Comment from Josiah Heyman

I am a distinguished university professor, identified in the Stanford-Elsevier career citation study as being in the top 2% of my discipline in the world. My recent research addresses the impact of heat in the urban environment. It is vital because heat is one of the worst weather killers in the United States. My research can help target warnings and mitigation measures (such as cool roofs and tree planting programs). I work closely with local governments and neighborhood associations. I currently work on effective tree planting outreach. I have been funded by the National Science Foundation and the U.S. Department of Agriculture, and am currently beginning a grant from the U.S. Forest Service. My research involves advanced scientific methods. This includes both spatial statistics (a very demanding area of statistics) and also face-to-face ethnographic methods. These are directed conversations and observations designed to learn from people themselves about their goals, capabilities, and concepts. Both sets of methods take years of skill-building and experience. The ability to identify and gather trustworthy data and the methods to analyze it to reach scientifically robust and publicly trustworthy conclusions are very special and valuable skills. With reason, we cannot not trust inexperienced and untrained or partially trained political appointees to do a valid review of research proposals and research outcomes reports. Data and methods are central and must be understood by decision-makers. For this reason, Section §200.205 — Political appointee review of grants, puts public well-being (e.g., heat risk mitigation) and scientific production at serious risk. It needs to be removed. Scientific peer review is the gold standard of science for the public good. My work has focused on communities at risk in urban environments (and similar issues are true of rural settings as well). With respect to heat, risk comes from a combination of physical features and social features. My work involves considering the combination of both and making use of our scarce resources to target most effective sites. On the social side, the elements of vulnerability include lower incomes, gender (pregnant women), age (both young children and the elderly), and social factors associated with lower incomes and less robust, older housing (e.g., race). Likewise, my face-to-face work on tree planting and sustainability requires understanding of community social and cultural characteristics. For these reasons, I need to document and analyze phenomena superficially termed DEI, such as race and gender. By doing this I save lives. It should be clear from what I have written that I analyze all scientifically relevant social variables, DEI or not, such as age: I am a good scientist, and I am inclusive. For these reasons, sections §200.300 — DEI and gender ideology prohibitions and §200.218 — Disparate-impact research banning, would cause irrecoverable harm to research which reduces illness, mortality, and suffering, and municipal emergency response and medical care costs. Disparate impact is especially necessary for effective heat mitigation targeting. Finally, and crucially, I work on urban heat in the context of long-term climate change, which increases the chance of heat waves. The topic of climate change is necessary background to my scientific and community work. In the past, I was co-leader of a major regional participatory project on water futures. We produced ways to model and represent the future that a wide variety of stakeholders could understand and consider, from farmers to urbanites. Climate change was a key variable in understanding river drought risks and impacts. For this reason, I express an emphatic recommendation that section §200.202 — Programs must align with administration priorities, must be removed. This also is a reason to express serious concern with Section §200.205 — Political appointee review of grants. I am proud that my scientific work upholds the highest standards, and that it directs my expertise to the well-being of the public (health and local government) and the private sector (my earlier work on climate and water with farmers). The proposal has fundamental and essential flaws, which I have identified in detail. These must be revised at a fundamental level.