Why does the EPA publish false claims about its Medical Office ENERGY STAR model?

To say that someone “lied” is a strong claim.  It asserts that not only is the statement false but the person making it knows that the statement is false.

The EPA revised and updated its ENERGY STAR Technical Methodology document for Medical Office Buildings in November 2014.  That document makes the following claims:

  1. it describes filters used to extract 82 records from the 1999 CBECS
  2. it claims that the model data contain no buildings less than 5,000 sf in size
  3. with regard to the elimination of buildings < 5000 sf the EPA writes, “Analytical filter – values determined to be statistical outlyers.”
  4. the cumulative distribution for this model from which ENERGY STAR scores are derived is said to be fit with a 2-parameter gamma distribution.

All of the above statements/descriptions are false.  The filters described by the EPA do not produce an 82 record dataset, and the dataset produced do not then have the properties (min, max, and mean) described in Figure 2 of the EPA’s document.  And a regression using the EPA’s variables on the dataset obtained using their stated filters do not produce the results listed in Figure 3 of the EPA’s document.  In short, this EPA document is a work of fiction.

I have published these facts previously in my August 2014 ACEEE paper entitled “ENERGY STAR Building Benchmarking Scores: Good Idea, Bad Science.”  Six months ago I sent copies of this paper to EPA staff responsible for the agency’s ENERGY STAR building program.

I have given the EPA the opportunity to supply facts supporting their claims by filing three Freedom of Information Act (FOIA) requests, the first (EPA-HQ-2013-00927) for the list of 1999 CBECS ID’s that correspond to their 82-building dataset, and the second (EPA-HQ-2013-009668) for the alpha and beta parameters for the gamma distribution that fits their data, and the third (EPA-HQ-2013-010011) for documents justifying their exclusion of buildings <5000 sf from many models, including Medical Offices.  The EPA has closed the first two cases indicating they could not find any documents with the requested information.  17 months after filing the third request it remains open and the EPA has provided no documents pertaining to the Medical Office model.  The EPA is publishing claims for which they have no supporting documents and that I have demonstrated are false.  The details of my analysis are posted on the web and were referenced in my ACEEE paper.

In November 2014 the EPA corrected errors in other Technical Methodology documents yet it saw no need to correct or retract the Medical Office document.  Why is it so hard for the EPA to say they messed up?

It is common for scientists to correct mistakes by publishing “errata” or even withdrawing a previously published paper.  No doubt EPA staff once believed this document they have published was correct.  But how is it possible the EPA remained unaware of the errors while it continued to publish and even revise this document for nearly a decade?  How can the EPA continue to publish such false information six months after it has been informed of the errors?

Is the EPA lying about its Medical Office building model?  I cannot say.  But it is clear that the EPA either has total disregard for the truth or it is incompetent.

If these follks worked for NBC they would have to join Brian Willams on unpaid leave for six months.  Apparently the federal government has a lower standard of competence and/or integrity.

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