Comment from Taylor Rubin

[200.202(e), 200.220] To the Office of Management and Budget: I am writing to comment on the proposed revisions to 2 CFR Part 200, specifically § 200.202(e) and § 200.220, as a PhD student in biology at the City University of New York (CUNY) Graduate Center and Queens College, where my research examines how urban scavengers influence disease dynamics through their interactions with human food waste. I offer these comments as a researcher whose work is, by design, international in scope, and whose scientific training and current collaborations would be directly affected by these provisions. § 200.202(e) — A domestic-first framework does not reflect how urban and disease ecology research actually works My research is deliberately transdisciplinary and interdisciplinary, integrating ecology, epidemiology, molecular biology, and sociology, and it depends on partnership with international colleagues. I collaborate through the Comparative Urban Ecology Research Training group, which brings together scholars specializing in social network analysis and urban ecology from multiple countries, because disease transmission and urban wildlife dynamics are not phenomena that respect national borders. Earlier in my career, my year as a research assistant in Puerto Iguazú, Argentina, and my subsequent volunteer work with VulPro, a South African vulture conservation organization, taught me directly that some of the most consequential conservation and public-health problems can only be understood and addressed through sustained international partnership — in that case, coordinating a conservation strategy during a crisis that depended on collaboration among the South African government, the international conservation community, and the Association of Zoos and Aquariums. The proposed § 200.202(e) would require that research and development awards go to U.S., state, or tribal entities, with any international element permitted only where a federal agency affirmatively determines it is justified, consistent with program objectives, and in the national interest — a determination that, under the broader proposed rule, could rest with a senior political appointee rather than a scientific reviewer. In practice, this shifts the burden onto every researcher with an international collaborator to build an administrative case for a partnership's legitimacy, on top of the scientific case already made through peer review. For an early-career researcher, this adds real risk and uncertainty to exactly the kind of cross-border collaboration that produces better science, particularly in fields like disease ecology where the phenomena under study move across borders regardless of where the funding originates. § 200.220 — Broadly defined "covered foreign collaborations" risk sweeping in legitimate scientific partnerships I understand and do not dispute the government's interest in preventing federal research funds from supporting collaboration with entities that pose genuine national security risks. But the proposed § 200.220 defines "covered foreign countries" and "covered foreign entities" broadly — by reference to shifting designations as a foreign adversary, a country of particular concern, or a country subject to sanctions — and applies the prohibition not only to direct programmatic funds but to indirect costs and any allocable share of federal support, regardless of whether the collaboration involves any sensitive technology, data, or dual-use research at all. As written, this provision does not distinguish between a partnership that raises legitimate security concerns and one that is, for example, a public-health data-sharing collaboration or a conservation partnership like the one I supported with VulPro. Restrictions on international collaboration will have a direct, negative impact on my current and future research partners, most of whom are not engaged in any activity implicating national security, but whose countries or institutions could plausibly fall within a broadly worded designation. Researchers cannot always predict, at the proposal stage, which countries or institutions might later be designated as covered, which makes long-term partnerships difficult to plan around and discourages exactly the kind of open, collaborative science that strengthens the credibility and reach of U.S.-funded research. Thank you for the opportunity to comment. I would be glad to provide further detail on how these provisions would affect ongoing, internationally collaborative research in ecology and public health.