Comment from Eric Wells

[200.205, 200.340] To Whom it May Concern: I am a professor of physics at Augustana University in South Dakota. While we are an undergraduate-focused institution, my research in atomic, molecular, and optical physics has been funded by federal agencies (mostly the National Science Foundation) for more than 20 years. 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. I have been able to maintain a steady stream of modest grant funding for many years because I am producing high quality research outcomes and strong students who have outstanding careers after their education is complete. These students contribute to the workforce and the economy in very positive ways. Building and maintaining a research program at a small school like Augustana in a region that does not have a lot of local research infrastructure takes consistent work. Most research is like this. Stopping and starting, changing direction at the whim of an elected official, or constantly having to chase the next funding category is a good way to make sure that little innovative science will result. Elected officials do have an important role in science policy - specifically they should set very broad priorities that are important for the nation. For example, the nation needs to find ways to manage chronic health conditions, or the nation should have a robust micro-electronics industry. These are goals of the past that were achieved. But the specific path to these results was and still is most efficiently determined by the scientific community, through merit-based peer review. The scientific partnership between government, industry, and higher education that developed after World War II has been very successful. The US has been a world leader in science and technology for many decades. These new rules threaten that model, and it is very doubtful that political appointees, whose vision typically does not go beyond the next election cycle, can manage scientific directions better than peer review and non-partisan civil servants. Science strives on stability, space to innovate, and the free mixture of ideas. Political preference overruling expert peer review will lead to instability and a loss in faith that good ideas and hard work will be rewarded. A mentor once told me that if 50% of your scientific ideas work, you will be fantastically productive. Funding has to understand that productivity will fluctuate. The continuous prospect of political termination of grant awards will discourage the pursuit of innovative, higher risk, ideas. It would be very hard for me to plan a long-term experimental program in the proposed environment. The proposed rules threaten fundamental, basic research in the United States. Peer review is at the heart of this process. Like all scientists I know, I take my duties in reviewing proposals or being on a panel very seriously. It's hard work, but it by far the best way to see that taxpayer money is invested wisely.