August 2, 2010

National Oceanic and Atmospheric Administration
Office of Program Planning and Integration
1315 East West Highway, Room 15749
Silver Spring, MD 20910

Re: NOAA's Next Generation Strategic Plan

Thank you for the opportunity to comment on NOAA's Next Generation Strategic Plan.

The American Institute of Biological Sciences (AIBS) is a nonprofit scientific association dedicated to advancing biological research and education for the welfare of society. Founded in 1947 as a part of the National Academy of Sciences, AIBS became an independent, member-governed organization in the 1950s. AIBS is sustained by a robust membership of individual biologists and nearly 200 professional societies and scientific organizations with a combined individual membership exceeding 250,000.

The draft strategic plan addresses many important issues facing the nation: addressing climate change, conserving biological diversity, and improving the health and resiliency of coastal and marine ecosystems. Meeting these challenges requires science. Although the strategic plan is infused with science, the plan's long-term goals fail to reflect the proposed mission statement, of which "science" is the first word. Instead, science is relegated to second tier "enterprise." Although science is essential for achieving each of the four goals outlined in the plan, the need for science within NOAA goes beyond these areas. In the final strategic plan, science should be a top tier, NOAA-wide strategic goal.

Within the new long-term goal for science, the existing objectives for science and technology should be supplemented to adequately represent the breadth of NOAA's scientific work. First, the objective to achieve "a holistic understanding of the Earth system through research" should include the important work of external partners in academia, government, nonprofits, and private industry. Limited resources in recent years have restricted NOAA's ability to partner with non-agency scientists and to fund extramural grants to conduct research. The revised plan should acknowledge this deficiency and set goals for remedying it.

The second scientific objective, "accurate and reliable data from sustained and integrated Earth observing systems" should be broadened to include the important contributions of environmental monitoring conducted by researchers. Although technology is becoming increasingly important in observing and monitoring Earth systems, personnel are vital for monitoring efforts, such as biological observations. The plan should reflect the fact that staff, in conjunction with observing systems, are needed to fully achieve all of NOAA's scientific goals.

In addition, scientific collections are an important part of NOAA's records of environmental information. The strategic plan should address the curation of, and access to, the 40 scientific collections held by the agency. The directors of the Office of Management and Budget and the Office of Science and Technology Policy instructed agencies to do so in the annual Memorandum for the Heads of Executive Departments and Agencies (M-10-30) released on July 21, 2010: "Agencies should implement strategies for increasing the benefits for science and society derived from scientific collections by following the recommendations in the report by the Interagency Working Group on Scientific Collections and efforts outlined in the National R&D Strategy for Microbial Forensics."

Scientific collections, including biological specimens, tissue and cell cultures, and soil and water samples, offer a treasure trove of information about Earth systems and aid in regulation and management of the nation's natural resources. These collections, which are irreplaceable data, contribute to cutting edge research on environmental contamination, biodiversity, and climate change. For instance, specimens collected from the outer continental shelf during past decades serve as baselines of the biological, sedimentary, physio-chemical, and oceanographic conditions of U.S. waters. In the Gulf of Mexico, this information will be vital in responding to the BP oil spill.

Thank you for your thoughtful consideration of these comments. If we may be of further assistance on this or any other matter, please contact Dr. Robert Gropp, AIBS Director of Public Policy at 202-628-1500.

Sincerely, Richard T. O'Grady, Ph.D. Executive Director

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