The Small Business Administration (SBA) is the source of some controversial language in a climate change memo sent from the White House Office of Management and Budget (OMB) to the EPA, according to news reports.

An official from the SBA Office of Advocacy, “The voice for small business in the Federal Government,” objected to the potential costs of regulating greenhouse gas emissions under the Clean Air Act. Apparently, the official is a holdover from the Bush administration.

OMB Director Peter Orszag said the memo was a compilation of comments from other agencies in the executive branch including, evidently, SBA.

According to EPA’s online docket, the memo was posted for all to see on April 24. To the best of my knowledge, I was the first person to find and comment on the now-notorious, unsigned, undated memo (see my April 29 post). This information went unnoticed for several days until two news services picked it up.

Then, some Republicans used the memo to bash EPA Administrator Lisa Jackson for ignoring the concerns raised in the memo. Some environmental advocates criticized reporters (and me as well) for giving Republicans ammunition and for failing to put the document in the proper context: When OMB reviews agency regulatory actions, it is routine for other agency officials to comment, and those comments do not necessarily reflect the position of the White House or the administration at large – though they can influence policy.

So what’s the lesson here? Sometimes, transparency is about quality, not quantity. EPA’s online docket for the endangerment finding is filled with hundreds of documents. But for documents related to OMB’s review of the finding, it is impossible to know who made what suggestions, comments, or edits, and it is difficult to know when they were made.

Yesterday, OMB Watch submitted comments to the White House on ways to enhance scientific integrity in government. Since EPA’s endangerment finding is predicated on scientific conclusions that global climate change is anthropogenic, the controversy over the interagency memo is in some respects a scientific integrity issue. Better transparency could have solved the mysteries of this document at an earlier stage. From our recommendations:

Agencies should make publicly available substantive written communications made between and among agencies, including White House offices (such as the Office of Information and Regulatory Affairs), regarding scientific results, conclusions, or policy. Substantive communications would be any exchanges that discuss findings, edits or changes to reports, policy options or recommendations, interpretation of results, prioritization of goals, or reasoning for government actions or decisions. Agencies should clearly indicate the officials communicating and the date of communication. 

As the Obama administration reviews scientific integrity and regulatory policies, I hope, and expect, it will make transparency a priority. But putting documents online is not enough, and, as the endangerment finding memo shows, it benefits neither the public nor the administration. Everyone would be better off if OMB and agencies released information with the kind of specificity outlined in our recommendations.

The controversy also highlights the inherent flaws in OMB/interagency review. OMB says it did not write the memo in question, it merely collected the comments of others. But it doesn’t really matter whether it was OMB, SBA, or another agency entirely. Some administration official, without relevant expertise on climate science and likely without detailed knowledge of the Clean Air Act, objected to a document that had been fully vetted inside the EPA and questioned decisions made on solid legal and scientific footing. The objections were probably quickly brushed aside by those who know better, but at a time when the federal government faces so many challenges, officials shouldn’t have to waste even a second dealing with such nuisances.