Comment from Christa Kelleher

I am writing to share my concerns as a federally funded scientist and professor at a small liberal arts college with regards to the proposed changes from OMB. I am deeply opposed to the suggested changes to federal funding. I share my opinions as a recipient of a grant from the USDA and multiple grants from the NSF which have funded many graduate students and undergraduate researchers, who are all the better for the experiences that they had through this grant funding. In section 200.340, federal agencies will be permitted to terminate active grants at any time if they are deemed inconsistent with program goals or agency priorities. This concerns me, because while the federal administration may change, good science on topics that are important for and benefit the American people directly do not. My concern is that by tying this to agency priorities, which may shift with federal appointees, this is suggesting a strong lack of trust in program officers and the review process for federal grants, which are rigorous and rely on the careful attention and time investments of US scientists as part of review panels or in providing ad hoc reviews. Having been a part of this process, I can attest to the rigor of this process: we scientists truly want the best work to be funded, and we take this process very seriously. In section 200.432, the new rule requires grant recipients to obtain pre-approval from federal agencies to use their funding to attend conferences. Science moves at a nonlinear pace, meaning that it is often challenging to know far in advance which conferences you will attend, and when your results will be ready for conference review. Moreover, this seems like adding more work to existing federal granting agencies, such as the USDA and NSF, that are already losing staff at alarming rates. We scientists are used to doing our science on shoestring budgets, and are careful with our funds. We do not want to waste these funds frivolously. I am unsure what the point of this new rule is, except to increase oversight and add more work to already strained granting agencies. In section 200.461, I am especially concerned about the decision to disallow federal grants from being used for publication costs and open access fees. One of the best ways we can share our work with the American public is by making our work publicly available. Removing our ability to fund this open access publishing (on the order of $3,000 for many journals, more for some) would only achieve the outcome of further removing access of American taxpayers to the science that they fund. Most importantly, as a professor at a predominantly undergraduate institution (PUI), I am deeply concerned with the suggested changes in Section 200.205 that states that "agencies should prioritize institutions that have demonstrated success in implementing Gold Standard Science." PUIs do not have the same research funding or output as R1 institutions, which are able to provide much more support to their faculty to complete research agendas. However, PUIs play an important role in developing the next generation of researchers. Because there are no graduate students, undergraduate students at a PUI have much more hands-on experience conducting cutting edge science. This experience prepares undergraduate students from PUIs for successful careers in research and beyond. Section 200.205 would jeopardize potential grant funding for PUIs, limiting the training opportunities available for undergraduate students at such institutions. Thank you for addressing my concerns.