Comment from Aaron Zimmerman

[200.205, 200.340] To Whom it May Concern: I am an associate professor of physics at the University of Texas at Austin. I am writing in my personal capacity to oppose the proposed revisions to sections 200.205 and 200.340 that would undermine the integrity of federal grant review processes and federal science agencies' ability to identify and fund impactful research. I have received NSF and NASA funding, and served on peer-review panels for proposals to these organizations. Peer review is the gold standard approach for judging scientific merit. It ensure that experts weigh the merits of each proposal and their potential to advance human knowledge, as well as meet any program-specific requirements that have been set. Fellow scientists are in the best position to understand and evaluate research in an objective way, and the current system, while not perfect, ensures that the opinions of scientists is taken seriously. Placing political appointees in the primary decision-making position (200.205) would leave the entire scientific enterprise in the US subject to political considerations, and damages science in the US in multiple ways. For one it means non-experts may override expert opinions, especially in areas that are hot-button topics like climate science, vaccine science, and any number of areas that are no scientifically controversial but may be politically controversial depending on the administration. Coupled to the ability to abruptly cancel grants with no justification (200.340), this would also create a huge amount of uncertainty year to year. NSF grants require Broader Impact components that may focus on education, outreach, or providing societal benefit. I have submitted grants with proposed activities that fit the solicitation and passed peer review, but which under 200.340 could well have been terminated by the next administration. This uncertainty makes it impossible to plan even medium term research efforts or fund research students over the course of their PhD. Simply put, these rules could prevent me and many fellow scientists from receiving the federal funding needed for our science. I urge the OMB to reject these rules.