April 3, 2012

Dr. Gary Machlis
Science Advisor to the Director
1849 C Street NW
Washington, DC 20240

Dear Dr. Machlis,

Thank you for the opportunity to comment on the National Park Service's (NPS) draft scientific integrity policy. The policy proposed by NPS upholds the ideals set forth in the directive issued by Secretary Salazar. Although much of the policy is commendable, several areas should be strengthened to ensure the greatest public trust in NPS science.

The American Institute of Biological Sciences (AIBS) is a nonprofit scientific association dedicated to advancing biological research and education for the welfare of society. AIBS works to ensure that the public, legislators, funders, and the community of biologists have access to and use information that will guide them in making informed decisions about matters that require biological knowledge. Founded in 1947 as a part of the National Academy of Sciences, AIBS became an independent, member-governed organization in the 1950s. Today, AIBS has nearly 160 member organizations and is headquartered in Reston, Virginia, with a Public Policy Office in Washington, DC.

Applicability to Employees

We strongly support the agency's decision to apply the policy to all NPS employees and appointees who engage in, supervise, manage, or influence scientific activities; communicate scientific information; or use such information to make decisions. We commend NPS for applying the policy to volunteers, contractors, partners, permittees, and others who develop or apply scientific results.

Universal coverage is essential to guaranteeing that the policy is effective. It is vital that decision makers are subject to the policy, otherwise the potential exists for senior NPS officials to misrepresent, alter, or suppress scientific information. The inclusion of communications staff is key to sustaining public trust in NPS and the information the agency communicates to the public and policymakers.

Foundations of Scientific Integrity

In its December 2010 memorandum on scientific integrity, the Office of Science and Technology Policy (OSTP) outlined several foundational principles that should be included in each agency's respective scientific integrity policy. As currently written, neither the NPS policy nor Interior's Departmental Manual explicitly states the Department's commitment to several of these principles. NPS should rectify this by incorporating the following principles into its final scientific integrity policy.

  • Require independent peer review of research findings by qualified experts. Peer review is a central tenant of science. NPS should aim for independent review of its research in order to ensure that its work is of the highest quality and to sustain public trust in its scientific work. As currently drafted, the NPS policy requires bureau decision makers to "encourage" staff scientists to seek peer review of their work. This provision should be strengthened by requiring all data and research used to support policy decisions undergo independent peer review by qualified experts.
  • Establish principles for conveying scientific and technological information to the public, including underlying assumptions, uncertainties, and best-case and worst-case scenarios. Without such information, decision makers and the public are not able to fully comprehend the ramifications of the research nor make appropriate policy and management decisions. The proposed employee code of conduct asks NPS staff to "differentiate among facts, personal opinions, assumptions, hypotheses, and professional judgment" and to report uncertainties. NPS should strengthen this provision by developing and implementing broader principles for communicating scientific and technological information.
  • Develop a public communications policy that promotes and maximizes openness and transparency. Such a policy should include a provision to allow agency scientists to speak freely to the media and the public about scientific and technological matters based on their official work. Additionally, we encourage NPS to consider following the lead set by the National Oceanic and Atmospheric Administration by allowing its scientists to present viewpoints that extend beyond their scientific findings, for example about policy or management matters, so long as they make clear that they are presenting their individual opinions.

Code of Scientific and Scholarly Conduct

The draft policy outlines a code of ethics for employees, scientists, and importantly those who supervise and manage scientific activities. The proposed code of conduct would benefit from two additions:

  • The requirement for all employees, appointees, contractors, cooperators, partners, permittees, leasees, grantees, and volunteers to report allegations of scientific misconduct to the appropriate authority.
  • Include in the code for decision makers that the selection and retention of employees in scientific and scholarly positions is to be based on the candidate's integrity, knowledge, credentials, and experience relevant to the responsibility of the position. Although this principle is currently included in Interior's Departmental Manual, the NPS policy would be strengthened by its addition.

Scientific Societies and Professional Development

We strongly support the policy's encouragement of NPS scientists to serve in the leadership of professional and scientific societies. The participation of government scientists in scientific societies contributes to their professional development and to that of the scientific community.

Additionally, we urge NPS to encourage its employees to publish research findings in peer-reviewed scholarly journals, to present research findings at professional meetings, and to serve as editors of scholarly journals. The December 2010 memorandum on scientific integrity from OSTP explicitly states that agencies should encourage these activities, as well as allow government scientists to receive honors and awards for their research and discoveries. The draft NPS policy does not currently address these matters, nor does Interior's Departmental Manual.

Training on Scientific Integrity

We encourage NPS to include in its final policy a commitment to provide regular integrity and ethics training to its employees, appointees, and contractors. This should include training to new and existing staff. Additionally, NPS should provide information to ensure that employees and contractors are fully aware of their rights regarding dissemination of their research, participation in professional scientific societies, and their responsibility to report waste, fraud, abuse, and scientific misconduct.

Thank you for your thoughtful consideration of these comments. If AIBS may be of further assistance to you on this or any other matter, please contact Dr. Robert Gropp, AIBS Director of Public Policy at 202-628-1500.


Richard O'Grady, Ph.D.
Executive Director

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