Here’s a link to another of my posts on this topic on Roger Pielke, Jr.’s blog.
My concern is that it is not clear what problem the memo is intended to solve. I am not sure that the authors are aware of the dailiness of using science in a variety of government decisions at different spatial and temporal scales. In clumsily attempting to go after the misbehaving, they are likely to target the innocent for unnecessary work. In this economic climate, one would think that people would be more careful about requiring hordes of federal employees to develop and follow unclear and unnecessary policies.
Here’s my summary of the memo (more on the guidelines later).
1. What if we were to apply the ideas espoused in the memo to the promulgation of the memo (as the memo is policy) itself? We might expect a section describing how the work of noted science policy experts was used in the development of the memo, with peer-reviewed citations. I’d expect to see Jasanoff, Sarewitz and Pielke, Jr., at least, cited.
2. Here are my four principles for improving the use of information in policy, (1) joint framing and design of research with policymakers (2) explicit consideration of the relevance of practitioner and other forms of knowledge (3) quality measures for scientific information (including QA/QC, data integrity and peer and practitioner review), and (3) transparency and openness of review of any information considered and its application to policy.
3. If the DQA (Data Quality Act) and the “Integrity” work are seen to be the result of inchoate longings by many for an improved “science to policy” process; and if they seem each to have become, instead, weapons to slime the opposing political party, then why not establish a bipartisan commission on improving the use of scientific and technical information in policy? Science policy experts would advise the commission, and the deliberations would be transparent and open to public comment. The terrain to be explored would include my four principles above, and add considerations of involving citizens more directly in working with the relevant Congressional committees in developing federal research budgets and priorities.