Comment from Anonymous
Anonymous AnonymousOpposeAcademic
Summary: A PhD student at Boston University opposes the proposed rule, arguing that it would destabilize research funding, restrict access to scientific journals, and hinder environmental health and medicinal research. The commenter requests that the OMB withdraw the provision to protect scientific progress.
I am a PhD student at Boston University that has been funded by both training and research grants. Many sections of this proposed rule would be extremely detrimental to the graduate student experience and advancement of research, both short- and long-term.
Section 200.340 opens the door to rapid destabilization of funding, which could lead to graduate students being removed from their programs at any time in their PhD, leading to a shortage of trained scientists. This would also lead to wasted money in the long term due to the time and research completed before termination that has to immediately be paused. Sections 200.454 and 200.461 preventing the use of funds for journal subscriptions and publications interrupts the important flow of peer-reviewed research and communication between scientists. Without access to journals and publishing, scientists will not be able to effectively synthesize information, propose new research, and share the impacts of their research with the broader scientific community. Section 200.218 would decimate environmental health research, as exposure assessment by definition requires an understanding of how demographic details affect how individuals come into contact with toxic chemicals. This would also drive medicinal research back decades by undermining important research aiming to understand how treatment options affect patients differently.
In the interest of scientific progress, OMB must withdraw this provision.