Last Monday, John Holdren told a large audience at the annual AGU fall meeting that the administration's much discussed--and long overdue--scientific integrity guidelines were basically ready. Holdren said he'd actually hoped to announce them at his talk, but "didn't quite make it." Instead of that Monday, the guidelines were then released last Friday in the afternoon. My plane from San Fran to Chicago landed at about 6 pm central, and I arrived to find lots of chatter about them on my email. Why couldn't they be released at AGU? Everybody knows that when you release something on the later end on Friday...well, you complete the sentence. In any event, the guidelines have certainly drawnattention: Here's the Washington Post and Greenwire. Here's Holdren's original blog post announcing the (4 page) guidelines. Here's a thoughtful post from regulatory specialist Wendy Wagner on the Center for Progressive Reform's blog. That does not even begin to scratch the surface of the commentary out there. PEER is bashing the guidelines, in a way that I find kind of extreme. They're one end of the spectrum. I don't think this work deserves that much criticism. After reading through what people are saying (and the Holdren memorandum itself), here are some thoughts of my own.
1. First, the memo basically hits all the right notes. Federal scientists shouldn't have their studies tampered with. "In no circumstances may public affairs officers ask or direct Federal scientists to alter scientific findings." Scientists should be appointed to federal advisory committees based on merit, not politics. Government scientists should be able to participate in standard scientific activities like publishing in journals and attending conferences. Etc. 2. None of this is controversial. Neither is it surprising, challenging, or intellectually very difficult. So here's the problem I have. Why on Earth did this take so long? I mean, there's nothing here that couldn't have been drafted fairly rapidly by someone familiar with the problems that had arisen during the Bush administration. And then, sure, lawyers and wonks would have had to review the thing (and add language like, "this memorandum is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity, by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person"). But still, that process should only have taken, at best, a month. So I'm still scratching my head. It's reasonably good content, but for precisely that reason, it shouldn't have been year-and-a-half-delayed content. Something simply doesn't add up. 3. Moreover, this is still just the beginning. Now all the agencies have 120 days to respond about how they're going to implement this memo. (Wanna bet on whether they will be on time?)
I don't blame John Holdren for any of this. He knows the importance of this issue, and stands firmly behind the principle of ensuring scientific integrity in government. I'm quite confident of that. So what's really going on? I won't speculate, but you'll recall that Holdren himself said that drafting the document "has been a more challenging task than expected, it has taken much longer than it was supposed to.” So bottom line: Good that the guidelines are out, and pretty good content; but the delay remains hard to understand, especially now that we've seen the content.