Comment from Dani Jones

(NOTE: I attempted to submit this comment through a third-party portal [AGU], but I'm not sure if it worked. Therefore I am posting it here, directly. Apologies for the possible duplicate posting.) I am a mid-career researcher working at the intersection of Earth system science, artificial intelligence, and environmental observing systems. I manage research projects and supervise staff members and students. My work depends on stable, merit-based federal research funding and on collaborations that span universities, federal agencies, and international partners. Much of my work focuses on the Great Lakes. I see the value of the current research system firsthand. Our research helps protect one of North America's most important freshwater resources. The science we produce supports drinking water, commerce, shipping and navigation, recreation, ecosystem management, and the communities that depend on the lakes every day. Doing that work well requires sustained investments in observations, software, partnerships, and people. Those investments are only possible with stable, predictable federal support for scientific research. I am particularly concerned about proposed §200.340, which would allow agencies to terminate active awards if they are deemed inconsistent with changing agency priorities. Scientific research often requires multi-year investments in data collection, software development, model development, and student training. The possibility that awards could be terminated for reasons unrelated to scientific performance would make it substantially more difficult to undertake ambitious research and would discourage investigators from proposing long-term projects. It also creates uncertainty for the staff members and students whose careers depend on those projects. I am also concerned about §200.461, which would limit the use of grant funds for publication costs. Publishing results, including through open-access venues when appropriate, is a core part of the scientific process. Federally funded research provides the greatest public benefit when its results are broadly available to scientists, operational agencies, industry, educators, resource managers, and the public. Restricting publication support would reduce the accessibility and impact of federally funded research. Section §200.432 would require pre-approval for conference attendance and professional memberships. Conferences are where researchers establish collaborations, receive technical feedback, train students, and share results with the broader community. They are part of doing good science, not an optional extra. Additional administrative hurdles would reduce participation, particularly for smaller research groups and early-career scientists. I am also concerned about §200.220, which would broadly restrict international scientific collaboration. Earth system science is inherently international. Weather, climate, oceanographic, and environmental observations do not stop at national borders, and many of the datasets, models, and observing systems that U.S. researchers rely on are developed through international partnerships. Broad restrictions on collaboration would make our science less effective. More broadly, these proposed changes reduce the stability and predictability that good science requires. The current peer review system is not perfect, but it provides a transparent, merit-based process for evaluating proposals. Researchers should be able to pursue the work they proposed and were selected to perform without concern that shifting political priorities could end a project before it is complete. **OMB should reconsider these provisions.** Stable, independent, merit-based research funding is essential for addressing long-term challenges such as protecting the Great Lakes, improving environmental forecasting, strengthening U.S. scientific capability, and ensuring that taxpayer investments in research deliver lasting public benefit.