Comment from Lorraine Remer

I have read the Proposed Rule: Regulation for Federal Financial Assistance issued by the Management and Budget Office and other agencies and have the following comments. As an active research scientist and recipient of many Federal Grants for nearly forty years, I am appalled at the direct harm this proposed Rule change will inflict on the ability of United States science to advance knowledge and maintain its superiority. The overall tone of the proposed Rule change is to transform a traditionally and purposely apolitical process into an overtly political one. Such a transformation represents short sightedness of significant degree. Let me illustrate. In Section 200.340 the Rule allows for discretionary termination of any awarded project in response to new direction from politically accountable leadership. This opens the possibility for wide-scale ideological cleansing of science endeavors every time a new administration takes control. The result is chaos. Administrations will come and go, canceling previous adminstrations efforts until the result is scientific stagnation. In my field, satellite remote sensing, the benefit of planning, launching and making use of the data from a long-lived space mission requires funding stability. For example, I started benefiting from Federal Financial Assistance in 1991 when planning for the MODerate resolution Imaging Spectroradiometer (MODIS). MODIS development had already been underway for several years when I became involved. I continued receiving Federal support through the MODIS program, recompeted every three or so years regardless of politics, as MODIS launched aboard the Terra mission at the end of 1999, and through the 25 years MODIS continued in orbit. MODIS images, data and products have significantly helped multiple U.S., state and local agencies meet their objectives, and provided information for industries as varied as agriculture, insurance and media. I note that this program was supported through eight different presidential administrations beginning with President Reagan. Another example of politicizing science is in Section 200.205 where peer review remains advisory and does not replace agency discretion. I have served on peer review panels, and I realize that awards are determined by a combination of peer review and agency programmatic considerations. However, when senior appointees must conduct these reviews, we leave final determination of complex scientific proposals in the hands of non-scientific appointees rather than in the hands of agency civil servants who are themselves scientists. The role of political appointees is in determining agency priorities when solicitations are written, not in judging the creative responses to the solicitations from individual scientists. Powerful science and the benefits resulting from that science require stability, and by politicizing the process, the proposed Rule change destroys that stability. I also have concerns about Section 200.220 and the restrictions on foreign collaboration. Science is an international endeavor. I realize that international collaboration introduces national security risk, but it seems to me that national security risk is already addressed through Export Control statutes such as Export Administration Regulations (EAR) and International Traffic in Arms Regulation (ITAR). Seeing Section 200.220 here in the proposed Rule change suggests that the Rule intends to go further than EAR or ITAR to create a more restrictive environment for possibly political reasons, unsupported by true national security risks. Additional unsupported restrictions on scientific collaboration will hobble U.S. science more than it will affect our international competitors. In summary, I see elements in the proposed Rule change that attack the fundamentals that have established the United States as a scientific powerhouse and these are political neutrality and stability. I urge a longer term perspective and rules written for the future, not for immediate expediency.