Comment from David Pollard

I am a Professor Emeritus in the Department of Earth and Planetary Sciences at Stanford University. During my 33 years on the faculty, I submitted many proposals to federal agencies including the NSF, DOE, and USGS and I received grants to support geological research and graduate students in my academic program at Stanford. All these proposals were peer reviewed by professional geologists with credentials comparable to mine. Their reviews provided expert advice that guided the resubmission of unfunded proposals, and informed our scientific methodology and research objectives for successful proposals. These peer reviews also informed the professional personnel at the NSF, DOE, and USGS, many of whom had similar professional credentials to mine, and guided their decisions about funding. None of these proposals were subject to a Pre-issuance review based on political criteria and carried out by political appointees. Therefore, I am deeply concerned about the changes to federal grant rules proposed by the Office of Management and Budget on May 29, 2026. In Section 200.205 on Federal agency merit review of proposals I read in paragraph (a): The pre-issuance review described in paragraph (b) may form the basis of a decision not to select an applicant to receive a Federal award. In paragraph (b) item (1) I read: Discretionary awards must, where applicable, demonstrably advance the President's policy priorities. The senior appointees could gain review authority without the many years of education and study of geology accomplished by the peer reviewers of my proposals or by the professional personnel at the NSF, DOE, and USGS granting organizations who funded my proposals. I believe this could undermine the credibility of the granting process and lead to rejection of scientifically sound and promising proposals based on criteria other than the objective and informed scientific knowledge of ones peers. Regarding the use of peer review in Section 200.205, paragraphs (c) and (d) I read: When conducting a pre-issuance review, senior appointees must not ministerially ratify or routinely defer to the recommendations of others (the peer reviewers) and that peer review recommendations remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding by senior appointees or their designees. Given the power to veto proposals in paragraph (b) and being strongly advised to use their independent judgment in paragraph (c) and treat peer reviews at best as advisory in paragraph (d), the senior appointee through the pre-issuance process attains a dominant role over the scientific peers of the proposals author. Therefore, I urge OMB to remove the entire pre-issuance review process from their changes to federal grant rules and return support to the peer review process of scientific proposals. The peer review process has worked for many decades to help create university Science, Technology, Engineering, and Mathematics (STEM) programs that are the envy of the World and these programs have spun off ideas, inventions, and knowledge to industries in the US that lead the World and enrich our citizens.