Comment from Casey O'Hara

I am writing in strong opposition to the proposed changes and additions to the OMB Guidance for Federal Financial Assistance. I am a Project Scientist at the University of California, specializing in marine systems and biodiversity conservation data science. My work for the past four years has been funded 100% through federal grants, with additional federal support during my years as a graduate researcher. The bulk of my work investigates how human influences on the environment, including fisheries, shipping, and climate change, threaten the health and persistence of marine species and ecosystems. Several of the provisions in the proposed changes will directly affect the type of scientific questions I am able to research, the quality of the science I am able to conduct, and the extent to which my science can reach a broader audience to inform policy and management. While my science is based on objective observational data and models, the management implications may have economic consequences for specific interest groups and industries. As such, under proposed changes to [200.202] (as well as potentially other provisions), my research funding may be directly at risk when political appointees, driven less by science and more by the influence of special interests, are granted arbitrary veto power over acceptable topics of study. This is exacerbated by [200.340] which allows for termination of funding dependent upon the discretion of politically motivated appointees rather than qualified scientists. Such political pressure undermines the public trust in American science and obscures the clear impacts of unchecked climate change and human activity on marine ecosystems, which threaten the benefits we gain from well-managed oceans: healthy seafood provision, protection of coastal infrastructure from storm surge and sea level rise, and the economic benefits and livelihoods from sectors including fisheries, shipping, and tourism. As a proponent of open, transparent, reproducible science, I appreciate the stated commitment to Transparency, Accountability, and Oversight in the introductory paragraphs of this proposal. However, the proposed changes to [200.432] and [200.461] stifle scientific communication by raising the administrative burden associated with conference attendance and publication charges in open access peer-reviewed journals. While I am concerned about the effects of these changes on my own career and livelihood, I am more concerned about the broad effects of the proposed changes on Americans and the standing of the United States as the global leader in quality scientific research across all domains. The same provisions that would put political pressure on my own research [200.202, 200.340] and stifle scientific communication [200.432, 200.461] will on a grander scale result in the US ceding our scientific and technological leadership to other nations, particularly to China. This is already evident with solar and wind technologies - having been politically coded for some reason as woke technologies, the US has already ceded leadership in this highly profitable and rapidly developing sector to China. In total, the proposed changes to the OMB Guidance for Federal Financial Assistance will, by accident or design, negatively impact thousands of American scientists in terms of the research they pursue and communicate, reduce trust in American science (directly undermining the stated goals of transparency and accountability), and weaken the United States leadership in the global scientific endeavor. I urge OMB to not finalize this rule.