On January 27, 2021, President Biden issued a Memorandum on Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking. The Memorandum directed the White House Office of Science and Technology Policy (OSTP) to convene an interagency task force to review the effectiveness of scientific integrity policies of federal agencies in preventing improper political interference in the conduct of scientific research and the collection of data and preventing the suppression or distortion of findings, data, information, conclusions, or technical results. The OSTP issued a Request for Information on June 28, 2021 and the OSTP’s Scientific Integrity Fast-Track Action Committee held listening sessions on July 28-30. Our comments are below.
My name is Deirdre Des Jardins, Director of California Water Research. Our organization works on science-based advocacy on California developed water issues. My comments are with respect to the Bureau of Reclamation’s Scientific Integrity Policy.
First, the Bureau of Reclamation’s Scientific Integrity Policy requires a finding that “The actions causing the scientific misconduct or loss of scientific integrity be committed intentionally, knowingly, or recklessly.” This is a high burden of proof and should not be required for a finding that remedial actions are necessary to restore scientific integrity. Procedural requirements to prove intention should be eliminated
Second, there needs to be a process to address instances where there was a wholesale loss of scientific integrity in the previous administration. While complaint processes were available during the previous administration, if there was overt political influence at the highest levels of agency administration, complaints were unlikely to be filed.
As an example, there was blatant political interference with the Endangered Species Act consultation on Reclamation’s Reinitiation of Consultation on Long-Term Operations of the Central Valley Project (CVP) and State Water Project (SWP). While the Biden administration has promised to reinitiate consultation on Long Term Operations of the CVP and SWP by October 1st , the situation which led to blatant interference in regulatory decisions by agency scientists has not been addressed. The deadlines to file complaints under the scientific integrity policies of the relevant agencies have also passed. We recommend that this be explicitly addressed going forward.
Scientific integrity also requires transparency and timely public access to relevant data used in policy decisions. Data access is not addressed in scientific integrity policies, but should be. There are currently issues that Reclamation’s Central Valley Operations Office is not providing timely updates to the 2021 Central Valley Project Water Delivery Monthly Tables. Reclamation has not yet reported deliveries for May or June of 2021, although in prior years data was available shortly after the end of a month.
There should also be a process to review whether working groups created under the previous administration institutionalize political interference in the utilization of science in decision-making. In the case of the Bureau of Reclamation, the new Delta Monitoring Work Group includes state and federal water contractors, and involves them in decisionmaking about real-time operations of the Central Valley Project and State Water Project to protect fish.
The Union of Concerned Scientists has advocated that the “use of science to inform agency decisionmaking must be as unbiased as possible, and the science itself should be independent—in other words, free of political, ideological, or financial influence.” For these reasons, our organization advocates that only agency staff should be in work groups making determinations about real-time operations of the CVP and SWP.
Read our written comments here.