13 July 26
A Drop in a Deluge
As I noted last Thursday, the deadline for submitting comments on the proposed Office of Management and Budget regulation that would turn federal funding into an ungodly system of patronage and at the same time devastate American science is this evening. This surely breaks the record for the most public comments on a proposed federal regulation — as of 11:59 PM last night 292,157 comments have been received. A text analysis of about 51,000 comments that were posted by July 9th indicates that 94% of the comments oppose the regulation. Of the 6% of comments in support of the regulation, they were almost all from a single form letter copy-and-paste campaign.
I am posting the public comment that I submitted below. My comment emphasizes the harms to science because that is where my expertise lies, but this regulation would basically codify a system of federalism by extortion, to use language cited in an excellent piece posted today.
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I am a retired geographer and environmental informatics specialist who over the course of a 34-year university career has received funding from many federal agencies including NSF, USDA, USFS, USGS, EPA, and USFWS. I am also a second-generation scientist. Both my parents were scientists, and I grew up deeply appreciating the massive postwar investment in scientific research that made the United States the leading power in science. All Americans have been beneficiaries of this investment and our country’s commitment to open research.
I strongly oppose the proposed rule change published as OMB-2026-0034 and urge that OMB withdraw it in its entirety. Its impacts to American science would be devastating. I will comment on some of these impacts below section-by-section.
Section 200.205 (b) would mandate pre-issuance approval of grant funding by a senior political appointee. Such political control over its direction is antithetical to the progress of science. Many comments to this proposed rule mention the case of Lysenkoism in the Soviet Union. Such a comparison is apt. Trofim Lysenko was a charlatan agronomist who curried favor with Josef Stalin and destroyed genetics as a science in the Soviet Union. Lysenko’s theories led to crop failures, and to this day Russia and the post-Soviet successor states lag behind in research in related fields like molecular biology.
Section 200.205 also states that activities under Federal awards should comply with administrative guidance respecting “Gold Standard Science”. This phrase is not defined anywhere in the proposed rule. It would be surprising if it could be defined — many decades of scholarship in the history and philosophy of science has shown that there is no one overriding methodology by which science can progress. The phrase “Gold Standard Science” is likely intended as a cudgel by which political appointees can squash research on topics that are uncomfortable for them.
Section 200.340 (a)(2) allows a federal agency to terminate a grant at any point due to arbitrary reasons. This is remarkably poor governance and is a violation of the public trust. People and institutions make serious commitments on the basis of funding agreements, especially multiyear ones, and it is a waste of public investment to halt these prematurely. I have personal experience here: in April 2025 the US Department of Agriculture ended the Partnership for Climate-Smart Commodities program which was about two years into its five-year funding cycle, the agency not wanting to continue a Biden-era program. Thousands of enrolled farmers lost funding under this termination. I was an academic partner on one of these grants, and the resultant halt in funding essentially ended my university career.
Section 200.340 (e) allows a federal agency to temporarily suspend a federal award for a period of up to 90 days. In funding-constrained environments like almost every university, a 90-day cessation of funding of an already-awarded grant will cause layoffs to occur. Some of the afflicted individuals end up leaving their field, an enormous waste of training, talent, and educational investment.
The “domestic-first” framework of Section 200.202 will strongly discourage foreign collaborations. But science is a global endeavor, and isolating the United States in such a manner will only serve to greatly weaken the country in science.
Section 200.461 would make all journal publication costs unallowable by default. Publication of one’s research findings is core to the scientific research process, and failing to pay for journal publication costs hurts American scientists and weakens American science as a whole.
Section 200.432 requires that conference travel be pre-approved and written into an award at the time of grant application. But research is a process of discovery, and a scientist may want to present their findings at conferences they did not anticipate when they applied for the grant. This requirement hinders scientific communication.
The proposed changes will be remarkably deleterious to the American scientific enterprise. American science has been an engine of our country’s prosperity in the postwar period, and such changes will make our country poorer, more isolated, and a more backwards place.
The added administrative burden of complying with this rule go way beyond science. It will be harmful to a huge range of entities including schools, universities, non-profit organizations, small businesses, and state, local, and tribal governments.
The scope of changes in this proposed rule is massive and will have many unintended consequences. There are too many interactions between the various pieces of the rule that will lead to harms that no one will be in a position to understand in their entirety, let alone correct. For a rule that claims to increase transparency, accountability, and oversight it will fail at all three of those goals. I strongly urge that the proposed rule be rejected outright.
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