Comment from Philip Mote

§ 200.205b The proposed rule implementing pre-issuance review by political appointees paves the way to a substantial weakening of the US scientific enterprise, which is the strongest in the world. Three elements of this proposed rule will weaken US science. First, incorrect assumptions about a proposed project. Research that provides value to the American public to solve a clear and immediate problem, for instance how to reduce the risk of forest fires, is built on decades of research that may not always have a clear application at the time. The steady investment in that foundation is essential to reaping the value when the need arises. Importantly, scientific research needs the freedom to explore untested ideas in order to broaden the knowledge base. By introducing pre-issuance review by political appointees, the proposed rule risks curtailing the ability of the science enterprise to explore untested ideas for a myriad of reasons, including that the person making the determination incorrectly believes that the proposed project is rooted in a disfavored concept simply because they lack the time or scientific knowledge to understand the nuances. Science magazine in June 2025 reported on 3200 grants flagged by the administration in addition to 1700 terminated, many of which on inspection had no obvious link to controversial issues. Second, and related, the nation badly needs to continue research on these controversial issues. The Science article reports that many of the flagged projects dealt with important topics like women’s health, how violence affects impoverished communities, or how wildfire smoke affects children with asthma. This proposed rule could curtail valuable and actionable research with a meaningful possibility to improve people’s lives simply because elements of it are currently out of favor with the ruling party. In fact, this rule could enable a future Democratic president from banning research on issues primarily affecting Republican voters. Third, the requirement that funded research must “demonstrably advance the president’s policy priorities” refashions the scientific enterprise into a political tool for each successive administration rather than serving the best long-term interests of the American people, in direct contradiction to the stated goal of this proposed reform. Even though the previous administration’s priorities in some instances may have affected research topics and conduct in controversial ways, the solution is not more political interference. It is possible to reshape research funding priorities through other means than this rule. The more the research enterprise is hindered by changing political actors, the less effective it will be. Provision (3) under this subcategory favors institutions with lower indirect cost rates (ICRs). ICRs are set through a data-heavy process by federal contracting agencies and reflect the real costs of doing research. Many of the top universities have high ICRs owing to higher real costs (they are in urban areas, they have more expensive lab equipment). Even though my university would benefit from this rule change (it has one of the lowest ICRs), I oppose this rule because ICRs reflect real costs. Provisions (6) and (7) refer to the undefined “gold standard science”. It is vague and should be stricken.