Last year, when President Donald Trump issued the executive order “Restoring Gold Standard Science,” I had my concerns but held out hope for greater emphasis on the use of peer-reviewed science in agency decision-making. In fact, the order specifically says, “Gold Standard Science means science conducted in a manner that is…subject to unbiased peer review.” However, not all that glitters is gold, and my hope has waned after some early interpretations of this standard in agency decision-making.
On Jan. 30, 2026, Judge William Young ruled in the U.S. District Court for the District of Massachusetts that Chris Wright, Secretary for the U.S. Department of Energy (DOE), skirted the law in putting together a small group of likeminded scientists to write a report downplaying scientific consensus on the linkages between greenhouse gases and climate change. This was a report later used by the U.S. Environmental Protection Agency (EPA) to propose removing greenhouse gases from vehicle emission standards under the Clean Air Act.
According to Young, the DOE’s Climate Working Group (CWG) and its report, titled, A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate, violated the Federal Advisory Committee Act (FACA). Congress passed FACA in 1972 to set requirements for creating advisory committees to prevent secret or biased outside influence on federal decision-making while providing a transparent way for federal agencies to use outside expertise.
The FACA challenge
In the lawsuit, Environmental Defense Fund, Inc. v. Christopher Wright, plaintiffs claimed that the CWG should be subject to FACA because it was assembled to provide substantive policy advice and recommendations to the DOE.
In the case, the plaintiff, the Environmental Defense Fund, argued that the DOE failed to comply with FACA because the agency assembled and tasked a privately-selected group of individuals with preparing a report that would specifically challenge the consensus view of climate scientists. They also pointed out that CWG meetings were not disclosed or shared with the public and the public did not participate in forming the final report. Further, they argued that the DOE did not disclose the existence of CWG until the day the report was used by the EPA to support a proposed rule, Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards. This rule would then repeal greenhouse gas emissions standards for cars by overturning the 2009 public health endangerment conclusion.
In the final court order, Young agreed with the argument made by Environmental Defense Fund, stating that CWG “violated FACA’s requirements for establishing and utilizing an Advisory Committee, holding open meetings, providing open records, and maintaining fair balance and influence.” As a result, the CWG became an unlawfully-formed committee. While the ruling does not remove the report the CWG created from the public record, it does make it procedurally invalid under law. That means the report may not be used on a technical basis for federal action, thus placing the EPA’s proposed rescission of the 2009 endangerment finding in question.
What does ‘restoring Gold Standards’ mean in practice?
The court’s ruling comes eight months after President Trump’s gold standard science order, which focused on re-establishing public faith in science by ensuring “that federal decisions are informed by the most credible, reliable and impartial scientific evidence available.” To achieve that objective, the order instructs all agencies to update their policies to adhere to new requirements on how science is conducted, used, interpreted and communicated. The order then places sole and exclusive oversight and enforcement authority in the hands of an agency-designated individual appointed by the president.
In many ways, I view the CWG’s report as structured to meet the requirements of the executive order. The report attempts to reorient the discussion around established climate change science by introducing concerns about precautionary assumptions, reproducibility and uncertainty. The report also provides a platform for alternative scientific opinions that support conclusions with a substantial effect on important public policies. These are all factors consistent with Trump’s new “gold standard science.”
The court ruling then acts as a natural foil to such an approach by pointing out that the report was not transparent and lacked balanced perspectives. It was also prepared to support a predetermined outcome and largely ignored the well-established body of peer-reviewed literature on the topic. The result is an administration publicly championing stronger scientific integrity while simultaneously ignoring traditional processes and systems for safeguarding scientific integrity.
Calling something gold doesn’t make it gold
A 2020 paper published in Frontiers in Psychology examined the often-used phrase “gold standard” to describe procedures and methodologies in scientific literature. Unsurprisingly, the authors found that use of the term is misleading, overly simplistic and often inaccurate, failing to capture the nuance, variability and imperfection of scientific constructs. The paper concludes with a challenge: “The task for the critical reader and cautious scientist is to view all such exaggerations with skepticism.”
The same caution applies to the Trump Administration’s “gold standard science.” The question, in my opinion, is not whether the standards can support high-quality science, but rather whether using the same rigid framework to align all federal science is the best way to assess the full spectrum of research methodologies needed to support federal management decisions. There is no singular process for building the knowledge needed to make informed decisions and as the Frontiers paper emphasized, “a one-size-fits-all standard of excellence stymies good research.”
If the ultimate intent of the executive order is to stymie good research or mislead the public through invoking a false sense of validity or superiority for reports such as that generated by CWG, then such an approach directly conflicts with The Wildlife Society’s Standing Position on the Use of Science in Policy and Management Decisions. A multiscale integrated model for ecosystem services designed to capture how ecological, economic and social systems interact, for example, will never achieve the same standards of reproducibility or certainty as a controlled lab experiment. However, it can be just as rigorous and provide unique data-driven insights into how policy choices or environmental changes may impact communities in the real world rather than in a controlled environment. The Wildlife Society advocates for the highest standards, not a singular “gold standard.” We recognize the uncertainty inherent in science and note that such uncertainty is not a reason to ignore or censure scientific findings. If the true intent of the order is to promote public trust in science, then that starts with greater public awareness and understanding of science, not the marketing of standards that deepen misunderstanding.
What happens next?
Following the court ruling, a spokesperson for DOE struck a defiant tone in a statement to reporters: “The activists behind this case have long misrepresented not just the actual state of climate science, but also the so-called scientific consensus. They have likewise sought to silence scientists who have merely pointed out—as the Climate Working Group did in its report—that climate science is far from settled.” The agency also continues to promote the findings of the CWG report on its website. So, at least initially, it appears that DOE will stand by the CWG report despite it being procedurally invalid under law.
Likewise, there is no current indication that the EPA will revisit its plans to rescind the 2009 endangerment finding, which again states that greenhouse gases from motor vehicles endanger public health and allows for the agency to legally restrict their emission from cars. Currently, the EPA has sent the proposed final rule to the president for review. If approved, the EPA will publish the Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards as a final rule in the Federal Register, and the CWG’s report will become a central element of further legal challenges. Under that scenario, and since the CWG report can no longer be used as justification, EPA would need to demonstrate through other legally valid and scientifically credible evidence that the scientific consensus has materially changed and that greenhouse gases no longer pose the risk previously identified as part of the original endangerment finding.
While the peer-reviewed science in TWS journals is unlikely to play a role in this case moving forward, the executive order on gold standard science applies “to all employees involved in the generation, use, interpretation or communication of scientific information, regardless of job classification, and to all agency decision-making.” As a result, cases like this warrant our attention as the outcomes may have lasting effects on how federal agencies conduct, manage and interpret wildlife science and use it in land management decisions. My renewed hope following the CWG court ruling is that such decisions will remain grounded in evidence and process supported by an extensive scientific record and not political disapproval of prior policies.
Article by Cameron J. Kovach
