Comment from Abygail Waggoner

[200.205, 200.340, 200.341, 200.432, 200.454, 200.461] I am writing in my personal capacity to voice my strong opposition to this proposed rule, as it would cause significant harm to the scientific community and signal an abdication of US leadership in the sciences. I am especially concerned by the following sections of the rule: Section 200.205: By making peer review advisory and mandating that senior political appointees review discretionary awards to ensure alignment with shifting political priorities, this rule introduces unprecedented political interference into scientific funding. The peer review system, a process widely regarded as the gold standard for evaluating scientific merit and funding decisions, is built on the rigorous evaluation of proposals by independent scientific experts. This ensures that funding decisions are based on mission-driven scientific innovation and potential impact - not political considerations, which is why the U.S. has consistently led the way in driving breakthrough research and accelerating technological innovation. Shifting final authority to political appointees will significantly undermine the grant review and award system and could distort federal research priorities based on ideological or partisan agendas, stifle innovation, and erode public confidence in research. Research should focus on scientific inquiry, promise, and innovation to advance science and improve public health above politics. Sections 200.340 and 200.341: The new grant termination authorities introduced in these sections could introduce significant instability for long-term scientific projects. Allowing federal agencies to terminate or suspend active, multi-year grants mid-project for broad, subjective reasons—such as a shift in agency priorities or "national interest" determinations—undermines the security needed to conduct cutting-edge research. In fields like astronomy, projects rely on years of continuous data collection, graduate student training, and stable collaboration. Canceling grants midstream due to ever-shifting agency priorities would squander investments already committed to facilities, equipment, and specialized personnel, reducing our return on federal spending and potentially undermining the principle of accepting negative results as positive outcomes. Further, permitting awards to be terminated for reasons unrelated to performance or compliance opens the door for administrations of either party to effectively end funding for lines of research deemed politically sensitive. Employing such terminations will create perverse incentives to align research results with political agendas. The constant threat of arbitrary cancellations will stifle innovation, discourage high-risk, high-reward research, and severely damage the retention of scientific talent, undercutting U.S. competitiveness in a global research environment where other countries offer more predictable funding streams. Sections 200.432, 200.454, and 200.461: The proposed rule will also place undue restrictions on collaboration that will isolate American scientists and stifle innovation. Presumptively treating conference costs, professional society memberships, and publishing costs as unallowable is overly restrictive and will only harm our community's ability to steward meaningful, high-reward science. Forcing researchers to navigate a political approval gauntlet just to share data at a conference or publish a peer-reviewed paper creates immense administrative burdens and isolates U.S. research. I strongly urge OMB to withdraw these damaging provisions and protect the non-partisan, merit-driven nature of federal research funding.