Comment from Janet Franklin

I previously made a comments but I want to add to it by addressing sections that I did not address before and that concern me; [Section 200.461 – Publication and printing costs] As a landscape ecologist and geographer, my research depends on publishing results in peer-reviewed journals that are accessible to scientists, natural resource managers, and policymakers. Federal agencies now require immediate public access to federally funded research, and article processing charges have become one of the primary ways researchers meet that requirement. Removing publication costs as an allowable expense while still requiring immediate public access puts researchers in a difficult position. Many investigators, particularly early-career scientists and those at institutions with fewer resources, may find it harder to publish their work in a way that meets federal requirements and reaches the widest possible audience. [Section 200.220 – International collaborations] Many of the environmental problems I study—including biodiversity loss, invasive species, changing disturbance regimes, and other aspects of global change—do not stop at national borders. Progress depends on collaborating with scientists working in other countries and comparing ecological responses across different regions. Broad restrictions on international collaborations would limit opportunities to share data, methods, and expertise, making U.S. research less effective and reducing our ability to address environmental problems that are inherently global. [Section 200.205 – Merit review and political approval] and [Section 200.340 – Termination of awards] Allowing political appointees to override independent peer review and permitting active grants to be terminated because priorities change would make it much more difficult to conduct long-term ecological research. Studies of ecosystem change often require many years of continuous observations before meaningful conclusions can be drawn. Researchers, graduate students, and collaborating agencies commit substantial time and effort to these projects with the expectation that competitively awarded grants will be evaluated on scientific merit and will continue unless there are scientific or financial problems. Greater uncertainty about whether projects can be completed will discourage ambitious long-term research and make it more difficult to train the next generation of scientists. Taken together, these proposed revisions would weaken many of the practices that have made the U.S. research enterprise so successful: independent peer review, long-term investment in research, international collaboration, and broad public access to scientific results. These changes would reduce the return on federal research investments and make it harder for U.S. scientists to remain leaders in addressing environmental challenges that affect our economy, natural resources, and quality of life.