Summary: EPA failed to properly validate the "major scientific assessments" underlying EPA's 2009 GHG CAA Section 202(a)(1) Endangerment Findings and the Third National Climate Assessment which EPA now relies upon as primary support for its proposed power plant rule. Since the peer reviews of these assessments did not conform with the Information Quality Act and relevant binding OMB and EPA IQA-implementing guideline conflicts-of-interest, financial and intellectual independence and peer review panel balance standards, the agency is precluded from relying up them until they are peer reviewed again.
The ITSSD has engaged in public outreach via disclosed correspondence to the following governmental and nongovernmental entities: the U.S. House of Representatives Committee on Science, Space and Technology (113th Cong.); the Senate Committee on Foreign Relations (111th Cong.); the U.S. Mission to the United Nations; the U.S. Senate Committee on Environment and Public Works (109th, 113th Cong.); the U.S. House Committee on Science, Subcommittee on Environment, Technology and Standards (109th Cong.); the U.S. Environmental Protection Agency, U.S. Department of State, Office of the Legal Adviser; and the American National Standards Institute ("ANSI").
Summary: This ITSSD correspondence and accompanying Annex cites nominee Koh's views on three different international law issues and concludes that such views could arguably threaten U.S. legal, political and economic sovereignty, U.S. individual including private property) rights, and ultimately, U.S. national security.
Summary: This ITSSD correspondence to U.S. Ambassador John Bolton identified and explained the practice of legal 'regime shifting' undertaken by certain UN member states within various UN agencies as a supplement to 'soft' law development for the purpose of establishing new global regulatory standards potentially inimical to U.S. national interests.
Summary: This correspondence from U.S. Senator James Inhofe expresses interest and support for ITSSD research efforts to examine how other countries are reading a broader than agreed upon version of the Precautionary Principle into the UNCLOS text, and the likely impact that such interpretation, coupled with U.S. UNCLOS accession, would have on U.S. national security and economic and technological competitiveness.
Summary: This testimony describes the various ways in which the European Union is employing and exporting around the world regional environment, health and safety (sustainable development-focused) regulations guided by the hazard-based Precautionary Principle to gain geopolitical leverage and a regulatory, and thus, economic comparative (trade-competitive) advantage vis-a-vis the U.S.
Summary: This correspondence identifies and describes the international dimensions of the Northeast Regional Greenhouse Gas Initiative ("RGGI"), in particular, how the European Union was invited to provide 'lessons learned' and assistance in shaping said regime.
Summary: These comments respond to the seven proposed ANSI initiatives to promote transparent voluntary, consensus-based, market-driven international industry-based standards, and discusses cross-cutting issues which, though not addressed in the USSS, must be carefully reviewed to protect and preserve U.S. international economic interests.
Issue Date Description
Library - Public Correspondences
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INSTITUTE FOR TRADE, STANDARDS AND SUSTAINABLE DEVELOPMENT