Comments on Proposed OMB Uniform Grant Regulations

On May 29th the Trump Administration Office of Management and Budget (OMB) published the text of a new Uniform Grants Regulation that will fundamentally change the way federal financial grant applications are reviewed and awarded by over 30 federal agencies. These include the National Science Foundation, which provides grants to cover the research of nearly every graduate student in the physical sciences; the National Institute of Health, which funds much of the nation’s leading edge medical research; the national laboratories such as Los Alamos, which develop advanced technologies which help give the USA its global technological advantage; and agencies such as DARPA, DOE, NOAA, EPA, USGS, and many others,which provide grants for military innovation, environmental, climate, strategic minerals, naturalhazard and other research that is critical to the nation’s health and prosperity.

The proposed OMB rules are justified to “improve oversight of federal grantmaking”, and are designed to strengthen “transparency, accountability and oversight while reducing certain administrative burdens”.All future grant applications and discretionary awards must be reviewed by senior federal agency department heads who are political appointees. This is to ensure that federal awards have clear goals that are aligned with presidential policy and priorities. Peer review by scientific specialty experts no longer applies as the leading determinant in making an award to a grant applicant.The justification for the elimination of peer review is that it will make the grant process “more efficient”.Scientists working on research that is not deemed in “the national interest” need not apply.Any proposals regarding diversity, equity and inclusion, or gender studies will not be eligible for federal grants. The government will no longer cover the expenses of researchers to attend scientific meetings, pay for subscriptions to scientific journals, or pay research paper publication fees.

As a past president of the American Geoscience Institute, the federation that represents 60 earth science professional societies of every discipline with a combined membership of over 250,000; as a former national secretary of the then 35,000 member American Association of Petroleum Geologists (AAPG), and former president of the AAPG Division of Professional Affairs; and as a former board member of the Council of Scientific Society Presidents (CSSP), an organization which at one time represented over one million scientists and educators in the physical sciences, I feel professionally obligated to comment on the scientific grant regulations proposed by the Office of Management and Budget. The regulations as proposed by the OMB will destroy America’s competitive advantage in global science, engineering and medicine.

The focus and direction of applied and theoretical science must not be mandated by current political policy. A technology that is considered a “priority” today, may be obsolete in a decade. Conversely, topics considered “not in the national interest” today, might develop into a leading “must have” technology in the future. Where would we be today if some political commissar had decided that federal sponsorship of early research into, for example, computer chips, recombinant DNA, GPS, or horizontal drilling and oilfield fracking was a “waste of time”? Peer review by subject experts assures that grant awards have scientific merit. Grant review, approval or rejection by political appointees is only “efficient” in the sense that the officials can quickly determine if the proposal is in the current “national interest” as defined by the president. Such political analysis does not assess the scientific merit of the proposal, nor how it might complement and benefit other research.Peer review also assures that the scientific studies supported by the awards, and the published results, are sound and reproducible.

The Trump Administration has made every effort to eliminate “climate change” as a national priority. If political appointees are put in charge of grant application review, most climate and related environmental studies will likely be rejected as “not in the national interest. The Trump administration’s description of climate change as a “hoax” and its efforts to end climate research by the nation’s scientific agencies is a national tragedy. OMB’s proposals will likely eliminate or severely reduce grants for climate research and will leave the country unprepared to deal with the ecological, financial, social, and geopolitical impacts of global warming.

The OMB prohibition of expense payments at professional society meetings is incredibly short-sighted.Attendance at scientific society meetings exposes scientists to new ideas, technologies and methodologies; provides a venue for feedback from peers when presenting papers and poster sessions on their research.Meetings are the best venue for networking and finding out who is doing what research. Professional scientific society meetings typically include representatives from industry, academia and government.Attendees learn from their counterparts in other sectors about technological trends of interest and the future direction of research, societal needs, workforce issues, and the regulatory framework governing their work.

Participation in international scientific collaboration and attendance at international scientific meetings will be significantly limited by the proposed rules. Inviting foreign scientists to meetings in the United States, and attendance at international events exposes American scientists to what other nations are researching and the results. It also exposes US scientists to global best practices.

OMB has proposed rules that will severely limit scientific communication. No longer paying for subscriptions to scientific journals and no longer providing financial support to publish scientific papers is counterproductive.Reading about the research of others in peer-reviewed scientific journals is very important for staying current in one’s scientific discipline, and being able to publish research is essential to the scientific enterprise.

The new OMB proposals prohibit any consideration of diversity, equity and inclusion (DEI) in grant awards. African Americans, Hispanics and Native Americans are significantly under-represented in engineering and the physical and health sciences. Over the next ten to fifteen years the population of the United States will approach 40% non-white citizens.Efforts must be made to reach out to the minority population in universities, high school, and even in middle school, to interest them in pursuing careers in engineering and the sciences. The National Science Foundation has previously supported DEI programs to promote recruitment of minority students into the sciences.This has now come to a grinding halt. The Trump Administration’s aversion to diversity is going to have significant future scientific workforce consequences.Unless we actively try to recruit “diverse” scientists, the United States can expect a serious shortage of qualified engineers and scientists to keep our economy running and innovative, and to keep us healthy.

The changes that OMB is proposing for the federal grant making process are not in the nation’s best interests.Representations that the proposals will improve transparency and efficiency have absolutely no merit. Any budget savings realized through cutting travel and publication expenses are insignificant when compared to the total budgets of the agencies affected. Exceptional science has made America great. Implementation of the OMB proposals will seriously damage the American scientific enterprise.They must be rejected by Congress.

Mr. Hobbs is an independent consulting geologist for global petroleum, mineral and geothermal exploration and production. He also manages a farm in Sheffield, MA.