Comment from Janet Franklin

**[Section 200.204 – Merit review and approval of awards]** I am a landscape ecologist and geographer whose research relies on competitive federal funding to understand how ecosystems respond to global change and environmental management. I am concerned that requiring political approval of discretionary research awards weakens the long-established system of independent peer review that has been the foundation of federally funded research. Scientific merit, rather than changing political priorities, should remain the primary basis for funding decisions. **[Section 200.340 – Termination of awards]** Much of my research depends on long-term ecological datasets that require continuous observations over many years. Allowing grants to be terminated because they no longer align with changing agency priorities would jeopardize studies that cannot simply be restarted or recreated once interrupted. Long-term ecological observations are essential for understanding ecosystem responses to global change, evaluating the effectiveness of restoration and conservation efforts, and informing natural resource management. The loss of these data would diminish the value of prior federal investments and reduce the scientific foundation available to resource managers and policymakers. **[Sections 200.456 and 200.472 – Conference travel and publication costs]** Scientific conferences and peer-reviewed publications are essential for communicating research results, receiving critical feedback, establishing collaborations, and training the next generation of scientists. Requiring case-by-case agency approval for conference participation or publication costs would create unnecessary administrative burdens, slow the dissemination of scientific findings, and reduce collaboration across institutions and disciplines. For these reasons, I urge OMB to substantially revise these provisions. The United States has built one of the world's strongest scientific enterprises through stable federal investment, rigorous independent peer review, long-term research programs, and the open exchange of scientific ideas. These policies have made the U.S. a global leader in scientific discovery and innovation for decades while generating substantial economic returns through new technologies, improved resource management, and a highly trained scientific workforce. The proposed changes would weaken these foundations by introducing political considerations into scientific funding decisions, increasing uncertainty for long-term research, and creating barriers to scientific collaboration and communication. Once long-term research programs, collaborations, and scientific capacity are disrupted, they cannot be quickly or easily rebuilt. Weakening the nation's research enterprise risks reducing U.S. scientific leadership and competitiveness at a time when other countries are making substantial investments in research and innovation. The long-term costs would extend beyond the scientific community to the nation's economy, natural resource management, and our ability to respond effectively to future environmental challenges.