Terry Gerton Stand Up for Science is doing something really interesting. You are convening two rapid response workshops to help individuals and organizations draft comments in response to a National Science Foundation proposal to update proposal and award policies and procedures guide. You wouldn’t be doing that, it seems to me, if people already knew how to do this. So, what are the biggest gaps that you’re trying to fill through these workshops?

Colette Delawalla Yeah, I think the first thing is just that people need awareness that this is a part of the American democratic process, that this our government asking for feedback, they’re asking for information and in this way, you know, yes, the lowest rung on the bar is to vote. But this is sort of the next step up, right? It allows people, it gives people the opportunity to share their expertise in areas that they have a lot of expertise in, in a way that can make an impact in how the government works and particularly how the government works sort of in their sphere or in an area that impacts them. So first thing is driving awareness. The second thing is making sure that people are armed with the know-how for how to write a comment that does affect change. And of course, there’s sort of two ways to go about it, right? The first thing, is just writing a comment, even if the comment is a couple sentences long that says, I don’t think this is American, or I don’t like this and here’s the reason why. You know, that is really important because it, in and of itself, draws attention to the matter, which we’ve seen with the OMB, you know, uniform guidance rule that actually that attention really does matter if it’s happening substantially. But the other thing is that there are some really specific, frankly, easy things that you can do to add some power and some punch to your public comments. And we want to make sure that people have the tool kit to do that, not just for this public comment, but for any that come down the line and they realize, oh, I’m the person that could answer this call for commentary.

Terry Gerton I’m wondering what you find as you talk to folks here, because I suspect that the average American, one, probably doesn’t know that they have this opportunity, but two, if they do know about it, might think that it’s either irrelevant because no one pays attention anyway, or two, that it is something best left to the professionals. What kind of are the biggest misconceptions here?

Colette Delawalla I think it’s exactly those two things, right, especially the best left to the professionals. And I think that people often discredit their own expertise and their own experiences as being unimportant. Like, we think that, oh, well I’ve only received a grant from the NSF. I’m not an expert on grant funding. Well, if you’ve received a grand from the NSF, you’re a participant and you have something to say about what is in this new, you know, this proposal, this proposed rule. It will impact you and so you should talk about how it would impact you if XYZ things were passed through. So, I think that there is just this tendency for people, I think especially scientists, to really discount themselves and to say, well, I’m not really an expert in this area. It’s like, no, no, you’ve received several grants from this agency. You actually know way more about it than the average person does.

Terry Gerton What happens when an agency gets these comments? How do they separate ones that are genuinely influential from ones that they go, oh, yep, and they put it in a pile.

Colette Delawalla Well, so the first thing is to note the usual way of doing things versus how this administration is doing things. So I do wanna make that distinction. In times past, what would happen is you’d have a team of one or two, you know, folks at that agency who would read — like a person, a human being — would read all of the comments and would separate out the ones that maybe, it’s just a, hey, this is un-American, I don’t like it, or, you know, protect the Keystone Pipeline, like that was a big one that had a large response. And then there are ones that cite specific parts of the proposal that say, that use this very special word, it is ‘reliant.’ So are you reliant? Is your lab, are you in your career reliant? Are your students reliant? Do you have employees who are reliant on funding or structures or something about what is being changed in this rule or proposed to be changed in the rule and being able to really directly tie in if the government does this, this is how it will impact me and my situation. And being able to tie that directly to provisions that are outlined in these documents are sort of what separates a good or impactful comment from one that is less impactful. Also organizations have sort of a higher rank standing than individuals. So for example, Federal News Network could do some public comments, those would be higher ranked or sort of land in a different place in the ranking compared to just an individual.

Terry Gerton Collette Delawalla is the founder and CEO of the Stand Up for Science Foundation. Collette, let’s follow that a little farther. You talked earlier about scientists really not thinking that they had standing or value in submitting these. If they don’t, if citizens in subject matters don’t submit their comments on rules like you’re engaged in right now, who winds up having the most influence over the rules agencies write?

Colette Delawalla The people who are in power, the people who are overseeing those agencies, you know, it ends up sort of falling by default to the leadership of the agency. You know, they have the ultimate say so in this, but there has in the past been a much greater respect for the expertise that the public brings in these public comment openings. It’s the reason why they do it, because they want to hear what the public has to say, they want to hear how, it’s sort of like finding blind spots. That’s how I think about this is it’s like, okay, the government has thought out a rule that they think is gonna work, but they’re not in the lab. They’re not the building. They’re not in your email inbox, having to deal with a fallout of the changes that would result from this rule. And so it’s sort of the government asking, all right, what blind spots, what plot holes do you see with what we’re recommending? If you don’t give the plot holes to the government, they cannot account for those plot holes. And then when you’re mad that there are plot holes, you know, you can’t really, like you had an opportunity to call it out before it came into contact. So I say that to make the point that yes, it is going to be the leadership of the agency that ultimately make decisions. And traditionally, we have seen that they have considered, and there’s legally required to consider these public comments. Now, I will say, in a time when were less maybe trusting of the leadership of these agencies and whether they’re operating in goodwill, these public comments set up grounds for future litigation to stop anything in the rule that may be causing harm to various people or institutions.

Terry Gerton You held your first one of these rapid response workshops on July 31st. What did you hear there? Anything surprising from the participants?

Colette Delawalla I don’t think it’s anything, we didn’t hear anything surprising in that one. I think that because we heard a lot of surprising things in our OMB rule rapid hours that we did through the month of June, and first part of July. And really, to me, the most surprising thing is people just like not thinking that they’re experts or thinking that they have nothing to add to this conversation. And anytime, you know folks who have experience with these agencies. Think to themselves or say out loud, oh, I don’t have anything to add to this. Yes, you do. You absolutely do. And that is, if there’s one take home message that I could send everybody off with, it is that if you have ever engaged with any of these agencies, you have something to add to the conversation.

Terry Gerton And you’ve got one more workshop coming up on this coming Friday, August 14th, specifically related to the NSF rule and the comment period there runs through August 24th. So you just mentioned your key takeaway to remember that you have something to add to the conversation. But with regard to this specific rule, are you looking for any specific or technical feedback?

Colette Delawalla Yeah, I do think that there are certainly some specific points. So I would encourage folks to highlight that enacting this rule as it is written, ahead of the OMB rule being enacted, which has been paused until December, would violate the procedures that typically go along with this, right? So any sort of complying in advance, we might say, or obeying in advance in this particular instance is illegal. And so I would encourage people to make that point. And they can make that points by calling out the very specific, there are specific lines in, or like sections in this, and we’ll go over which sections they are, in the NSF proposed rule that harken to the OMB proposed rule. And sort of preemptively  implement these changes at the NSF. And that cannot stand, that absolutely cannot stand. And so the more pushback that we have on that particular point, I think the better.