Comment from Josiah Heyman

I am a researcher in human impacts of environmental hazards. I am a tenured professor at an R1 university, involved in grants worth over $8 million across my career. These include (among others) NSF, USDA, NIH, NOAA, and US Forest Service. My research has been useful to municipal government. Here, I comment on §200.205 — Political appointee review of grants. This step will consume substantial periods of time, especially for long applications (e.g., 15 pp single spaced for each application or potential award) and for competitions with many applications (as many as 50 or more). A serious review will take hours per application. AI skimming of vocabulary to save time will make many mistakes, including fatal misunderstandings. There may be lengthy and laborious discussions with the applicant, and requests for revision or clarification. Time delays are money costs—significant ones. Good researchers (PhD or MD) cost $75/hour or more. Research scientists on staff cost $50/hour or more; graduate students, $17.50. Time on review thus has a high opportunity cost, both the time of the reviewer and the applicant. This is real paid expense. It also is time not dedicated to other valuable tasks, such as other research or teaching. It is made worse if time is wasted by erroneous evaluations and queries by non-expert political appointees or by clumsy, shotgun use of AI. Even expert scientific agency review or peer review takes long periods of time; non-expert review or misused AI will add greatly to the time cost. Non-scientific time cost is a waste of taxpayer dollars, as well as an unnecessary source of scientific error. It will slow scientific progress, damaging the public good (time spent on bureaucracy is a very underestimated impediment to science). Bureaucracy to ensure regulation and accountability is unavoidable but avoiding bureaucratic inefficiency is vital to making good science move effectively and efficiently forward. Section §200.205 needs to be removed.