Comment from Cameron Casey

I am a researcher at the University of Wisconsin-Madison writing to express my opposition regarding the proposed revisions to §200.202, §200.204, §200.205, §200.340, §200.454, §200.461, §200.300, and §200.218. Sections §200.454 and §200.461 jeopardize the dissemination of scientific findings. Because federal funding comes from tax payer dollars, U.S. citizens have the right to access the products of federally funded research. They also threaten the quality of future research by limiting the scope of scientific literature that researchers have access to when designing experiments, developing grant applications, and writing up results for publication. This will create critical gaps in context that are likely to result in misinterpretation of data and ill-founded proposals that ultimately cost the American public MORE than the costs of publication. The revisions to sections §200.202, §200.204, §200.205, and §200.340 critically endanger scientific integrity by taking decision making power about science away from scientists and giving it to arbitrary political figures who are likely unqualified to be making these decisions. This will undermine trust in science by politicizing what research is approved to be funded. The specification in §200.202 that programs must “Align with administration policies and priorities” provides unprecedented political control over what research gets funded. §200.340 would also result in exorbitant waste of tax payer money by allowing politicians to terminate in-progress studies without justification, rendering their results incomplete and tax payer investment wasted. §200.204 would further allow funding agencies to exempt grant competition from public notice, fundamentally undermining transparency. This would allow politicians to award funds on the basis of favoritism rather than merit. Rather than preventing discrimination, §200.300, and §200.218 would enforce discriminatory practices. When scientific evidence identifies issues that preferentially harm a group of people, e.g., racial, ethnic, gender, sexuality, or religious denomination, it is imperative that research be allowed to address those issues. These changes will create greater disparity in who benefits from scientific research. For these reasons, I implore the OMB to withdraw revisions§200.202, §200.204, §200.205, §200.340, §200.454, §200.461, §200.300, and §200.218 to protect the integrity of scientific research and the benefits it provides to the American people.