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Guidance on Advocacy and Recommendations in USGS Information Products

Updated March 2014

Background

The following guidance is provided in response to questions from authors related to advocacy and placing recommendations in U.S. Geological Survey (USGS) information products.

The USGS is known for the quality of its science, and because of this it is frequently sought out by others to provide high quality information. Our partners, customers, and stakeholders often request "recommendations" to accompany our reports and other publications. USGS information products do not recommend or appear to advocate or prescribe a particular public policy, however, some science-based recommendations are allowed.

USGS studies are primarily natural-science based in their considerations. It is rare that they would take into account factors such as affordability, social justice, public opinion, political quid pro quo, or other considerations that may have to be factored into a decision. A better course of action is to present what the best science predicts, and what happens under less optimal or alternate science scenarios. The decision maker can then decide if the optimal or an alternate scenario is the most desired path for society weighing factors other than science. The key distinction is that these recommendations from USGS scientists must relate to technical issues that are based on peer reviewed science and not to a particular public policy direction. As "the" recognized multi-disciplinary experts, we have the understanding and breadth of knowledge to address the entire science related, fact-based consequences of recommendations more fully than many resource managers and planners. Therefore, USGS scientists have a responsibility to provide recommendations that are based on peer reviewed scientific facts and presented as unbiased, impartial interpretations.

Guidance is delivered herein by providing examples of acceptable and unacceptable recommendations. Separate guidance for recommendations made from committees in which USGS scientists are members is also included. Bureau Approving Officials (BAOs) in the Office of Science Quality and Integrity can assist with drafting intended recommendations for particular products, including suggested word choices to ensure that the author is addressing only the science. Authors should consult the BAOs if they have doubt about whether a recommendation they intend to use meets USGS policy.

Examples of Acceptable Recommendations

The following relate to instances when USGS scientists have been asked to provide recommendations to cooperators. Included are real examples where appropriate, acceptable recommendations, based on facts and presented as unbiased, impartial interpretations that do not prescribe a particular management or policy decision, have been used.

  1. USGS was asked to review the storm water monitoring program run by a State department of transportation, compare it to storm water monitoring programs run by a County and by a City, and then recommend changes in processes and protocols to improve the program and the quality of the information collected.
  2. USGS was providing technical assistance to the Navy in their efforts to mitigate a solvent plume at one of their sites. We were asked to evaluate the potential of natural attenuation to mitigate contamination from their site and recommend or not, reliance on it.
  3. A science panel chaired by a USGS scientist was charged with providing recommendations on how to best implement adaptive management experimental designs based on lessons learned from Mississippi River restoration projects, to a partnership of Federal and State natural resource agencies. Note: the panel was not asked to recommend what restoration projects should be done but rather how to design experiments to learn the most from these restoration projects within an adaptive management framework so that future restoration projects can be most effective.
  4. Models have been developed by USGS scientists that predict locations of suitable habitat for threatened and endangered birds. The U.S. Fish and Wildlife Service and State natural resource agencies needed recommendations based on model results as to where to concentrate their conservation activities based on these model results. A list of ranked alternatives was provided. Note: we were not asked what conservation activities (or policies) to pursue, but to provide a science based recommendation of where the activities should be concentrated.
  5. The new generation of nest survival models appears to be ideal for intensive, short-term investigations of raptor breeding biology. Extensive, long-term monitoring efforts, especially those that involve legacy datasets, may not be able to take full advantage of nest survival models and may be forced to rely on more traditional measures of nesting success. Investigators should be aware of biases when using old approaches. In some cases, these biases are neither consistent nor predictable. Traditional measures of nesting success tend to be unreliable for species whose nesting attempts are difficult to locate and for situations in which a small proportion of the population is sampled. The ANS estimator could be sufficient for assessing long-term trends of species with highly detectable nests. Traditional measures may be adequate for studies with extensive background data on nesting territories, but they are not suitable for studies in new areas with limited background information. We recommend that biologists design future surveys to collect data necessary for newer nest survival models. A minimum monitoring effort would include at least 2 visits to the nest. At minimum, biologists should record the date, the stage and viability of the nesting attempt, and age of the young if present. If sampling from a larger population, we recommend that the biologist implement a stratified random sampling approach.
  6. Knowledge of timing larvae emigration success for cui-ui in relation to Tahoe sucker and Lahontan Reside is important for managing water to promote the emigration success of all three species. In the low-flow year of 2012, Tahoe sucker larvae were sparsely represented, and their emigration occurred approximately 1 month after cui-ui. Lahontan redside larvae were so few in number, and most were captured in 1 day, that that we were unable to discern a distinctive emigration pattern. Timing of emigration of the three species should be monitored in the future when the populations of Tahoe sucker and Lahontan redside are more robust. The water management plan for the Pyramid Lake fishery would benefit from knowledge of the respective emigration patterns of cui-ui, Tahoe sucker, and Lahontan redside larvae into Pyramid Lake over a broader seasonal sampling period (that is, February through August) and under different flow regimes representing a range of wet to dry water years.
  7. Cursory morphological inspection of Five Spring pupfish suggests some degree of convergent evolution with Warm Springs pupfish (Cyprinodon nevadensis pectoralis). Similar to Warm Springs pupfish (Miller, 1948), the pelvic fins of Five Springs pupfish appear to be vestigial. The isolated Five Spring's population of Amargosa Ash Meadows pupfish requires protection and management to ensure its persistence.
  8. We recommend that data from this and future studies of fish approach and passage at Willamette Basin dams be analyzed and reported in a standard manner to enable identification of causal mechanisms affecting guidance, attraction, and passage, and to facilitate comparisons among studies. Studies of fish passage at dams on tributaries of the Willamette River are increasing in number and location; identifying common analytical methods and reporting metrics will simplify comparisons among studies and foster efficient learning. We suggest that time-to-event methods be used to describe rates of dam passage and other pertinent events when suitable data are available. These methods make efficient use of the data from all subjects at risk of an event such as dam passage (rather than focusing only on subjects that experience the event), enable the use of time-varying covariates, and perform efficiently with skewed data that are common in studies of fish migration (Hosmer and Lemeshow, 1999; Castro-Santos and Haro, 2003; Castro-Santos and Perry, 2012). We also recommend that standard distances from passage routes or structures be used to evaluate guidance, approach, and passage (metrics described by Castro-Santos and Haro, 2010), as well as other metrics such as discovery efficiency and entrance efficiency (as recommend by Sweeney and others, 2007). Because physical environments differ among dams, a single distance need not be used, but a series of standard distances could be adopted. The distances from the dam outlet we used in analyses of dam passage were chosen arbitrarily to illustrate the changing effects of diel period, discharge, and elevation with distance from the outlet. There may be more meaningful distances in terms of providing information useful to the design of alternative operations or structures to enhance downstream fish passage.
  9. For future predation analyses, we recommend coverage of the peak salmon migration periods and sampling efforts throughout the reservoir, as well as a focused effort in areas with high potential for either predator abundance and/or predation. Our results for 2011, specifically the hotspot analysis, as well as those from Thompson and others (2012), indicate that the area near the mouth of Crab Creek (in the Priest Rapids mid-reservoir reach) is an area of potential concern. Efforts could be expended to continue to explore incorporating hotspots in conjunction with the randomized monitoring sample frame within the reservoir relative to survival and predation, specifically Crab Creek. We also recommend emphasis on other areas, such as the near-BRZ, and BRZ for both forebay and tailrace reaches. Furthermore, research efforts could be expended to look into alternate predator collection and removal methods, to better understand the differences between angled fish and electrofishing collection results in the tailrace environments.

Examples of Unacceptable Recommendations

The following are hypothetical examples to illustrate types of policy and management recommendations that are unacceptable and must not be used (although the scientific studies and conclusions leading to them may be excellent):

  1. Scientific studies indicate that a dam has had detrimental and unacceptable effects on downstream ecosystems, including certain fish populations. The USGS recommends that the only viable solution is to remove the dam. (Note--as stated this is a policy prescription. Were the statement to read "USGS describes several options and the natural resource costs/benefits of each" then this would be acceptable.)
  2. Geological and geophysical studies have identified a new high-risk seismic area. In order to protect life and property, USGS recommends that zoning or other regulations should be implemented to require stricter building codes and retrofitting of structures within one mile of this fault zone. (The authors should have stopped short of making a recommendation and simply presented their findings on the presence and characteristics of the seismic area, along with any other information that might have been included in the report.)
  3. Studies of the risk factors for population viability of an endangered species indicate that adult mortality is a critical factor. The first-choice solution is to stop man-caused mortality through hunting.
  4. USGS scientists are asked to help another DOI agency develop a long-term ecological monitoring program, including recommendations for the administrative structure of the program.

Group (Committee) Authored Information Products

USGS scientists are regularly asked to sit on international, national, or regional committees and science advisory boards or panels of experts to evaluate and make recommendations, develop certain limits (for example, water quality standards or estimates of oil spill volume) and advocate solutions to natural resources problems. Traditionally, serving on such committees has been allowed and encouraged. In addition, USGS scientists are often selected to join larger groups reviewing subjects with specific policy implications such as global climate change, management of endangered species, consequences of energy extraction, management of Arsenic or Selenium, and risks from hazards. Such work a priori has a charge from a sponsoring body such as a scientific society to review and analyze data and then to develop explicit recommendations of next steps for further scientific investigation, management of earth resources, or policy development. Occasionally, the committee's charge is to provide a list of alternatives. Conversely, on other committees the charge is to provide a ranked list or even one explicit remedy to a confounding management issue. Regardless of the overall nature of the final product, policy recommendations at some level are part of the requested effort of these committees.

When USGS scientists are chosen for such endeavors, it is a recognition of both the quality of USGS science and the scientific stature of individual USGS scientists. USGS, although bound by a nonadvocacy policy regarding its science, as a public agency cannot participate in the broader scientific discourse without participating in such activities. Indeed, USGS insight is often critical to the success of such efforts.

Below are four approaches that are currently used in the USGS to participate in such efforts while maintaining the appropriate nonadvocacy scientific role:

  1. Allow the recommendations if the information product is from the committee as a whole and not the committee members, and if it is clearly identified as a product of the sponsoring organization;
  2. Organize the information product by chapters that are identified by author. The USGS author is not identified with the chapter containing recommendations but only with the specific chapter authored;
  3. Remove the USGS scientistís name as author and instead recognize the participation of the USGS scientist in the acknowledgement section of the information product. That is, the USGS provided X and that person is recognized for their expertise but the scientist is removed from involvement with specific recommendations;
  4. When impossible to maintain the non-advocacy role using the methods above, USGS scientists have requested complete name removal from products produced by such committees.

Exemption from USGS Fundamental Science Practices (FSP): If a USGS employee serves on a committee that produced a product for a sponsoring organization (for example, the National Research Council), the committee has its own bona fide peer review process and the employee is identified as a committee member rather than as an author of the committee findings, then that manuscript shall not be subject to USGS FSP policy for peer review and Bureau approval (http://www.usgs.gov/fsp/).

Procedurally this is an important exemption since groups such as the National Academies have their own robust peer review process in place and they disallow contributing committee members from sharing any of the preliminary work outside the specific committee. Under these circumstances, the USGS peer review process would be impossible. Requiring that the USGS review and approval process be imposed in these cases would effectively prevent USGS authors from participation in such committees.

Note: Notification to and concurrence of the USGS Ethics Office is not required in order for USGS employees to serve in their official capacities on international, national, or regional committees and science advisory boards or panels of experts. Participation must be approved by an employee's supervisor, who must determine there is a benefit to the USGS and that the service is a good use of Federal Government time and resources.

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