Comment from Abigail Knight

I am a faculty member in the Department of Chemistry at the University of North Carolina at Chapel Hill. I have served as a Principal Investigator since 2018, and currently hold over $4M in active federal and foundation funding as PI across six awards, including grants from NIH, DOE, NSF, and DOD. This funding supports a group of 8 graduate students, 3 postdoctoral researchers, and 3 undergraduates; since 2018 I have trained 7 PhD graduates (whose positions now include faculty at Villanova and scientists at Eastman Chemical and Nanite), 12 undergraduate researchers, and 2 postdoctoral researchers. Science is an inherently collaborative, worldwide pursuit, and several provisions of this proposed rule would undermine that in ways that directly affect my group's work. [200.205] My group has spent years developing fundamental, curiosity-driven separation chemistry, long before critical-mineral recovery and rare earth element separation were named national priorities. That sustained basic-research investment is precisely what now allows us to apply our platform to a current priority area. This pipeline, from fundamental science to applied national impact, only works if grant proposals are evaluated by subject-matter peer reviewers who can assess long-term scientific merit, not solely current administration priorities. Had this rule been in place a decade ago, the foundational work that now positions us to contribute to critical-mineral recovery may never have been funded in the first place, since its eventual relevance wasn't yet apparent. Political appointees evaluating proposals for alignment with current priorities, ahead of technical peer review, would systematically disadvantage exactly this kind of basic research, even though it is what makes future applied breakthroughs possible. [200.340] The expanded authority to terminate or suspend active grants with little explanation is especially concerning for multi-year awards, which funds long-term PhD training; a typical PhD takes 5-6 years, and funding uncertainty mid-training would jeopardize both ongoing science and the careers of the students depending on it. [200.220] Restricting funding for collaboration with foreign entities would directly affect how my group operates. This year, one of my students traveled to Spain to conduct research in a partner lab, and a student from that lab visited ours in turn; I also presented our work at international conferences in Bordeaux and London. These exchanges are how scientific collaborations and shared resources arise in the first place. Broadly worded restrictions risk limiting legitimate, mutually beneficial international scientific exchange. [200.432, 454, 461] Requiring federal pre-approval for conference travel, society memberships, and publication costs would add administrative burden to exactly the activities through which our findings are communicated to the broader scientific community, generating new collaborations and opportunities to share resources and expertise. Slowing or gating this process would slow the pace of scientific progress itself. I urge OMB to reconsider these provisions and preserve a federal grant-making process grounded in technical peer review, funding stability for long-term research and training, and open scientific exchange across institutions and borders.