Comment from Destenie Nock

I am an Associate Professor at Carnegie Mellon University, with a joint appointment in Civil and Environmental Engineering and Engineering and Public Policy. My research focuses on energy systems, affordability, and infrastructure. I use methods from operations research, electrical engineering, statistical analysis, and machine learning to study how infrastructure decisions affect households. I am submitting this comment because federal research funding is one of the ways the United States builds the knowledge required to address complex public problems for the betterment of all citizens. In my field, those problems include how to protect households during extreme heat and cold, build a reliable electricity grid, and how to make public investments that are both technically sound and socially responsible. Accountability matters. Federal research dollars should be used responsibly. Research should be rigorous, transparent, and oriented toward the public good. But the proposed rule would weaken rather than strengthen the scientific process by inserting political discretion into decisions that require technical expertise, creating uncertainty for active research projects, and making it harder for scientists to communicate findings and learn from one another. [200.205(d)] The proposed revision would require peer-review recommendations to remain advisory and would prohibit senior appointees from routinely deferring to those recommendations. I strongly oppose this change. Peer review is not perfect. It can and should be improved. But the appropriate response to imperfections in peer review is to strengthen the process, not to displace scientific judgment with political judgment. In my field, evaluating a research proposal competently may require expertise in electric-power-system modeling, optimization, energy economics, utility regulation, statistical analysis, machine learning, climate adaptation, and the distributional consequences of infrastructure decisions. No individual senior appointee can be expected to independently replicate the collective technical judgment of researchers with relevant domain expertise. The proposed rule would require senior appointees or their designees to exercise independent judgment rather than “ministerially ratify” or “routinely defer to” expert recommendations.¹ This creates a structural problem. A political official may appropriately confirm that an award is lawful and aligned with the purpose authorized by Congress. But the scientific merit of a proposal should be evaluated primarily by people with the expertise needed to understand its methods and whether those are appropriate, assumptions guiding the work, appropiatness of the data that will be involved in the study, and likely contribution to the field. The consequences extend far beyond universities. When federal agencies fund research on electricity reliability, energy affordability, public health, extreme-weather resilience, or infrastructure planning, the quality of the review process affects the quality of the evidence available to utilities, regulators, policymakers, and communities. The people who ultimately bear the risk of poor decisions are often households with the fewest resources to absorb them. I urge OMB to remove the language in Section 200.205(d) prohibiting routine deference to peer-review recommendations. Agencies should retain the ability to conduct lawful oversight, but expert peer review should remain the central mechanism for evaluating scientific merit.