Comment from Catie Ball

The Office of Management and Budget ,I recently received my PhD in astronomy, and am gravely concerned about how the proposed regulations will hurt the productivity and competitiveness of scientific research in the US. Astronomical research requires significant, long-term investment in flagship projects. The success of projects like the Hubble Space Telescope, James Webb Space Telescope, and the Atacama Large Millimeter Array allow the US to be a world leader in astronomical research. The development of these observatories required decades of stable investment into technological development as well as consensus within the astronomical community about how to design observatories so that they have the greatest scientific yield. Sections [200.205] and [200.340] insert political decision making into grant funding, which will upend the processes that have allowed US astronomical research to be stable, ambitious, and world-leading for decades. For decades, the US has positioned itself as a leader in the field BECAUSE it was able to put scientific priorities before politics -- these rules upend that, and threaten the collaborative and cooperative nature of our science and how it is funded.Sections [200.202] and [200.220] are also seriously worrying. Many of the leading observatories, which are funded in part by NASA and the NSF, require significant international collaboration to run. A few particularly egregious examples: the Event Horizon Telescope, which is world-renown for its unique ability to image black holes, can only do its science by collaborating with observatories located in other countries. This is a physical restriction -- the telescopes need to be a certain distance apart in order to create adequately detailed images. Similarly, having gravitational wave detectors outside of the US is necessary to increase their precision beyond previous generations. Cutting-edge millimeter/submillimeter telescopes need to be placed in locations that have very little water in the air -- there are an extremely small number of these places, and most are not in the US. These experiments have been designed carefully, collaboratively, and with the understanding that the US wants to be a world leader in this science. If rules like [200.202] and [200.220] are finalized, it will restrict the science that US scientists are able to participate in. This will, in effect, limit the scope of what we can learn about our universe on the basis of vague "policy priorities" and broad references to "the national interest". It is a step backwards and a step away from the US's history and reputation as a world leader in this science. I urge the OMB to withdraw this proposed rule. [ ]