Comment from Martin Hilbert

I am submitting this comment as a professor and researcher at the University of California, Davis to urge the Office of Management and Budget to withdraw the proposed Regulation for Federal Financial Assistance (Docket OMB-2026-0034). I do not say that lightly. If this rule is finalized, it will do lasting harm to the enterprise that made American science the strongest in the world, and it will damage my own ability to do my work. Three provisions concern me most. International collaboration, Section 200.220. Barring federal funds from supporting collaboration with covered foreign countries or entities by default does not make American science safer. It makes it smaller. The hardest problems we face, from pandemics to climate to fundamental physics, are solved by no nation alone, and walling our researchers off from international partners simply hands the lead to everyone else. Dissemination of knowledge, Sections 200.432, 200.454, and 200.461. Making conference attendance, journal subscriptions, memberships, and publication fees (including open-access article processing charges) unallowable by default cuts researchers off from the exchange that turns a finding into progress. Knowledge that cannot be published, presented, or read is not science, it is a locked drawer. These determinations would rest with political appointees who need give no reason, which is no way to run a research enterprise. Political independence, Sections 200.205, 200.340, and 200.202. American science works because funding follows peer-reviewed merit, not the priorities of whoever holds office. Reducing peer review to advisory status, requiring awards to advance the President's policy priorities, and permitting discretionary termination of multi-year grants for openly political reasons trades the pursuit of truth for a test of loyalty. No serious scientific career can rest on a commitment that can be revoked at will. For these reasons I respectfully request that this rule not be implemented. Martin Hilbert Professor, University of California, Davis Scholars Council of the Library of Congress Chair DE Computational Social Science Dpt. of Communication | GG in Computer Science www.martinhilbert.net