Comment from Stefan Llewellyn Smith

[200.432, 200.454, 200.461, 200.206, 200.450] To Whom it May Concern: I am a professor and department chair in Mechanical and Aerospace Engineering at a leading R1 university. I am writing in my personal capacity to oppose the proposed revisions to sections 200.432, 200.454, 200.461, 200.206, and 200.450 that would restrict typical professional expenses, curtail the communication of scientific results, and place excessive scrutiny on the activities of scientists. Scientific conferences are one of the major ways I keep informed of what is going on in my research areas. There are yearly meetings, whcih I attend consistently, but also more infrequent and specialized meetings that are sometimes announced only a few months ahead of time. These are often the most productive. Beyond learning about new work conferences are a good place to hear potential postdoctoral fellows and faculty recruits speak, helping to recruit excellent junior colleagues. It is franklly impsossible to advance science without access to the scientific record in a STEM field like mine. A considerable fraction of my work appears in journals that have page charges. If page charges, article processing charges and open access fees become unallowable, I and others will no longer published in these venues, of which the strongest are often US-based. Some of them are run by scentific societies that may not have other sources of revenue. There has been considerable discussion at a policy-making level of the importnace of open access journals so that the public can see the result of federal spending. This contradicts one of the stated goalf of this section, since the open access fees will be disallowed. This rule will limit the venus in which high-quality research is published and the ability of US researchers to attend the leading meetings. As a result the US will fall behind.