Comment from Rebecca Asch

[200.205, 200.340] To Whom it May Concern: I am an associate professor at a state university who works in the field of biological oceanography. I have served as a principal investigator, co-investigator, or senior personnel on approximately 10 federally funded grants over the last 9 years. 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. I'm concerned that this provision will reduce the competitiveness of US science. Political appointees will not necessarily understand or be well informed about which scientific proposals are most relevant to address or what is practical implement. This will result in less efficient science funding, making our country less competitive in this realm. Also, this is likely to lead to whiplash with priorities changing across different presidential administrations. Most federal grant programs do not have timelines that are well aligned with presidential terms increasing this whiplash effect. Since thousands of graduate students, undergraduate students, postdocs, and staff in my state are funded by grants, this could also affect employment and educational opportunities, as well. Termination of grants midway through a project is also potentially very wasteful for federal funds. Projects stopped midway through are sunk costs that cannot be recouped, and the results will make research useful may not be ready at the time when a project is terminated. As mentioned previously, this will reduce employment opportunities and student educational experiences in many communities in the US. Often times it is impossible or very difficult to restart projects due to loss of personnel, so again this can contribute to whiplash between different political administrations.