December 17, 2017

Beware the Peer Review

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ExposeCorruptionFor several years now, Roxanne Quimby, founder of Burt’s Bees, has tried to get Maine to buy into the idea of creating, yet another, national park in the Baxter State Park region. Quimby sits on the board of directors for the National Park Service and recently turned the idea of the park over to her son Lucas St. Clair.

At a recent meeting in the Millinocket area, proponents and opponents met to exchange barbs and attempt to discredit each other. Nothing new.

According to the Bangor Daily News, St. Clair said:

…he could not count the number of wrong facts and figures in the presentations, but that it was vast. As an example, he said, the economic studies done on the park’s effect were peer reviewed, and approved, by the state’s former economist and a University of Maine forest products professor.

I cannot address specifically the economic studies referred to in this piece because I have not read them. Therefore, my following comments are based upon general facts and information that all U.S. citizens should be educated about concerning the dreaded “peer review” of scientific data.

We all cherry pick when it comes to selecting information to support our causes. Often those that do don’t realize that for each document you produce to support your claim, there may be just as many to disprove it. So, which documents are right and which ones are wrong?

Well, I cannot answer that question honestly and herein lies the rub. The system of peer review is seriously flawed. It’s down right broken.

To those willing to not bury their heads in the sand and pretend things are just ducky, we have known for some time that peer review is a worthless instrument. Yes, and unfortunately that is the truth. Corruption and greed have destroyed what may have been a good system of checks and balances….or at least a better one.

With all the complaining that has gone on, perhaps we are now beginning to hear some noise about this peer review process.

All decisions are based upon “best available science.” Best available science is a vague term, with no conditions or parameters set in order to maintain a truthful method of checks and balances. For that reason, peer review, which once was necessary if you ever had any hope of being heard, is mostly worthless. Anybody, with money and connections can obtain peer review. The trick is to keep the available peers contained within a specialized group to ensure no opposition is heard or considered – stacking the deck or rigging the system.

We saw this play out nicely in the Draft Environmental Impact Statement for the reintroduction of wolves to the Greater Yellowstone area. While the fake and rigged process allows for anyone to submit information, studies, data, concerns and yes, peer reviewed documents, there’s no control over which ones get serious attention and which ones don’t. Never mind the rules. It’s a free for all.

Back in December of 2014, the House Natural Resources Committee released a report about the concerns over whether or not “best available science” was using independent peer review and in general the report actually questions the quality of the so-called “science” being used.

The ESA requires that decisions on whether to list a species as threatened or endangered must be based on the “best scientific and commercial data available.” As one of the chief agencies responsible for implementing the ESA, the U.S. Fish & Wildlife Service (“FWS”) has issued policies and guidance concerning the use of the best available science.

A review by the Committee’s Majority oversight staff of the FWS’ recent ESA listing decisions has found:

* The FWS’ peer review process, information quality policies, and guidance documents are used to justify the FWS’ listing decisions under the ESA. However, the policies are ambiguous as to what constitutes “independent” peer review. This has led to inconsistency in how FWS Regional offices conduct peer review.

* The FWS regularly recruits scientists to peer review its listing decisions who are well-known experts on the specific species at issue. In fact, the FWS routinely bases its listing decisions on science that has been developed by the same people who have been recruited by the FWS to serve as peer reviewers. Rather than providing a fresh perspective on how the science was conducted or whether the listing decision is supported by science, the peer reviewers are in effect being asked to review how the FWS has characterized their studies and research.

* The FWS does not have clear or consistent procedures in place across all FWS Regional offices to ensure that potential peer reviewers undergo a screening to identify possible conflicts of interest or impartiality. In many cases, those who have received grants or financial assistance from the Department of the Interior (“Department”) and its bureaus or other federal agencies to study the species at issue or who have known biases, positions, or affiliations with groups that have advocated for conservation of the species under the ESA are allowed to serve as peer reviewers.

* The FWS does not consistently disclose to the American public information about who serves as peer reviewers for ESA listing decisions, the instructions they are given, the substance of their comments, or how their comments are addressed by the FWS. Peer reviewer identities are often withheld, and their comments are not clearly identified or made publicly available in the course of the listing decisions.

While this report of the House Committee on Natural Resources is specifically addressing science involved with Endangered Species Act, surely the same problems exist concerning peer review for any document. The short of it is, no longer can peer review be trusted.

Recently the Washington Legal Foundation (WLF) released a working paper addressing many of these same problems. In the Executive Summary, page x, it states:

Fueled by decades of ineffective oversight, federal agencies’ respect for science and the scientific process has severely diminished. For that reason, one can easily foresee many potential applications of the enforcement framework offered in this paper.

Clearly we are seeing more and more concerns about important decisions being made based on what more and more people are seeing as biased, unsubstantiated, politically and monetarily driven trumped up “science.”

In 2000, Congress passed the Information Quality Act, (IQA) supposedly for the purpose of making sure crap wasn’t brought into decision making processes. WLF writes:

The law requires federal agencies to ensure the quality, objectivity, utility, and integrity of the scientific, technical, and statistical information that federal agencies adopt and disseminate to the public.

Fifteen years after passage of the IQA, and what we are hearing from places like the House Committee on Natural Resources, is that it’s still “crap in and crap out.”

Evidently the Office of Management and Budget is responsible for implementing the 2000 IQA law. The OMB’s guidelines were supposed to set minimum standards.

OMB’s IQA Guidelines required that each federal agency develop and adhere to their own IQA guidelines, and set out minimum criteria for scientific peer review of agency-drafted and third-party studies and scientific assessments, as well as criteria for the selection of peer reviewers. OMB dictated that these peer-review standards be especially rigorous for “highly influential scientific assessments.” Federal agencies must also provide an administrative review mechanism that will allow affected entities to seek correction of agency-disseminated information that was not adequately validated. Agencies routinely carry out this mandate by addressing requests for correction as part of their responses to public comments in a final regulation—an approach, the paper argues, that does not afford sufficient due process to stakeholders.

Sounds nice but obviously it’s not working. To be honest, with this sort of self-regulation within a corrupt government and rigged process, I have just about zero amount of faith that there can ever be reliable science-based documentation done with valid, quality peer review. There’s just too much money involved. Best Available Science therefore becomes a travesty.

It’s a crying shame for the science industry. We live in a post normal scientific era. People are crying out for honest and reliable scientific processes and information. Yet, nothing and no one can be trusted. Agendas run too deeply. People must understand that peer review is garbage. Do not accept it and do not rely on it – even when it involves stuff you want to hear. You are being used.

Whether Maine buys into the sales pitch to accept 150,000 acres of land for the purpose of a national park, that is up to the people in the state of Maine. As far as the rest of are concerned, we should make sure that we let the National Park Service and our congressional representatives know how we feel about another park and this idea of peer reviewed science.

However, Maine residents need to tread lightly over claims that any data necessary to make these major decisions is “peer reviewed science.” It may be valid or it may not. It’s up to you, because nobody else can be trusted, to find out.

And we know that will not happen. Good luck!

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