Policy Statements » Letters from the President:
22 December 2006
Mark Myers, Ph.D
Director
U.S. Geological Survey
John W. Powell Federal Building
12201 Sunrise Valley Drive
Reston, Virginia 20192
Dear Dr. Myers,
The undersigned organizations are all long-time supporters of the U.S. Geological Survey and are committed to ensuring that the USGS is able to effectively conduct research and disseminate it findings to all interested communities. We were glad to see your response to the Washington Post article regarding the peer review policies of the agency. We agree wholeheartedly that USGS science should be subject to peer review.
We do, however, have concerns about some aspects of the Fundamental Science Practices and wish to express them to you.
- Section 205.18 places approval authority in the hands of regional directors for "new interpretive material." These directors may not even be in the same discipline, much less qualified as experts to conduct peer reviews, of the scientific studies for which they have been given authority. Under such circumstances the USGS opens itself to the perception of censorship and risks undermining its deservedly high reputation for scientific integrity
- If significant new peer-review responsibilities fall on USGS staff, it risks causing delays to scientists charged in completing their own important work. The system must be carefully designed to avoid excess burden. The White House Office of Management and Budget, recognizes this in its direction to agencies to consider that “[t]he costs of peer review include both the direct costs of the peer review activity and those stemming from potential delay in government and private actions that can result from peer review.” As there is no apparent lack of quality of the research disseminated by the USGS, increased scrutiny would provide little benefit. Accordingly, additional costs should be minimized. The USGS peer-review practices should be finely-tuned to avoid delay, minimize burden on USGS scientists, and not serve as barriers to dissemination of USGS science.
We wish to suggest that:
1. The USGS make a preliminary determination as to the acceptability of the journal peer review process for the journal(s) to which USGS science is submitted. In so doing, the USGS should consider the fact that many of these journals use USGS scientists – the very same scientists who are likely to be doing internal USGS peer reviews – or their non-USGS collaborators – as peer reviewers. The quality of the review is therefore the same whether the review is internal or external. This would make dual review (internal and external) of papers submitted to journals unnecessary. The OMB itself recognized that journal peer review process may be adequate, as is reflected in the text of the OMB Peer Review Bulletin, enclosed and highlighted for ease of reference.
Adding an additional internal review to papers submitted by USGS scientists to scientific journals also runs the risk of creating conflicts that might prevent publication. For example, while in some instances, review leads to the discovery of an error that needs correcting, it is more typical that peer review is an evaluation that provides constructive comment. These comments are often editorial in nature, or reflect the different approaches of the reviewers. Scientists are expected to consider these comments and determine what changes, if any, are needed. They are not obligated to make all suggested changes. The ultimate decision to publish is that of a journal editor and is based on a number of factors, including suitability of the paper for that particular journal. An additional internal review by USGS can lead to subtle but important conflicts between USGS and the journal editor and external peer review panels. USGS scientists would be in a quandary as to who they should satisfy the journal or the agency, and with what consequence?
2. Many “disseminations” by government-funded researchers are not disseminations under the OMB Peer Review Bulletin (as indicated in the text of the OMB Peer Review Bulletin, enclosed and highlighted for ease of reference). For this reason, it seems unnecessary to
- Add addition internal review of abstracts submitted to scientific meetings and conferences. Abstracts are typically preliminary summaries of work to be presented at a meeting. They have little scientific content (no methods or data; if a conclusion is presented, it is a very brief summary). There is little here to be reviewed. The OMB Peer Review Bulletin even suggests that talks at scientific meetings need not be reviewed, but instead can bear a disclaimer stating that the presentation is not a formal agency dissemination (as reflected in the enclosed text, highlighted for ease of reference). If the talk itself is not a “dissemination,” the abstract of that talk should not be treated as a “dissemination.”
- Add additional peer-review to funding proposals which already undergo scientific review prior to funding decisions. Under the OMB Peer Review Guidance, funding proposals need not be peer-reviewed because they are not disseminated to the public.
Generally, we are concerned that some aspects of the new USGS peer review policy might unnecessarily serve as a barrier to dissemination of its high quality science to the larger scientific community, to decision-makers, and the American public.
Finally, we ask you to consider the impact on two important groups of non-USGS scientists: those who collaborate with USGS scientists and potential employees.
First, will non-USGS scientists want to continue collaborating with their USGS colleagues if their work is subjected to peer review beyond what is appropriate and that may become “excessive” and the cause of unnecessary delay?
Second, will the kind of leading scientists that have been a mark of USGS still want to work for an agency if their work must undergo additional layers of review, more than would be the case if they worked for another agency or an academic institution? To attract and retain more of the top-notch scientists such as those who constitute the highly regarded corps of USGS scientists, the USGS must be careful to avoid imposing unwarranted burdens and restrictions on its scientists.
Again, we wish to state our support for peer review and for the USGS’s efforts to conduct and communicate the highest quality science.
We thank you for this opportunity to share our concerns with the USGS and hope that these comments prove useful.
Sincerely,
Ellen Paul*
Executive Director
Ornithological Council
Laura Bies
Associate Director of Government Affairs
The Wildlife Society
Nadine Lymn
Director, Public Affairs
Ecological Society of America
Robert Gropp
Director of Public Policy
American Institute of Biological Sciences
Peter Saundry
Executive Director
National Council for Science and the Environment
*To whom responses should be addressed:
Via regular mail:
8722 Preston Place
Chevy Chase, MD 20815
Via e-mail:
ellen.paul@verizon.net
Via phone:
(301) 986 8568, Via fax:
(301) 986 5205
