On February 28th of this year, RAINN released a document that pissed off many feminists and delighted every rape-culture-denying anti-feminist on the internet. Written by Scott Berkowitz, President and Founder of RAINN, and Rebecca O'Connor, RAINN’s Vice President for Public Policy, this document supposedly debunks rape culture—and because RAINN is such a prominent and well-respected source on sexual assault, everything they say is fact. Those of us who do believe in the existence of rape culture have all been schooled.

Anti-fems have been gloating over this for awhile, which isn’t surprising. It is, however, irritating, especially since this gloating is coming from many of the same people who criticize feminists for being part of a hivemind. That said, the gloating is also unwarranted, for a number of reasons:

Feminists who write about and work to dismantle rape culture do not actually need RAINN’s endorsement. RAINN does not explicitly reject the concept of rape culture. Rape culture is not the focus of the document. The focus is rape prevention–and while RAINN’s suggestions for fighting campus sexual assault are generally good, one does not have to agree with their statements on rape culture to support those suggestions. RAINN is wrong.

I’ll start by going through the parts of the document dealing with rape culture, then move to an analysis of the full text. This will be excruciatingly long (about 3,000 words), so it’s going under a read more.

The document starts well enough, with a summary of RAINN’s various services and accomplishments, but then we are treated to this:

In the last few years, there has been an unfortunate trend towards blaming ‘rape culture’ for the extensive problem of sexual violence on campuses. While it is helpful to point out the systemic barriers to addressing the problem, it is important to not lose sight of a simple fact: Rape is caused not by cultural factors but by the conscious decisions, of a small percentage of the community, to commit a violent crime.

First, it’s worth noting that Berkowitz and O'Connor don’t actually deny that rape culture exists; rather, they criticize how the growing awareness of rape culture has influenced rape prevention measures on college campuses. Yes, the quotation marks around the phrase “rape culture” are a red flag, but the authors also put scare quotes around “masculinity” in the next paragraph, and I doubt they’d outright deny the existence of that. It seems more likely that they object to how rape culture is (allegedly) discussed in the context of campus sexual assault.

That said, this paragraph is vague as hell. “The systemic barriers to addressing the problem”? What barriers? What problem? And while rape is obviously caused by rapists, rape culture contributes to the exoneration of rapists, both in judicial courts and the court of public opinion; prevents victims from coming forward; and places the responsibility for rape prevention on pretty much everyone except rapists. So you’d think that discussions about rape culture would be relevant here, especially if Berkowitz and O'Connor want us to lay the blame for rape on rapists themselves…but nope.

While this first paragraph is the one that’s received the most attention from anti-fems, it’s the following paragraph that really bothers me:

While that may seem an obvious point, it has tended to get lost in recent debates. This has led to an inclination to focus on particular segments of the student population (e.g., athletes), particular aspects of campus culture (e.g., the Greek system), or traits that are common in many millions of law-abiding Americans (e.g., “masculinity”), rather than on the subpopulation at fault: those who choose to commit rape. This trend has the paradoxical effect of making it harder to stop sexual violence, since it removes the focus from the individual at fault, and seemingly mitigates personal responsibility for his or her own actions.

But this is a misrepresentation of both rape culture and the conversations taking place. The idea is not that rape culture makes rapists rape, but that it condones their actions and treats rape as an inevitability. Rape culture misallocates blame. It silences victims and forces potential victims to be constantly on their guard. Rape culture says that rapists can’t change their behavior, because men are sharks and women are food, so women and girls who want to avoid rape should make themselves less appetizing. It lets rapists get away with their crimes, then turns around and blames victims—for the violence itself, for their response to trauma, for not reporting or fighting the rapist off, for whatever behavior supposedly “made” the rapist rape. Rape culture also ignores or outright denies that certain people can be raped—men, “promiscuous” women, sex workers, the elderly, people with disabilities.

So when Berkowitz and O'Connor write that this emphasis on rape culture “removes the focus from the individual at fault, and seemingly mitigates personal responsibility for his or her own actions,” they have it backwards. It’s rape culture that does this, not discussions about rape culture. And the fight against rape culture is a fight against rape, not a distraction from it.

Then we have this gem:

By the time they reach college, most students have been exposed to 18 years of prevention messages, in one form or another. Thanks to repeated messages from parents, religious leaders, teachers, coaches, the media and, yes, the culture at large, the overwhelming majority of these young adults have learned right from wrong, and enter college knowing that rape falls squarely in the latter category.

Sure, if by “prevention messages” they mean “avoidance tips that usually don’t work anyway,” and if by “rape” they mean “something that happens exclusively in a dark alley with a masked stranger and a weapon.” Of course, this paragraph, like much of the section, is almost too vague to refute—“18 years of prevention messages, in some form or another”? What form? Because that matters.

The implication here is that continuing to spread these “prevention messages” is unnecessary—but if that’s the case, why is there so much hostility to anti-rape campaigns? Why does the “Don’t Be That Girl” counter-campaign exist? How did Steubenville or Cleveland, TX even happen? It’s not like there’s a shortage of studies which suggest that many people who would likely never commit rape themselves condone certain types of rape and engage in victim-blaming, so while we may not have much hard data on the success of these campaigns (there’s this, but as far as I’m concerned there’s no proof of a causal relationship between the campaign and the reduction in assaults), Berkowitz and O'Connor haven’t provided any compelling arguments against them.

Well, maybe they have. After all, they do bring in Dr. David Lisak, a clinical psychologist who studies the psychology of rapists:

Research supports the view that to focus solely on certain social groups or “types” of students in the effort to end campus sexual violence is a mistake. Dr. David Lisak estimates that three percent of college men are responsible for more than 90% of rapes. Other studies suggest that between 3-7% of college men have committed an act of sexual violence or would consider doing so. It is this relatively small percentage of the population, which has proven itself immune to years of prevention messages, that we must address in other ways. (Unfortunately, we are not aware of reliable research on female college perpetrators.) Consider, as well, the findings of another study by Dr. Lisak and colleagues, which surveyed 1,882 male college students and determined that 120 of them were rapists. Of those determined to be rapists, the majority —63%—were repeat offenders who admitted to committing multiple sexual assaults. Overall, they found that each offender committed an average of 5.8 sexual assaults. Again, this research supports the fact that more than 90% of college-age males do not, and are unlikely to ever,rape. In fact, we have found that they’re ready and eager to be engaged on these issues. It’s the other guys (and, sometimes, women) who are the problem.

This isn’t a misrepresentation of Lisak’s work, but it is a bit selective. Yes, Lisak did find that most college men do not rape, and that most rapists are serial offenders. This finding is a compelling explanation for the discrepancy between women who report being assaulted by men and the number of men who admit to assaulting women. However, it doesn’t necessarily follow that all prevention campaigns are futile. Lisak identifies “hyper-masculinity” as one trait common to rapists (page 8, paragraph 2), so while we probably can’t do much to challenge anti-social personality traits, we could, say, fight the idea that masculinity and strength necessarily = dominance. Would it work? Maybe not, but I see no reason not to try.

Oh, and remember that second paragraph I looked at, where Berkowitz and O'Connor dismissed the idea that “traits that are common in many millions of law-abiding Americans (e.g., 'masculinity’)” might affect the high rates of rape? Well, that’s an interesting claim, given how well-acquainted they supposedly are with Lisak’s work.

That said, much of what Lisak writes does seem to support their overarching point. In Understanding the Nature of Predatory Violence, Lisak writes:

Prevention efforts geared toward persuading men not to rape are very unlikely to be effective. […] Rather than focusing prevention efforts on the rapists, it would seem far more effective to focus those efforts on the far more numerous bystanders—men and women who are part of the social and cultural milieu in which those rapes are spawned and who can be mobilized to identify perpetrators and intervene in high-risk situations (Lisak 8-9).

The thing is, these efforts already exist. (Maybe not in 2002, when Lisak published this paper, but certainly now.) Missoula’s “Make Your Move” campaign, for example, includes posters showing individuals pictured next to stories about how they intervened in dangerous situations.The UK-based campaign “This is not an invitation to rape me” could be addressing potential rapists, but is more likely targeting anyone who engages in victim-blaming. And while “My strength is not for hurting" did target potential rapists, it challenged the idea that male strength is synonymous with dominance and violence—in other words, the “hypermasculinity” Lisak identifies as a characteristic of many rapists. The effectiveness of the campaign is up for debate, but it did try to attack one cause of rape, rather than the rapists themselves. (The campaign ended over two years ago, but the images are still passed around.)

I would also argue that, while most of these campaigns do not target rapists directly, they send rapists an important message: That we recognize their crimes for what they are. That their actions have consequences. That they cannot dismiss accusations by saying their victim was “asking for it.” And I think these are important messages to send. We may not be able to “fix” rapists’ pathology, at least not with posters, but that doesn’t mean we can’t discourage some of them from raping. Furthermore, if this message encourages victims to report their assaults, and if those reports are taken seriously, the number of overall assaults will likely decrease (especially since, as Lisak observes, most rapists are repeat offenders).

Ultimately, I reject the assumption that the fight against rape culture is unproductive or overly-focused on rapists themselves. I think that even suggesting this is a misrepresentation of anti-rape campaigns. And as an aside, I find it interesting that Berkowitz and O'Connor are so dismissive of rape culture while Lisak acknowledges “the social and cultural miliu in which those rapes are spawned.”

It gets worse, though. While most of Berkowitz and O'Connor’s advice focuses on systemic changes within universities, they also suggest “Risk Reduction” measures:

As anyone who has worked on rape prevention knows, risk-reduction messaging is a sensitive topic. Even the most well-intentioned risk-reduction message can be misunderstood to suggest that, by not following the tips, a victim is somehow to blame for his or her own attack. Recent survivors of sexual violence are particularly sensitive to these messages, and we owe it to them to use them cautiously. Still, they are an important part of a rape prevention program. To be very clear, RAINN in no way condones or advocates victim blaming. Sexual assault is a violent crime and those who commit these crimes are solely responsible for their actions. That said, we believe that it is important to educate members of a campus community on actions they can take to increase their personal safety. In fact, we believe it’s irresponsible not to do so.

Remember when Berkowitz and O'Connor argued that overemphasis on rape culture as a cause of rape “seemingly mitigates responsibility for [the rapist’s] actions”? I do. And yet now they’re issuing statements that veer so close to victim-blaming, they actually have to make a disclaimer.

Anyway, I don’t think that giving people the tools and knowledge to protect themselves is wrong—if I did I’d be a pretty absurd person—but I do wonder whether these measures are necessary. Earlier the writers claim that “By the time they reach college, most students have been exposed to 18 years of prevention messages, in one form or another,” suggesting that similar campaigns and messages for college students are overkill. But students are inundated with risk-reduction messages, not prevention messages. This is, of course, a component of rape culture: It puts the responsibility for rape “prevention” on potential victims instead of the rapists themselves.

The authors continue:

Over decades, it has been shown that risk-reduction messaging is an important component of crime prevention overall. This approach has significantly contributed to reducing the number of violent and property crimes. It has a similar value in sexual violence prevention.

I suppose it depends on what you mean by “risk reduction,” doesn’t it? After all, part of the problem with so-called rape prevention tips is that they rarely account for the majority of rapes. Self-defense training, pepper spray, gouging eyes with strategically-held keys—these strategies may be helpful in dark alley stranger rapes, or in certain acquaintance rapes, but they don’t protect against all forms of sexual assault.

The other problem, of course, is that most of the advice is blindingly obvious–and that it could just as easily be applied to other types of crime. Whatever we’d like to believe, sexual assault is treated differently, and that’s important to consider when advocating and developing risk prevention measures. Most girls are warned about protecting themselves early on, yet rape happens anyway–and there are people who blame victims for failing to stop it.

Like many of Berkowitz and O'Connor’s claims, this one is almost too vague to refute, but I remain suspicious. Arming people with the tools and skills to protect themselves is great, but it’s important that these measures are 1) effective, and 2) not used to justify victim-blaming.

I’d love some data on the success of these tactics as well. It’s not a new strategy, so there must be something…right?

Berkowitz and O’Connor continue:

Many institutions incorporate risk-reduction tips into their awareness messaging and we encourage the federal government to support this type of messaging. Many respondents —survivors, faculty, and others —to our survey on the issue of campus sexual assault (see Appendix) endorsed this view as well.

Odd, then, that the Appendix does not include any of these endorsements. In fact, all the responses included in the Appendix advocate changes in how sexual assault accusations are handled by universities, an increase in victim support services, and more severe punishments for convicted rapists.

And finally:

This recommendation is intended to impart tools of empowerment, not victim blaming.

Which is great, but I’d like hard some evidence showing that these measures are 1) necessary and 2) useful. And again, I’d like to know what the tips actually are. “Don’t leave your drink unattended”? “Drink in moderation or not at all”? “Hold your keys between your fingers and aim for the eyes”?

Of course, this is all kind of irrelevant, isn’t it? Most of the document is dedicated to policy suggestions: get rid of internal judicial boards, treat rape as a felony, involve local law enforcement, increase services for victims. It’s all good advice, but you don’t have to downplay the effects of rape culture to stress the importance of policy change. If, as I suspect, Berkowitz and O'Connor were trying to shift the focus from cultural factors to institutional ones, they could have done so without throwing anti-rape culture activists under the bus. It would be so easy to rewrite that first paragraph—here, I’ll do it now:

Original: “In the last few years, there has been an unfortunate trend towards blaming “rape culture” for the extensive problem of sexual violence on campuses. While it is helpful to point out the systemic barriers to addressing the problem, it is important to not lose sight of a simple fact: Rape is caused not by cultural factors but by the conscious decisions, of a small percentage of the community, to commit a violent crime.”

Revised: “In the last few years, many attempts to address the extensive problem of sexual violence on campuses have focused on rape culture, victim-blaming, and the nature of consent. While these campaigns and discussions are helpful in aiding victim recovery, encouraging bystander intervention, and reducing incidents of victim-blaming, it is important to not lose sight of a simple goal: Apprehending rapists and encouraging victims to report their assaults.”

Boom, easy.

This may seem like an unnecessary revision—after all, the document is addressed to the White House Task Force to Protect Students from Sexual Assault, so as long as the recommendations are solid who cares? But this document is posted on RAINN’s site, and is therefore targeted not only at the Task Force, but at anyone who cares about the issues. It’s a clear attempt to change the discourse on campus sexual assault, and the question is why.

Regardless of their intent, what Berkowitz and O'Connor are doing here is both unnecessary and dangerous. They’ve effectively armed anti-feminists and rape-culture-deniers with (poorly-reasoned) ammunition, downplayed the effects of rape culture, and misrepresented much of the challenges to rape culture and victim-blaming. I can think of plenty of reasons for their actions—say, making concessions to the opposition in an attempt to win more allies—but ultimately, there is no benefit that outweighs the danger of their statements.

But disappointing as those statements are, they don’t have to matter. RAINN is an organization with many useful services for victims and information about sexual assault, not the final word on rape culture. Still, if you would like to contact RAINN about their irresponsible and inaccurate statements on rape culture, you can always write them at info@rainn.org.