Comment from Jeffrey Catalano

I am a professor in the Department of Earth, Environmental, and Planetary Sciences at Washington University in St. Louis. Over the course of my nearly 20-year academic research career, I have been awarded major research grants by NSF, NASA, and DOE totaling over $5 million. This research has focused on a range of topics that include leaking nuclear waste, the fate of heavy metal contaminants in soils and groundwater systems, past habitability of Mars, and novel critical mineral resources. I have supervised ten students who completed Ph.D. degrees, with five students currently working towards their degrees. Attending scientific conferences is critical to learning the current state of knowledge in the field. This exposure to new information stimulates novel research ideas and is essential to training the next generation of our STEM workforce. The policy change proposed by OMB regarding pre-approval of conference attendance [200.432] is understandable in principle but unworkable in practice, and will result in arbitrary application of the policy to researchers. Proposals for new research funding are effectively written and submitted the year before a project commences because of the long timeline for review and award making. Requiring that Federal financial awards may only support conference attendance if that conference was specifically included in the original proposal, a practical implication of [200.432], is an impossible request because the topical programs of conferences are not known more than 6 to 12 months in advance. Further, the dates and locations of conferences are not always known at the time of proposal preparation. Further, these may change in response to future events. Predicting which specific conferences will be attended at the time of proposal preparation is impossible to do with 100% accuracy because the necessary information is not available. Requiring knowledge of the future which cannot be obtained poses an arbitrary requirement on scientists that cannot be met. While agencies might be expected to setup a system to allow scientists to propose attending conferences different than listed in their original award, [200.432] implies that the agency would then need to issue a revised award to the sponsoring organization. The additional workload from such a system would likely require more Federal staff time, and thus labor expenses by the Federal agency, then would be saved by restricting which conferences can be attended. In addition, such a system would require quick decision making that Federal agencies to date have not indicated are possible. [200.432] would effectively restrict conference attendance, including attendance at new conferences specifically supported by Federal agencies, without a clear benefit to the Federal government. This would result in a hindering of the sharing of idea and the stimulating of new research directions. Finally, [200.432] does not address how it would be applied to existing awards. The proposals that resulted in such awards often do not contain lists of specific conferences to be attended. Without a clear transition policy, this would effectively ban conference travel under all existing awards despite it being an allowable expenses without pre-approval at the time of proposal submission and at the time of award issuance. Overall, this policy is harmful to the scientific development of the United States by establishing arbitrary and unworkable restrictions without a clear corresponding benefit to our country.