Comment from G. Philip Robertson

RE: Section 200.340 (Termination and Suspension) I am a university scientist with 45 years of continuous federal support via competitive grants programs at NSF, USDA, and the Dept. of Energy. I conduct fundamental work in agricultural ecosystems related to their productivity, resilience, and environmental outcomes. My work is relevant to the growth and economic health of agriculture in the US and to the livelihoods of agricultural producers and their families. My work is further relevant to those who are affected by agricultural pollutants – whether nitrate in groundwater that makes its way to the Gulf of Mexico or nitrogen trace gases that impact atmospheric chemistry and thence weather instability. I have served on dozens of merit review panels for NSF, DOE, and USDA and peer-reviewed countless proposals in the past 45 years and have served as editor and peer reviewer for major agricultural and environmental journals. I am a member of the US National Academy of Sciences. Section 200.340, which provides funding agency authority to terminate awards without cause, would have an unnecessarily disruptive impact on fundamental research in the US. Without the certainty of a clearly defined and honored grant award period it will be difficult for funded researchers to recruit the best students and postdocs to their research labs – what graduate student would want to start a 6 year career with funding that could be pulled at the whim of a federal grants bureaucrat? The best students will gravitate towards careers with greater economic security, and likewise, postdocs will pass up the opportunity to spend time working a project funded by a grant that could be yanked at any time for any reason. Science in academia and industry requires funding that is stable for at least a few years in order to justify the substantial time, energy, and creative resources that go into making research projects work. That go into producing peer-reviewed publications that power the advance of knowledge and eventually the economic engine of the U.S. Why would you want to risk the current and historical success of the US science enterprise by providing grant administrators the power to terminate or suspend grant awards with little or no credible justification? Please reconsider this rule proposal and reject it. Respectfully yours, G. Philip Robertson University Distinguished Professor Michigan State University East Lansing, MI 48824