Dr Grabowski's  provocative article supports the integration of the National Institutes on Alcohol Abuse and Alcoholism (NIAAA) and the National Institute on Drug Addiction (NIDA) and even proposes a name for this new agency. My response is both one of caution and trepidation. I suspect that there are more factors in this complex matter that must be considered, and I fear that the arguments for the National Institute on Substance Use Disorders (NISUD) focus mainly upon the disorders and addiction side of NIDA and NIAAA at the serious diminution of environmental and other social forces that continue to impact significantly substance use and abuse.
Some of my concern is well exemplified by the suggestion of NISUD as the agency's name, given that it implies that NIDA and NIAAA's research efforts are focused solely or very largely upon disorders. That is, it is presumed that the portfolios of all NIAAA and NIDA research efforts are, or should be, diagnostic- and treatment-related. This assumption is both simplistic and somewhat naive. It minimizes the importance and major influence of larger societal factors on substance use and misuse and disregards completely any solutions that may involve changes in social policy. Will this mean that NIAAA, for example, should abandon funding of drinking driving, underage drinking or taxation policy because they do not fit into a disorders framework?
Reducing the missions of NIAAA and NIDA to substance use disorders does a great disservice to the alcohol, tobacco and drug fields and the public health issues within which they are embedded. It should be noted that in 2007, efforts were made to change the name of NIDA to the National Institute on Diseases of Addiction and NIAAA to the National Institute on Alcohol Disorders and Health . While, to date, these changes have not occurred, this endeavor represents another effort to narrow agency scope to one that is individualistic  and will diminish concerns for broader approaches to alcohol, tobacco and other drug problems.
In May 2010, a task force of the Scientific Management Review Board of the National Institutes of Health (NIH)  reported on their findings after considering the advantages and disadvantages of a wide range of organizational models that could address some overlap and duplicative research agendas of NIDA and NIAAA. The majority of the task force endorsed a functional model that would foster a collaboration between the agencies in their research efforts. It is important to note that Dr Volkov, Director of NIDA, supported a structural model of full integration while Dr Warner, Director of NIAAA, argued against this approach and supported a functional model. Dr Warner reminded the Board that unlike most biological research at NIDA that focuses upon drug effects on the brain, alcohol affects multiple organ systems beyond the brain that are being researched actively by NIAAA funding.
While I would agree that there are duplicative efforts across agencies, this issue is not the sole providence of NIAAA and NIDA. Clearly, other agencies within NIH (e.g. National Cancer Institute, National Institute on Aging) and outside NIH (e.g. Department of Defense, National Highway Traffic Safety Association, Center for Disease Control and Prevention) conduct alcohol, tobacco and other drug research. It is clear that there is a lack of intra- and interagency coordination and finding ways to bridge and enhance mutual research trajectories would be beneficial. I would also agree that there are commonalities in some treatment and prevention approaches between NIDA and NIAAA, but that these commonalities are far from a full overlap.
One wonders why NIDA wants to merge so emphatically with NIAAA. Beyond the arguments that alcohol and other drugs are the ‘same science’, perhaps a less obvious reason is organizational survival. I live in California, which passed a law legalizing medical marijuana in 1996 and where a proposition calling for legalizing recreational marijuana use for adults will be on the ballot in November 2010 (it is currently polling evenly). In this context, should marijuana use be eventually legalized or decriminalized, NIDA's portfolio could shrink considerably given that the vast majority of illicit drug use is marijuana , and NIDA has focused mainly upon illicit drugs (with the notable exception of tobacco), often defining any use of illicit drugs as misuse.
In summary, there are powerful scientific, political and survival forces that make integration of NIDA and NIAAA problematic. NIAAA and NIDA should work together strategically along with other agencies (within and outside NIH) that are conducting research involving alcohol, tobacco and other drugs, and NIH should provide sufficient financial incentives to do so. Unlike Dr Grabowski, I do not see the overlap issue as ‘sun downing’; rather, I choose to see it as the ‘sun also rises’—perhaps a metaphor for an opportunity to move both agencies ahead in innovative ways. Let us hope this rising sun encourages collaboration.