Comment on OMB-2026-0034-0001

Resource DecisionsOpposeBusiness
Summary: The Principal of Resource Decisions, a consulting firm specializing in economics and the environment, opposes the proposed regulation. They argue that the rule gives political appointees too much power to override professional scientific reviewers, which could lead to inefficient spending and hinder scientific progress.
I am the Principal of Resource Decisions, a consulting firm in economics, energy and the environment. I hold a doctorate in Natural Resource Economics from the University of Wisconsin, Madison, a MS in Water Resource Management and a BS in Geology. In addition to my 40-year professional career, I am a life-long environmentalist, a father and grandfather. My comment addresses Sec. 200.205. I am concerned that the procedure defined in this section prioritizes the judgment of political appointees over professional peer reviewers in grant review. Political appointees, possibly with no scientific expertise can override well-qualified professional scientific reviewers. This leaves grant approval subject to the priorities or even the whims of a political process. Scientific advancement is an orderly process which builds on prior research. Political appointees who may not have scientific knowledge or may not be aware of the state of knowledge in a particular field, would under this section, have the ultimate decision-making power in grant selection. This process will not lead to the advancement of science or direct public spending in the most cost-effective direction. Our nation and the world is a perilous historical time. Environmental degradation threatens to overwhelm technical and social progress. Scientific progress is needed to save our nation and the world from these perils and ensure that the planet is habitable and sustaining for ourselves and our progeny. Scientific progress can help avoid these perils only if research is supported in the most efficient and cost-effective manner. This rule would not allow scientific progress to be supported efficiently or cost effectively.

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