Four public comments to file in the next month (one due Monday)

The Trump Administration continues to attack science, federal employees, and democracy itself in a multitude of ways. There is an opportunity to provide public comment on four recent proposals, and I encourage my audience to do so. Remember that every substantive comment is supposed to be responded to, and if the administration fails to respond to a substantive comment1, it creates a legal vulnerability.

• OMB Proposal granting political appointees carte blanche to mess with science grants: comment here through AGU, deadline July 13th.

• OPM Proposal requiring government employees to sign restrictive NDAs (with chilling implications for government scientists): comment here, deadline June 26th.

• Post Office Proposal to allow the post office to block mail-in ballots in states that don’t kowtow to Trump’s demands: comment by email, see federal register document, deadline July 2nd.

• Trump Arch: deadline June 15th!!! Comment here. This is the least important of the comments, but the one with the first deadline.

I include my four draft letters in this post. A) feel free to take and adapt as wanted. B) let me know if you have any suggestions on how to make them stronger. Note that any comment you submit to the federal register will be public: don’t include anything that you don’t want attached to your name.

I would also like to point to Jeremy Berg’s letter (he includes a word document in his Bluesky post), along with statements by AAS, AAAS, and AGU among many other scientific organizations. My draft letter follows:

To whom it may concern,

I am writing to strongly oppose the OMB proposed Regulation for Federal Financial Assistance.

While elections should, and do, have consequences, including for scientific funding, the proposed rule would open the doors to a level of political manipulation and barriers to effective work that could grievously disrupt the American scientific enterprise (a scientific enterprise that has been one of America’s crown jewels over the past 70 years, and an envy of the world).

I write as a graduate of MIT and Caltech, as a scientist who served for 18 years in the government, and as an author of more than 50 peer-reviewed papers. I write to object to three issues in the proposed rule in specific, but disagree with the politicized tenor of the whole rule and the downweighing of scientific judgment in general.

FIRST

OMB’s proposal to “require all discretionary grants to permit termination for discretionary reasons” (200.340). The problem with this is that many scientific awards are designed as multi-year projects for really good reasons. Science does not move quickly, particularly in fields that require long-term observations or require working with biological entities. My experience funding projects, where the research was based on reduced complexity modeling and leveraged existing work, generally required a full year to produce a paper that was of proper quality for journal submission followed by another half year or more for revisions with the journal. More fundamental research will take much longer from conception to producing a deliverable. There is a reason that doctoral students spend 4–6 years working on their dissertation research. Moreover, project leads often hire postdoctoral associates based on the funding they have acquired with a grant: the level of uncertainty that would be introduced into the scientific process by allowing for arbitrary cancellation of existing awards would be crippling.

Moreover, this enables unscrupulous administrations to target states or universities that are politically disfavored. There is evidence that this has recently happened with Department of Energy grants – see https://www.latitudemedia.com/news/energy-department-to-reinstate-11-clean-energy-grants-canceled-in-blue-states/.

SECOND

The plan for OMB to “make publication costs unallowable” (200.461). Science that does not become part of the scientific literature has little value. Peer reviewed scientific publication is a key step in the scientific process. Open-access publications are particularly valuable, and in fact open access is now required under a 2022 federal policy for federally funded research to be publicly accessible.

THIRD

The additional requirement by OMB that “costs for attending conferences are allowable only if participation in the conference is expressly approved by the agency” (200.432). Conferences are a critical part of the scientific enterprise. They are an opportunity to showcase preliminary work and receive feedback from the community, which will lead to improvements in the final scientific product requested by the agency. Even more important is the conversations in the hallways of conferences: in my experience, the insights acquired in these conversations lead directly to substantial improvements in the science I produce.

I include by reference the following articles:

• https://elizabethginexi.substack.com/p/what-we-need-to-do-next-ombs-proposed

• https://climatecafe.substack.com/p/the-latest-step-in-trumps-war-on

• https://holdenthorp.substack.com/p/red-alert-the-omb-regulations-could

In closing, I object to this proposed rule that replaces evidence-based judgment with politicized interference and places barriers between good science and its dissemination.

Respectfully submitted,
–Marcus C Sarofim, MIT PhD, Caltech MS, NYU Senior Research Scientist, JHU Lecturer.

To whom it may concern,

I am writing to strongly oppose the OPM proposal to require federal employees to sign an NDA (Docket ID: OPM-2026-0100). I write as a former government scientist who found the ability to collaborate and publish research at the EPA an important facet of my job, and who would have found an NDA requirement a reason to leave government service.

There are numerous reasons that this is a bad idea.

• It raises serious First Amendment concerns.

• Existing laws and regulations already protect our nation’s secrets and protected information. Every year I had to take a training on Confidential Business Information (CBI), Personally Identifiable Information (PII), and Controlled Unclassified Information (CUI), and we took all of these data classifications very seriously.2 In particular, we knew that any specific details about pending regulations (whether proposed or final) was particularly sensitive as leaks could provide a competitive advantage.

• Civil servants are dedicated and diligent, and there is neither need nor justification for any federal employees, whether new or existing, to be required to sign a blanket NDA. This requirement would be one more brick thrown at civil servant morale and the ability of the government to hire the best and the brightest.

But my comment is going to focus on a separate topic: the effect of such an NDA on government science and scientists. NDAs are unheard of in academia, and the ability of government to compete with academia for scientists will be impeded by the NDA requirement. An NDA would have a chilling effect on collaboration with non-government scientists. It would create uncertainty regarding the ability to continue scientific projects after leaving government service.

Trump has a history of pushing NDAs to uncomfortable limits – see nyujlpp.org/quorum/nondisclosure-agreements-trump-white-house. It includes examples of his corporations (2013 Miss Universe, 1996 Barbara Corcoran), his personal life (1992 Ivana Trump, 2016 Stephanie Clifford, 2020 Mary Trump), his campaign (Cliff Sims and Omarosa Manigault Newman), and his White House (2020, Stephanie Wolkoff). The current administration has shown its willingness to illegally punish employees for legal disclosures – see https://www.nbcnews.com/politics/politics-news/fema-welcoming-back-15-whistleblowers-placed-leave-kristi-noems-tenure-rcna342924.

These examples of Trump pushing NDAs to their limits, along with general abuse of private NDAs in the wider community (e.g., Michael Bloomberg and NDAs regarding sexual harassment complaints) would contribute to the chilling effect of any NDA requirement, regardless of whether the NDA itself is carefully crafted to only cover already illegal disclosures.

I include by reference the following articles:

• https://www.afge.org/article/proposed-nda-rule-is-yet-another-attack-on-nonpartisan-federal-employees/

• https://federalnewsnetwork.com/workforce-rightsgovernance/2026/06/federal-employees-are-facing-a-proposed-nda-that-could-deter-whistleblowers/

• https://news.bloomberglaw.com/legal-exchange-insights-and-commentary/trumps-ndas-for-federal-employees-would-hide-workplace-abuses

In closing, I object to this proposed rule that would make NDAs (whether voluntary or required) a commonplace feature of government employment for its chilling effect on collaboration and creation of yet another negative impact on civil servants, making it harder to hire and retain the best and the brightest to government service.

Respectfully submitted,
–Marcus C Sarofim, MIT PhD, Caltech MS, NYU Senior Research Scientist, JHU Lecturer, EPA AAAS fellow 2008–2010, EPA scientist 2010–2026.

To whom it may concern,

I am writing to strongly oppose the proposed Ballot Mail for Federal Elections regulation because it creates the potential for inadvertent vote suppression.

[24.5.3] “Mailings that do not comply with 24.5.1 and 24.5.2 will not be accepted and will be returned to the authorized ballot mailer.” This requirement could (and likely would) lead to absentee ballots being returned to the state, leading to a delay that would lead to a voter not receiving their ballot in a timely manner. This creates the potential for suppression of votes. The US already has a lower level of voter participation than many comparable nations, and adding additional barriers to vote is exactly the wrong direction for the country to be taking.

I am also nervous about the creation of a centralized federal database tracking who has requested absentee ballots. The rationale for this requirement appears to be a fear of voter fraud, which the evidence shows is exceedingly rare – the Heritage Foundation’s own database documents only on the order of a thousand potential cases over two decades against hundreds of millions of ballots cast, and a 2020 American Statistical Association study found no evidence that voting by mail increases fraud risk.

I include by reference the following articles:

• https://www.nytimes.com/2026/06/11/us/politics/usps-mail-voting-democratic-resistance.html

Note: I have no objection to the creation of voluntary standards that states could choose to follow that would enhance the processing and delivery of election ballots. But as soon as the standards become a requirement, that creates the potential for non-delivery of ballots by the Post Office, which is a red line that should not be crossed.

Respectfully submitted,
–Marcus C Sarofim, natural born citizen.

To whom it may concern,

I am writing to strongly oppose the proposed construction of a Triumphal Arch at Memorial Circle.

I have been a DC resident since 2008. I know that construction of additional memorials, museums, and other structures on the National Mall has historically been a process that takes years. This time span is necessary in order to make sure that there is sufficient public input into the process, that multiple designs are taken into account before choosing a final version, and that the purpose of the construction is made clear to the American people and to Congress. For example, the Vietnam Veterans Memorial, one of the most striking memorials in DC, was a process that started with the establishment of a non-profit organization in 1979, the selection of a site in 1980 (including Congressional authorization), a selection of design among 1421 submissions in a national competition, and approval of the design by 1982. The National Museum of African American History and Culture had an even longer history: a bill was first signed in 1929, but was interrupted by the Great Depression. George W Bush signed new legislation in 2003 after decades of lobbying. Design and construction occurred between 2009 and 2016.

This Triumphal Arch proposal is, in contrast, a rushed process. This is particularly unfortunate given all the potential impacts: on traffic during construction, on sightlines between the Lincoln Memorial and the Arlington Cemetery, and on incoming flights into the Washington National Airport. Moreover, I dislike the aesthetics of the arch – it is a throwback to 19th century European construction. Why not propose something novel and uniquely American?

I include by reference the following articles:

• https://ldad.org/letters-briefs/action-alert-triumphal-arc

• https://www.nytimes.com/2026/06/12/opinion/trump-arch-arlington.html

• https://www.politico.com/news/2026/06/12/trumps-massive-arch-could-snarl-traffic-years-00960554

In closing, I object both to the specific design and to the process by which this Triumphal Arch has been pushed forward. New major additions to the Washington DC monumental landscape should be chosen through a considerate process with substantial public and Congressional input.

Respectfully submitted,
–Marcus C Sarofim, DC resident, natural born citizen.