Comment from Andrew Mugler

[200.205, 200.340] To Whom it May Concern: I am an associate professor in biological physics. I am writing in my personal capacity to oppose the proposed revisions to sections 200.205 and 200.340 that would undermine the integrity of federal grant review processes and federal science agencies' ability to identify and fund impactful research. I have grants from the National Science Foundation and the National Institutes of Health, on topics including yeast cell sensing and mating, bacterial growth and ecology, and cellular aging. These grants were awarded based on their scientific merit as judged by my peers. If instead they were subject to the judgement of political appointees, then specific topics or terms, however misconstrued (e.g., mating, mRNA, etc) run the risk of being deemed misaligned with presidential priorities, which is not how science should be decided. Almost all science in my research group is performed through the process of training PhD students. This training takes 6 years on average. This timescale requires long-term planning of funding. If a grant can be terminated at any time, this planning is impossible. The impact of specific terminations would be bad, but far worse would be the chilling effect on my department and university. Without funding security, these units would shrink our PhD program out of fiscal prudence, training fewer students. This already happened in 2025 (33% less students) due to the uncertainty around case-by-case grant terminations. If the right to terminate were institutionalized, the effect on training the next generation of scientists would be catastrophic. These rules would severely harm the integrity of merit-based review and dismantle the security of research funding. Science departments would have no choice but to train fewer scientists, thus crippling US scientific leadership. No one wants that.