Comment on FR Doc # 2026-12725 from Karen Holl

I have been a faculty member at the University of California, Santa Cruz for over 30 years and have deep expertise in the field of restoration ecology. I have conducted extensive research on forest, chaparral, and grassland restoration with funding from the National Science Foundation, as well as other federal agencies. The proposed changes to the NSF Guidance on Financial Assistance (GFA) make substantial changes to the scientific funding process, which will strongly undermine US scientific leadership and will have negative impacts on the health and wellbeing of American citizens. Below I list the items that are of most concern to me. [G8.Authorities] First, I am extremely concerned about the change to the section of 2 CFR 200.205 that calls for senior agency appointees to ensure. I have served on multiple scientific review panels for the National Science Foundation, in which we provide rigorous scientific review and feedback on grants. We are assigned to review grant proposals in our area of expertise and select those that are most likely to comprise transformative science. It is ludicrous to think that senior officials, even with scientific training in a specific area, are qualified to review the caliber of the science being done across a range of topical areas in a given NSF Directorate. I could not meaningfully review proposals in the health sciences, and I have a doctorate in Biology. If political appointees become the primary deciders of who receives scientific funding, important research on health and the environment will not be funded because it does not align with political priorities, whereas limited NSF funding is likely to be wasted on some poorly designed research that is a pet project of certain officials. This is not how taxpayers’ money is spent most effectively to advance science. [G25.A.Term 2] Second, I am extremely concerned about the requirement that to receive funding, recipients must sign a statement accepting that their funding could be suspended or terminated at any time. I do research on forest restoration, which is a long-term process. The maximum length of a grant from the National Scientific Foundation is 3-5 years, which means that my research is already subjected to rigorous scientific review every few years. Once I have received a grant, then I can plan for the next few years, by hiring to staff to conduct the research and conducting a well-coordinated series of experiments and data collection. If grants can be terminated at any time, then it again will result in a waste of taxpayers’ money due to incomplete research and will impede scientific training and advances. Scientists will be hiring and firing staff and will not be able to do the sustained experiments and monitoring to make new discoveries. [G12.A Term 1] Third, I object to 2 CFR 200.461, which states that NSF will not pay for publication costs, as they are not necessary to carry out research. They are necessary to be able to share the results of research, which is key to making sure that taxpayer-funded research is disseminated and used. The proposed changes together represent a narrowing and politicizing of federally-funded scientific research, which goes against the whole scientific enterprise.