Comment from Gail Rosen

[200.300, 200.218] To Whom it May Concern: I am a Professor of Electrical and Computer Engienering. 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 a variety of initiatives to attract, train, retain underserved populations in STEM. They range from teaching in K-12 underserved neighborhoods to undergraduate and graduate education. These initiatives, 200.300, would severely decrease the amount of low-income and underserved populations pursuing STEM fields. This results in loss of perspective and creativity that diversity brings to US innovation. A NSF S-STEM scholarship grant was terminated despite nearly $1 million in funds remaining. This grant was supporting 23 low-income students in Mechanical and Electrical/Computer Engineering. These students have done everything right: they are in good standing, the majority maintain GPAs above 3.0, and the program has achieved a 96% retention rate. Many are already working multiple jobs to afford college. The sudden loss of $10,000 per year (for 4 years) in scholarships has left them devastated. One student shared: “I already work two jobs to cover rent and food. Without this scholarship, I don't know how I can keep going to school.” Another told us: “This support was the only way I could afford to study engineering. Losing it means I may have to drop out.” These are not isolated cases. Without immediate intervention, we risk seeing talented students forced to abandon their education because the financial burden has become impossible. Compounding this, our proposed AI-DeV-4-UrbanAg graduate studies traineeship program—which would have trained graduate students at the intersection of artificial intelligence, agriculture, and environmental science—was reviewed positively and RECOMMENDED by the program officer but blocked from funding due to misalignment with “priorities” and lack of funds. That decision means dozens of additional students will miss out on cutting-edge research and professional development opportunities that would prepare them for careers addressing urgent national priorities such as sustainable agriculture, food security, and climate resilience. This type of termination in 200.340 directly resulted in lost opportunities: * 23 low-income engineering students now face the real prospect of leaving college. * Dozens of graduate students will not have access to interdisciplinary training in AI and agriculture. * The long-term impact includes fewer skilled workers in high-demand STEM fields, especially from underrepresented and low-income backgrounds. For the S-STEM, with nearly $1 million in committed scholarship support already sent to us, it was a tragic waste of federal investment and human potential to abandon this vital training. The proposed OMB rules, 200.300 and 200.218, will stifle USA innovation and science progress that benefits taxpayers and public health.