Comment from Rouven Essig

[200.205, 200.340] To Whom it May Concern: I am a professor in theoretical particle 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. The proposed rules together would inflict serious, lasting harm on the American scientific enterprise, and on the students and postdoctoral researchers who are its future. The existing merit-review system exists precisely to insulate scientific funding decisions from political interference. The proposed rules dismantle this system at both ends of the funding lifecycle: § 200.205 empowers political appointees to override peer review at the award stage, while § 200.340 allows those same officials to terminate active grants at any point without detailed justification. Together, these provisions replace scientific judgment with political judgment at every stage of the research funding process. Graduate students and postdoctoral researchers commit years of their lives to advancing our understanding of nature for the benefit of society. They accept demanding work and modest salaries in exchange for intellectual purpose and career stability. The prospect that a grant, and with it their salary and livelihood, could be terminated at any moment for reasons having nothing to do with scientific merit, fundamentally changes that calculus. Talented individuals will reasonably conclude that the United States is no longer a reliable place to build a scientific career. Many will pursue their work elsewhere, taking their skills, their ideas, and their future contributions to science and the economy with them. My ability to recruit the best students and postdoctoral researchers, domestically and internationally, depends on offering them a stable research environment. Chronic uncertainty poisons that environment even when termination never occurs. This is not a partisan concern. Political appointees of this administration, or any future one, of either party, should not have the authority to substitute ideological alignment for scientific merit, either in awarding grants or in terminating them. I urge OMB not to finalize the pre-issuance political review authority proposed under § 200.205, to retain the requirement that grant terminations under § 200.340 be grounded in documented, merit-based findings, and not to adopt any convenience termination authority that provides no procedural check on arbitrary action.