Fish and Wildlife Study Reminds Us That Informing Policy Doesn’t Mean Dictating Policy

Here’s a link to David Bruggeman’s post on his blog. I subscribe to, and recommmend, David’s blog to keep up with science policy issues.

David cites the Nature blog, here it is and below is an excerpt:

The researchers claim that this is the first study to examine government peer review. “Peer review is fundamentally different in a government setting than at a scientific journal,” says Noah Greenwald, a co-author and endangered species program director at the Center for Biological Diversity in Portland, Oregon. “There’s no editor looking at whether they followed the advice of reviewers and whether they have a good explanation for not following it.” Most of the time, the final habitat boundaries did not match the drafts set by the internal scientists. In 81% of the cases, the researchers found, the habitats were cut by more 40% between the draft and final policies.

The FWS says it did not have time to review the study, but issued a short statement, arguing that the agency, in setting boundaries, must consider economic and national security concerns, and not just science. “Scientists may not always agree on the conclusions of a scientific analysis, especially in analyses as complex and challenging as critical habitat designations. In some cases, peer reviewers may disagree; in others, our biologists may not agree with the conclusions of individual peer reviewers.”

Karen Hodges, an ecologist at the University of British Columbia in Kenowa, agrees that designating critical habitat can be a tricky business. “Here’s a species that you need to protect, and you need to pick how much habitat to protect so it doesn’t go extinct. Good luck with that! That’s hard for species we know about, let alone species with limited data,” she says.

Note from Sharon: Karen’s statement sounds a bit like my previous comment. Also, there is a substantial literature on peer review in the sciences and the results are not all rosy. It would be too easy to go after some of the climate peer review debates; but I was cleaning out my office this week prior to retirement and found some older literature (95 ish) about gender bias in peer review. Scientists are people, after all, with the inherent tribal tendencies, and reviewing manuscripts fall under “other duties as assigned.” For you non-scientists, when scientists go on about the wonders of peer review, you might want to look closely at what else they are trying to communicate. In fact, their statements about peer review don’t seem to be informed by the best science..

However, this was not”peer review” of a scientific publication, it really sounds like what David says here in his post, it’s a policy decision:

This drew my attention because of a comment in the Nature piece by one of the co-authors of the BioScience piece. He described the FWS actions as ‘a scientific integrity issue.’ Which raises the perennial disconnect for many scientists. Having scientific and technical information inform policymaking is not the same thing as having it dictate policy. As Nature describes the FWS response to the study,

“the agency, in setting boundaries, must consider economic and national security concerns, and not just science. ‘Scientists may not always agree on the conclusions of a scientific analysis, especially in analyses as complex and challenging as critical habitat designations. In some cases, peer reviewers may disagree; in others, our biologists may not agree with the conclusions of individual peer reviewers.'”

Absent additional evidence, or further explanations of how the study authors see the political interference they refer to in the BioScience piece, I don’t think they have made the case that FWS action in this case qualifies as a scientific integrity matter. While they acknowledge that other influences factor into agency decisions, they don’t seem to like it. Near the conclusion of the article, they state:

“scientists within the USFWS need to be given leeway and clear direction in order to base their decisions solely on the best available scientific information. The loss of biodiversity is too serious a problem to let short-term political interests intrude.”

The authors aren’t wrong to want these things. But they should recognize that they are advocating for changing how policy decisions are made, rather than restoring the role of science in decisionmaking. They aren’t alone in this.

The discussion of informing versus dictating reminds me of all the discussion on the planning rule about considering versus some other word. Which could have been informed by research on science technology policy studies; or perhaps dictated ;)?

I also find it kind of bizarre that scientists feel like they can show a fundamental misunderstanding and/or disrespect of legitimate (and democratic) political processes in, of all places, a scientific journal. I wonder what the editors were thinking.

7 thoughts on “Fish and Wildlife Study Reminds Us That Informing Policy Doesn’t Mean Dictating Policy”

  1. Sharon, thanks for your postings on this. I happened to be in DC when this came out, and after talking with Stuart while walking amongst the huge federal buildings and thinking about this debate, I came to realize what a huge disconnect there probably is between scientists working in the field and the biocrats (I’m trying to not use that term pejoratively) who are the final arbiters of these processes.

    Aside from the technical questions of peer review (which I must admit, I don’t fully understand) I think the point CBD was trying to make with its study is that there has been an overwhelming PATTERN of cutting critical habitat designations, in many cases to the detriment of recovery efforts.

    These are not just paper exercises; for the species in question they are life and death decisions.

    Stuart described in detail the process with the Cape Sable sparrow, where all the available science clearly indicated the need for more protected areas to ensure recovery, yet based on political pressure under the Bush administration, the FWS ignored all that.

    I see the same thing happening in Colorado, where at least some critical habitat designation for lynx is clearly warranted, yet the FWS is twisting every way it can to avoid it, based on some informal agreement between the state and the feds made before there was much good lynx recovery science available.

    If the FWS is going to follow this path, it should at least be obligated to show how its final habitat proposals meet the mandated recovery goals of the ESA and not just be allowed to stand on administrative protocol, IMO.

    Reply
    • Bob B.: These really are — mostly — “just paper exercises.” They are NOT “life and death decisions” — unless you can offer even the slightest evidence of even a single instance in which a species’ existence was negatively affected through ignoring scientists’ demands for more critical habitat acres. And by “paper exercises” I mean “politics,” not science. And by “science” I mean proven cause-and-effect, not biased speculation.

      No, there has NOT been “an overwhelming PATTERN of cutting critical habitat designations,” despite CBD assertions. Much (much) the opposite. When I was a kid there was zero “critical habitat,” — now there are millions of acres of this new type of zoning. How is that “cutting,” much less a “PATTERN” of cutting?

      Critical habitat has been designated for millions of acres, several of which have gone up in flames during the past 30 years. How is that helping anything (other than the Ologists and firefighters who deal with these things for a living)? Today’s paper has news of the latest murrelet zoning dispute in western Oregon. Enviros in court. Loggers being promised health insurance and food stamps. Lucky murrelets or lucky lawyers? At some point this charade needs to have a flashlight pointed at it.

      Reply
      • I think it’s a lot easier to show cases where critical habitat designations HAVE been effective, mainly to conserve species with fairly small, isolated pockets of home ranges (certain butterfly species come to mind). It’s pretty hard to prove it the way you phrased it, but I think it is possible to show examples where a species declined or even went extinct because its habitat wasn’t protected. I understand the CBD’s ultimate goals and I see their efforts (characterized as extreme by some) as a counterweight to the juggernaut of habitat destruction and fragmentation. They know they’re never going to get what they ask for, but if they keep pushing, some species might get just enough to survive.

        Reply
        • Bob, CBD is certainly entitled to their agenda. I don’t actually see a “juggernaut of development” on public land.. but that’s just from my perspective.

          I was more concerned about the tactics of saying that the “science” shows one path and policy should be be directed by what “scientists” think. As if all scientists thought the same.

          But those of us in the trenches see unknown answers to “how many acres?” “where?” “”protected” from what”? “based on what logic path?” “how do we know that that will work considering climate change?” that, to my mind, deserve a variety of disciplinary thoughts and open discussion.

          Let’s go back to the ecologist from BC’s quote:

          Karen Hodges, an ecologist at the University of British Columbia in Kenowa, agrees that designating critical habitat can be a tricky business. “Here’s a species that you need to protect, and you need to pick how much habitat to protect so it doesn’t go extinct. Good luck with that! That’s hard for species we know about, let alone species with limited data,” she says.

          Reply
    • Bob, I think the lynx is a good example. I don’t know everything about it, but I know some things about Colorado..

      I don’t think we know how much habitat species “need”. Some thought the recovery efforts in Colorado would be unsuccessful as there wasn’t “enough” habitat and it is at the southern end of its range. Then if climate change is changing things drastically and unpredictably, how do you factor that in? We don’t know how climate change is going to impact vegetation (which is habitat). We don’t know how climate will impact bugs that change vegetation. We don’t know how climate will impact fires, which change vegetation and hence habitat. So how can there be lynx recovery science separate from the unknown climate prediction science?

      But I think all regulatory science round-ups should be conducted publicly on the internet. I think it would be the best pragmatic science education in the world to see how people link the information they have to predict what will keep populations going into the unknown and really unknowable future. In my work, I have seen some great discussions among regulatory and regulated scientists (plus in some cases outside scientists from a variety of disciplines and perspectives).

      We have an idea that we use in administrative appeals about the link between “facts found” and “conclusions drawn.” It would be great to see that linkage and watch it be discussed and debated.

      Until that happens, though, any assertions about “the science” and what it says is pretty much “trust someone” and having observed people for many years in this biz, I would say let’s instead openly show the work and have the discussion.

      Now I don’t think many members of the public would have the time or the stomach for it but some of us here on this blog might. I think it should be standard operating procedure.

      Reply
      • It is kind of of out there for the public in a way, with biological opinions and assessments, jeopardy findings, and so on. But it certainly could be done in a much more transparent way.

        I focused on lynx because I’ve been reporting on them for so many years. Now we know where they den, where they forage and, most importantly, how they move through the larger landscape.

        Probably not all those areas need to be designated as critical habitat. Some are in wilderness, with low threats, if any. But based on many conservations with biologists, some of those critically important areas are vulnerable and probably need that level of protection.

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      • Sharon: I am 100% in full agreement with your statement:

        “But I think all regulatory science round-ups should be conducted publicly on the internet. I think it would be the best pragmatic science education in the world to see how people link the information they have to predict what will keep populations going into the unknown and really unknowable future.”

        Taxpayer funded science should be fully transparent, for numerous ethical reasons. The Internet is an ideal method of making information available to almost everyone, and at little cost. Blogs are excellent methods for discussing scientific methods, findings, and recommendations.

        Reply

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