Comment from David Bonan

David BonanOpposeAcademic
Summary: A scientist whose research is federally funded opposes the proposed regulations, arguing that they could undermine research effectiveness. The commenter highlights concerns regarding grant termination due to changing priorities, restrictions on international collaboration, publication cost limits, and increased administrative burdens for conferences and memberships.
I am a scientist whose research is supported by federal funding. I am concerned that several provisions of the proposed revisions could reduce the effectiveness and efficiency of federally funded research. The provision allowing agencies to terminate active grants based on changing program priorities would create significant uncertainty for research projects that often span multiple years. Scientific studies require long-term planning, personnel commitments, and investments in data collection and analysis. Increased uncertainty regarding grant continuity could make it more difficult for researchers and institutions to undertake projects that address important scientific questions. I am also concerned about restrictions on international scientific collaborations. Many fields depend on international observations, data sharing, and collaboration. Limiting these activities could reduce access to valuable scientific expertise and datasets, ultimately diminishing the impact of federally funded research. The proposed restrictions on publication costs could make it more difficult to communicate research results to the scientific community and the public. Publication is a fundamental component of the research process and ensures that the outcomes of federally funded projects are broadly available and subject to scientific scrutiny. Similarly, requiring pre-approval for conference attendance and professional memberships would increase administrative burdens for both researchers and federal agencies. Scientific conferences provide important opportunities to share findings, develop collaborations, receive feedback, and train early-career scientists. Additional administrative requirements could reduce participation in these activities without providing clear benefits. Overall, I am concerned that these provisions may increase administrative costs and reduce the efficiency with which federally funded research is conducted and disseminated. I encourage OMB to carefully evaluate the potential impacts on the scientific enterprise and consider revisions that preserve accountability while maintaining the flexibility necessary for successful research.

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