January 2, 2015

Mr. Robert Martin
Records Officer
Information Policy, Planning and Training
NIFA/USDA
Mail Stop 2216
1400 Independence Avenue SW
Washington, DC 20250-2216

Comments on the Proposed Requirement for Letters of Intent

Dear Mr. Martin,

The American Institute of Biological Sciences (AIBS) appreciates the opportunity to provide comments on the proposed establishment of a requirement for researchers and other potential grantees to submit a letter of intent.

We understand the need for federal programs to improve the efficiency of the competitive review process. Requiring a letter of intent prior to a full proposal could save time for both grantees and program officers. In and of itself, such a requirement is not likely to have adverse impacts on the research community. We are concerned, however, that this is the first step by the National Institute of Food and Agriculture (NIFA) to implement more burdensome requirements.

In 2012, the National Science Foundation (NSF) implemented a requirement for the submission of preliminary proposals. Also included with this change were new limits on the number of pre-proposals a researcher could submit per cycle and a change in the submission deadline to once per year.

The scientific community has expressed serious concerns about these changes, as was summarized in the attached article, "Gauging Satisfaction with the New Proposal Process in DEB and IOS at the NSF." The article appeared in the September 2014 issue of BioScience, which is published by AIBS. A survey of more than 4,700 researchers who had received NSF funding found that almost 70 percent of respondents were satisfied or neutral with the switch to a preliminary proposal. The change to a single annual deadline, however, garnered 80 percent dissatisfaction. Most survey respondents believed that changes would "negatively affect the ability of new investigators and untenured faculty to advance their careers" and would stymie advancements in science.

In light of the research community's concerns with the changes at NSF, we urge NIFA to carefully consider changes that could be create overly restrictive submission policies associated with pre-proposals.

The AIBS is a nonprofit scientific association dedicated to advancing biological research and education for the welfare of society. AIBS works to ensure that the public, legislators, funders, and the community of biologists have access to and use information that will guide them in making informed decisions about matters that require biological knowledge. Founded in 1947 as a part of the National Academy of Sciences, AIBS became an independent, member governed organization in the 1950s. Today, AIBS has more than 140 member scientific organizations and institutions.

Thank you for your consideration of these comments.

Sincerely,

Richard O'Grady, Ph.D.
Executive Director

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