Comment from Ian Billinge

Ian BillingeOpposeAcademic
Summary: Ian Billinge, a postdoctoral researcher at Yale University, opposes the proposed rule changes because they would stifle innovation, isolate American scientists from international collaboration, and allow political appointees to make scientific funding decisions. He argues that the changes would lead to wasted federal funds on politically appealing but scientifically unsound projects.
The Office of Management and Budget ,To the Office of Management and Budget:I am a postdoctoral researcher at Yale University. I study water treatment -- specifically, how to turn wastewater into the ultrapure water used in advanced manufacturing. Ultrapure water is key to pharmaceutical, semiconductor, and aerospace manufacturing.The recent proposed rule changes to scientific research, particularly §200.202, §200.205, §200.220, and §200.340, will have strong, adverse impacts on America that will last for decades. America is currently the world leader in scientific research, a position that was gained through governmental funding of scientific research of all kinds. Federally-funded scientific research has led to the development of many products that make America a leading world economy -- the iPhone, ChatGPT, Tesla cars, Ozempic, and much more rest on this funding. The recent proposed rule changes would stifle innovation and lead to severe long-term economic consequences. Proposed rule §200.202 and §200.220 call for a domestic-first framework for scientific collaboration. Isolating American scientists from international counterparts will mean that the international scientific community will move past the US, and American scientists and engineers will not have the opportunity to work on cutting-edge research with international colleagues. The research that I work on, which will help rebuild the American semiconductor industry, would not be allowed under this rule, since my funding comes from the South Korean government (who also has an interest in developing semiconductor manufacturing). Proposed rules §200.205 and §200.340 put politics into science by allowing a politically-appointed overseer to allocate funding (instead of scientific experts, as is the case now) and allow the immediate termination of federal research grants on political grounds. With respect, science is best done by scientists. The topics that should be researched are best understood by subject matter experts, not by administration officials. The breadth of science is huge -- and differences between promising science and research dead ends are subtle. If this rule is enacted, much federal money will be wasted on projects that are flashy and politically appealing but scientifically bogus. And much research that would bear fruit for the United States in the fullness of time will be ignored since it is not immediately politically relevant.I also oppose proposed rule §200.300 on the same grounds as §200.205 and §200.340 -- it restricts what can be studied on political grounds.In short, I urge you to reject these proposed rule changes, for the good of the United States. Entangling politics with science leads to bad outcomes. It has ever been so -- the Soviet scientist Trofim Lysenko proposed a false but politically appealing system of biology that led to catastrophic agricultural policies that killed many thousands of people. I do not want to see the United States become like the Soviet Union, where the demands of politics determine scientific outcomes.Yours very sincerely,Ian Billinge, PhDIanConnecticut

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