AAU, AAAS, APS, APLU, and COGR submitted a joint response to the Department of Energy's Office of Research, Technology and Economic Security in regards to the current risk matrices under development. The letter outlines the need for soliciting feedback from the research community to ensure a strong research security review process.
Dear Mr. Turk,
The undersigned organizations — representing hundreds of American research institutions as well as thousands of researchers across the country — are writing to request that the Department of Energy’s (DOE’s) Office of Research, Technology and Economic Security (RTES) fully engage with — and solicit feedback from — the research community broadly prior to implementation of the risk matrices currently under development. Taking the time necessary to do so will lead to a research security review process for extramural research that is appropriately rigorous and protects national security interests while at the same time has buy-in from — and is able to be effectively implemented by — the affected research community.
As you know, if science is to advance, it is essential for fundamental research to remain open to the maximum extent possible. While there is a need to consider security, overly-broad security policies have the potential to chill international collaboration, punish honest mistakes, impede scientific advancement, and cause long-term damage to the U.S. scientific enterprise. The value international collaborations provide to the United States is clear, but we also recognize that there are legitimate research security concerns with unwanted foreign influence.
The CHIPS and Science Act (Section 10114) directs DOE to develop and maintain tools and processes to manage and mitigate research security risks associated with Office of Science supported research, and we support DOE developing and implementing a transparent, risk-based approach to research security reviews of fundamental research. Instituting policies that require making risk-based assessments — instead of relying on non-discerning filters — is an essential step towards appropriately balancing research security risks and the research requirements for open science.
While all of our organizations appreciate having had the opportunity to meet briefly with RTES staff to learn about their draft plan for reviewing research security risks of extramural research grant applications, the short duration of our meetings limited discussion and the opportunity for feedback.
Our understanding is that RTES intends to publish its new research security review processes — without soliciting input on its proposed risk matrices from key stakeholders or offering any formal period for public comment — by the end of September. Prior to unveiling its first research security matrix, DARPA held listening sessions with senior university research officials to better understand potential scientific community impact and made changes prior to implementation. Additionally, leadership from the Department of Defense’s (DOD’s) Basic Research Office took the time to engage with and solicit feedback from stakeholders across the academic research community while developing its decision matrix. These efforts likely helped pave the way for a smoother transition when DOD rolled out its full agency policy in 2023. Currently, the National Science Foundation is rolling out its new TRUST process by pilot testing it with quantum science grant proposals. RTES introducing this new process before affording the research community broadly sufficient opportunities to provide feedback or piloting the new review process will likely result in a weaker research security review process that lacks buy-in from the research community and also may be difficult to implement.
Thank you for your leadership in working to ensure the United States remains a global leader in science, technology, and innovation. We urge DOE to take the time necessary to follow DOD’s example and fully engage the research community in its effort to implement transparent, risk-based research security reviews. Doing so will help lead to a more uniform approach to research security taken by all federal science agencies. If you have questions or would like to further discuss our concerns outlined above, please do not hesitate to reach out to the organization contacts listed below.
Sincerely,
American Association for the Advancement of Science
Contact: Joanne Carney, [email protected]
American Physical Society
Contact: Mark Elsesser, [email protected]
Association of American Universities
Contact: Tobin Smith, [email protected]
Association of Public and Land-grant Universities
Contact: Deborah Altenburg, [email protected]
Council on Governmental Relations
Contact: Krystal Toups, [email protected]
CC:
The Honorable Geri Richmond, Under Secretary for Science and Innovation Julie Anderson, Director, Office of Research, Technology and Economic Security Harriet Kung, Acting Director, Office of Science
Jermey Ison, Senior Policy Advisor, Under Secretary for Science and Innovation
Jennifer Mahalinghappa, Senior Legal Advisor, DOE Office of General Counsel