October 22, 2019

Office of Science and Technology Policy
The White House
Washington, DC 20500

RE: RFI Response: Bioeconomy

Thank you for the opportunity to provide comments on the bioeconomy. The American Institute of Biological Sciences (AIBS) is a non-profit scientific organization that works to increase the understanding of all life. To do this, we promote informed decision-making that advances biology for the benefit of science and society.

Enhancing the bioeconomy requires that federal agencies use the best available scientific information to guide policy decisions and inform scientific research and education priorities. Science advisory boards and committees are one important way for federal decision-makers to access current and accurate scientific information and expertise. There is serious concern within many segments of the biological sciences community about the politicization of these panels. It is important that federal advisory bodies be chartered and allowed to openly advise federal programs without fear of political interference.

The breakdown of the appropriations process has become a chronic frustration to the scientific community and has certainly impeded the bioeconomy. The needless chaos created from the failure of the Congress and President to make timely appropriations limits the ability of federal funding agencies to initiate new funding programs, delays funding for researchers, and creates additional workload for federal research program managers. There is an immediate need for the federal government to prioritize making annual appropriations for scientific research. We must fix what is now a broken process if we are to support and stimulate the bioeconomy.

We commend the Office of Science and Technology Policy (OSTP) and the Office of Management and Budget for recognizing the importance of scientific collections in this year's S&T funding priorities memorandum to federal agencies. Indeed, biodiversity collections represented by free-standing natural history museums and botanic gardens, living and stock collections, university-based natural science collections and museums, and government collections held by various federal agencies are centrally important to advancing new research frontiers. Earlier this year, the Biodiversity Collections Network issued a community informed call for the development of an Extended Specimen Network, or ESN.

As outlined in this call to action (https://www.aibs.org/home/assets/BCoN_March2019_FINAL.pdf): "Science and industry rely on physical specimens housed in U.S. biodiversity collections. Rapid advances in data generation and analysis have transformed understanding of biodiversity collections from singular physical specimens, to dynamic suites of interconnected resources enriched through study over time. The concept of the 'extended specimen' conveys the current perspective of the biodiversity specimen as extending beyond the singular physical object, to potentially limitless additional physical preparations and digital resources."

The report offers a vision that builds on the accomplishments of the past decade. Existing specimens are extended through digitization and linkages with associated data, including genetic, phenotypic, behavioral, and environmental. New specimens will be collected with these extended attributes in mind. Combined with and even driving data integration technologies and relevant data layers, extended specimens will form the core of a powerful new research and education network. When fully realized, the Extended Specimen Network will support innovative new research in such areas as bioprospecting for natural products and pharmaceuticals, synthetic biology, bioengineering, biotechnology, agriculture, natural resource stewardship, and biodiversity conservation.

The concept of the Extended Specimen Network aligns well with various federal initiatives, including many of the National Science Foundation's 10 Big Ideas. It also reflects emerging discussions about the need to reintegrate the biological sciences - to breakdown silos and to increase collaboration with other disciplines. The outcomes of the ESN would also advance the scientific interests of the National Institutes of Health and the Departments of Agriculture, Commerce, Defense, and Interior.

We encourage OSTP to coordinate a government-wide initiative to build the Extended Specimen Network.

Additionally, the biological sciences and the bioeconomy will not advance without international collaboration. The United States must actively and constructively engage in international discussions related to biodiversity and sustainability treaties. Unintended consequences of the Convention on Biological Diversity's Nagoya Protocol, for example, can have chilling effects on biological research. International agreements will also increasingly be needed to realize the potential of new tools and technologies. Without such agreements, the markets for new products arising from the use of some new tools and techniques will be needlessly limited.

Thank you for your thoughtful consideration of these comments. Please do not hesitate to contact me at rgropp@aibs.org if you have any questions or require additional information.

Sincerely,

Robert Gropp, Ph.D.
Executive Director

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