Comment from Name Withheld

[200.205, 200.340] To Whom it May Concern: I am a professor in that studies the immune system working on new therapies for cancer and autoimmunity. I am writing in my personal capacity to oppose the proposed revisions to sections 200.205 and 200.340 that would undermine the integrity of federal grant review processes and federal science agencies' ability to identify and fund impactful research. Grants are currently primarily on merit after review by peer scientists. While granting agencies have been able to overrule this in some cases, this has never been the explicit design. Having political appointees decide on whether a grant should be funded or not undermines *the entire basis* of scientific investigation that leads to advances. Merit-based funding of science is what has led the United States to greatness in innovation and advancement - you would be very hard pressed to find a biomedical advance that has *not* been developed in the United States. Putting a political appointee in charge of awards risks this entire system. On what basis should a non-expert make a final decision about an award? This has actually been tried in other countries - the Soviet Union did this, and look where they went... There is a follow on consequence that has not been considered. Peer review is a *major* amount of work. Reviewers are not compensated and devote their time freely. The entire system depends on reviewers believing their hard work will shape the future by judging the merit of a proposal. Why would anyone commit to being a peer reviewer if some political appointee is just going to override their judgement by the whims of the current political climate? Overall, this is a terrible idea that would undercut the entire system of advancement and innovation that has led to American greatness. Scientific advancement takes time, diligence, and commitment. It's not rapid fire. If a project is cut short, that investment is lost. Moreover, jobs would be lost. Building a research enterprise requires staff who need some degree of stability. Why would anyone take a job as a grant-funded technician if they knew the position could be eliminated at any time due to some political appointee's whim? Scientific advancement takes a commitment to merit and time. This would undercut it, reduce America's current standing, drastically reduce the likelihood of future advancements, and lead to the loss of jobs and future development. An agency can *always* decide not to fund a particular area by simply not accepting proposals in that area. Lastly other countries - China for example - are ramping up advancements in science and technology. This whole proposal is a gift to them.