Comment from Daniel Borrero

[200.432, 200.454, 200.461, 200.206, 200.450] To Whom it May Concern: My name is Daniel Borrero, and I am the Chair of the Physics Department at Willamette University and an active researcher in experimental fluid dynamics. I am writing in my personal capacity to express my strong opposition to the proposed revisions to sections 200.206, 200.432, 200.450, 200.454, and 200.461 of the Uniform Guidance (2 CFR). These changes would severely restrict necessary professional expenses, curtail the transparent communication of results, and subject scientists to ideological scrutiny. At a small institution, being a professor can feel like living on a scientific island. We lack massive departments or a built-in army of graduate students to drive research. Because of this, professional societies like the American Physical Society (APS) and the American Association of Physics Teachers (AAPT) serve as vital lifelines. They provide the national network I need to stay connected to cutting-edge physics, discover collaborative opportunities, and access undergraduate research forums that give my students resume-building experiences. The ban on using research funding for professional society memberships proposed in Section 200.454 will make it challenging to stay abreast of the latest developments in my field and convey them to my students. Furthermore, traveling to scientific conferences is essential for keeping my research alive. Crucially, innovation happens when a researcher has the flexibility to attend meetings slightly outside their immediate field. As an experimental fluid dynamicist, attending an applied mathematics conference provides me with entirely new tools to analyze the physical turbulence I measure in my own lab. These cross-disciplinary leaps break me out of my academic silo and bring fresh perspectives back to my students. The restrictions proposed in Section 200.432 will significantly harm my ability to gain these crucial interdisciplinary perspectives. Science is a continuous global discussion. Sir Isaac Newton famously noted that he saw further by "standing upon the shoulders of giants." Seamless access to the latest research saves taxpayer money by preventing us from repeating costly mistakes. The changes proposed in Section 200.454 that restrict journal subscriptions will leave scientists probing in the dark, making American science less competitive. Additionally, if Section 200.461 prevents me from paying standard journal publication fees from research grants, it will directly harm my undergraduates. Publishing our recent paper testing Einstein's general relativity gave my students a critical leg up when applying to graduate schools; losing this funding undercuts these transformative student experiences. Beyond these operational barriers, the proposal introduces deeply troubling political boundaries. Under Section 200.206, scrutinizing grant applicants' professional and extracurricular affiliations creates an environment of conformity, effectively establishing a system of political vetting. Similarly, banning "issue advocacy" on politically sensitive topics selected by whoever is in power (Section 200.450) stifles the academic voice. When the government dictates which topics are too sensitive for scientists to address, it compromises scientific integrity and halts vital, evidence-based advocacy on pressing societal challenges like public health and environmental safety. In summary, these revisions threaten American innovation by cutting off the pathways scientists use to collaborate, publish, and stay informed. By restricting basic costs like conference attendance, publication fees, and society memberships while introducing political vetting, this policy will isolate researchers at small institutions and cripple undergraduate STEM opportunities. Ultimately, replacing an independent, merit-based scientific enterprise with rigid political oversight will stifle breakthroughs and compromise U.S. global leadership.