July 16, 2009

National Science and Technology Council
Joint Subcommittee on Ocean Science and Technology
Via e-mail: public-comment@jsost.org
RE: Request for comments on updating "Charting the Course" (74 Federal Register 29524)
Thank you for the opportunity to provide comments on the Subcommittee's planned update to the January 2007 report, "Charting the Course for Ocean Science in the United States for the Next Decade: An Ocean Research Priorities Plan and Implementation Strategy."  The American Institute of Biological Sciences (AIBS) is a nonprofit scientific association dedicated to advancing biological research and education for the welfare of society.  AIBS counts among its members roughly 5,000 biologists and 200 professional societies and scientific organizations; the combined individual membership of the latter exceeds 250,000.
The 2007 ocean research priorities plan focuses needed attention on a number of important research topics.  A concerted national research effort addressing the stewardship of our natural and cultural ocean resources, better mitigating ecosystem recovery from natural and manmade events, improving ecosystem health, and understanding the linkage between ocean health and global climate change are all timely research issues that warrant a robust and sustained federal investment.  However, a number of other important ocean research issues also deserve inclusion in the plan.  Thus, these comments suggest issues for further consideration by the Joint Subcommittee on Ocean Science and Technology (JSOST).

Research Funding

The draft report fails to clearly articulate how funding will be sought to achieve the proposed goals.  A number of the research activities proposed are already initiatives at various federal agencies, yet progress has been slow due to what some consider inadequate and unpredictable funding.  A written commitment to a minimum yearly budget, which should increase sustainably towards a set goal, should be a necessary component of a revised plan.  Such a request and multi- year commitment to research program managers is a necessary element for the ultimate success of the JSOST research plan.
Fundamental Research

Another concern with the current plan is the relatively little emphasis placed on fundamental scientific research.  Several of the Research Priorities outlined in the plan call for a greater understanding of ocean processes, largely to be acquired through monitoring, modeling, and analysis. These research approaches are undoubtedly critical to a comprehensive ocean research plan, and we applaud the emphasis placed on them in the report.  Our nation's environmental satellites are long overdue for replacement, and monitoring activities have been suffering for years as a result of budget cuts.  Proper monitoring, modeling, and analysis are critical for providing us with a global understanding of intricate ocean processes.   
However, it is also important to recognize that basic science underpins all forecasting and modeling done by scientists.  Moreover, research that informs ocean processes does not exclusively come from ocean-based research.  For example, the fundamental understanding of the processes of evolution and ecological succession that comes out of any research arena, be it terrestrial or aquatic, can help us predict the ocean's response to environmental change.  The basic biological sciences are inherently cross cutting, and it is therefore important to not only support basic research in the marine and aquatic sciences, but also to ensure that mechanisms are in place that aid in data sharing between ocean scientists and scientists in other fields.  Such collaboration will not only benefit the oceans, but will have broad positive impacts across all fields of science.
Natural Science Collections

In looking at the future of ocean research, a revised Charting the Course report should reflect the importance of a sustained investment in our established research infrastructure, such as natural science collections.  Natural science collections and the institutions that house them serve national education needs as well as underpin scientific research in many fields, from aquatic biology to zoology.  Scientific collections hold important genetic, organismal, and environmental samples.  With such samples, researchers are able to answer questions about the impacts of climate change, the spread of invasive species and disease, and the loss of biological diversity. JSOST should work to ensure that the revised ocean research plan includes appropriate policies and funding for natural science collections involved with the collection and curation of ocean, coastal, and Great Lakes specimens and data.  Additionally, natural collections should be identified as a "necessary tool" for implementing theme 1, "Stewardship of Natural and Cultural Ocean Resources," and theme 5, "Improving Ecosystem Health," of Charting the Course.

Climate Impacts on Marine Life

Significantly, the 2007 report prioritized research to understand the ocean's role in climate.  Research Priority 12, "[u]nderstand the impact of climate variability and change on the biogeochemistry of the ocean and implications for its ecosystems", outlines observations,research, and modeling that will help us to understand how the oceans are changing.  However, this research priority does not directly call for science that will study or predict how marine living systems will be impacted by climate change.  The revised report should elevate the need to study climate impacts on marine species, food webs, and ecosystems.  Language should be added to themes 1 (natural resources) and 5 (ecosystems) that calls for the study of the effects of climate change on marine life.  Research on interactions between climate changes and other environmental stressors, such as habitat loss, eutrophication, and invasive species, should also be addressed.

Timeline for Implementation

Finally, the impact of Charting the Course would increased if it laid out a timeline for the implementation of each theme.  While the identification of four near-term priorities is useful in focusing research efforts, a more concrete course of action and set of goals will help ensure that the plan achieves its proposed results.   We recommend setting a timeline for implementation of each theme, as well as setting dates for regular updates of the Plan.  Setting a long term timeline for the remaining 20 research priorities would also enable their successful implementation.
Once again, thank you for the opportunity to comment on the Plan and for your continuing efforts to ensure a robust ocean, Great Lakes, and coastal research action plan.  If AIBS may provide further assistance to you on this or other matters, please do not hesitate to contact AIBS Director of Public Policy Dr. Robert Gropp at 202-628-1500.
Richard T. O'Grady, Ph.D.
Executive Director 

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