Here’s a bit of trivia: with the 4000 character limit on comments on the National Nanotechnology Initiative Draft Strategic Plan, you might as well ditch the official portal, and tweet your comments to the Office of Science and Technology Policy – 28 tweets would do it!

As you can probably guess, I’ve just been compiling my response to the request for comments on the current NNI strategic plan, and have been just a little frustrated by the 4000 character limit.  This includes spaces by the way.  And formatting characters – I had to delete any formatting (bold headings for instance) to get below the limit.

However, the comments – brief as they are – are completed and submitted.  If you’re interested, they are posted below – all 3929 characters.

The comment period on the strategic plan closes at 11:59 PM on November 30th – still time to get your voice heard, as long as you can do it in 4000 characters or less.

The draft strategic plan can be downloaded from here, and the comments portal can be accessed here.

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My submission:

The draft National Nanotechnology Initiative (NNI) strategic plan, which was opened up to public comment on November 1 2010, provides an overview of the NNI, outlines agency involvement in the initiative, and sets out four goals that the member-agencies intend to address over the coming years as they work together to support the NNI vision of “a future in which the ability to understand and control matter at the nanoscale leads to a revolution in technology and industry that benefits society”.  This is a useful strategic plan in that it outlines a number of goals that will help member agencies take steps toward realizing this vision – individually, together, and working in partnership with non-government stakeholders.  However, the draft strategic plan is light on detail, and falls short of providing a plan as to how specific and accountable actions will lead to measurable and efficient progress towards stated goals.

Given the 4000 character limitation on comments, I would like to take this opportunity to highlight just eight specific aspects of the strategic plan:

Specificity: This is a very non-specific strategic plan.  In fact, it is hard to find clear evidence of a plan within the document at all, in terms of measurable and accountable actions (with a few exceptions).  In this respect, it provides non-binding and broad direction to government agencies, with no assurance that anything of substance will be achieved.  More specificity would be helpful.

Goals: Some of the stated goals (specifically goal 2 and its stated objectives) are clear and, to an extent, measurable.  However others are vague, mapping out areas of desired activity in ways that will make it extremely difficult to evaluate progress, and return on time and funding investment.

Signature initiatives: These would seem to be a positive step forward in stimulating targeted and innovative research and development – and are one of the few instances of specific actions within the document.  I look forward to seeing how they are developed, and the outcomes that arise from them.

Engagement: While the plan addresses engagement with stakeholders, there is very little detail as to how this will occur, and how the NNI will be held accountable to stakeholders through engagement processes.  There is remarkably little in the way of a strategy for citizen stakeholder engagement, where citizens are empowered to be part of the process of technology development and commercialization.  This is a critical area if sustainable and responsive technologies are to arise from investment in nanotechnology.

Environmental, health and safety impacts: The forthcoming nanotechnology EHS strategic plan is eagerly awaited.

Accountability: There is a profound lack of accountability within the strategic plan.  If goals are not met, investments do not lead to results, stakeholders are not adequately engaged, information is not disseminated effectively, or nanotechnology-relevant governance frameworks and mechanisms are not developed in a timely manner developed, who is accountable?

Building on the past 10 years: Reading the strategic plan, it is hard to imagine that this builds on ten years of work and over $12 billion worth of federal agency investment.  It would be helpful to see a clear roadmap for the coming years of the NNI that is developed with respect to what has already been achieved.  As just one example: on page 36 of the draft, the need for a web-based information and dissemination hub is mentioned – It would be helpful to know why, after ten years of the NNI this does not currently exist, what has been learned of needs and mechanisms for effective dissemination, and how the NNI specifically intends to address the need.

Agency actions: The strategic plan would be strengthened considerably if it contained more information on what precisely the member agencies will be doing to support the NNI’s goals and objectives.