GSA submitted the following letter to the Office of Government Ethics suppporting a proposal to permit federal employees to serve in their official capacity as an officer or director of a scientific society.
From: Craig Schiffries
Sent: Tue 7/5/2011 4:13 PM
Cc: Jack Hess
Subject: Proposed Rule Exemption and Amendment Under 18 U.S.C. 208(b)(2)
Richard M. Thomas
Associate General Counsel
Office of Government Ethics
1201 New York Avenue, N.W.
Washington, DC 20005–3917
RE: RIN 3209–AA09
Proposed Rule Exemption and Amendment Under 18 U.S.C. 208(b)(2)
Dear Mr. Thomas,
I am writing on behalf of the Geological Society of America (GSA) to strongly support the Office of Government Ethics’ (OGE) proposal to amend Section 208(b) of title 18 of the United States Code to permit Government employees to serve in an official capacity as an officer, director, or trustee of a private nonprofit organization, such as a scientific society or professional association.
The Geological Society of America endorsed a position statement from the Council of Scientific Society Presidents (CSSP) on “Maintaining the Benefits of Involvement by Federal Scientists in Scientific Society Leadership” (December 2007). This position statement provides a basis for GSA’s support for OGE’s proposed rule on this topic. The complete text of the position statement is provided below:
Maintaining the Benefits of Involvement by Federal Scientists in Scientific Society Leadership
The Council of Scientific Society Presidents strongly urges the Federal Government to allow employees to be fully participatory in their respective scientific societies, including but not limited to, service in positions of leadership.
Federal scientists have a long and distinguished history of leadership within professional scientific societies. These societies are engaged in education, scientific discourse, and networking among professionals. Benefits of leadership in scientific professional societies include (1) increased professional engagement, (2) enhanced awareness of issues and opportunities, and (3) opportunities to hear diverse perspectives that often transcend those of the general membership of the respective societies. Bringing these perspectives back to the agencies increases agency credibility. Restricting leadership by agency employees denies the government and taxpayers opportunity for voice within scientific arenas. Federal employees can recuse themselves in situations where there may be conflict of interest, in accordance with agency and professional scientific society guidelines, and federal law.
Decision making in the government benefits from the two-way street maintained by federal scientists and professional scientific societies. Moreover, scientific societies depend on diverse, active memberships that encompass the full range of thoughts and perspectives from all professional sectors. Therefore, full participation by federal scientists, including leadership, is critical to maintaining these benefits.
When action by federal agencies restricts employees within those agencies from being fully participatory as leaders in scientific societies, agency perspective can be diminished or lost within the ranks of the societies. This hurts not only agency professionals and the societies, but also seriously impacts the quality of scientific input to decision making in federal agencies. It also may impair the agencies’ ability to recruit top talent. This is a serious restraint that could jeopardize the full range of benefits to agencies, their scientists, the American people, and the national interest.
The Geological Society of America, founded in 1888, is a scientific society with over 24,000 members from academia, government, and industry in all 50 states and more than 95 countries. Through its meetings, publications, and programs, GSA advances the geosciences, enhances the professional growth of its members, and promotes the geosciences in the service of humankind. GSA encourages cooperative research among earth, life, planetary, and social scientists, fosters public dialogue on geoscience issues, and supports all levels of earth science education.
Thank you for the opportunity to comment on the Office of Government Ethics’ (OGE) proposal to amend Section 208(b) of title 18 of the United States Code to permit Government employees to serve as an officer, director, or trustee of a private nonprofit organization. For additional information or to learn more about the Geological Society of America please visit www.geosociety.org or contact Dr. Craig Schiffries at cschiffriesgeosociety.org.
Craig M. Schiffries, Ph.D.
Director for Geoscience Policy
Geological Society of America
1200 New York Avenue NW - Suite 700
Washington, D.C. 20005
Tel: 202-669-0466 (cell)