Comment from Kristen Burson

[200.205, 200.340] To Whom it May Concern: I am an associate professor of physics at Grinnell College. I am developing the next generation of materials for radon mitigation and for improving the safety of nuclear energy production. 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. The peer review process should be conducted by experts in the field of study, without override by political appointees. Science depends on a merit-based allocation process to function effectively. Allocation processes that are political, rather than merit based, are a threat to continued US dominance in scientific research. Such processes lead to brain drain where top scientists seek positions in other countries; this happened in both Hungary and cold-war era East Germany when political tests were implemented for securing scientific funding. These are not the models we want to follow for the safety, security, and scientific dominance of our nation. National priorities for scientific research are already in place through the budget process and should continue to be pursued through that channel rather than through manipulation of a peer review process. Meaningful research results in my field often require multiple years to come to fruition. If active grants could be terminated at any time for political reasons, hours of time, effort, and financial resources will be wasted without product. A bigger threat is for workforce development. I work with many undergraduate students, aspiring scientists who are seeking graduate programs. We have already seen graduate programs cut back on admissions in a more uncertain funding environment. PIs depend on active grants to hire and develop graduate students -- the future of the scientific workforce. Since graduate degrees take ~5 years to complete, stable funding is needed to support graduate student development. Unexpected grant termination mid-grant will curtail the development of a needed US-based scientific workforce. Recent uncertainties in the US funding landscape are already shaping the decision of top US-students to seek graduate degrees abroad. Added uncertainty will exacerbate this reality. The new process will introduce funding uncertainty that impedes innovation and workforce development. It will lead to US brain drain by moving away from a merit-based process evaluated by experts in the field.