Comment from Sophia LaRochelle

I am a researcher at Michigan State University, and I see many of the proposed rules as damaging the powerful US research engine in profound ways. The US government has for decades made major investments to build its capacity for research and development nation-wide, and the entire country has benefited in ways that are hard to overstate, from military to medical advancements, food security, and countless technological advancements where we lead the world. Throwing away our status as world leaders in research would be a huge mistake which would not only undermine decades of investment but would also ultimately weaken the US in a myriad of ways from food security to medical advancements. I am alarmed by the effects and implications of the majority of the proposed rules but will address and highlight rules about peer-review of grants, termination of grants, international collaboration, and publication fees as particularly concerning. Rules 200.205 and 200.205(d) that undermine the merit-based, peer-review grant award process will stifle US innovation. Other scientists are not partisan - they are experts – they have the specific expertise necessary to evaluate the merit of proposed work. No single person could possibly assess the value of all grants offered to even a single agency, yet this is what the changes would instate. Furthermore, the benefits of many grants are always obvious from the outset. Indeed, many of the most beneficial and useful scientific innovations, like insulin and the internet, were made possible by curiosity driven research which rule 200.205(b) has the capacity to critically underestimate. Rule 200.340, on the termination of grants at any time will have a harrowing impact on all types of research. It is important to recognize that this would not only harm researchers and research programs that the current administration does not agree with but instead has a far-reaching disturbing effect. Researchers’ certainly that awarded funding will be available for the entire grand period is fundamental and central to high-quality and innovative research. This uncertainty will result in huge waste of federal resources by spending money on projects that are ultimately prevented from producing any useable products or outputs. For myself, rules 200.205(d) and 200.340 could have canceled a federal grant program I participated in – RaMP STEGG-INTERACT (Research and Mentoring for Post-Baccalaureates (RaMP) Program in Biology and Biochemistry, The Southeast Texas Evolutionary Genetics and Genomics Integrative Research and Collaborative Training (STEGG-INTERACT)) which was funded by the NSF. This grant was fundamental in my development as a researcher and enabled my application to graduate school where I am currently a PhD student. The rules that undermine US researchers’ ability to collaborate with the best of the best globally will have enormous impacts on the quality of US research. Particularly rules 200.202(e) on ‘domestic first’ policy and 200.303 on verification with DHS will prevent US researchers from working with the best collaborators and hiring the best candidates to work in their labs on federally funded projects. My own field, the study of plant viruses, highlights the importance of international collaboration - communication and collaborative projects are essential in our understanding of plant viruses as they occur and travel the world globally irrespective of borders. In such cases international projects and participation are essential in our research - which rule 200.202 critically undercuts. Rule 200.461 which would prevent the use of federal funds to cover publication not only conflicts with the 20022 rule requiring open access – but also critically impacts researchers’ journal selection. Covering publication fees of all kinds is the best way to ensure that this publicly funded research has the most impact possible. High publication fees can cause researchers to choose less-well known journals for their work because it is cheaper to publish - even if their work is high quality and impactful enough to make the “big name” journals which while more expensive, can reach broader audiences. Without federal funding to cover publication cost how can US researchers’ hope to be competitive, communicate our research, and lead on the global stage? Many of these rules - if enacted - damage decades of investment in US publicly funded research which has made the US research engine the most powerful in the world. While these changes may not become apparent overnight - they will ultimately translate into a reduction of medical advances, loss of our prowess as a producer of consumer military technology, damage to agricultural security and disaster prevention and relief, and ultimately reduce US citizens’ quality of life.