carnegie ngo role

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COMMENTS OF

JAMES D. WERNER

SENIOR ENVIRONMENTAL ENGINEER

ON BEHALF OF THE

NATURAL RESOURCES DEFENSE COUNCIL

ON THE

Carnegie Commission Report (October 1992) --

"Facing Toward Government:Nongovernmental Organizations and

Government's Quest for Scientific and Technical Guidance"

FEBRUARY 16, 1993

INTRODUCTION

Perhaps not since the time of Sir Francis Bacon has the challenge of better integrating science

and technology into public policy been so salient as today. The Carnegie Commission on

Science, Technology, and Government has addressed this vital issue in a series of reports1; the

latest, "Facing Toward Government...", reviews a peculiarly American aspect of it - the role of

science and technology (S&T) nongovernmental organizations (NGOs).

The Task Force asserts that, "it is desirable for more scientists and engineers...to become

involved in [S&T] policy activities and public affairs," and that the role of the Task Force was to

"provide[] some of the principles that must underlie increased engagement,"2 Unfortunately,

although the report may arguably acheive this modest goal, it is not rigorous enough to

recommend as a useful guide either to NGOs wishing to become more involved in public policy

or S&T policy veterans seeking to improve the quality of their input. In addition, the report

seems curiously fixated on the National Academy of Sciences as a modern day "House of

Solomon,"3 seemingly unable to draw examples from other arenas.4


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Before addressing the content the report, a couple of structural issues warrant comment,

beginning with the composition of the Task Force. Despite the impressive credentials of the

Task Force members, the biographies do not indicate that any of the Task Force members have

any experience working as advocacy NGOs, according to the report's own typology.5 Because

advocacy NGOs normally have more regular interaction with government and policy makers than

other types of S&T NGOs, inclusion of representatives from advocacy NGOs would have addedmuch insight and some balance to the Task Force. Moreover, the absence may help explain some

of the substantive omissions of the report.

Also, the report fails to note that it was written in the context of a series of Carnegie Commission

reports on related topics that, together comprise a broader examination of science, technology

and government. These other reports, which deal with topics such as S&T support for states and

planning issues could have helped support certain points in this review of NGO issues.

Finally, the report is sometimes written is an obscure style that gives scientists and engineers a

bad name. For example, the report seems to take a swing at Congressman John Dingell's

investigation of university overhead charges, with an oblique reference.6 Similarly, the reportsuggests that certain NGOs, such as National Laboratories7 were spared the budget knife in the

early 1980s because they were viewed as sympathetic to the political views of the day (e.g.,

support for Star Wars and nuclear testing). In addition to dense prose, the report fails to follow

up with the logical conclusion that this Stalin-like pattern of "defunding NGOs suspected of

unsympathetic policy tendencies" should be corrected.8

Despite these shortcomings, the report provides some useful contributions in this important field

- it poses a good set of questions9 to be answered by an NGO getting involved in public policy

and a useful, albeit incomplete, set of recommendations.10

1. The Report Fails to Address the Proper Role of S&T NGOs Where Insufficient Scientific

Data Exist.

How should NGOs and government act when faced with uncertainty in pertinent scientific data?

This issue is particularly important because situations where some dispute remains about the

scientific basis for a policy decision are probably more numerous than where consensus exists.

Examples abound:

- What data should be considered necessary and sufficient for judging the

health effects of exposure to the millions of chemicals in public commerce?

- How much evidence is necessary to support taking action on global

warming? What level of response is required?

- What degree of certainty is required for assuring the safety of plans to deal

with nuclear waste - some of which remain hazardous for more than 10,000 years?


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In many cases, S&T NGOs urge waiting until more evidence is available before rendering a

judgement about risk (e.g., chemicals currently on the market and global warming). In other

cases, S&T organizations recommend making a decision on the basis of limited data (e.g., drugs

and chemicals awaiting market approval, and nuclear waste disposal facilities).

Good public policy often demands that decisions be made in the face of scientific uncertainty.This common dilemma is neither a failure of scientists nor policy makers, but simply a

fundamental difference in how each field operates. The greatest contribution of S&T NGOs is

not to skew available evidence to support a policy preference as "scientifically and technically

rational", but instead to provide a realistic appraisal of the current state of knowledge, of the

potential for resolving the uncertainties (including costs and time), and of the potential

implications for inaction. It is then up to the policy-makers to render a decision based on

available information.11 At a minimum, S&T NGOs should explicitly acknowledge and respect

this difference between science and policy making.12 To its credit, the report warns: "NGOs

should not go lightly into policy research or policy advocacy." Scientific uncertainty is a

predictable problem in this minefield for which the Task Force might have usefully provided

some guidance.

2. The Report Fails to Address Information Access Problems for NGOs Attempting to

Provide Advice to Government.

For individuals at NGOs accustomed to working in a collegial setting among academics, the

information restrictions often imposed by the government may be a rude awakening. In policy

battles where information is power and data are the bullets, the government is often reluctant to

arm its opponents. Limitations on data access are particularly frustrating when government

agencies use allegedly "objective scientific facts" as a smokescreen to promote subjective policy

positions. Several methods are used to stymie independent review of public policy decisionsusing facts or analyses gleaned from the government.

First, the most common method is to follow the rule: information delayed is information denied.

Many documents must be obtained through Freedom of Information Act requests, which

commonly take years to fill - far too long for use in formulating advice on annual budgets. In

some cases, government agencies will mail a requested report the day after a key Congressional

vote or the close of a comment period on a regulation. Health data that could be used for

independent epidemiological studies has also been withheld.13 Second, information is often

released only in a form that makes analysis very difficult.14 Third, the most pernicious method

of withholding information is to restrict it as a national security secret or another of a variety of

classification techniques.15

The problem of information access is a regular stumbling block for those who would advise

government on S&T policy issues, and deserves some discussion in the report. Moreover, the

report's recommendations section could have usefully called for collective action by NGOs to

eliminate unreasonable restrictions on access to government information.


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3. The Report Fails to Provide Much-Needed Guidance on Avoiding Bias and Conflicts of

Interest.

Perhaps because of the composition of the Task Force, the report gives short shrift to the critical

problem of avoiding biases an conflicts of interest in advising public policy decision makers. Tobe fair, the report mentions the issue, in a section on "Quality":

[i]t is all to[o] easy to begin to sacrifice objectivity for a comfortable relationship with a

sponsor.16

However, because this report presumes to lead S&T NGOs into the fray of government

policymaking, this crucial topic deserved a much more rigorous treatment than it received. The

report would have been more effective and even-handed if it had examined all potential sources

of individual and organizational bias among NGOs. Instead, the report unfairly singles out

"advocacy" NGOs17 as being more susceptable to biases, using a worn and inaccurate

stereotype:

[A]dvocacy organizations may have incentives to exaggerate and sensationalize scientific

findings to attract members and funds.18

Completely missing is any broader review of the sources of bias in other types of NGOs or ways

of dealing with them. Anyone who has attended even a single scientific meeting, from a brown-

bag University seminar to a national conference, has probably witnessed scientists overstating the

value and validity of their findings.19

Even the august National Academy of Sciences, which soars, according to the Task Force, to

"Olympian heights"20 is vulnerable to this temptation of spinning its results to the advantage ofits client agencies. For example, last year, in the midst of a Congressional debate on legislation

that would help the Energy Department open its Waste Isolation Pilot Plant, a NAS panel

released a review critical of the Department's test plan. Predictably, few Congressional staff and

fewer Members read the report compared to those who read the newspaper headlines about it,

which were thought to be inaccurate and damaging to DOE's prospects for passage of the

legislation. In response to a request from DOE, the President of the NAS, Frank Press, quickly

sent a one-page "clarification" letter, which appeared to soften the criticism of the original report,

to the three Committee Chairmen in the U.S. House of Representatives with primary jurisdiction

over the legislation being considered.21 Scientists involved with the technical report believed

that the letter was not an accurate summary of the original report, but appeared to lend support to

DOE's plans from the NAS at an extremely critical juncture.22 Unfortunately, because of the

rush to release it to the news media and Congressmen involved in the intense negotiations at the

time, Press' letter was not reviewed by individuals familiar with the report, contrary to the

normally rigorous NAS review process.

Anecdotes such as this cannot reveal whether one type of NGO is more susceptable to bias than

another. Such examples can suggest, however, some of the subtle ways that all S&T NGOs may,


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intentionally or unintentionally, influence policy debates.23 Moreover, because of the NAS's

established procedures for avoiding bias, this example helps illustrate how difficult it is to avoid

the appearance of a lack of objectivity. The basic point is that NGOs may influence public policy

outside the four corners of their reports, regardless of how objective and credible they may be, as

a result of factors such as timing (releasing findings prior to a key committee vote) and context

(holding press conferences to facilitate easy media access or quietly mailing out reports). TheTask Force could have helped identify these pitfalls.

Having acknowledged that it is virtually impossible to find experts without some bias, and

analyzed the potential mechanisms for bias to creep into S&T advice to government, the report

could have provided some practical assistance to S&T NGOs new to the policy arena in avoiding

even the appearance of bias.24 The report's suggestion that the NAS set down its procedures in

writing to help others attempting to avoid bias is a useful step in that direction.25 Other ideas

that might have made a useful contribution include:

- Explicitly revealing any potential sources of bias or conflicts of interest (e.g., previous,

current or prospective contracts; personal relationships, etc.). This should be expressed beforedeliberations of review panels and be recorded in individuals' biographies, instead of the regular

practice of selectively extracting credentials. Members of EPA's Science Advisory Board have

recently been called upon to disclose organizational and contractual affiliations.

- Balancing the composition of review panels so that they are as representative as

possible of the range of views in the field.

- Employing an ombudsperson to ferret out possible sources of bias and to remind

members of disclosure responsibilities.

Ironically, by excluding representatives of advocacy NGOs from the Task Force, the reportmissed an opportunity to receive input from the groups who may have the most experience at

identifying biases and obtaining recommendations for avoiding bias.

4. The Report Failed to Outline Specific Suggestions for Follow-up.

Two particular opportunities for followup could have been included as part of the Task Force

report. First, and perhaps most importantly, the report fails to outline an implementation plan

and thereby fails to heed its own admonition against letting useful analysis languish.

Implementation could have included:

- follow-up reviews of specific issues (e.g., eliminating unnecessary restrictions on

government information, and identifying and eliminating bias);

- distributing the report systematically to S&T NGOs;

- arranging to have the findings presented at major S&T NGO meetings and

conferences (e.g., AAAS, ACS, etc.); and

- organizing training sessions for S&T NGOs interested in expanding their abilities


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to interact with government policy makers.

Second, recognizing the unique role of S&T NGOs in the U.S., the Task Force could have

encouraged efforts through existing or new NGOs to export the idea of forming or enhancing the

effectiveness of NGOs in other countries. In Russia and Eastern Europe, the concept of an NGO

is often so foreign, it is difficult to explain. Yet once the translation succeeds, tremendousenthusiasm usually follows. NGOs are an American export worth promoting.


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February 16, 1993

Mr. Evan R. FergusonDirector of Programs

Sigma Xi

99 Alexander Drive

P.O. Box 13975

Research Triangle Park, NC 27709

RE: Critique of Carnegie Commission Report - "Facing Toward Government:

Nongovernmental Organizations and Government's Quest for Scientific and Technical

Guidance"

Dear Mr. Ferguson:

I am pleased to enclose our response to your December 4, 1993 letter requesting comments on

the above-captioned report. Thank you for the opportunity to review this report on a matter ofvital importance.

We hope that this critique is helpful and look forward to working cooperatively again in the

future. Please do not hesitate to call if you have any questions.

Sincerely,


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James D. Werner

Senior Environmental Engineer

cc: Frances Beinecke, NRDC/NYO


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XXX

The report also fails to acknowledge the range of methods advocacy NGOs use in their work,

stereotypically referring solely to their "extensive reli[ance] on litigation to achieve theirends."26 This characterization results in a perpetuation of an unbalanced perspective of

advocacy NGOs without any mention of other aspects of their work that actually occupies more

time such as research and writing for highly-regarded technical books, reports, and articles in

peer-reviewed journals.27 The awards conferred on advocacy NGOs illustrate further how blurry

the line is between advocacy and other S&T NGOs.28


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