Board of Directors President: Carolyn Whetzel BNA Inc. Vice President, Program Chair: Peter Fairley Independent Journalist Vice President, Membership Chair: Rob Davis VoiceofSanDiego.org Treasurer: Don Hopey Pittsburgh Post-Gazette Secretary: Peter Thomson PRI’s The World Ashley Ahearn KUOW-FM, Seattle Jeff Burnside WTVJ NBC 6 Miami Douglas Fischer DailyClimate.org Christy George Oregon Public Broadcasting Thomas Henry Toledo Blade Robert McClure Investigate West Jennifer Weeks Independent Journalist Sharon Oosthoek Independent Journalist Representative for Academic Membership: Tom Yulsman University of Colorado Representative for Associate Membership: Heather King Independent Journalist Founding President Jim Detjen Michigan State University SEJournal Editor Mike Mansur Executive Director Beth Parke August 19, 2011 Dr. Jane Lubchenco Under Secretary of Commerce for Oceans and Atmosphere and NOAA Administrator National Oceanic and Atmospheric Administration 1401 Constitution Ave., N.W. Washington, D.C. 20230 BY ELECTRONIC MAIL Re: Draft Scientific Integrity Policy Dear Dr. Lubchenco: These comments on NOAA’S draft Scientific Integrity Policy are filed on behalf of the Society of Environmental Journalists, an international organization of more than 1,400 individual journalists, students and scholars working to strengthen the quality, reach and viability of journalism across all media to advance public understanding of environmental issues SEJ is the largest and oldest organization of journalists who cover topics related to the environment. Members work in a variety of media including television, radio, print and online. SEJ monitors transparency of government agencies, including NOAA, through its Freedom of Information Task Force and the associated Watchdog Project. We wish to thank NOAA for the opportunity to comment on the Scientific Integrity Policy. We also urge the agency to publicly publish all of the comments on the policy after they are received so as to be completely transparent about the process and what comments may have affected the final policy. We were encouraged to see that you, in the June 16 cover notice, set the right tone by saying: “This scientific integrity policy is fostering an environment where science is encouraged, nurtured, respected, rewarded and protected.” The NOAA proposed Scientific Integrity Project sets a good goal when, in Section 4.03 it states: “In support of a culture of openness, and consistent with DAO 219-1 (Public Communication) and their official duties, NOAA scientists may freely speak to the media and the public about scientific and technical matters based on their official work, including scientific and technical ideas, approaches, findings, and conclusions based on their official work. Additional guidance for employees is available in DAO 219-1 (http://www.osec.doc.gov/omo/dmp/daos/dao219_1.html).” However, that guidance document itself (http://www.osec.doc.gov/opog/dmp/daos/dao219_1.html) is problematic. Section 8, "Official Communication with the News Media" requires advance approval by the public affairs office whenever NOAA staff scientists give interviews or otherwise make statements about their work. The policy further generally requires public affairs officials to sit in on all interviews unless other arrangements are approved by the public affairs staff. These sorts of limitations on scientists' communications with the news media (and through the media, the public) are simply unacceptable in a free society. The Society of Environmental Journalists agrees with the Union of Concerned Scientists, which said in a 2008 report (http://www.ucsusa.org/assets/documents/scientific_integrity/interference-at-the-epa.pdf) that government agency media policies regarding scientists must “respect two fundamental rights: 1) scientists have the right to speak freely about any topic (including agency policy) if they clarify that they are speaking as private citizens, not as agency representatives; and 2) scientists should have the right to review and correct any official document (such as a press release or report) that cites or references their scientific work, to ensure that accuracy has been maintained after the clearance and editing process.” SEJ recommends that NOAA adopt the language contained in the Union of Concerned Scientists' model media policy (http://www.ucsusa.org/assets/documents/scientific_integrity/Model-Media-Policy-1.pdf). We also note that we see no mechanism for enforcing the Scientific Integrity Policy. Perhaps this is a good thing if NOAA intends to pursue a policy that makes it difficult for scientists to communicate with the public through the public’s proxy, the news media. Two final points: * In Section 4 .02, NOAA PRINCIPLE OF SCIENTIFIC INTEGRITY, the last line, beginning: “Development and dissemination…” The concluding portion of that sentence refers to “other legislative and policy mandates.” Because of the relevance of this is a description, perhaps those mandates should be named or referenced for clarity. * In Section 5.02 d, NOAA POLICY ON INTEGRITY OF SCIENTIFIC ACTIVITIES says “Ensure that NOAA and Department of Commerce public communications guidance provides procedures by which scientists may speak to the media and public about scientific and technical matters based on their official work and areas of expertise…” We need to know what these procedures are. They are left undefined. Thank you for the opportunity to comment on this policy, and we trust you will incorporate this critique into your final policy. Sincerely, Carolyn Whetzel, President Society of Environmental Journalists Board of Directors Ken Ward Jr., Chairman, Freedom of Information Task Force Society of Environmental Journalists