On Sept. 30th, 2015, at events celebrating citizen science at the White House, the Office of Senator Coons introduced the Crowdsourcing and Citizen Science Act of 2015 (CS2). This Bill is intended to ease barriers for the use of citizen science by US Federal agencies.
The CSA Board – and a number of members of the citizen science community – had the opportunity to review the text in advance of its proposal, in order to understand and advise on the bill in draft form. The CSA Board has provided Senator Coons’ office a letter stating that we appreciate, “… federal-level efforts to acknowledge these grounds for effective citizen science and crowdsourcing, and the CS2 Bill’s intent to enable federal agencies to lead, manage, support, and use research from these initiatives” (read the full letter here).
Such legislation is unprecedented, and drafting something is necessarily difficult and iterative. For this reason, the CSA Board also appreciated the efforts of Senator Coons’s office to field and engage concerns from members of the citizen science community. The CSA Board itself raised a number of concerns regarding early versions of the legislation, and found the Senator’s office to be responsive when changes could be made and also forthcoming about how they were or were not able to address each concern at this point in the process. Below are a few of the concerns that we raised, and our understandings of the responses that we received:
- We are concerned that reporting requirements, as detailed, are arduous and could prove discouraging or even prohibitive to agencies considering citizen science.
Senator Coons’ office clarified that reports are only for projects that are conducted at the agency level, not PIs funded by agencies. Reporting under this Bill would be due only every four years. The Office of Science and Technology Policy would compile the reports, and would work with feedback from stakeholders and agency representatives to determine what kind of reporting details would be helpful.
- Current wording enabling partnerships with “public institutions of higher education” might be read as excluding partnerships with private non-profit universities.
Representatives of Senator Coons’ office clarified that the Bill did not exclude federal agency partnerships with privately funded universities, and adjusted language to reflect this.
- Wording indicating that volunteers “cannot be financially compensated” (Bill page 7 line 19) might preclude such things as reimbursement of volunteers for mileage – we would recommend adding “for their time.”
Our conversations with Senator Coons’ office suggested that this wording change was made, so that choices about compensation for expenses could be determined on a project-by-project basis.
- We suggest that the requirement for all collected data to be public must be tempered by ethical considerations around consent, privacy, and sensitive data (such as in cases of medical data or endangered species).
Although federal regulations indicate that government datasets are required to be made available online (see the website data.gov), with the belief that open innovation data should be made available to the public (whenever possible), Senator Coons’ office acknowledged that there will always be data that cannot be made public. They indicated that they would soften language to read that agencies “shall endeavor” to make citizen science data open.
The CSA Board recognizes a few remaining concerns with the Bill as currently written, and believe that it could be improved in detail by a few minor modifications. Given future opportunities for technical amendments, the Board offers the following friendly critiques for improvement upon the principle of this Bill:
- We agree with the sentiment that citizen science should not displace Federal jobs, but caution that requirements to “prove” that this is the case for each project could lead to onerous or even prohibitive procedures.
- We appreciate the acknowledgment that federal funds can be used in support of citizen science. However, we are concerned by a suggestion that it will cost nothing to implement this Bill. Citizen science projects can be cost effective but are not free, and the efficiencies possible through these projects do require investment.
Even with the above limitations, which we suggest be considered in a process of technical amendments, the CSA Board is optimistic about the intent of this Bill, and is in support of the principles it aims to advance. The Board also acknowledges that the membership of the citizen science community has additional expertise and insights – we invite comments here for inclusion in correspondence with Senator Coons’ office regarding technical amendments to this Bill.