Comment from Jesus Pando

[200.300, 200.218] To Whom it May Concern: I chair the Physics and Astrophysics department and am an associate professor of physics. I am writing in my personal capacity to oppose the proposed revisions to sections 200.300 and 200.218 that would impede STEM recruitment and retention initiatives and restrict certain research fields vital to broadening participation in STEM. I work on programs that involve undergraduates in research very early in their careers. The programs include not only actual research experience but also professional development workshops on issues such as communication, working in teams, building agency, etc. In addition, I work on programs that are aimed at improving pedagogy across STEM by training faculty in active engagement strategies that have been shown to retain students. I have a NASA grant aimed at building capacity in institutions that have not received NASA research grants due to a lack of capacity. I also work on NSF grants aimed at increasing student success by involving them in research and by providing training to faculty to improve the pedagogy. The impact of this rule would be to further amplify the disparity between well-resourced universities and those with lesser resources. Because universities with fewer resources often have a mission of giving opportunities to communities that have the most needs, this disparity will transcend just the academic world.