Group Paints Path to Cut Scientific Integrity Policies
In 2021, President Biden signed a presidential memorandum that initiated a process to strengthen scientific integrity across all federal agencies. The memorandum led to the formation of a taskforce on scientific integrity that created a scientific integrity framework to guide the development, or update, of agency scientific integrity policies. After four years of the Trump administration’s unprecedented attacks on science - policies that more strongly protect federal scientists and their work from political interference were needed.
Now, multiple groups are attacking this progress on scientific integrity. A new group, The Council to Modernize Governance, is the most recent to join in the fight to undo progress on scientific integrity. The group recently released a paper that paints a picture for how a new administration can undo this progress on scientific integrity. Here’s what to know and why it’s important.
Who?
The Council to Modernize Governance is a think tank whose goal is to reduce the power of the administrative state. It does not appear that they have been around for a long time - possibly starting work in 2023 from what I can glean from their work.
The staff of the group seems to be just one person thus far - Curtis Schube. Mr. Schube is a lawyer (not a scientist) who has previously worked for the Pennsylvania Family Institute “where he both litigated and advocated for laws in legislative settings related to pro-life issues and religious liberty.” He previously worked as the Assistant Attorney General for the state of Missouri, as attorney for the Fairness Center, and as an attorney for the Dhillon Law group.
The board of advisors for the group is made up of three people - David L. Bernhardt, Dr. Stephen Hollingshead, and Gregg Renkes. I imagine many SciLight readers might recognize David L. Bernhardt who served as the Department of Interior’s Secretary under the Trump administration. Bernhardt is also a former oil and mining company lobbyist with a history of pushing for fossil fuel interests at the expense of public lands and health. I co-wrote a report covering multiple attacks on science at Interior under the leadership of Mr. Bernhardt.
The Call to Eliminate Scientific Integrity
Earlier this month, the group released a paper titled, “Scientific Integrity Under Attack: Is Scientific Integrity the Latest Front in the Effort to Protect the Administrative State from Representative Democracy?” In the first 5 pages of the report, the author, Mr. Schube (not a scientist), mostly discusses what the Biden administration has done to strengthen scientific integrity and describes some agency policies. It’s really the last two pages and a section labeled “Dangers” that begin to promulgate misinformation about what scientific integrity policies do and calls for some policy changes that will endanger public health and safety, namely the elimination of scientific integrity policies.
The last part of the report is the most concerning to me in which Mr. Schube paints a picture for the next administration to eliminate all progress on scientific integrity. The paper calls for the next president to rescind Biden’s executive order that strengthens scientific integrity. It also paves a way for the president to rescind all agencies scientific integrity policies. Additionally, it provides a strategy to bring legal challenges against union contracts that have embraced scientific integrity - something that EPA’s employee unions have been considering.
I’m afraid that these strategies could, indeed, put a dent in scientific integrity progress. Although it’s worth noting that scientific integrity is more-so a culture than anything. Make no mistake - the policies are certainly important - but so is having a staff that are firmly committed to a culture of scientific integrity. And years of trainings and education on these policies has enshrined the values of scientific integrity in federal agencies. That much is not going anywhere.
Why eliminate these policies?
The paper’s main argument for eliminating scientific integrity policies is that the policies take power away from political appointees. It points to policy provisions that would prevent political appointees from being involved in the “design” of research, for example. By taking away power from political appointees, science may override other considerations, such as economic considerations, the paper argues.
I don’t agree with these arguments, so let me explain why.
Let’s start with the argument that scientific integrity policies will strip away power from political appointees.
Scientific integrity policies do not dictate a political appointee’s policy direction. Nor do these policies dictate what science needs to be conducted to inform agency policy. What these policies do is ensure that political appointees are not interfering in the scientific process.
If a political appointee wants to implement a policy that would change an annual standard on an air pollutant, for example, the political appointee is free to move forward with that policy change - as long as they are following applicable laws and statutes, of course. But that policy change would require scientific input - science that would be developed by agency experts. It is at this point that the scientific integrity policies truly kick-in and prevent the political appointee from interfering with that scientific process.
What is political interference? NOAA’s scientific integrity policy defines it as:
Suppressing, altering, or otherwise impeding, the collection, content, or timely release of scientific data or scientific or technological findings or conclusions, including advice from Federal advisory committees (FAC), unless explicitly required by a Department or government-wide statute, regulation, Executive Order, Presidential Memorandum, or other legal authority; or
Intimidating or coercing employees, contractors, recipients of financial assistance awards, Federal advisory committee members or others to suppress, alter, censor, or otherwise impede the collection, content, or timely release of scientific or technological data, findings or conclusions; or
Implementing or causing to be implemented institutional barriers to cooperation and the timely communication of scientific or technological findings or conclusions.
These policies ensure that the science informing policies that affect people in the U.S. is based off of independent and objective research - not politics - and that the public has timely access to that work. Political appointees often have political goals, so it makes sense that they shouldn’t be involved in scientific research. Appointee’s political biases could lead them to interfere in the scientific process, potentially in attempts to sway the science in a certain direction. Aside from their political biases, political appointees are not appointed to conduct or be involved in science - it simply isn’t their job.
What political appointees decide to do with the final results of agency science is often up to them, unless a statute dictates otherwise. For example, in the case of listing and delisting decisions under the Endangered Species Act - decisions must be based solely on the best available science. I think that most experts in the science policy world understand that science is often one factor, among many, that is considered in decisions, but it is not always the deciding factor.
But science should be heavily considered when a government decision will significantly impact the health and safety of the public - such as during a pandemic. The paper uses COVID-19 as an example of when economic considerations should have been higher on the list of our government’s priorities. “During the height of Covid-19, certain scientific theories about masks, alternative medicine, or vaccines were branded ‘political’ or ‘inappropriate’ or ‘unjustified,’” the paper states. It goes on to say, “The economic consequences of lockdowns would now be limited to the siloed analysis of a select group of unaccountable bureaucrats shielded from both electoral accountability and consideration of the wide range of information that senior appointed officials use to inform their policy choices.”
The “scientific theories” that the paper takes issue with, such as masking up and getting vaccinated, were actually good practices based on sound scientific evidence that saved people’s lives. Hundreds of thousands of people died from COVID-19, particularly in states where masking and vaccination was politicized, or where people were led to believe that hydroxychloroquine was an effective treatment for COVID-19. Leaders who said that masking was not needed, or questioned the safety of vaccinations, were political statements that were inappropriate. The pandemic is absolutely an example of when the government needed to be prioritizing science over economic considerations.
Scientific Integrity is Needed
What the Biden administration has done for scientific integrity was absolutely needed after the unprecedented frequency of sidelining science under the Trump administration. And the work is not over - who knows what other scientific integrity issues lie in the dark that we currently don’t know about, and new policies might need tweaking, too. That’s why the Biden administration instituted an iterative process that allows for learning and updating over time.
Science is critical to informing policies that protect us and our environment from harm. SciLight recognizes that it’s not the only factor that informs decisions, but it certainly deserves a seat at the table. And it also deserves to show up to the table in pristine condition.
This new paper is hogwash - scientific integrity policies do not take away power from political appointees, nor do they give federal scientists unfettered control over policy decisions. Political appointees are appointed to take agencies in a certain policy direction - not conduct science. That’s why agencies hire scientists - that’s their job. Let scientists do their jobs because ultimately, they’re doing us all a favor by ensuring that government policies make sure that the air we breathe is clean, the water we drink is clean, that we have access to non-harmful medical care, and that the very food we eat is safe. The elimination of scientific integrity policies would put all our health and safety at-risk - we cannot and will not let this happen.