FFA’s petition recognizes the crucial role of OMB’s Peer Review Bulletin in implementing the DQA and raises conflict of interest questions regarding FWS’s peer review process. As FFA explains, "The Final Bulletin specifically requires certain conflict of interest standards be met in peer review of highly influential scientific assessments. Those standards were not met by the peer review document disseminated with the Effects Analysis. Two of the reviewers were either authors of papers upon which the BO is based and/or receive funding or commissions from the government agencies which authored the Effects Analysis."

Among the FFA’s petition requests are that "the Effects Analysis...include a discussion of the limitations of existing climate models" and that the "Effects Analysis... recognize that climate change will occur independent of Project operations, and thus is not an ‘effect’ of the Projects."

FWS has a record of taking seriously their responsibilities under the Data Quality Act. For example, FWS took multiple corrective actions in response to a Data Quality petition regarding the Florida Panther. FWS’s response to FFA’s Request for Correction will be closely watched to help ensure that the agency continues their commitment to data quality.

See FFA IQA cover letter

See FFA Detailed IQA Request

See OMB Watch article on FWS Data Correction