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THE DECISION OF THE DANISH MINISTRY OF RESEARCH ON DEC. 17TH, 2003, concerning
A COMPLAINT LODGED BY BJØRN LOMBORG ON FEBRUARY 13TH, 2003.

A summary
Background: Bjørn Lomborg (BL) lodged a complaint to the Danish Minister of Research, Helge Sander, in a letter dated Feb. 13th. In this letter, he made a brief statement that UVVU (= The Danish Committees on Scientific Dishonesty) did not have the right to bring its verdict that his publication, The Skeptical Environmentalist (TSE), is deemed to fall within the concept of objective scientific dishonesty, and is clearly contrary to the standards of good scientific practice. This claim was supported by a "responsum" of more than 20 pages written by Peter Pagh, Professor of Environmental Law at the Copenhagen University, in which Pagh argues that the decision of UVVU was unjustified. BL sent supplementary information to the Minister on March 4th.
    The Ministry gathered comments from the National Social Science Research Council and from UVVU. The ministry furthermore received complaints from the following persons: 1) from Lars Thomsen, January 17th. (pro-Lomborg) 2) from Kåre Fog, March 15th (anti-Lomborg) 3) from Arthur Rörsch, April 7th (pro-Lomborg) 4) from Mette Hertz and Henrik Stiesdal, April 23rd (anti-Lomborg)
    All four complaints were rejected by the Ministry on July 10th, on the grounds that only persons having an essential individual interest in the decision had the right to complain, whereas people whose interest is of an ídealistic, non-personal character, do not have this right.
    The final decision of the minister, published Dec. 17th 2003, encompasses 70 pages. The first 28 pages are a review of the case, with quotations of relevant letters, whereas the rest contains the Ministry´s arguments on a long series of items. Its final conclusion (p. 69) is as follows: "For the reasons referred to above the Ministry finds that it must return the case to UVVU. At the same time, the Ministry declares that the treatment of this case by UVVU has, in its opinion, been reprehensible. "
    The most important points of criticism were the following:
    Item 5.1.2: The concept of "good scientific practice". Peter Pagh has alleged that UVVU was not entitled to make decisions on "good scientific practice", because this phrase is not mentioned in the statutes of UVVU. In comments from the Ministry's working group concerning rules of ethics in research, which was established on February 13th 2003, it is argued that UVVU can nevertheless discuss this concept, because they can apply the principle of "the less contained in the more". They are entitled to discuss the concept in the premises for their decision. However, there is no definition of "good scientific practice", and therefore this concept cannot be a part of the decision. The working party notes that there has been much discussion as to whether the norms for "good scientific practice" are the same in social science as in the exact sciences, and points out that the Social Science Research Council has made statements that the works of other scientists must be cited in such a way that their points of view are clearly understandable from the text and not distorted. The working party concluded that the citing of violation of "good scientific practice" in UVVU´s decision is misleading, because the reader may believe that this judgement is a part of the decision, and not a part of the premises. The consequences of this for the accused person are potentially so grave, that this cannot be accepted. The working party therefore decided that this error made by UVVU is so serious that their decision cannot be accepted, and the that case must be treated anew. The Ministry requested that, in any future case, UVVU coordinate its decisions with the recommendations of the Social Science Research Council.
    Item 5.1.3. The concept of "objective scientific dishonesty" In the statutes of UVVU, it is stated that they can treat cases of "misleading application of statistical methods" and "distorted interpretation of results and distorted conclusions." It is not completely clear from these formulations whether these acts must be deliberate, and this lack of clarity means that a person can be accused of these acts even if they were not deliberate. The Ministry accepts that UVVU, in the present case as well as in previous cases, uses a working method where they first evaluate if there is a case of objective dishonesty, and after that investigates whether this dishonesty was deliberate. However, this implies that the concept of "objective dishonesty" be a part of the premises, not of the conclusions. The ministry finds that a splitting-up of the dishonesty cannot be repeated in the conclusion, because this may create a misleading impression of the conclusion proper, viz. that in the opinion of UVVU, this was not a case of dishonesty in the understanding of the statutes. However, the Ministry does not find that this error is so serious that it can by itself cause the case to be returned to UVVU.
    Item 6.1: Missing information on the basis of the decision According to the "official principle", any public authority must ensure that all relevant information has been obtained. In the Ministry´s opinion, UVVU has not done that. They have presented no documentation detailing exactly at which points BL has been biased in his selection of data and in his argumentation, and no grounds are given as to why UVVU agrees with the complaining party. It is insufficient merely to present criticism of a scientist´s working methods. UVVU has to relate to this criticism and decide whether it is justified, and why. Because UVVU has not accomplished these two tasks, their decision is not valid, and the case must be returned to UVVU for fresh consideration.
    Item 6.2: Is the book TSE a scientific publication which may be evaluated by UVVU ? The Ministry reviews the 4 arguments mentioned by UVVU why the book should be considered a scientific publication. These are: 1) BL designates himself as "Associate professor of Statistics at the Institute of Social Science at Aarhus University". 2) The publication makes extensive use of notes and references. 3) In the yearbook of Aarhus University for 2001, the book is listed under the heading: "Publications/Research publications/monographs." 4) It is widely regarded in the public as a scientific publication. As to point 4, the ministry argues that this claim cannot be tested and is therefore of no value. The Ministry also rejects the three other arguments, simply by stating that these are insufficient to prove that the publication is scientific. Their conclusion, therefore, is that UVVU has not documented that the book is scientific. As they have not done this, their decision is invalid, and the case is returned to them for reconsideration.
    Item 6.5 The importance of peer review The Ministry criticizes UVVU on this point for using a double standard. Firstly, UVVU writes much about peer review as an important type of quality control in science. Next, the Ministry cites the "kronik" published by Chris Harrison in Politiken on March 4th, 2003, where he writes that Lomborg´s book was not accepted until it had been thoroughly reviewed by four acknowledged scientists. The Ministry, in a letter to UVVU, asked if this was new information to them, and they answered: "UVVU did not investigate on what basis the publisher decided to publish the book, and we have therefore no information about a possible peer review". To this, the Ministry comments that it is strange that UVVU first lays great stress on the importance of peer review, and then completely fails to investigate whether TSE was peer-reviewed. They also point to a quote from Raven and Wilson, viz. "We are deeply disturbed that Cambridge University Press would publish and promote an error-filled, poorly referenced and non-peer-reviewed work." The Ministry criticizes UVVU for agreeing with Pimm and Harvey without investigating whether this claim is correct. However, the Ministry states that because this subject has not been considered by UVVU, it cannot either be considered in a new hearing of the case.
    6.6.2 Hearing of the involved parties before publishing the final decision The Ministry feels unable to decide for certain if BL should have been allowed to comment on the final decision before it was published. - But see item 6.8.
    6.7 The tone of the language According to the Ministry, the language of the decision was not sober. They cite the following examples: P. 2: Other members thought that the term "bad science" should not be an obstacle to a complaint being admitted for consideration by UVVU. P. 4: Bjørn Lomborg´s most egregious distortions and feeblest analyses are his citations of cost-benefit calculations. P. 7: Lomborg is giving skepticism - and statisticians - a bad name. P. 7-8: BL cynically spurns this method, because such estimates sound more ominous. P. 8: The chapter on acid rain is equally poorly researched and presented. P. 9: . . the prime example in our time of someone who distorts statistics and statements to serve his own political end. The Ministry writes that even though most of the cited sentences are quotations or indirect quotations, UVVU should not quote text that does not meet the norms of good administrative practice. When UVVU criticizes BL for smearing others, they should not smear BL themselves. The Ministry demands that UVVU uses a more urbane tone in the future, but does not consider this point so serious that it by itself demands a new treatment.
    6.8 Publication of UVVU´s decision. In his response, Peter Pagh stresses that the statutes of UVVU prevents the decision from being made public. But although this possibility is not specifically included in the list of what UVVU is entitled to do, there have been several precedents for UVVU decisions being published. The decisive point is that UVVU's decisions are covered by legal statutes giving right of access to documents. In the present case, as in previous ones, there were a number of Danish and foreign journalists who demanded this right. They were denied this by UVVU, but at the same time they were told when the decision would be announced, so that the publication for the press on January 6th 2002 could be considered the point of time when they were given their right to access. However, the Ministry discusses which types of information are open to the right of access. Information on private matters are not included in this right. Danish law states that in the case of persons in leading positions, disciplinary actions as serious as, or more serious than, a formal warning are covered by the law of right to access. However, when BL published his book, he was not in a leading position, and therefore this paragraph is not relevant in the present case. That is, information concerning the position of a person who is not a leader may be kept secret. When balancing the requirement to protect private information with that of the public's right to know, there will at least be a requirement that the person concerned be given a right to comment on the decision before it is published. However, cf. item 6.6, BL was not given this right, and this, in the Ministry´s opinion, was an obvious error. Whether the decision could have been published after the hearing of BL, cannot be known. It would depend on the result of the hearing. The Ministry writes, however, that the right of access concerns the decision, not the premises of the decision. And the claims of objective dishonesty and violation of good scientific practice should not have been decisions. UVVU were entitled to mention these points as a part of their premises, but not as a part of the decision. Therefore, because they made the error of formulating the premises as if they were the decision, they made the error of publishing the premises, which they were not entitled to do. In conclusion, the Ministry states that because the damage to BL caused by the publication cannot be remedied, a new hearing of the case would not change this. But the Ministry expresses criticism that BL was not heard.

 This summary was written by Kåre Fog Dec. 19th, 2003.