion, Kepler's analysis, and Newton's solution just so it can use the law of gravitation when assessing the environmental impact of falling asteroids.

          It is actually HIGH TIME they were held to the basic standard of science, because as it is one cannot even fight its star chamber edicts. Now, is everything it does bad? Of course not -- this bill doesn't mean that either. It just means that when it SAYS something is bad, it has be able to show that it is bad based on actual data that anybody can look at, obtained with methods that are openly published, and it has to show in some equally scientific way that its remedies to the problem (that is now proven to actually exist and be objectively serious) are at least scientifically effective if not cost-effective. How can this be a problem? How can this be viewed as some unreasonable burden? If only we held ALL government activity to such a standard! Drug laws would vanish overnight. People of alternative sexual orientation would be loudly ignored until and unless it is demonstrated scientifically that their sexual proclivities involve blood sacrifice of babies. But the commons could and will still be protected -- dumping mercury into our drinking water is an objectively demonstrably bad thing all the way down to some very small level indeed, and this permits cost-benefit analysis to be conducted on an objective basis.

          Since even now a huge fraction of the artificial light we use comes from exciting mercury vapor (in both my laptop and the overhead lights in my office at this instant, for example) this issue is extremely relevant. In the real world we have to trade off many evils in order to realize a greater good. If we use incandescent lighting, the bulbs themselves have little impact but we literally burn a lot more stuff and spend in the long run a lot more money. If the EPA had completely banned mercury use ANYWHERE because all mercury used in e.g. a light bulb sooner or later makes its way into the water and/or biosphere, then we would have burned a lot more coal over the decade or so where CFL bulbs were available in parallel with incandescent. Coal (in addition to containing mercury on its own) releases bad things that cost money to remove and aren't always fully removable, and has an ecological cost to the commons mining it. It isn't OBVIOUS how to balance the interests, the costs, and the benefits here, but doing it without full transparency and open public debate is not a good solution no matter how good your intentions. The advent of LED bulbs makes this even more complex, as the LEDs are themselves doped with still OTHER toxic metals (less toxic than mercury, fortunately). They also use still less energy, and as economy of manufacturing scale kicks in so they are overwhelming cheaper as well in even a pretty damn short run, they will probably obsolete all other forms of bulb except for a few special use cases in short order, with or without regulation.

          The point of which is, that decisions in the public interest, even ones in defense of the commons, are not necessarily "simple" -- they involve cost-benefit tradeoffs and often hurt a lot of people even as they (perhaps) help the majority. Government agencies in general, and to be frank government LAWS in general, should ALL be based on transparent, openly debated from a common set of assumptions and data, reasoning.

          I'm frankly hopeful that this law, if passed, can be used to challenge each and every regulation throughout government based on religion. Republicans might find that what is really good medicine for all government agencies in their decision making process tastes bitter to them as it is even BETTER medicine for the legislative process itself.

    • Re: (Score:3, Insightful)

      by Rei ( 128717 )

      Sounds like a bill based on an understanding of science from people who've never worked in a scientific field. All research affected by HIPAA would be banned by this bill. Which is the majority of medical research. All research involving external sources of proprietary data - which no researchers like using, but sometimes you have no choice - would also be banned.

      And furthermore, not all research is reproducible. "Hey, I just detected the highest energy cosmic ray collision ever in my detector, here's my p

      • And furthermore, not all research is reproducible.

        Quite true, but what non-reproducible research is necessary for writing regulations? Even when the data is incidents and accidents that no one wants to reproduce, the research itself is reproducible by redoing the analysis.

      • All research affected by HIPAA would be banned by this bill.

        No. If it is not personally identifiable, you can publish it. EPA could still use a paper, that says, for example, "Of the 5000 people exposed to such-and-such-sulfate, 537 developed such-and-such-iasis." As long as it does not identify the patients.

        Indeed, if doing research in the first place and making it available to the EPA was not in violation of HIPAA (or, rather, HITECH [wikipedia.org]) privacy rules, the EPA can publish it further.

        To pretend, this is abo

        • by drew_kime ( 303965 ) on Friday March 31, 2017 @12:13AM (#54148703) Journal

          But we already know another blatant mistake of the governments, which has lead to the explosion of the obesity epidemics and millions of premature deaths — the War on Fat [time.com]. And on cholesterol [foxnews.com] — though manufacturers are still marketing "low cholesterol" foods, the government's current stance is Cholesterol is not a nutrient of concern for overconsumption [health.gov]...

          I'm with you so far.

          Though Americans — and other nations following America's lead — grew obese, no one was punished for that mistake [pbs.org].

          Umm, maybe. Who do you think should be punished? The scientists? They were saying at the beginning of the War on Fat that the science was inconclusive. It was the politicians who said [youtube.com], "We don't have time to wait for facts. We need to act."

          Without any accountability for the FDA personnel even when the fault is obvious, what is there to restraint the EPA? What "checks and balances" are there to prevent them from banning anything another "charismatic and confident" doctor [theguardian.com] suggests to ban without much proof?

          I see how you can get there. But as I said, the problem wasn't with the scientists. It was the politicians pushing the agenda, and the sugar industry funding it [nytimes.com].

          The "Trust Us" science is junk science — and Congress is absolutely right to fight it, even if they are too chicken to abolish the EPA altogether [nbcnews.com].

          And that's where you go off the rails. In the case of fat, there was heavy industry lobbying in favor of a position that scientists said was unsupported by current research. We now know that it wasn't just unsupported; it was wrong.

          In the case of environmental regulations, the industry money is all lining up to say we don't need to reduce fossil fuel use. And the vast majority of scientists are saying that the science is settled, and it goes against what industry is pushing.

          But my biggest gripe with your solution is the suggestion that if the EPA isn't perfect, the solution is not to fix it but to abolish it. That's a common solution for certain advocacy groups (and political parties) who know that it's a lot easier to destroy programs that benefit society than it is to build them.

          • Abolish EPA (Score:5, Informative)

            by mi ( 197448 ) <slashdot-2017q4@virtual-estates.net> on Friday March 31, 2017 @01:15AM (#54148897) Homepage Journal

            Who do you think should be punished?

            I, actually, didn't say, somebody should be. What I said was, since no one was, there is nothing to hold the EPA in check...

            The scientists? They were saying at the beginning of the War on Fat that the science was inconclusive.

            Not according to Guardian [theguardian.com]:

            Ancel Keys was brilliant, charismatic, and combative. A friendly colleague at the University of Minnesota described him as, “direct to the point of bluntness, critical to the point of skewering”; others were less charitable. He exuded conviction at a time when confidence was most welcome. The president, the physician and the scientist formed a reassuring chain of male authority, and the notion that fatty foods were unhealthy started to take hold with doctors, and the public. (Eisenhower himself cut saturated fats and cholesterol from his diet altogether, right up until his death, in 1969, from heart disease.)

            But as I said, the problem wasn't with the scientists. It was the politicians pushing the agenda

            Stipulating for a second, the scientists were innocent and it were all the politicians at fault at the FDA, how is the EPA different? That is, what did happen at the FDA, that does not and will not happen at the EPA?

            It was the politicians pushing the agenda, and the sugar industry funding it [nytimes.com]

            Wrong. First of all, your link describes (with the weaselese "may have" rather than firm "has") such efforts, which ended in 1967 — USDA's "dietary guidelines" denouncing fat were published only in 1980ies [shape.com]. And second, the "sugar industry", according to your link, didn't lobby the politicians — instead, they paid scientists. And it was hardly a massive bribe — the three scientists from Harvard were paid an equivalent of today's $50,000 to publish a paper, which the believed to be valid.

            In other words, the smart assholes at NYTimes realized what massive egg is on the Big Government's face and wanted to create some smokescreen for it to shift the blame towards the Greedy KKKapitali$t$, but failed. Well, almost failed — you fell for it...

            In the case of fat, there was heavy industry lobbying in favor of a position that scientists said was unsupported by current research

            You aren't citing any sources and I call bullshit. Why would industry lobby — heavily! — for a major overhaul of its production lines? The "fat free" stuff is not any cheaper, the margins on it aren't specifically higher, while developing it requires work and brings about uncertainty. No. Once the demand was there, the industry responded to satisfy it — praise be to Capitalism — but it made no sense for anyone to lobby for it...

            the suggestion that if the EPA isn't perfect, the solution is not to fix it but to abolish it. [...] a lot easier to destroy programs that benefit society

            My argument is, the EPA does not "benefit society". If only for this reason — they can ban and banish anything they please willy-nilly... We already have toilets, that don't flush (even the EPA themselves admit [epa.gov] such problems "in earlier models") and dishwashing machines, that do not wash dishes [cnsnews.com]. In a rush for "renewable energy", we

            • by Raenex ( 947668 )

              My argument is, the EPA does not "benefit society".

              Disagree. The EPA was created by the Nixon administration amid protests about the quality of the environment, in particular our water and air. Things have improved a lot since then. You can compare that to the industrial hellholes that existed in the Soviet era or China's industrial binge.

              Sure, the EPA can go off the rails, and hopefully Trump can reign it in without doing too much damage, but I think we need its basic functionality.

              • Re:Abolish EPA (Score:4, Interesting)

                by mysidia ( 191772 ) on Friday March 31, 2017 @07:59AM (#54150127)

                Things have improved a lot since then. You can compare that to the industrial hellholes that existed in the Soviet era or China's industrial binge.

                I think if we roll back the last 20 years of ADDITIONAL EPA regulation and expansion, we should be good, and we won't be a hellhole.
                Trouble is the EPA SOLVED those problems it was created to solve, Then like all bureaucracies its leadership decided to keep expanding and make more and more rules beyond its original and appropriate scope. They're not being paid to keep donig exactly what they're doing... Any person who is acting as a Leader/Committee person sees their agency's role to be constantly doing more than what they've been doing.

          • "In the case of environmental regulations, the industry money is all lining up to say we don't need to reduce fossil fuel use. And the vast majority of scientists are saying that the science is settled, and it goes against what industry is pushing."

            Except for the green lobby and the majority of federal politicians for the last 12 years who funneled billions of dollars to fund "green" jobs that never materialized and a global warming crisis that became a climate change crisis that became a nothing story...

      • I believe you've carefully danced around the key point of the issue: EPA. Congratulations!
      • Sounds like a bill based on an understanding of science from people who've never worked in a scientific field. All research affected by HIPAA would be banned by this bill. Which is the majority of medical research. All research involving external sources of proprietary data - which no researchers like using, but sometimes you have no choice - would also be banned.

        no
        HIPAA provides for anonymizing records for research heres the guidelines https://www.hhs.gov/hipaa/for-... [hhs.gov]

        And furthermore, not all research is reproducible. "Hey, I just detected the highest energy cosmic ray collision ever in my detector, here's my paper showing proof of the detection!"

        If the EPA wants to regulate cosmic rays let me know I need a laugh. Anything that will need regulation will inherently be reproducible if it's not it's B.S. not science.

        Nice try.

  • by Anonymous Coward on Thursday March 30, 2017 @08:40PM (#54147957)

    While they are at it, how about all tax payer funded research be open to US citizens and allies.

  • Ooh, does this mean House Republicans will start reading the science now? And having confidence in the EPA decision-making process? Yay for transparency!

    • by parallel_prankster ( 1455313 ) on Thursday March 30, 2017 @08:58PM (#54148035)

      Nope, thats not it at all. This is because they will put up some excuse and create "alternative facts" over everything the EPA does so as to pretty much destroy the EPA if they have not already done so. Only an idiot would think that Republicans, especially this administration, cares about science!

    • by whoever57 ( 658626 ) on Thursday March 30, 2017 @10:04PM (#54148253) Journal

      No, it's the opposite.

      This is a clear anti-renewable energy move.

      Some of the climate science relies on non-free information. Since it cannot be released, no regulations that depend on this data can be promulgated.

      • Some of the climate science relies on non-free information. Since it cannot be released, no regulations that depend on this data can be promulgated.

        Aha. So despite the fact that even the summary addresses this, you are still peddling this lie? Here's from the summary:

        allow anyone who signs a confidentiality agreement to view redacted personal or trade information in data

        The gist of the law is to allow anyone verify that the data on which research is based can actually yield the outputs given the stated methodology. Otherwise, it's garbage-in-garbage-out.

        • Here's from the summary:

          allow anyone who signs a confidentiality agreement to view redacted personal or trade information in data

          Right. If a government agency wants to publish, they must agree to release the data to anyone who signs the NDA.

          And if the original research was not done by that government agency, then they may not have the authority to release that data.

          So if they aren't allowed to release the data, they aren't allowed to publish the data.

          • by superwiz ( 655733 ) on Friday March 31, 2017 @12:49AM (#54148823) Journal
            Then why would you trust that their methodology leads to the results they claim? If it can't be independently verified, it's not science. This model may be used for commercial purposes because trade secrets are the norm. But it breaks down when it comes to public policy. You can't have public policy based on data you can't verify. There is no way to verify that the data wasn't doctored to fit a model or that the model was not applied erroneously. Garbage-in-garbage-out is ok if you are willing to carry the cost of it. But when the cost is to be carried by the general public, it has the right to see the data. If that means that the payment model for the data has to change, then this has to be accounted-for in the grants.
          • Just so we are clear, there is already a lot of the data which is not available for public examination. Insurance companies don't have to justify the data to which they apply their actuarial models, for example. But they carry burden of having to apply the models correctly because they suffer the cost of mistakes (at least in theory). So it maybe overall that some data will not be available for EPA research. But since it's such a large customer, it's more likely that the data will just have to be purcha
  • I hope the released science info is validated and that politicians actually believe the EPA's claims.

  • by Kwyj1b0 ( 2757125 ) on Thursday March 30, 2017 @09:32PM (#54148131)

    Rep. Lamar Smith, R-Texas, said "the days of 'trust me' science are over," adding that the House bill would restore confidence in the EPA's decision-making process.

    While I agree with the idea that any science conducted should be available to the public that pays for it, it seems like the current proposal is a stepping stone to (a) Allow lay persons (or even entire industries with paid "scientists") to challenge the results, and (b) delay the process of making new regulations by requiring the agency to jump through hoops (both in responsible releasing of confidential data, and providing enough evidence to justify their conclusions).

    Science isn't a democracy, and this proposal will only make it harder for any regulations to be implemented. Even with a majority of scientists on one side of the fence, lawmakers are fighting environmental regulations tooth and nail. So this clearly isn't about improving regulations through good science, it is about creating more noise that allows a politician to justify their (pre-selected) bad position on scientific issues. I can just see a politician saying that he read 100 facebook posts by citizen-scientists disproving the EPA experts' conclusions, and that is why a ban on setting up oil refineries in national parks should be repealed.

    • > a stepping stone to (a) Allow lay persons (or even entire industries with paid "scientists") to challenge the results

      That certainly sounds good. Everyone can see the data discuss the analysis, see if it holds up to scrutiny, and often see other, completely unexpected information revealed in the data. Quite often, when I graph data looking for a relationship between X and Y, I'm surprised to find a clear relationship between X and Q, new information I didn't even know to look for.

      > and (b) delay t

      • by serviscope_minor ( 664417 ) on Friday March 31, 2017 @03:13AM (#54149193) Journal

        That certainly sounds good. Everyone can see the data discuss the analysis, see if it holds up to scrutiny, and often see other, completely unexpected information revealed in the data

        Lol no. Sure it's designed to look like that on the surface, but Rep Lamarr is hardly going to have a bill called "Rep Lamarr is a cunt bill". Rep Lamarr is a flat-out denialist and he's been trying to hamstring the EPA for ages because he doesn't believe science. The climate is (a) changing and (b) we're the primary cause. Science showing this result have already been replicated numerous times with many sources of data and you personally getting access to the exact set that the EPA uses is not going to change a thing.

        Rep Lamarr is deeply anti science, and if he's put this forward as a good thing then you should bee deeply suspicious of it because it's not designed to promote science, it's designed to suppress scientific results that he personally wishes were otherwise.

    • by AmiMoJo ( 196126 )

      Bingo. It's about making it easier to generate "alternative facts" and "interpretations" of the results. It also allows them to reject a lot of climate science, because we can't build a second Earth to reproduce results on.

  • Mythbusters (Score:5, Interesting)

    by PopeRatzo ( 965947 ) on Thursday March 30, 2017 @09:48PM (#54148203) Journal

    1) The EPA's science is already released publicly.

    2) This bill requires the data to be released publicly.

    3) The EPA's data is already released publicly.

    On February 22, 2013, the White House Office of Science and Technology Policy (OSTP) directed federal agencies that conduct research to develop plans ensuring peer-reviewed publications in scientific journals and related digital scientific research data resulting from federally-funded scientific research are accessible to the public.

    February 22, 2013.

    • Re:Mythbusters (Score:5, Informative)

      by ooloorie ( 4394035 ) on Thursday March 30, 2017 @11:49PM (#54148651)

      Right now, that is a presidential directive that can be revoked whenever the president feels like it. Putting this into law will ensure that it will happen under future presidents as well.

    • On February 22, 2013, the White House Office of Science and Technology Policy (OSTP) directed federal agencies that conduct research to develop plans ensuring peer-reviewed publications in scientific journals and related digital scientific research data resulting from federally-funded scientific research are accessible to the public.

      If they conduct the original research, yes. But they will no longer be able to cite anyone else's research. Will the EPA's budget be increased sufficiently that they can perform original research to duplicate all that is currently performed by other entities?

    • Re:Mythbusters (Score:5, Interesting)

      by ShakaUVM ( 157947 ) on Friday March 31, 2017 @01:14AM (#54148893) Homepage Journal

      >develop plans

      Says it all. This bill will actually implement it. It's a good thing. And it can't be overriden by Trump, which is also good.

      The Replicability Crisis (https://en.wikipedia.org/wiki/Replication_crisis) is the most serious issue in modern day science. When 70% of published papers can't be reproduced, that means that you are making the correct bet to believe that any published, peer-reviewed, landmark study in a prestigious journal is wrong. And that's a very sad thing that I just had to write. But this is what happens when people set up a system that works the way ours does - people game the system and the trust and credibility of science is hurt by it.

      So yeah. We really, really need to be pushing hard for public datasets and replicability of results.

      If I were the head of the NSF, I would treat any paper that has not been replicated yet as tentative, and only accept it as a scientific finding until it has been repeated at least once by a third party.

  • by rsilvergun ( 571051 ) on Thursday March 30, 2017 @10:02PM (#54148243)
    Congressmen don't write their own bills, especially corrupt ones like this, so I'm not going to chalk this up to stupidity. It makes me wonder what bit of nastiness is behind all this...
  • The EPA has left harmful regulations in place for decades, which caused 1600 unnecessary deaths [nytimes.com] at Fukushima, and countless more [thebreakthrough.org] by helping suppress the most effective source of clean energy. While renewables may capture the limelight, the leading source of new energy worldwide is coal, and it is growing far faster.

    Present radiation regulations are based on bad science. [atomicinsights.com] The linear no threshold hypothesis is provably false today, and counter evidence already existed even at the time of its adoption. Since

  • . . . . paid for by taxpayers, released to the public ??

  • by fygment ( 444210 ) on Friday March 31, 2017 @06:45AM (#54149789)

    Forcing publicly financed science to be made ... public.
    Demanding that results be replicable?

    In what universe are these things wrong? Finally some measure of a move to try to ensure that any policies that are spawned are actually based on real science.

  • by account_deleted ( 4530225 ) on Friday March 31, 2017 @07:57AM (#54150115)
    Comment removed based on user account deletion
  • by kingramon0 ( 411815 ) on Friday March 31, 2017 @09:47AM (#54150899) Homepage

    But reading the actual text of the bill, it seems to me that it only requires that enough information be publicly available so that the research being used *can* be reproduced, not that it *shall* be reproduced. I don't think it is making it mandatory to replicate the research before it is used in rule-making, but that the information be available in case someone wants to try to reproduce it at any future date.

Keep up the good work! But please don't ask me to help.

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