Comment from Philip Mote

§ 200.206 The risk assessment (items (2) i-vii are sensible. The (iv) history of performance would have precluded several entities that received awards from this administration, for example, under the FIPSE grant from the Department of Education to new would-be accreditors. Provision viii looks innocuous but the determination of what sorts of organizations pose a risk to e.g. public safety or national security is worrisomely vague and could in the future be used broadly to penalize universities whose faculty belong to a variety of organizations. § 200.220 International collaboration greatly strengthens American science in service to the American public. Safeguards are currently in place to prevent certain countries from inappropriately benefiting from US research. The proposed rule vastly increases the restrictions on collaboration and would harm US science competitiveness. §200.340 Terminating grants midstream runs directly counter to Objective 3 of this reform, as we have seen in innumerable cases over the last year, by greatly increasing the non-research effort that grant recipients must make to deal with the consequences of unexpected terminations. Stopping and starting research is very inefficient. §200.432 This provision could greatly hamper the free and productive exchange of scientific ideas. When I write a grant proposal for a 3 or 5 year project and include in the budget some funds for conference attendance, I need the flexibility to determine which conference or workshop is most valuable for the advancement of the project. While some large annual conferences are highly predictable as to value and even location several years out (e.g. the American Geophysical Union annual meeting), often a smaller topical conference is more valuable but typically is only announced 6-12 months in advance and therefore cannot be included in a proposal under this rule. Requiring proposers to specify in advance which conferences they would attend is unworkable and a needless burden.