Comment from Deirdre Shoemaker

[200.205, 200.340] To Whom it May Concern: I am a Professor of Physics and Director of the Center for Gravitational Physics at The University of Texas at Austin. For more than two decades, my research in gravitational-wave astrophysics and numerical relativity has been supported by competitive grants from the National Science Foundation, including research that develops the numerical models and computational infrastructure needed to interpret gravitational-wave observations made by the Laser Interferometer Gravitational-Wave Observatory (LIGO). During that time, I have led federally funded research programs, managed research awards, mentored graduate students and postdoctoral researchers, and collaborated with scientists across the United States and around the world. I also serve as a member of NASA's LISA Science Team, contributing to the U.S. scientific program for the Laser Interferometer Space Antenna (LISA), a joint mission of the European Space Agency (ESA) and NASA. 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. Over the course of my career, I have seen firsthand how the U.S. system of competitive, peer-reviewed federal research funding has enabled transformative scientific discoveries while providing strong stewardship of taxpayer resources. More than twenty years of NSF support have allowed my research group to contribute to the scientific success of LIGO, develop open computational tools used by the broader scientific community, train undergraduate and graduate students and postdoctoral researchers, and advance fundamental understanding of gravity and the Universe. This record illustrates the extraordinary return on taxpayer investment that a stable, merit-based research enterprise can achieve. While I support efforts to improve the efficiency, transparency, and accountability of federal financial assistance, I am concerned that several aspects of the proposed regulation could unintentionally weaken the principles that have made the U.S. research enterprise so successful. Independent peer review is essential to scientific excellence. Independent expert peer review should remain the primary mechanism for evaluating scientific merit. Modern scientific research is increasingly specialized, and only researchers with the appropriate technical expertise can reliably evaluate the originality, feasibility, and potential impact of complex research proposals. Merit review has enabled federal agencies to identify the most promising scientific opportunities while ensuring responsible stewardship of public funds. Decisions that move away from expert scientific evaluation risk reducing both the quality of funded research and the long-term return on federal investment. Scientific research programs often span many years and support graduate students, postdoctoral scholars, research staff, and shared computational infrastructure. Increased administrative uncertainty or reduced predictability in grant administration can disrupt research, delay student training, and discourage talented early-career scientists from pursuing research careers in the United States. The long-term effects extend far beyond individual awards and ultimately reduce the nation's scientific and technological capacity. Federal investment in basic research has consistently generated discoveries that fuel innovation, economic growth, national security, workforce development, and scientific leadership. I respectfully encourage the Office of Management and Budget to ensure that the final regulation preserves the principles that have made this system successful: rigorous independent peer review, support for responsible international collaboration, transparent and predictable grant administration, and funding decisions based on scientific merit. Training future STEM and leading the world in science relies on reliable funding. Politics has no place in science.