The link between science and policy has never been clearer. Science continues to help shape the government’s response to COVID-19, its current and future decisions regarding the climate crisis, and standards for education, nutrition, and wages. When the government needs to know how to tackle our toughest challenges, it should reliably look to science. More still, when it comes to the federal rulemaking process used to regulate countless aspects of our society, the perspective of scientists is invaluable! Now, as a science advocate or scientist yourself, you may be wondering how to weigh in on that process.
In 1946, Congress enacted the Administrative Procedures Act, which formalized how the public could provide input on regulations through public comments. But few people are aware of the public comment process. Briefly, when Congress passes a law, individual agencies interpret and carry it out through rulemaking. For example, if Congress wants to regulate pesticide usage near estuaries, the EPA will propose a rule to decide the specifics—which pesticides can be used, who can use them, and the like. Any time a rule is proposed or amended, the public can weigh in: community organizers, students, parents, members of industry, and, yes, scientists.
Remember that the public comment process is an opportunity. It is the public’s chance to provide feedback on our government’s decision, or perhaps state a position that lawmakers may not have considered. This is why we need more scientists involved in the public comment process. An informed, well-written public comment offers more insight and carries more weight than a copy-and-paste public comment campaign. As scientists, our expertise is meaningful to decision-makers, as is any knowledge or data we can share during the rulemaking process. More input from the scientific community is desperately needed to ensure the best available science is used in the decisions that shape—and protect—our society.
I’ve seen firsthand the importance of scientists’ participation in rulemaking. In 2019, I served as president of the Penn State Science Policy Society, a graduate student organization dedicated to bridging the gap between science and public policy. During my tenure, I visited DC and met with other organizations that shared our mission. The purpose of our visit was twofold. First, we wanted to speak with our representatives about our research and explain the need to continue to support scientific funding. Second, we worked with advocacy groups, like UCS and AAAS, to learn how to communicate more effectively with legislative audiences. Through these meetings, I became aware of the public comment process as a tool for science communication. I wanted to share this newfound tool with others at Penn State, so I organized the Public Comment Committee, which is now our organization’s most popular sub-committee for new members. We submitted our first comment within a few months of my return and have submitted several more since on diverse topics, from restoring the American chestnut tree in the U.S. to setting academic science standards in Pennsylvania. I am proud of our organization’s achievements.
There were challenges, however. For example, navigating the government website for submitting public comments online was challenging at first, and researching, writing, and submitting comments can take a lot of time. Nevertheless, through that process, we learned how to best structure a comment and some key things to include:
- Establish your expertise regarding the proposed rule. Do this early, in the first sentence or two, so the agency can take special notice of your comment.
- Be clear about what you support and how you would like to see this rule formulated. Again, do this early on.
- For the main body of the comment, provide the “why”; construct an argument and provide data (your own, whenever possible). It doesn’t have to be long, but it should be backed by sound evidence. It’s also important to explain why this issue matters to you. Does this rule affect your community, your research, your life? How?
- Recommend a solution. Conclude your argument and propose specific actions you would like the agency to take in formulating its rule.
Many of us became scientists so that we could make a difference. At the federal level, that difference is decided on every day. Your voice matters in the decision-making process. Be heard.
For more resources on writing public comments, visit this UCS page.