The U.S. Congress attached strings to its annual appropriation to the Environmental Protection Agency (EPA). Namely, the agency was prohibited from engaging in "propaganda" and "grassroots lobbying in support or opposition to proposed legislation."
Suspecting the EPA violated that rule, the Republican chair of the Senate Committee on Environmental and Public Works asked the Government Accountability Office (GAO) to investigate.
The GAO report, issued on December 14, declared the EPA had violated both rules. Make of that what you will. What we find interesting is the logic the agency used in reaching that conclusion.
First, the GAO defines propaganda as disguising the source of communication either by omission or mis-direction. So far, so good.
The EPA allegedly engaged in propagandizing when it used a crowd-sourcing web site, Thunderclap, to post a message on the social media "pages" or "timelines" of self-selected supporters who have an estimated 1.8 million followers.
The message -- "Clean water is important to me. I support EPA's efforts to protect it for my health, my family, and my community." -- included a hyperlink to the EPA web site. But the GAO declared the message "covert propaganda" because the EPA's role in originating the message was not made clearer to the ultimate recipients.
In addition, the GAO found that hyperlinks within other EPA social media campaigns constituted "lobbying" because they led to third-party sites such as the Natural Resources Defense Council and the Surfrider Foundation which, in turn, included hyperlinks to contact members of Congress in opposition to pending legislation that would overturn the EPA's rules on clean water.
The GAO found that by including those external links on its own web pages, the EPA was "clearly associating itself" with efforts to lobby Congress in violation of the law.
Hiding the source of information is clearly unethical. And while we don't believe it's unethical to encourage the public to call on legislators to vote one way or another, it's clearly a violation of the law, which in itself is wrong.
The real question is whether the EPA's use of social media was a cynical attempt to circumvent the law and hide behind intermediaries. In my opinion, that's a stretch. And I see no concrete evidence to support that position in the GAO's report.
Social media, by its very nature, harnesses the power of networks and is ever-changing. If an agency were held responsible for the incidental content of web sites it links to, much less second and third-hand Facebook or Twitter postings over which it has no control, it would have to avoid social media altogether.
What does seem unethical is to limit any agency's ability to communicate with the public within its areas of competency and authority. By the same logic, members of Congress shouldn't be allowed to use public funds to explain their positions on legislative matters through social media.
As a matter of ethics and law, the government's bias should be towards full and open communications through all available media.