Comment from Rebecca Asch

[200.432, 200.454, 200.461, 200.206, 200.450] To Whom it May Concern: I'm an associate professor at a state university who studies biological oceanography. In my nine years in this position, I have led or collaborated on approximately 10 federal grants. I am writing in my personal capacity to oppose the proposed revisions to sections 200.432, 200.454, 200.461, 200.206, and 200.450 that would restrict typical professional expenses, curtail the communication of scientific results, and place excessive scrutiny on the activities of scientists. Professional society membership helps inform researchers of opportunities and helps them form collaborations with other scientists. Many of the collaboratory relationships formed early in one's career can persist helping to shape the trajectory of science careers. Scientific conferences alert researchers to the most recent developments in their field, often a year or more before research is published. Presenting early stage research at a conference increases its robustness because you can learn about concerns or weaknesses of a project while it is underway and make adjustments in a timely manner. Attending scientific conferences also helps establish new collaborations that can lead to new research ideas. Conferences are typically announced one year in advance but grants typically last 2-5 years depending on the grant program. As a result, it is hard to anticipate in advance what is the most relevant conference for presenting your research at the time of writing a grant. Having access to the complete scientific record is essential for the competitiveness of American scientists. Without this, people are likely to duplicate existing studies sinking time, money, and effort. I typically publish 1-5 papers/year. Publications are a key currency in my field. Scientists that do not publish regularly are unlikely to be competitive for jobs. Also, publication is important for disseminating research results that can have societally important implications.