Comment from Taylor Rubin

[200.205, 200.340] To the Office of Management and Budget: I am writing to comment on the proposed revisions to 2 CFR Part 200, specifically § 200.205 and § 200.340, as a PhD student in biology at the City University of New York (CUNY) Graduate Center and Queens College, where my federally-relevant research examines how urban scavengers influence disease dynamics through their interactions with human food waste. I offer these comments based on firsthand experience running an interdisciplinary, multi-year, community-embedded research program that depends on the very structures this rule would weaken. § 200.205 — Politicized pre-issuance review undermines the merit review process researchers rely on My path to this research was built entirely on competitive, peer-reviewed opportunities: an NSF Research Experience for Undergraduates award that gave me my first research training in 2007, a master's degree in neuroscience and animal behavior, and now a doctoral program whose funding depends on proposals being judged on scientific merit. The proposed § 200.205 would insert a senior political appointee into that process, with authority to override or bypass peer-review recommendations — which the rule's own language would render "advisory only" — based on whether a proposal "demonstrably advances the President's policy priorities." My research is deliberately transdisciplinary, integrating ecology, epidemiology, molecular biology, and sociology, and it depends on partnerships that could easily be read as falling outside a narrow definition of "priority" work: an epidemiologist at the CUNY School of Public Health, a disease ecologist and soil scientist at the Cary Institute for Ecosystem Studies, and international colleagues through the Comparative Urban Ecology Research Training group. If political alignment rather than scientific merit becomes the deciding factor in whether awards are issued, work like mine — and, more broadly, entire fields of interdisciplinary and international science — becomes vulnerable not because it lacks rigor, but because it does not fit a political litmus test. Researchers cannot design multi-year studies, recruit students, or commit community partners to a project if funding decisions can be reshaped by criteria unrelated to scientific quality. § 200.340 — Discretionary termination and suspension authority destabilizes long-term, community-based research My current research is not a lab-bench project that can pause and resume without cost. It involves camera deployments and biological sampling across 12 New York City public schools, coordination with the NYC Department of Health and Mental Hygiene and the NYC Department of Education's Office of Environmental Sustainability, partnerships with local pest-control companies for sample collection, and a year-long, student-led research mentorship through the New York Academy of Sciences' Scientist-in-Residence program, in which I currently guide an eighth-grade class through their own research project. These relationships take years to build and depend on consistency: schools, city agencies, and community partners need confidence that a research program will still be there next semester. The proposed § 200.340 would allow an agency to terminate an award, in whole or in part, whenever it determines the award "does not effectuate program goals, Federal agency priorities, or the national interest as they exist at the time of termination" — a standard that can shift year to year, or administration to administration, without any relationship to the quality or progress of the research itself. The companion 90-day discretionary suspension authority compounds this: a sudden stop-work order, unaccompanied by a requirement to state a reason tied to program performance, could halt fieldwork mid-season, break commitments made to partner schools and city agencies, and interrupt the mentorship of students and early-career researchers who are relying on a stable, multi-year project. For research programs like mine that are built on sustained trust with municipal agencies, schools, and community members, this kind of instability is not a manageable administrative risk — it is a threat to the research model itself. I would also note that my academic collaborations include international colleagues, and that restrictions on international collaboration under this and related provisions would have a direct, negative impact on current and future partnerships that are central to my field's ability to study cross-border phenomena like disease transmission. Thank you for the opportunity to comment. I would be glad to provide further detail on how these provisions would affect ongoing, federally-relevant urban and disease ecology research.