"the EPA relied on work done by others and did not determine whether the data met its own quality guidelines before distributing it"

Cuccinelli: EPA study on climate broke rules - Washington Times

Among a number of shortcomings, the report concluded that rather than performing its own research, the EPA relied on work done by others and did not determine whether the data met its own quality guidelines before distributing it.

“As the EPA Inspector General found, the EPA has no procedures with respect to reliance on third parties,” the brief states. “Therefore, when the agency uncritically accepted the conclusions of others without established standards for doing so, it necessarily engaged in arbitrary and capricious rulemaking.”