Comment from Hans Dam
Hans DamOpposeAcademic
Summary: A professor of Marine Sciences at the University of Connecticut opposes the proposed OMB regulations, arguing that they grant excessive control to bureaucrats and undermine the expertise of funding agencies. The commenter specifically criticizes provisions that would allow for the arbitrary termination of active grants, restrict funding for publication costs, require pre-approval for conference attendance, and allow for non-public grant advertisements.
I am a professor of Marine Sciences at the University of Connecticut. I am writing to oppose several of the provisions of the proposed OMB regulations on research grants. In a nutshell, I oppose provisions that hand control of research grants to OMB bureaucrats. Such control should remain within the funding agencies, which have the capacity and expertise required to regulate and make decisions on research grants. Specifically, I oppose:
1) "Allowing federal agencies to terminate active grants at any time if they are deemed 'inconsistent with program goals or agency priorities.” [200.340]. This seems irrational. If a grant is funded, it is because it has been shown, after peer review, to be consistent with program goals or agency priorities. Such a provision opens the door to the administration. It is also counterproductive, as researchers would also be shrouded in uncertainty after their grants are approved.
2) Disallowing federal grants from being used for most publication costs and open access fees. [200.461]. This provision ignores the realities of research publishing. While not all papers are published in open-access journals or incur publication costs, most do incur some form of publication costs. Even society journals charge for pay charges. So, who is going to pay for these costs of grants don't?
3) Requiring that grant recipients obtain pre-approval from federal agencies to use their funding to attend conferences or obtain professional memberships related to the scientific work covered by their grant. [200.432]. Costs of attending conferences are an allowable expense on grants. Why is there now a need to get pre-approval? What purpose must such a provision serve? This seems a waste of time and money by adding more bureaucracy.
4) Allowing federal agencies to receive exemptions from the requirement to publicly advertise grant competitions when “publicly announcing an opportunity would pose a risk to national security or is in the national interest of the United States.” [200.421]. This is ill-defined. How will bureaucrats decide what's in the national security or interest of the United States? This provision just seems to give bureaucrats more power over research grants.