Comment from David Christiani

I am submitting these comments as an individual, senior scientist, at an academic institution. They represent my views and not necessarily those of the university or hospital in which I work. This proposed rule, if enacted, will be a threat to faculty, researchers, employees, and the larger scientific community. It will also threaten the well-being of the American public whose taxpayer dollars fund this work. In many ways, the proposed rule seeks to enshrine in regulation: arbitrary termination of grants, at any time in the life of the grant [200.340]; refusal to fund research that does not align ideologically with the politics of the Executive Branch, including research that discovers and documents disparate impacts and addresses health disparities [200.218; 200.300]; impeding the ability of scientists to travel to conferences and pay the costs for open access publication [200.432; 200.461]; rendering it more difficult to have foreign collaborators [200.220]; and empowering the belief that power, not evidence, should determine which scientific research is deemed worthy of funding. Additionally, the proposed regulations are intended to centralize power in the OMB, in ways that encroach on the agency and judgment of not only federal agencies but even Congress itself, and which would render legal challenge to the OMB’s prerogatives more difficult. This is a recipe for disaster. The rules, if enacted, will be the death knell of scientific and academic progress in the United States, as well as seriously threaten domestic and international collaborations.