Our Scientific Integrity Comment to the White House Office of Science and Technology Policy

We thank you for the opportunity to comment on the Administration’s vital effort to elevate scientific integrity.  Trusted Future is a new organization dedicated to the belief that we need smarter, better-informed efforts to enhance trust in today’s digital ecosystem in order to expand opportunities for tomorrow. 

We support this Administration’s important effort to elevate scientific integrity, which we agree is essential to sound evidence-based policymaking.  As science and new technologies become increasingly intertwined, more technical, and more essential to a well-informed policy process, it is also inherent on policymakers to elevate technical integrity along with scientific integrity. 

Technical integrity – and the ability to ensure that policies involving technologies are informed by the best available facts, data evidence, technologists and engineers – is as critical to good policies that involve technology as it is to scientific integrity. OSTP leaders from the Obama White House have previously referred to the need to elevate TechIQ or TQ in this very way. 

As science and technology become more intertwined, it is increasingly essential that technical integrity principles be elevated alongside scientific integrity principles. This will ensure that policy decisions are made on the basis of the best available engineering and technical expertise, data, and evidence.   

Whether its policies that deal with technology itself, or efforts to drive healthcare innovation, improve education, elevate competition, or improve the environment, today, all these subject areas have technical (software, hardware, networking, data, security, privacy) underpinnings where technical understanding and integrity is vital for driving effective and technologically sound outcomes.  In each case, just as science must be at the table for issues involving science, well informed policy demands that technologists also be at the table to better inform decision that touch on technology in order to achieve the most effective and informed decisions.  And as the administration is successful in elevating its focus on cybersecurity, in advancing comprehensive privacy protections, and in passing the Bipartisan Innovation Bill to further crank up our innovation engine and elevate a new technology directorate at the National Science Foundation, technical integrity will become even more essential.   

For example, in order to tackle climate change and the as-of-now-unknown challenges of the future, evidence-based policy making must include consideration of technology and technical integrity issues in particular.  We need computer scientists, data scientists, and technical experts at the policy table, along with other science experts, and the integrity of their work protected. For example, spectrum engineers are needed to inform good spectrum policy.  Security and privacy professionals are needed to inform policies implicating technology, and micro-economists are needed where industries are implicated.   Ensuring technical integrity in policymaking is consistent with both the White House and Congress recognizing the need to promote not just technological literacy amongst policymakers, but ensure that the way technologies work, and its potential impacts, are considered as a forethought and not an afterthought with input from capable technologists.  

Trusted Future is a non-profit organization dedicated to the belief that we need smarter, better-informed efforts to enhance trust in today’s digital ecosystem in order to expand opportunities for tomorrow. We believe we deserve a vibrant digital ecosystem that is trusted, responsible, inclusive, and safe — one where you can trust that your privacy will be protected, your data will be secured, your safety can be protected, that leads to a more just, equitable and inclusive society, and that fosters previously unthinkable opportunities to improve your life.  We bring together experts, advance new research, highlight common sense best practices, policies and recommendations, and explore new ways to foster and enhance the basic trust we need to support and sustain a healthier digital ecosystem. 

Technology will be Key to Solving Today and Tomorrow’s Public Policy Problems 

Our world is interconnected in ways that no one could have imagined just a few decades ago. Technologies have delivered untold advances in our lifetimes, fundamentally changing the way we work, learn, and live. And we have only seen a fraction of what the digital revolution can deliver.  

As technology has been woven into more parts of society, and become critical to solving an ever-increasing number of societal challenges across a broad range of policy domains, getting it right on technology issues has never been more important.  And as technologies have become more complex, more ubiquitous and more impactful, it’s also become more important that strong technical input goes into every technical decision – especially as some of our most critical challenges, like leading the world in technology innovation and production, lie right at the intersection of science and technology. 

Aided by the Biden Administration’s leadership, and expected passage of the Bipartisan Innovation bill, major new advances are just over the horizon, including advances in: 5G and wireless, artificial intelligence, mobile devices, wearable technology, augmented reality, and robotics. And when we invest in our future like this, and continue to drive trust, experts predict that emerging technologies have the potential to:  

  • dramatically improve health outcomes for millions; 
  • radically boost energy efficiency to help meet climate goals,
  • put increasingly powerful computers and applications in the palm of our hands; 
  • and help close economic divides for a more equitable, prosperous, and healthy future. 

Because it has become a key driver and enable across some many domains, it is now impossible to disentangle technology from public policy across those domains.  In this age of cloud computing, cyber challenges, AI transformation, and remote work, every public policy domain and every policy decision has a technology component.  At the same time, the distinction between technology and science is increasingly blurred, both in the laboratory and in the policy world.  Already, key technology standards and policies are advanced by computer scientists and data scientists.  While at the same time science itself is increasingly being performed across federal agencies with technology components – sensors in labs, data visualizations of results, programs to process data. They are often inextricably linked.   

OSTP has previously and wisely recognized the importance of elevating “tech IQ” or “TQ” in public policy processes.  In order to navigate the challenges ahead successfully, there must be a focus on  ensuring that public policy that comes out of the Executive Branch is strengthened by experts with high TQ just as it is strengthened by experts and policy professionals with economic, legal, management, communications, scientific and other domains of expertise.  A roadmap for doing so already exists due to the work of Alexander Macgillivray and others in the Obama White House. SeeToward Ever Better Public Policy Informed by Tech Expertise”. 

For example, as they wrote in January 2017: “Technology for autonomous and connected vehicles has the potential to fundamentally change the transportation system but could be delayed by overly prescriptive regulation or by public reaction if safety and security are not also improved through an understanding of the most effective ways to achieve that balance.” 

Like science, technology – and trust in technology – is not a statistic field.  Given the complexities of trust, cybersecurity, privacy, and national security with existing and emerging technologies, policymakers need the ability to stay apprised of the changing threat landscape based on the best technical information, and apply an up to date ‘security screen’ on any policy proposals.  The future is literally on the line..  Failure to integrate these considerations into the fabric of our decision-making could inadvertently create unintended consequences. Ultimately, decisions that make technologies less useful, less secure, and less capable of protecting our citizens, critical infrastructure, and national security systems will erode our ability to ‘win the future.’  A lack of trust in the use of technology will only delay adoption of new technologies, leading to lower economic growth, slower innovation, and an undermining of global technology leadership.  

Elevating Technical Integrity is Consistent with Statements and Actions from the White House, Congress, and Several Science-focused Agencies 

To ensure that integrity in decision-making doesn’t stop at the laboratory door, the focus on integrity must extend beyond the sciences to include technology, especially at agencies and offices explicitly charged with maintaining a dual focus on science and technology, such as the Office of Science and Technology Policy and the proposed National Science and Technology Foundation.  

We agree with President Biden that evidence-based decisions should be guided by the best available “technological information, data, and evidence” and that access to such information is “central to the development and iterative improvement of sound policies, and to the delivery of equitable programs, across every area of government.”  See Presidential Memorandum on “Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking,” Jan. 27, 2021.   

In his January 2021 memorandum, the President declared that “[w]hen scientific or technological information is considered in policy decisions, it should be subjected to well-established scientific processes, including peer review where feasible and appropriate, with appropriate protections for privacy.”  See id. (emphasis added).   He went on to direct OSTP to “ensure the highest level of integrity in all aspects of executive branch involvement with scientific and technological processes” and  “that executive departments and agencies (agencies) establish and enforce scientific-integrity policies that ban improper political interference in the conduct of scientific research and in the collection of scientific or technological data, and that prevent the suppression or distortion of scientific or technological findings, data, information, conclusions, or technical results.” Id. (emphasis added).  We wholeheartedly agree with the President’s dual emphasis on scientific and technical integrity.   

While the initial report from the Scientific Integrity Task Force, Protecting the Integrity of Government Science, does a laudable job of outlining key steps for bolstering scientific integrity, it falls short by failing to sufficiently address the critical need for technical integrity.  Going forward, proper attention must be paid to similarly elevating technical integrity, which we regard to be crucial to advance technically sound policies.    

We know from prior experience that engaging technical experts so that their insights and knowledge are part of the conversation in Washington leads to better outcomes.  For example,  the Obama White House relied on the Tech Policy Task Force (TPTF) to advise other policy councils on tech-related issues; to initiate and create tech-related policy, such as the Federal Source Code Policy and the White House’s Artificial Intelligence Initiative and Report; to advise on or co-lead agency efforts, such as international connectivity with the State Department; and to answer questions raised by other policy councils, such as considerations regarding encryption policy and cybersecurity. To maintain this progress in the future, it recommended the next Administration should consider including groups such as TPTF in the processes of core policymaking bodies, such as the National Security Council, and continuing to increase the scientific, technical, and innovation understanding at senior levels of agency policymaking. 

We also note the greater recognition by policymakers, both in Congress and at the agency-level, of the need to consider science and technology in tandem.  NASA’s scientific integrity policy for example, already commits to maintaining the “highest standards of scientific and technical integrity.” The National Institute of Standards and Technology similarly commits to “the integrity of the scientific and technological information it develops and disseminates to the public.” 

Looking ahead, Congress is currently moving forward on significant technology-related legislation to promote innovation and American competitiveness. The U.S. Senate’s passed version of the Bipartisan Innovation bill, specifically the Endless Frontiers section of the bill, would establish 10 technology focus areas for the National Science Foundation, which would become the National Science and Technology Foundation to reflect the agency’s dual focus on promoting scientific and technological innovation. These focus areas include: 

  1. Artificial intelligence, machine learning, autonomy, and related advances 
  2. High-performance computing, semiconductors, and advanced computer hardware and software 
  3. Quantum information science and technology 
  4. Robotics, automation, and advanced manufacturing 
  5. Natural and anthropogenic disaster prevention or mitigation 
  6. Advanced communications technology and immersive technology 
  7. Biotechnology, medical technology, genomics, and synthetic biology 
  8. Data storage, data management, distributed ledger technologies, and cybersecurity, including biometrics 
  9. Advanced energy, industrial efficiency technologies including batteries, and advanced nuclear technologies including for the purposes of electric generation 
  10. Advanced materials science, including composites and 2D materials 

There are also certain considerations that cut across technology applications, further why it is essential to incorporate consideration of technical integrity issues whenever decisions impact technology. For example, we need to ensure that privacy and security are baked in from the start. As President Biden noted last year: “[W]e must build technology securely by design, enabling consumers to understand the risks in the technologies they buy. Because people – from those who build technology to those to deploy technology – are at the heart of our success.”  

Facilitating the free flow of scientific and technological information and maintaining open communication are critical.  For example, just as NIST was included in the NSTC Scientific Integrity task force, NTIA and its able computer scientists should be at the table too.   

Adoption of robust technical integrity principles can also head off counterproductive interagency disputes, such as the conflict between the Federal Communications Commission (FCC) and National Telecommunications and Information Administration (NTIA) regarding electromagnetic spectrum allocation by driving decisions through fact based, technical and engineering-based discussions. But when decisions aren’t informed by the best available evidence, hill leaders describe a “chaotic processes” that ultimately “undermined the U.S. government’s efforts in international spectrum coordination proceedings.”  These types of issues can be most effectively resolved by getting engineers to talk with engineers, and ensuring that technical input is always at the table when making these kinds of decisions.  

Fortunately, both the FCC and NTIA appear to recognize this need as well, launching an initiative last month aimed at improving coordination of spectrum management across the federal government.  As a part of the effort, the agencies state they will “recommit to scientific integrity and evidence-based policymaking,” which will involve compiling “principles, guidelines, accepted technical standards, interference protection criteria, propagation models, and other characteristics” for spectrum engineering compatibility analysis.   

As technology becomes more central to solving so many policy challenges, it’s time we also incorporate TechIQ and technical integrity across all policy domains, just as we do for scientific integrity.  Ensuring the integrity of the technical analysis, input, and understanding of technologies in government decision-making has become even more critical.  Just as well informed and properly implemented scientific integrity principles can elevate trust in science, so can well informed policy process that incorporate well informed technical input elevate trust in technology.   

Therefore, as OSTP develops a framework for regular assessment and iterative improvement of agency scientific integrity policies and practice, we encourage you to also pay attention to developing and assessing technical integrity policies and practices in tandem with your scientific integrity efforts.