The DNR’s Scientific Integrity Policy = Unaccountability

The Trojan Horse of Scientific Integrity

One of the most pronounced features of progressivism is its perpetual attempts to cloak itself in the symbolism and language of all that it opposes.

Hence, totalitarian societies employ names like the People’s Republic of China, or the German Democratic Republic, the name of the old Soviet satellite of East Germany back during the Cold War.

Progressives still use the same tactic today of pledging support for the very things they want to abolish. The progressive-birthed Consumer Finance Protection Bureau actually punishes consumers through its heavy-handed regulatory schemes and excessive fines, which disproportionately harm community banks. And when Democrats say democracy is on the ballot, they mean bureaucracy is on the ballot and must be saved at all costs.

When Democrats warn that the Trump administration is injecting politics into the federal workforce and undermining the nonpolitical and independent civil service, they mean they are worried that the president will actually hold a highly ideological bureaucracy beholden to special interests accountable to elected officials. Ditto for government misinformation and disinformation campaigns—progressives actually want to obliterate any challenge to their propaganda—and, as I reported last week, that mission is alive and well in states with Democratic governors, including Wisconsin.

There are in fact oh so many tools the left uses to erect facades that conceal their true intentions, and one of the biggest Trojan Horses the left uses is that of so-called settled science, or “scientific integrity,” in which the left cooks up the science it needs to justify its power seeking, and then labels any attempts to challenge the “expert” consensus as existential threats to humankind.

Because the very heart of the scientific method is the testing of hypotheses designed to undermine consensus—if the consensus is right (and it is often wrong) it will hold—ongoing investigation and challenge to prevailing orthodoxies is baked into the scientific cake in the pursuit of truth. Not only does robust antithesis further human progress, it provides a check against those who would seize temporal consensus as absolute truth and demand public surrender to it.

Science is never settled, nor should it be, and the left’s scientific consensus machine has become in modern politics the ultimate Trojan Horse.

In Wisconsin, the state Department of Natural Resources (DNR) has wielded for decades the Trojan Horse of Scientific Integrity to push an ideological agenda. Today, with a newly appointed left-wing and unqualified agency secretary, and with a proposed gubernatorial budget that, among other things, would punish hunters, cement industrial and environmental health policies placing state government in control of the economy, and fuel an unprecedented assault on private property rights using taxpayer dollars, lawmakers need to especially take action to rein in this agency’s power and its huge propaganda machine.

Dismantling the governor’s budget is a necessary but not sufficient condition for doing so. Beyond the budget, the legislature needs to pass legislation requiring the agency to rigorously pursue real science using an external and independent peer review process that allows participation and debate by all sides of debate, including regulated communities. Sen. Mary Felzkowski (R-Tomahawk) and then Sen. Duey Stroebel (R-Cedarburg) pursued similar legislation in 2021 and 2022, to no avail, but lawmakers must revive that effort and at least use public hearings to expose the agency’s scientific integrity policies as the fraud they are until a new governor can be elected.

The legislature’s oversight is needed to expose the enemy within, the DNR’s Trojan Horse of Scientific Integrity.

The Bureau of Science Services

To understand what must be done, we must first take a look at how we arrived at our current destination. The truth is, the DNR, particularly during the administration of Democratic Gov. Jim Doyle, became infected with hard-left ideologues—former water quality division chief Todd Ambs, a radical environmentalist, was the poster child for bureaucratic intolerance in those days—who constructed what in effect was a Ministry of Truth at the agency.

It was otherwise known as the aptly Stalinist sounding DNR Bureau of Science Services. Cloistered in this radical cell, bureaucrats spent their days making up the science the agency needed to pursue its climate change and anti-property rights agendas.

Their science, if you could call it that, was often wildly wrong. It peddled extreme United Nations’ climate forecasts for Wisconsin—distributed the propaganda to public schools, free of charge—long after those models were debunked, and marched into circuit court after circuit courts with fake science, which was often exposed but not without harm to innocent property owners.

To cite just one example, the DNR pursued a resident of Manitowish Waters relentlessly on a variety of issues, from oversized piers to a seawall repair the agency said harmed the lake’s water quality, and, just as important to the agency, detracted from natural scenic beauty.

The property owner and his attorney proceeded to make a mockery of the DNR’s science in court, showing that the agency did not employ the simplest of scientific methods used to analyze seawall activity and shoreline impact, such as wave height calculations or bathymetry analysis, and it resorted to such sloppy methods as using estimated average wind speeds rather than actually measuring winds on the lake.

They ignored established international standards in making calculations as well, and much of their analysis was prepared by an agency employee who admitted she had never designed a seawall and was not an engineer. In her deposition, however, she did call herself an expert in determining what was natural scenic beauty and what was not. According to the deposition, “every structure that’s a human-placed structure . . . diminishes natural scenic beauty.”

Over and over again, the DNR’s science was tossed out of court and ridiculed for its allegiance to averages rather than to specific scientific measurements; or for relying on hypothetical assumptions rather than verifiable field tests to determine many of its conclusions.

And from where did this science come? Well, the Bureau of Science Services, which was built to service the bureaucracy, not science. In reality, it was a Ministry of Truth so arrogant that its bureaucrats thought they could objectively define beauty. Once an agency does that, once a government defines what is aesthetically pleasing for you, you know you’ve crossed the boundary into totalitarianism.

Walker walked it out the door

Of course, when Scott Walker became governor, the bureaucrats knew their days were numbered. And sure enough, the governor and his allies in the legislature promptly moved to disband the bureau, reduce staff, and disperse remaining bureau employees throughout the agency, thereby diluting Propaganda Central.

Progressives were apoplectic. Here’s how Ron Seely, writing for the Center for Investigative Journalism, another left-wing front, put it: “Critics, both inside and outside the agency, say such a reorganization would rob the state of impartial science that should guide critical natural resource management decisions. Instead, they say, management would more likely be driven by policy decisions and politics.”

Never mind that agency management should be driven by policy decisions and politics, i.e., the representatives who are elected by the people. Never mind that a long trail of documents and court cases exposed that the bureau was anything but impartial in its science, and never mind that truly impartial science invites all sides to the investigatory table, something that never happened in the tightly controlled and manipulative cabal known as the Bureau of Science Services.

Appropriately, Gov. Walker walked the bureau down the plank to the waters of nonexistence. Of course, because of Wisconsin’s anti-democratic and archaic civil service system, Walker could blow up the nest but could not get rid of its inhabitants.

Soon enough, they were able to regroup, if informally, and devise a new poison pill, dressed in the language of high ethics in the public interest. In fact, agency bureaucrats had been dissatisfied with Walker’s actions since his election in 2010 and had already been preparing what they believed would save their scientific hegemony—a new policy called “scientific integrity.”

At the time so-called “scientific integrity” was only a nascent and emerging strategy within the progressive left. But what it was was a growing movement to, as Curtis Schube, executive director of the Council to Modernize Governance, put it, “revise scientific integrity standards in order to remove political appointees from the decision-making process and stymie a future administration’s ability to revisit controversial or ill-advised regulatory proposals.”

In a 2024 article for the council, “Scientific Integrity Under Attack: Is scientific integrity the latest front in the effort to protect the administrative state from representative democracy?,” Schube provides a useful timeline of the strategy, particularly on the federal level.

For starters, Schube wrote, before the turn of the century scientific integrity policies were focused on having standards and procedures in place for science used in policymaking.

“In 1999, for example, Environmental Protection Agency’s (EPA) ‘Principles of Scientific Integrity’ focused upon having ‘work… performed objectively, without predetermined outcomes,’ to ‘represent [findings] fairly and accurately,’ to acknowledge the work of others, etc.,” he wrote.

Schube wrote that those policies evolved but remained intact until the Biden administration came to power, including in the Obama years when administration policy memoranda stressed transparency and the “free flow” of scientific information through scientific inquiry.

However, it is also true that Obama began—along with the larger progressive movement itself—to target political interference, as Emily Berman and Jacob Carter pointed out in their “Scientific Integrity in Federal Policymaking Under Past and Present Administrations.”

“The Obama administration quickly made scientific integrity explicitly central to its mission; in addition to promising in his inaugural speech to ‘restore science to its rightful place,’ in an April 2009 speech before the National Academies of Science, Obama noted that ‘we have watched as scientific integrity has been undermined and scientific research politicized in an effort to advance predetermined ideological agendas,’” Berman and Carter wrote.

Gradually, Berman and Carter wrote, scientific integrity transformed from a research term to a policy term and, finally, to a policy itself.

None of which is to say the so-called political interference was unwarranted if the actual scientific malpractice was occurring in the federal agencies, which is a good bet. All the while, though, federal agencies were erecting institutional barriers, or formal infrastructure, to shield agency scientists from that very “political interference,” or what others might call safeguards and external peer review.

“For example, the EPA’s scientific integrity policy established a Scientific Integrity Official whose role is to ‘champion scientific integrity throughout the Agency,’” they wrote. “Furthermore, the policy states that this lead official ‘chairs a standing committee of Deputy Scientific Integrity Officials representing each EPA Program Office and Region.’”

In essence, welcome to the science police.

To be sure, no one wants improper, biased interference with scientific research and conclusions, whether the interference is political or not. The problem is pinpointing what exactly constitutes inappropriate political interference.

“The clear danger with these scientific integrity policy changes is how to define what science is ‘political,’ ‘inappropriate,’ ‘unjustified,’ etc,” Schube wrote.

Precisely. Increasingly, “political interference” has come to mean not money-laundered corrupt influence peddling by corporate monopolists, as it was in robber baron days, or by pharmaceutical companies and other special interests as it is today and was especially during Covid, but input from the public constituencies and elected policymakers, whether it is a stakeholder’s desire for independent scientific review or a lawmaker’s plea for answers to questions posed by the lawmaker’s constituents.

No longer is questioning agency science is allowed; it is instead considered unethical political interference. Scientific integrity has become a closed shop to differing viewpoints, and that only accelerated during the Biden years.

Leader of the Pack

Against this backdrop came the DNR’s own scientific integrity policy. It appeared on the agenda of the Natural Resources Board (NRB) as far back as April 2013 and was formally enacted in 2014. There is no explanation why a scientific integrity policy was suddenly needed, especially when a code of ethics for state employees already existed, as did a DNR code of ethics for department personnel, DNR work rules, and other state personnel rules and policies.

The policy itself, however, did give away the agency’s motives, if not a need: “The policy in this handbook is created against a complicated management and regulatory backdrop; the policy is intended to guide department activities in areas that are already subject to numerous rules and policies for various purposes.”

The “complicated” management and regulatory backdrop would seem to be Gov. Scott Walker’s control of the agency, and his and the GOP legislature’s bold attempts at the time to roll back DNR regulations. It’s hard to imagine what else the handbook could refer to.

The policy’s background section makes it even more explicit:

Translated: The extraordinarily biased Bureau of Science Services and its (often laughed-out-of-court) scientists wanted it, leaked the threat to their empire from the Walker administration to the press, which approached the NRB and voila! Not surprisingly, according to the document, the scientists at the Bureau of Science Services, who can define objective beauty and deem all other landscapes to be pollution, got the right to sign off on the working draft.

The message was to resist, and to form a network that might provide a shield to the agency’s ideological agenda.

It was also a document that began to infuse equity into the scientific framework. If issues brought forward by elected lawmakers were suddenly taboo, that wasn’t so for cultural, social, and other factors such as climate change—one might even call them “political’ factors—they were suddenly essential to scientific policy-making:

“It is the policy of the Natural Resources Board and the department to seek the best available and most current scientific information on which to base its policy, management, and regulatory decisions,” the policy states. “Other factors that may inform department decision making include social, cultural, legal, economic, budgetary, institutional, and environmental considerations.”

The handbook requires all DNR decision makers to involve science experts on scientific issues, and to rely upon scientific and scholarly information in decision-making.

Well, scientific and scholarly information were deemed to be documented protocols and procedures that include physical, biological, cultural, or social and economic sciences as well as landscape architecture, engineering, mathematics, and statistics that employ the scientific method. The experts are defined as those with opinions informed by credentials, training, education, profession, skill, publication, or experience beyond that of the average person, and decision-making is to be based on the “best, most current scientific information available on which to base its management and regulatory decisions.”

Finally, “in the context of this policy, expert opinion relates to opinions about the facts associated with scientific and scholarly activities, not policy or legal interpretations.” Except of course those cultural and social equity factors that overnight became part of the fabric of the scientific method.

Obviously, excluding policy and legal interpretations in decision-making forecloses most public input, which is, after all, about policy making, and it rules out any significant input from lawmakers who are by definition policy-makers, not scientists or scholars or science experts.

As for those scientists and scholars, they are largely defined as “science professionals,” meaning scientists the agencies hired.

Still, it must have sounded all so innocent, because the NRB bought it hook, line, and sinker. And, by the way, just to show how radical the DNR was at the time, in 2020 it was one of just two state agencies in the country that had such a policy, according to the Climate Science Legal Defense Fund. The other was the California Department of Fish & Wildlife.

Hate to say we told you so but …

Not surprisingly given the policy, critics of the DNR and its science have continued to complain about the agency’s bias in the ensuing years, so much so that Sen. Mary Felzkowski (R-Tomahawk) and then Sen. Duey Stroebel (R-Cedarburg) introduced a bill in 2021 to bring accountability to agency science by allowing external stakeholders and the joint rules committee of the legislature to request peer review of the agency’s work.

Felzkowski’s bill would have required the state government to show their proof, utilize feedback from impacted industries, and be held accountable for any scientific irregularities in promulgated or published rules that were based on, or relied on, scientific studies, scientific technical data, scientific methods, or other similar scientific information.

“This bill is very simple—follow the science,” Felzkowski testified at a February 2022 hearing on the bill. “Time and time again, we hear this phrase mentioned throughout the Capitol; here is an opportunity to put hyperbole aside and ensure that decisions being made for the state of Wisconsin fulfill our duty of creating sound, scientifically accurate policy.”

The bill had several components, but the most important would have given the legislature’s joint rules committee or those who might be regulated under a rule the right to an external peer review if they objected or questioned the data, methods, or findings of the DNR.

All in all, Felzkowski said in her testimony, the bill was about transparency.

“We owe it to the people of Wisconsin to ensure that the science behind state regulation is based on data that is supported by the scientific community,” she said. “Science has no room for partisan agenda, and this is a great first step in achieving sound, scientifically accurate policy.”

Naturally, the DNR was opposed to transparency and peer review. In its response to the legislation, the agency argued that it already follows a scientifically sound peer review process when promulgating science-based rules and that the bill would would add a step in the rulemaking process that gives “private individuals and interest groups an unprecedented role that would undermine the scientific process.”

“The current scientific peer review process works,” the agency argued. “The department regularly receives detailed critique of proposed rules from scientists and scientific organizations. The agency scientists review and consider this feedback and revise the rule as necessary, including changing standards in light of scientific information raised during the public comment process. This is scientific peer review.”

But the DNR’s objection to the bill demonstrated just how the scientific integrity policy works in real life: In adhering to the policy, science professionals inside the agency make the call, farm out review to the scientists they favor, and do not consider “private” interests who might be regulated, meaning the public. In other words, they peer review themselves.

This is how Wisconsin Manufacturers & Commerce accurately described it:

This bill or a similar one needs to be reintroduced if there is to be accountability in the science of the DNR. The proposed DNR budget needs to be thoroughly deconstructed, and then the agency’s internal scientific regime, especially its corrupt so-called scientific integrity policy, needs to be scrapped.

Only then will this agency have any integrity at all.