February 2010

Rules and Views

Scientists also can share their expertise to provide agencies with information that will inform the drafting of proposed rules. While not necessarily required by law, agencies often issue notices of proposed rule-making, allowing the public to submit comments and information that will aid in the formulation of a proposed rule. By submitting information directly to agencies, scientists can help ensure that policymakers have the best information available when drafting new rules.

Comments Matter

Many scientists may worry about the time commitment involved in responding an agency’s comment request and whether that comment is likely to have an impact. While practices vary from agency to agency, comments are read and often get public responses. For example, the EPA recently published 11 volumes containing more than 500 pages of responses to the more than 1,000 comments it received on regulating greenhouse gas emissions under the Clean Air Act (2). If they do not appropriately consider and respond to the comments they receive, federal agencies make themselves vulnerable to lawsuits.

A Seat at the Table

President Obama has brought science and scientists back into the policymaking fold. Steven Chu’s appointment as U.S. secretary of energy and the new importance of the President’s Council of Advisors on Science and Technology are just two prominent examples. But effective, thoughtful science policy will be created with the advice of the entire scientific community, one public comment at a time.

Footnotes

1. Rulemaking provisions of Administrative Procedures Act: http://www.archives.gov/federal-register/laws/administrative-procedure/553.html
2. http://www.epa.gov/climatechange/endangerment.html

Kyle M. Brown (kmbrown@asbmb.org) is an ASBMB science policy fellow.

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