Comment from Brenna Long

I am a graduate student in infectious disease ecology at Illinois State University. My research, which improves our understanding of how threatened pollinators are affected by disease, is partially funded through grants with NIH and the USFWS. Several provisions in this proposed rule are concerning, beginning with section 200.205, which establishes that grant reviews will align with Executive Order 14332, a partisan order which undermines the value of and politicizes scientific research. Furthermore, this section will grant review power to political appointees, who will lack the relevant and field-specific knowledge necessary for grant review. This is an intentional attack on the freedom and independence of science from political intervention. The President’s policy priorities are not what is best for science. Further, §200.454 and §200.461 disallow the use of federal funds from being put towards journal subscriptions and publishing, which interferes with the ability of scientists to communicate with each other and the public. The most important part of scientific research is communication of results, and is crucial for scientific advancement. Making publications open-access, or readable for anyone, is an expense which improves accessibility and strengthens the scientific community. Though I don’t participate in human research, I’m also extremely concerned by Section 200.218 which states that no federally funded research can suggest theories or hypotheses that personal characteristics including race, sex, or age can adversely impact one group over another. I can not overstate how limiting this is, particularly in medical research. It is well known that risk for certain diseases increases with age or environmental factors, and that risk for certain cancers can increase with genetics and race. Limiting what medical researchers can and can’t say will only hurt American citizens. This proposed rule contains other concerning sections which allow the cancellation of federal grants for any reason and at any point (§200.340), prohibit collaboration with foreign researchers (§200.220), and prevent fair competition for grant awards (§200.204), among other frightening notions. Personally, this rule will hurt my chances, and the chances of others in conservation biology and environmental research, of receiving funding because it’s not a priority of the current president. It will prevent me and my peers from communicating the results of our research at conferences and in journals, which will hurt our job prospects after graduation and careers over time. At a larger scale, reduction in environmental research and science communication will harm the environment and the futures of American children. Further, the proposed rule will harm the scientific community in America and reduce our competitiveness globally. Therefore, I urge OMB not to finalize this rule.