Comment from Daniel S.

I am a professor in psychology and linguistics whose work uses experiments and computational models to understand how children learn language. This is important because differences between children in language development are societally consequential -- for example, it is not good for the country's children if we do not understand how to help children to overcome language-related deficiencies that can lead to failure to read or to thrive in school. Part of developing treatment is to understand normal development and variation in normal development. This requires research. Historically, the US has been a leader in this domain because of healthy support from NIH and NSF. Because the best research in this area takes a few years to do, continuity of funding is important: we take on PhD students for 5 year terms; we take on postdocs for 2-3 year terms. If continuity in this funding is not there, our smartest students would arguably not be acting in their own interests if they chose to serve the country by becoming scientists. For this reason, I oppose §200.340 which allows for grant termination. If our best students think that they can start a PhD program and suddenly have to leave it because the lab has no more funding or their support has been cancelled, then our best students will not become scientists, and our best current scientists will not be able to function: science is collaborative, and it works through a process of senior researchers training new up-and-coming ones. I personally have a student starting this fall on an NSF grant (where it's similar to NIH). If my support were abruptly canceled, I would not be able to support this student's work, and she would have to leave. I also oppose §200.220. Some of my work on machine learning (AI, in essence) to model infant language development has been aided considerably by my interaction with French researchers who are the best in the world in this domain. My collaboration with them meant I didn't have to waste years re-inventing what would have been an inferior wheel. Sometimes the talent is out there, and bringing skills in to the US makes my work much stronger, which in turn is good for US research and ultimately US society. Finally, I also oppose §200.205. There is no reason for political appointees to review grant proposals. Proposals are already reviewed by experts in the relevant domains. This review process is no joke: in my area, fewer than 12% of proposals are funded. Often it's closer to 1/20 than 1/10. Experts are the ones who can best predict whether a proposal will be impactful. If researchers have to write grant proposals both for the experts and for political appointees, the proposals will tend to be less specific and harder to review effectively. The review system as it is works. Adding appointed political officials helps no-one. I am speaking here of concrete harms. US science has thrived in the past 75 years because our universities have gotten some of our most brilliant future scientists to consider a career in research. This science has improved health and supported the economy. I urge OMB to withdraw these provisions.