Polar Bear Study Opened Up for Public Comment Period to Undermine its Findings

Published Mar 24, 2020

What Happened: The Trump administration opened an unprecedented public comment period on February 18th to solicit public feedback on a peer-reviewed scientific study. The study, authored by scientists at the Fish and Wildlife Service and United States Geological Survey, investigated the effects of oil and gas exploration on polar bears.

Why it Matters: Opening up a public comment period on published research sends a signal to federal scientists that their own employer does not trust their work, its validity, or the peer-review process. Comments will likely come in from non-experts that could be critical of the published research. If the administration heeds comments from non-experts, this could lead to the peer-reviewed study not informing decisions to protect polar bears from the effects of oil and gas exploration in the Arctic.

On February 18th, the Trump administration opened an unprecedented comment period asking the public to provide feedback on the value of an already published peer-reviewed study. The study, “Seismic survey design and potential impacts to maternal polar bear dens,” was authored by the administration’s own scientists from the US Fish and Wildlife Service (FWS) and US Geological Survey (USGS). The study investigated how different seismic survey designs may affect the survivability of polar bears and their cubs during spring.

Opening up a public comment period on a study that has already been through a peer-review process is unprecedented. Even the FWS admitted that the move was unusual - FWS spokesperson Gavin Shire stated, “This is not something we have typically done in the past that I am aware of…”

Peer review is the evaluation of an expert’s work by one or more people with similar competency and expertise. The process works very similar to an inspection and essentially assures the public that someone who knows what they’re doing has double-checked it. It is still the best process for assuring the scientific community and the public that the study is representative of good scientific practice and that the authors have interpreted the results of the study well.

Since the peer-review process is still the best known process for scientific quality assurance, the administration is sending a signal by opening up this public comment period that it does not trust this process or the quality of work of its own scientists . This will likely further deflate the morale of agency scientists working to protect public health and safety.

If the peer-review process ensures high quality scientific work then why would the Trump administration open up a public comment period on a peer-reviewed study? Shire, the FWS spokesperson, says that this is part of new efforts by the administration to increase transparency. However, the agency has not opened up public comment periods on any previous peer-reviewed studies published at FWS so this seems to be a weak argument. The public comment period doesn’t make sense because many who will be commenting on the study do not have the appropriate credentials to review the intellectual merit of the study.

Dr. Andrew Rosenberg, director of the Center for Science and Democracy (CSD) at the Union of Concerned Scientists (UCS), believes that the administration is opening the public comment period to allow special interest groups to weigh in on the study. “What it looks like to me is they’re giving industry the opportunity to negate the study,” Rosenberg said. The evidence is piling that there may be a concerted effort by the Trump administration to sideline the science saying polar bears may be harmed by oil and gas exploration in the arctic. In February of 2019, MotherJones released an internal FWS memo from scientists that found oil exploration activities would harm polar bear populations in the Arctic National Wildlife Refuge. The memo was ignored and the Bureau of Land Management issued a finding of no significant impact from oil exploration on polar bear populations as part of an environmental assessment.

Scientific experts and their work should inform government decisions, and the government should trust their work, especially if it has gone through a peer-review process. By undermining trust in their own scientists, the Trump administration is sending a chilling signal to its own employees that will likely negatively affect worker morale, effectiveness, and productivity. Additionally, if the administration chooses to listen to non-experts or those with conflicts of interests in protecting endangered species, those species may be lost forever.