Comment from Michael Green

I am writing to comment on the proposed OMB-2026-0034 rule. I have over 60 peer reviewed publications and books in a career as a Professor of Chemistry, and am now Professor Emeritus. The following points, covering several sections of the proposed rule, are particularly disturbing, and suggest that the probable consequence of this rule would be the effective end of basic research in the United States. 1: Science is a career that requires extensive preparation, generally at least a decade; during this time, especially after the initial four years for an undergraduate degree, pay is much less than the trainee scientist could earn elsewhere. As a consequence, a very large number of American scientists are imported, a free benefit to the U.S. I have not checked the numbers, but I believe that something like half of American scientists were not born in the U.S., but came for the opportunity to work in the most advanced scientific establishment in the world. Here I am counting grad students, many of whom stay here and build our scientific strength; the population of conferences I attend seems to show approximately this proportion. This would be ended by the new proposed rule, through several sections. 2: Because of the sacrifices required to start as a scientist, the uncertainty imposed by this rule, in which careers can be ended by political whim; it is hard to be certain that a project is consonant with presidential priorities, and that it continues to be so. If work is terminated after perhaps two or three years effort, with the key results still to be published, the students who have put in the effort are effectively not only thrown out of work, but out of the profession. Under the circumstances, no rational student would start. 3: Some students, who are often the very best, are determined to do science. The flow of talent will reverse, and the best scientists will leave the U.S. Many will go home to China or India. This is a tremendous boon to China, and a national security threat to the U.S.. which will fall further and further behind. 4: The consequences will be irreversible on a scale of at least a generation; building a scientific group takes years, and with no students to build from, such rebuilding will not even be begun. The U.S. will join the ranks of less developed countries, and will not simply be able to restart that which has been stopped. 5: Consequences will be immediate. For example, the prohibition on attending conferences with grant money will already be sufficient to isolate those dependent on grants from the rest of the world scientific community, with the result that anything produced in an American lab is in immediate danger of being obsolete because it is impossible to keep up with progress elsewhere. For another case, many students will switch careers as soon as possible, or will leave the U.S. quickly, especially as it will be a matter of just going home for many of them. This has become a fairly long comment. I could continue with ways the new rule would interfere with any further progress in scientific groups in the U.S., but this is enough to show how hardly any new scientists will emerge from American universities, the best American scientists will either retire early or if young, leave the country. It will stop American science on a time scale of more than a generation. The greatest beneficiary will be China, making this rule a serious threat to national security. Michael E Green Professor Emeritus of Chemistry The City College of the City University of New York