On November 19th a group of “scientists based in British Columbia” produced an open letter to Premier John Horgan, and several of his cabinet colleagues, about improving British Columbia’s Environmental Assessment (EA) process. The letter, was from the Earth to Ocean Group from Simon Fraser University and co-signed by a number of academics and graduate students and it betrays common, but serious, misconceptions about how science is done in the private sector.

I am a private sector environmental consultant. I am the professional hired by commercial and industrial clients to develop the sampling programs; collect and analyze the data generated; and prepare the reports being criticized by these academic scientists and frankly I am insulted by their faulty claims about our work. As a private sector consultant I am writing this blog post in response to the errors in this letter.

I am not, however, surprised by the content of this letter. The problem lies in the fact that while every private sector scientist has spent time in public institutions, virtually none of the academics or activists, who insult us, have spent significant time in the private sector. As such they really have no clue what is involved in private sector environmental consulting. They create a strawman version of private sector consultants and in creating that strawman demonstrate how little they know or understand about the topic.

As a private sector scientist, I have lots of first-hand experience encountering this type of bias. As a Professional Biologist, I am required to complete ethics courses and sign on to a Code of Ethics. My most recent ethics course was taught by an academic and the target audience was regulators (although one other consultant was in the course with me). Virtually every scenario presented involved the unethical private sector consultant skewing data and the brave regulator identifying the ethical lapses and calling them out on them. This is how we are viewed. We are the cartoon villain with no redeeming characteristics.

Now here is the truth. Unlike these academics (protected by tenure) and NGO scientists (hired precisely because they are willing to push a one-dimensional viewpoint) professional scientists are held responsible for what we say and how we do our work. I have previously written a blog post: A primer on Professional Governance in the Natural Resources Sector where I explain how professional scientists are governed. As I wrote in that piece outsiders like these academics:

imagine that environmental consultants act as advocates for their clients. Nothing could be further from the truth. A consultant who advocates solely for their client will soon cease to be able to operate as a consultant once their professionals lose their revocable professional designations and the government refuses to accept their submissions.  

Put simply, professional scientists in BC are held to much higher standards than our academic or NGO peers. We operate under strict rules of behaviour and practice guidelines and are overseen by regulators and our professional bodies to ensure that our work meets the highest standards. When our work does not meet those standards we are subject to disciplinary panels who have the ability to destroy our careers. We have a huge incentive to behave well and virtually no incentive to behave badly.

So let’s look at what else these academics got wrong in their letter:

1) Lack of scientific independence.

A lot of academics I have spoken seem to think that consultants are like lawyers. Lawyers are hired to advocate for their clients. This is not the case for environmental consultants. We are explicitly constrained from advocating for our clients. We are required to be both objective and independent. It is that very independence that explains our industry’s very existence. Most large industrial firms have the resources to hire in-house staff to do this type of work but no regulator would trust work done solely by in-house experts. That is precisely why our industry exists. To provide arms-length expertise that can be trusted by the regulators.

No consultant would have a career if they were known as being willing to be influenced by their clients. You simply can’t pay me enough to skew my results for one client because doing so would put my entire career at risk. That is why the only people who make these claims are activists and academics who have never done this type of work.

Sometimes junior staff make the mistake of acting as advocates for their clients. But every organization has policies to ensure that our people work in an above-the-board manner. Virtually every story you read about misbehaving consultants involves early-career individuals and junior field technicians rather than actual decision-makers. That is because it takes years to get your professional designation and during that time you have to learn how to be an effective and objective consultant.

This is why being insulted by activists is so ironic. The activist scientists are literally paid to promote the views of their employers. They go into the discussion with a fixed viewpoint and then look for the information to support that viewpoint. That is why it has been so easy for me to debunk their work at this blog. In this case it is clear, they are projecting their lack of objectivity on others.

2. Lack of peer-review of evidence.

This is another common trope from academics who simply don’t understand how private sector science works. These academics imagine that the academic model for peer review is the only model that exists. They are wrong. I have written a long post: On blogging and the irrelevance of academic peer review in multi-disciplinary fields which explains how peer review works in the private sector. Put simply, no report would leave our office until it has had a full review by appropriate experts who are arms-length from the project.

Moreover, as I will describe in the next section, unlike the academics and activists; our work is fully transparent. We include all the information used to generate our analyses in the reports themselves.

So no my report was not reviewed by some outsider who may not be familiar with the details of our work or the regulatory requirements in our region. Our work is reviewed by actual experts in our field and then submitted to regulators with all the information necessary for that regulator to confirm that everything I have produced is scientifically defensible. The letter authors complain that the regulators don’t have the expertise to review the work, but they ignore the fact that the regulators regularly hire outside specialists to review the work on their behalf.

Another important consideration is that I submit my reports under the penalty that if my report does not meet muster I can have my professional designation revoked and I can lose my job. I’m betting more academics would write their articles differently if instead of a rejection letter, every time a paper was judged unsuitable for publication, they were pulled up in front of a disciplinary committee investigation from their professional college. As I wrote in my Professional Governance post:

The college is tasked with ensuring that professionals act within professional standards; they don’t act outside their specific area of expertise; they don’t have undisclosed conflicts-of-interest and they act and operate independently of their client and/or government. You may be paid to do a task by your clients and/or you may work for the government but as a professional you have a responsibility to the public good and to behave ethically and the College has to be there to ensure that every professional measures up to that heady standard.

3. Lack of transparency.

This is another one that makes me laugh. Anyone who has read one of my reports knows that they are designed so that any outsider with time can completely replicate our analyses. The last report I submitted to the government was over 12,000 pages long. It was that long because every analytical result, every borehole log, every monitoring event is documented along with all its supporting information. Unlike academics who hold back critical portions of their work, in the private sector we have to provide the results of every analysis and every monitoring activity in our reports.

I would challenge any academic to provide the level of detail in one of their reports that we provide in ours. The NGOs are even worse. Look at their reports. They provide summaries with no information provided to establish the reliability of their results.

What is particularly funny, in a letter of this type, is that one of the few references in the document doesn’t even get the information right. Reference 4 is to a document: The Insignificance of Thresholds in Environmental Impact Assessment: An Illustrative Case Study in Canada by Murray et al. According to the letter that reference makes a claim that:

Under the proposed EA process, there is no requirement that all data generated by the proponent, or the evaluation of evidence by the Technical Advisory Committee, be made available to the public.This has been identified as a major flaw of the current EA process in BC.

I have carefully read reference 4 several times and nowhere in that article do I see the statement the authors of this letter claims it makes. That is not surprising because that claim is false. I am going to say this to be absolutely clear here: the claim made in this letter is simply wrong and is in no way supported by the reference they supply to support their faulty allegation.

Transparency is a fundamental basis of our industry. Often reviewers complain because we provide so much information in our reports that they find it hard to review it all. Anyone who has seen an Environmental Assessment wouldn’t make such a ridiculous claim. I simply cannot believe that so many academics signed this letter without confirming that the references cited actually supported the claims made.

To conclude let me be absolutely clear: the entire premise of the letter is wrong and the authors of the letter demonstrate that they have no clue about how private sector science is conducted. Not terribly surprising that a group of academics who have never held a decision-making, level position in a private sector environmental firm don’t know how the industry works.

The reason organizations and businesses hire private sector scientists is our objectivity. The reason the government trusts our work is because of our objectivity and the reputation our industry has built as being objective and transparent. Certainly like every industry there are bad actors, but unlike our peers in the activist or academic communities, in our industry misbehaviour is punished. We can’t lie about something and then claim it was a “non-verifiable statements of subjective opinion“. To do so will lose us our careers. Unlike academics and activists,we are bound by ethical and legal rules that preclude us from behaving in the manner that these activist academics imply we do. We operate under strict rules of behaviour and practice guidelines and are overseen by regulators and our professional bodies whose sole role is to protect the public by ensuring that we behave in a manner consistent with our rules of ethics and that our work meets the highest standards.