http://www.rssboard.org/rss-specification 720 https://escholarship.org/uc/ucop/rss Recent eScholarship items from UC Office of the President Thu, 3 Sep 2026 03:16:13 +0000 https://escholarship.org/uc/item/7d17013p This comment letter responds to AAALAC International's proposed draft of their new position statement on "The 3Rs". UC recommends that AAALAC revise the 3Rs position statement to use more precise and flexible language, including referring to “scientifically validated” non-animal models and saying reduction techniques should be “considered” rather than automatically “applied” in all animal activities. UC also asks AAALAC to better account for wildlife research by adding examples such as camera trapping and non-invasive sampling, and to clarify that 3Rs training should apply as appropriate to institutionally affiliated personnel involved in animal care and use. The content of this letter was submitted through a comment portal and did not require a signature. https://escholarship.org/uc/item/7d17013p Wed, 2 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/5qq5413q This comment letter responds to the Department of State Directorate of Defense Trade Controls (DDTC)'s proposed amendments to the International Traffic in Arms Regulations (ITAR) originally issued on July 29, 2024. UC supports DDTC’s proposed ITAR revisions as a helpful effort to clarify defense-services controls, distinguish controlled from non-controlled activities, and protect national security while preserving professional and academic exchanges. UC endorses AUECO and COGR requests for further clarification on exclusions for repair or maintenance of EAR-controlled commodities/software, routine academic activities, medical and translation services, and definitions related to intelligence activities, so low-risk academic and research activities are not unnecessarily affected. https://escholarship.org/uc/item/5qq5413q Wed, 2 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/59z9m16x This comment letter responds to AAALAC International's proposed draft of their new position statement on "The Culture of Care". UC supports AAALAC’s effort to articulate Culture of Care as an institutional mindset and notes that UC has already adopted the concept, but asks AAALAC to clarify the intent of the position statement and how its key components should be implemented. UC recommends several wording changes, including removing the unnecessary qualifier “good,” consistently capitalizing Culture of Care, emphasizing communication with all institutionally affiliated people involved in animal care and use, clarifying the role of veterinary and animal care practices within the broader program, and promoting 3R approaches during protocol review as well as animal care activities. The content of this letter was submitted through a comment portal and did not require a signature. https://escholarship.org/uc/item/59z9m16x Wed, 2 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/3x1637k7 This comment letter responds the United States Patent and Trademark Office (USPTO)'s Notice of Proposed Rulemaking on terminal disclaimer practice to obviate nonstatutory double patenting. UC endorses the Association of University Technology Manangers (AUTM)’s opposition to the USPTO’s proposed terminal-disclaimer rule, arguing that it would undermine the enforceability and presumed validity of issued patents, create due process and coercion concerns, and exceed the USPTO’s administrative rulemaking authority. UC warns that the proposal would harm university technology transfer, deter investment in federally funded inventions, weaken the Bayh-Dole innovation framework, and reduce the market introduction of new technologies, so it urges USPTO to withdraw the rule. https://escholarship.org/uc/item/3x1637k7 Wed, 2 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/3367v4kt This comment letter responds to the Office of Management and Budget (OMB)'s request for information on proposed revisions to 2 CFR, Subtitle A, Chapters I and II (Uniform Guidance). UC endorses COGR’s comments and recommends that OMB reduce administrative burden under 2 CFR by eliminating the DS-2 requirement, raising the subaward MTDC cap from $25,000 to $75,000 with regular reevaluation, and reconsidering the 26% cap on administrative F&A costs. UC also asks OMB to clarify that negotiated indirect cost rates must be accepted unless limited by statute or regulation, specify that § 200.112 concerns procurement-related conflicts rather than research COI, and rewrite subrecipient indirect-cost-rate rules in plain English so pass-through entities and subrecipients have clear, workable options. https://escholarship.org/uc/item/3367v4kt Wed, 2 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/9vd827xq This comment letter responds to the Office for Human Research Protections’ draft guidance on the use of a single Institutional Review Board (IRB) for cooperative research. UC supports clearer guidance but recommends additional flexibility and clarification around single-IRB exceptions, selection of reviewing IRBs, local institutional review responsibilities, and reliance agreements, while urging OHRP to reduce administrative burden by developing resources such as a compendium of state laws relevant to human-subject research. https://escholarship.org/uc/item/9vd827xq Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/9sn6m48b This comment letter responds to the FDA’s draft guidance on the use of real-world data and real-world evidence to support regulatory decision-making for drugs and biological products. UC recommends clarifying that certain non-interventional studies using existing real-world data do not require IRB review and further aligning FDA requirements with the Common Rule by permitting appropriate exemptions from IRB review for minimal-risk research, thereby reducing administrative burden while maintaining human-subject protections. https://escholarship.org/uc/item/9sn6m48b Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/9mf9j9bq This comment letter responds to the FDA’s Guidance for Sponsors, Investigators, and  Institutional Review Boards on Key Information and Facilitating Understanding in Informed Consent. UC generally supports FDA’s proposed guidance on key information and facilitating understanding in informed consent, including harmonization with the Revised Common Rule, use of plain language, conflict-of-interest disclosure, and flexibility for study-specific presentation. UC raises concerns that the suggested bubble format may create accessibility, equity, IRB-review, and administrative problems, and recommends adding contact information and clearer language on consent elements while deleting recommendations for glossaries, references, tables of contents, and page-number cross-references that could increase burden and undermine plain-language consent. https://escholarship.org/uc/item/9mf9j9bq Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/9h75q200 This comment letter responds to the FDA’s proposed rule revising human-subject protection and Institutional Review Board regulations to better align them with the Common Rule. UC supports harmonization but recommends closer alignment on definitions, informed consent, activities preparatory to research, waivers of consent documentation, and continuing IRB review, as well as a longer implementation period for the final rule. https://escholarship.org/uc/item/9h75q200 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/95s6f2pd This comment letter responds to DOE's proposed "Financial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy Requirements", published on June 18, 2024. UC appreciates DOE’s effort to strengthen research integrity but urges DOE to align its final conflict-of-interest policy with the longstanding PHS COI regulations, preferably by finalizing the existing DOE Interim Policy with targeted changes rather than creating divergent requirements. UC specifically recommends removing conflict-of-commitment requirements from the COI policy, using existing biographical sketch/current and pending support disclosures for COC information, adopting PHS-style definitions and thresholds, shifting reporting to before expenditure of funds, clarifying disclosure obligations, and allowing one year for implementation. https://escholarship.org/uc/item/95s6f2pd Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/95r7x067 This presentation will introduce UC San Diego Library's campus research outputs data dashboard. The interactive dashboard provides a novel, library-centric view of UC San Diego's scholarly ecosystem by consolidating and visualizing data from multiple sources across campus and the UC system.The dashboard began as a proof of concept to better visualize and advertise UC San Diego researcher outputs available in Dimensions, a campus-licensed research intelligence platform that aggregates metadata and metrics about publications, grants, datasets, and patents. The Library’s Research Data Curation group had been receiving questions from campus partners about researcher collaboration, departmental publication counts, and other research metrics, and while answers to these questions could be found in Dimensions, the process was time-consuming and required enough technical expertise to be challenging.We realized that what we needed was a flexible, multi-purpose dashboard that could address... https://escholarship.org/uc/item/95r7x067 Tue, 1 Sep 2026 00:00:00 +0000 Labou, Stephanie https://escholarship.org/uc/item/93g1s074 This comment letter responds to the Drug Enforcement Administration’s proposed rule governing the cultivation of marijuana for research in the United States. UC supports expanding the lawful supply of cannabis for research but urges faster approval of additional growers, access to a wider variety of research materials—including products legally available under state law—and clearer requirements concerning DEA possession, product testing and quality, costs, and the regulatory status of CBD. https://escholarship.org/uc/item/93g1s074 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/8z99q8c0 This comment letter responds to the FDA’s proposed rule on the protection of human subjects and Institutional Review Boards, intended to harmonize FDA regulations with the Common Rule. UC requests a 60-day extension of the comment period, for a total of 120 days, to allow adequate consultation with researchers, administrators, and compliance and privacy experts regarding the proposal’s implications for human-subject research protections and oversight. https://escholarship.org/uc/item/8z99q8c0 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/8nj635p3 This comment letter responds to the National Institutes of Health’s draft supplemental guidance on protecting the privacy of human research participants when sharing data under the NIH Data Management and Sharing Policy. UC supports a flexible, principles-based framework but recommends greater recognition of consent waivers, clearer and more consistent standards for de-identification and controlled access, broader consideration of legal protections and data-use agreements, and continued NIH investment in field-specific data repositories. https://escholarship.org/uc/item/8nj635p3 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/8m65c5h9 This comment letter responds to the National Institutes of Health’s request for input on its NIH-Wide Strategic Plan for COVID-19 Research. UC recommends expanding the plan to address additional research priorities in COVID-19 biology, testing, treatment, prevention, and health disparities, while calling for sustained federal investment in basic science, research infrastructure, data science, and workforce development to strengthen preparedness for future pandemics. https://escholarship.org/uc/item/8m65c5h9 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/89w7t4r0 This comment letter responds to the National Science Foundation’s request for comments on proposed government-wide common disclosure forms for biographical sketches and current and pending support. UC supports standardized forms as a means of reducing administrative burden but recommends limiting agency-specific exceptions, simplifying certification requirements, harmonizing definitions and submission requirements across agencies, and allowing sufficient time and technological support for implementation. https://escholarship.org/uc/item/89w7t4r0 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/89s69064 This comment letter responds to the Department of Education’s proposed rule conditioning certain federal funding on public universities’ compliance with First Amendment requirements and their treatment of religious student organizations. UC argues that the rule could unfairly jeopardize federal funding based on unrelated litigation, increase legal and administrative burdens, and conflict with Supreme Court precedent and institutional and state nondiscrimination requirements. https://escholarship.org/uc/item/89s69064 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/7v11n0rm This comment letter responds to the FDA’s proposed rule requiring single Institutional Review Board (IRB) review for cooperative research and harmonizing FDA requirements with the Common Rule. UC supports greater regulatory alignment but recommends updated analysis of the costs and administrative burden of single-IRB review, clearer exceptions for certain studies and circumstances, greater discretion for local IRBs, and streamlined reliance agreements. https://escholarship.org/uc/item/7v11n0rm Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/7sz8s1zc This comment letter responds to the National Institutes of Health’s request for information on proposed updates and long-term considerations for its Genomic Data Sharing Policy. UC supports modernizing and harmonizing the policy with NIH’s broader Data Management and Sharing Policy but recommends additional public engagement and clearer guidance on genomic data de-identification, privacy risks, data linkage and consent, while seeking to minimize duplicative requirements and administrative burden. https://escholarship.org/uc/item/7sz8s1zc Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/7f05k19f This comment letter responds to the Drug Enforcement Agency (DEA)'s Advanced Notice of Proposed Rulemaking on Controlled Substance Destruction Alternatives to Incinceration, issued on October 31, 2023. UC explains that it currently uses reverse distributors to destroy controlled substances used in research and clinical care, but that limited reverse-distributor capacity can force institutions to store expired or unusable substances longer than intended. UC asks DEA to allow or clarify that controlled substances purchased or used for research or clinical care may be rendered non-retrievable on-site, including through hardening agents or activated carbon under documented chain-of-custody, two-witness handling, and DEA Form 41 recordkeeping procedures. https://escholarship.org/uc/item/7f05k19f Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/6vx692vq This comment letter responds to the FDA’s draft guidance on Certificates of Confidentiality (CoCs) for protecting identifiable, sensitive information collected in human subjects research. UC supports the guidance’s privacy protections and streamlined CoC process but requests greater clarity on what qualifies as sensitive information, when individual investigators may obtain CoCs, appropriate informed consent language, and the circumstances and options associated with FDA denial of discretionary CoCs. https://escholarship.org/uc/item/6vx692vq Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/6s53z1g1 This comment letter responds to the Office of Science and Technology Policy’s draft characteristics for repositories used to manage and share data resulting from federally funded research. UC supports efforts to improve long-term stewardship and public access to research data while recommending greater consistency in data policies across federal agencies, adequate federal support for data curation and preservation costs, and clearer standards for repository functionality, security, and protection of human subjects data. https://escholarship.org/uc/item/6s53z1g1 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/6p60f04g This comment letter responds to the California Department of Justice’s proposed modifications to regulations governing researcher access to the Controlled Substance Utilization Review and Evaluation System (CURES). UC argues that requiring individual patient consent would effectively prevent population-level research using identified CURES data and recommends restoring provisions that permit access under existing privacy, security, and human-subject protections, including the option to restrict access to DOJ’s secure laboratory. https://escholarship.org/uc/item/6p60f04g Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/6815j3dq This comment letter responds to the Drug Enforcement Agency (DEA)'s Notice of Proposed Rulemaking "Schedules of Controlled Substances: Rescheduling of Marijuana", published in the Federal Register on May 21, 2024. UC supports DEA’s proposal to move marijuana, marijuana extracts, and naturally derived delta-9-THC from schedule I to schedule III as a step toward reducing research barriers, but argues that rescheduling alone will not let researchers study the real-world cannabis products available in state-regulated markets. UC urges DEA to allow universities to access state-legal cannabis products and fresh plant material for research, classify naturally and synthetically derived delta-9-THC consistently, assess THC isomers and derivatives through the eight-factor analysis, and issue updated guidance explaining the regulatory requirements for cannabis research. https://escholarship.org/uc/item/6815j3dq Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/6755426q This comment letter responds to the Office of Science and Technology Policy’s request for information on strengthening the American research environment. UC recommends greater coordination and consistency across federal agencies in policies addressing research rigor and integrity, administrative burden, research security and foreign influence, and safe and inclusive research environments, while emphasizing the importance of preserving open international scientific collaboration. https://escholarship.org/uc/item/6755426q Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/6546b70g This comment letter responds the DOJ's proposed rule on provisions pertaining to preventing access to U.S. sensitive personal data and government-related data by countries of concern or covered persons. UC supports DOJ’s goal of protecting sensitive personal and government-related data, but urges the agency to avoid impairing academic research, especially by adding an exemption for covered data transactions in non-federally funded research. UC also endorses COGR’s recommendations for clearer definitions, more detailed compliance guidance, practical tools, and sufficient implementation time so universities can comply consistently without undermining global research collaboration. https://escholarship.org/uc/item/6546b70g Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/637846c7 This comment letter responds the NIH's RFI on their Draft Public Access Policy, issued on June 18, 2024. UC strongly supports NIH’s Draft Public Access Policy and supplemental guidance, especially the government use license language allowing broad reuse and derivative works, and urges HHS/NIH to harmonize this approach with federal grant regulations to support consistent zero-embargo access. UC also asks NIH to clarify and support publication-cost planning, preserve PubMed Central as a no-cost deposit route, create a mechanism for post-award publication costs, and work with universities and publishers to automate multi-repository deposits to reduce administrative burden and compliance risk. https://escholarship.org/uc/item/637846c7 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/5wz509zr This comment letter responds to the National Institutes of Health’s draft Policy for Data Management and Sharing and supplemental guidance. UC supports NIH’s efforts to expand research data sharing but recommends clearer definitions and implementation standards, standardized data management plan templates and requirements, protections for sensitive data, and adequate funding for both short- and long-term data management, curation, preservation, and infrastructure costs. https://escholarship.org/uc/item/5wz509zr Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/5ws0k723 This comment letter responds to the Department of Defense’s interim rule implementing new cybersecurity assessment and certification requirements for federal contractors. UC supports strengthened cybersecurity protections but requests clearer guidance on how the requirements apply to fundamental research, greater transparency regarding assessment levels, and confirmation that compliance costs are allowable as direct costs on DoD awards. https://escholarship.org/uc/item/5ws0k723 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/5wd6c2xg This comment letter responds to the National Institute of Health (NIH) Office of Laboratory Animal Welfare (OLAW)'s request for information on the NIH Notice Clarification of Animal Activities Exempt from the PHS Policy Requirements for IACUC Review (NOT-OD-23-119). UC supports OLAW’s effort to clarify which animal activities do not require IACUC review and approval, but recommends avoiding the term “exempt” because it may be confused with human-subjects research terminology. UC also asks OLAW to clarify several examples involving observational field studies, commercially available surgically modified animals, and reliance on another institution’s IACUC review, and urges OLAW and USDA-APHIS to harmonize field-study requirements and definitions to reduce administrative burden. https://escholarship.org/uc/item/5wd6c2xg Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/5w46r8j9 This comment letter responds to NIST’s proposed revisions to regulations implementing the Bayh-Dole Act governing federally funded inventions and licensing of government-owned inventions. UC recommends clarifying that consumer pricing cannot be a basis for exercising federal march-in rights, providing greater flexibility in requirements related to small-business licensing preferences, and extending the period for converting provisional patent applications to non-provisional applications from ten to twelve months. https://escholarship.org/uc/item/5w46r8j9 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/5ng1c3d5 This comment letter responds the National Institute of Health (NIH)'s proposed Framework for Discussion for reforming NIH through structural and policy reform. UC urges Congress to approach NIH reform cautiously, with meaningful scientific-community input and independent review before major structural changes, warning that consolidating institutes, capping F&A costs, limiting PI grant holdings, or broadly pausing gain-of-function research could create serious unintended consequences. UC recommends reducing administrative burden, preserving peer review and basic science, supporting early-career and diverse researchers, adjusting grant-size thresholds for inflation, avoiding duplicative research-security requirements, and using risk-based expert oversight for sensitive research areas. https://escholarship.org/uc/item/5ng1c3d5 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/4p55d0x9 This comment letter responds to the Food and Drug Administration (FDA) and National Institutes of Health (NIH)'s joint request for information on a glossary of terms related to clinical research and clinical study designs. UC asks FDA and NIH to clarify whether the proposed clinical research terminology glossary applies only to FDA-regulated studies using real-world data for medical products, or more broadly to other clinical research and observational studies. If the glossary is intended to apply broadly, UC recommends revising certain observational-study definitions and adding definitions for real-world data and real-world evidence so the glossary can serve as a clearer one-stop reference for clinical research terminology. https://escholarship.org/uc/item/4p55d0x9 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/4fb874mt This comment letter responds to the Department of Health and Human Services’ request for input on potential revisions to the Public Health Service Policies on Research Misconduct. UC generally supports retaining the existing framework while recommending clearer standards for findings of misconduct, harmonized and flexible investigation timelines, expanded confidentiality protections, and additional guidance on inquiries, investigations, and the application of the six-year limitation on misconduct allegations. https://escholarship.org/uc/item/4fb874mt Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/4d06s3qs This comment letter responds to the California Department of Justice’s proposed modifications to regulations governing access to identified individual-level data in the Controlled Substance Utilization Review and Evaluation System (CURES). UC recommends that researchers accessing CURES data through established research-review procedures not be required to use DOJ’s proposed consent form, arguing that the form is inconsistent with standard human-subject research practices, creates unnecessary participant burdens, and may increase privacy risks by requiring excessive identifying information. https://escholarship.org/uc/item/4d06s3qs Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/3rs8v26w This letter requests changes to the Office for Human Research Protections’ IRB Registration Form to allow more inclusive representation of IRB members’ gender identities. UC recommends replacing the form’s binary male/female designation with at least three gender identity options, arguing that the change would better reflect federal requirements emphasizing diversity and nondiscrimination in IRB membership. https://escholarship.org/uc/item/3rs8v26w Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/3qf4328f This comment letter responds to the General Services Administration (GSA)'s Information Collection on the Federal Funding Accountability and Transparency Act Sub-Award Reporting System Registration Requirements for Prime Grant Awardees (FFATA reporting requirements) published in the Federal Register on February 29, 2024. UC acknowledges that FFATA subaward reporting is statutorily required, but says GSA’s estimated annual burden of 30 minutes per respondent is a major underestimate because UC submits reports monthly and campuses spend roughly 18 to 30 hours per report, or about 200 to 360 hours per year. UC recommends improving FSRS guidance and technical support, resolving recurring system errors, reducing duplicative data entry, carrying forward unchanged information for existing subawards, and limiting required FSRS fields to those actually required by FFATA. https://escholarship.org/uc/item/3qf4328f Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/3mj4m7rm This comment letter responds to SMART IRB's proposed revisions to their Reliance Agreement 3.0. UC asks SMART IRB to preserve continuity for existing studies under prior reliance-agreement versions, clarify confusing withdrawal/reporting language, and allow flexibility for non-federally regulated research through agreed-upon commensurate protections rather than defaulting rigidly to SMART IRB SOPs or the Common Rule. UC also raises several deal-breaker legal and operational concerns, including overly broad liability and indemnification language, burdensome or unclear QA/QI and reporting obligations, lack of flexibility for DOE-managed labs, and governing-law/venue provisions that could complicate participation. https://escholarship.org/uc/item/3mj4m7rm Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/3f23p0r7 This comment letter responds to the U.S. Department of Agriculture’s interim final rule establishing a domestic hemp production program. UC requests clearer and more flexible requirements for universities conducting hemp research, particularly regarding pre-harvest THC testing, use of DEA-licensed laboratories, negligence standards, disposal requirements, and distinctions between hemp grown for consumption and industrial or research purposes. https://escholarship.org/uc/item/3f23p0r7 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/36d5w13t This comment letter responds to the National Institute of Standards and Technology (NIST)’s request for information on the Draft Interagency Guidance Framework for Considering the Exercise of March-In Rights (Draft Framework) issued on December 8, 2023. UC strongly urges NIST not to issue the draft march-in framework, arguing that using Bayh-Dole march-in rights as a price-control tool would reinterpret the statute, conflict with congressional intent, and create uncertainty that could deter licensing, investment, public-private partnerships, and commercialization of federally funded university inventions. If NIST proceeds, UC asks it to revise and reissue the framework for public comment, including clear definitions and methods for terms such as “reasonable” price, “extreme,” “unjustified,” and “exploitative,” while ensuring the framework does not chill innovation across technology sectors. https://escholarship.org/uc/item/36d5w13t Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/31h4n0qg This comment letter responds to AAALAC International's proposed revisions to their position statement on "The Attending Veterinarian and Veterinary Care". UC generally supports AAALAC’s proposed revisions to the position statement, but recommends retaining language that makes surgical training/qualification and classification of major versus minor surgeries a shared responsibility of the IACUC and veterinary staff. UC also objects to using the undefined phrase “standards of veterinary practice,” urges AAALAC to reference regulatory expectations instead, and recommends adding clearer language on AV communication mechanisms, part-time AV oversight limits, and the AV’s role in animal husbandry. The content of this letter was submitted through a comment portal and did not require a signature. https://escholarship.org/uc/item/31h4n0qg Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/2vf29083 This comment letter responds to the Department of Commerce Bureau of Industry and Security (BIS)'s proposed amendments to the Export Administration Regulations originally issued on July 29, 2024. UC supports BIS’s proposed EAR amendments aimed at clarifying export controls and protecting privacy against unjustified government use of facial recognition and other mass-surveillance technologies. UC endorses AUECO and COGR recommendations for clearer Foreign-Security End User provisions and a more specific definition of facial recognition systems so regulators and institutions can better identify high-risk uses while excluding low-risk organizations and activities. https://escholarship.org/uc/item/2vf29083 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/2rv788dm This comment letter responds to NIST’s request for information on rebuilding the Interagency Edison (iEdison) system for reporting federally funded inventions. UC strongly supports modernizing the system and recommends greater consistency in invention-reporting requirements across federal agencies, improved functionality to address outdated and burdensome processes, and continued stakeholder engagement in developing and testing the replacement system. https://escholarship.org/uc/item/2rv788dm Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/2ng1337v This comment letter responds to HHS’s establishment of and call for nominations to the NIH Human Fetal Tissue Research Ethics Advisory Board for FY 2020. UC nominates three faculty members based on their expertise and accomplishments in biomedical and stem cell research, science policy, ethics, bioethics, and law. https://escholarship.org/uc/item/2ng1337v Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/2db6h4gd This comment letter responds to the National Institute of Health (NIH) Office of Laboratory Animal Welfare (OLAW)'s request for information on Flexibilities for Streamlining IACUC Review of Protocols and Significant Changes (NOT-OD-23-152) issued on July 11, 2023. UC supports efforts to streamline IACUC review but says OLAW’s proposed flexibilities mostly restate existing guidance or offer only minor clarifications, and UC recommends clearer wording on designated member review, accelerated three-year reviews, alternate member availability, and reporting expectations. UC urges OLAW to pursue more meaningful burden-reduction measures, such as longer or eliminated Assurance renewal cycles, less burdensome Assurance templates, five-year IACUC protocol approvals, and a more flexible NIH Just-in-Time process that allows certification of pending IACUC approval before animal work begins. https://escholarship.org/uc/item/2db6h4gd Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/2d78g9kf This comment letter responds to the Office of Science and Technology Policy’s request for information on public access to peer-reviewed publications, data, and code resulting from federally funded research. UC strongly recommends a zero-day embargo for federally funded peer-reviewed manuscripts, standardized data-sharing requirements across federal agencies, and continued federal support for open-access publishing and long-term research data management costs. https://escholarship.org/uc/item/2d78g9kf Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/29q041pz This comment letter responds to the Environmental Protection Agency’s supplemental proposed rule on “Strengthening Transparency in Regulatory Science.” UC urges EPA to withdraw the proposal, arguing that its expanded data-transparency requirements could exclude rigorous scientific studies from regulatory decision-making, undermine protections for confidential human research data, and give EPA excessive discretion to favor or exclude particular studies rather than relying on the best available science. https://escholarship.org/uc/item/29q041pz Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/28j9736p This comment letter responds to the FDA’s proposed rule on Institutional Review Boards and cooperative research, which seeks to harmonize FDA human-subject protection regulations with the Common Rule. UC requests a 60-day extension of the comment period, for a total of 120 days, to allow sufficient consultation with researchers, administrators, and compliance and privacy experts regarding the proposal’s implications for human-subject research protections and oversight. https://escholarship.org/uc/item/28j9736p Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/2665z321 This comment letter responds to the California Department of Cannabis Control’s proposed regulations governing research funding under the state’s Medicinal and Adult-Use Commercial Cannabis Regulations. UC recommends aligning the program with standard research administration practices by requiring peer review, providing feedback to unsuccessful applicants, using the California Model Agreement for UC and CSU awards, clarifying records-retention and personnel requirements, and leveraging UC’s existing grantmaking expertise. https://escholarship.org/uc/item/2665z321 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/1w09d5c3 Improved Asphalt Bases and Slab-Base Engineered Interlayers for Rigid Pavements https://escholarship.org/uc/item/1w09d5c3 Tue, 1 Sep 2026 00:00:00 +0000 Mateos, Angel Millan, Miguel Angel Harvey, John Paniagua, Fabian Yu, Justin Nassiri, Somayeh Buscheck, Jeff Brotschi, Julian https://escholarship.org/uc/item/1cz5808q This comment letter responds to the U.S. Department of Education’s proposed information collection requirements for reporting foreign gifts and contracts under Section 117 of the Higher Education Act. UC supports transparency regarding foreign relationships but argues that the proposed requirements exceed the statute, impose substantial administrative burdens, and raise privacy and confidentiality concerns, particularly regarding submission of complete agreements, information about individual donors, and reporting of foreign-affiliated entities. https://escholarship.org/uc/item/1cz5808q Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/0xg8p774 This comment letter responds to the U.S. Patent and Trademark Office’s request for comments on its National Strategy for Expanding American Innovation. UC supports increasing participation in invention and entrepreneurship and recommends federal support for educational programs, community partnerships and mentoring, improved access to capital, standardized data collection to measure participation and outcomes, and continued support for the Bayh-Dole Act and a strong patent system. https://escholarship.org/uc/item/0xg8p774 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/0r54j9xv This comment letter responds to the National Institutes of Health’s request for information on research interests and barriers related to studying the health effects of cannabis and its constituents. UC calls for increased and broader research funding, a streamlined federal regulatory framework, improved access to cannabis products representative of those actually used by the public, and coordinated federal resources, infrastructure, training, and regulatory support to expand cannabis research. https://escholarship.org/uc/item/0r54j9xv Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/0p60d992 This comment letter responds to the FDA’s Final Order expanding the list of tropical diseases eligible for the Tropical Disease Priority Review Voucher (PRV) Program. UC supports the announced additions but urges FDA to also include coccidioidomycosis (Valley Fever), arguing that it meets the program’s eligibility criteria and that PRV incentives could encourage development of urgently needed diagnostics, treatments, vaccines, and cures. https://escholarship.org/uc/item/0p60d992 Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/0gr9367z This comment letter responds to the National Institutes of Health’s request for information on developing consent language for the future use and sharing of research data and biospecimens. UC recommends that NIH provide flexible guidance rather than standardized sample language, clarify how the proposal relates to broad consent requirements, avoid a default opt-out approach to future sharing, and address the varying federal, state, and local laws governing informed consent and research privacy. https://escholarship.org/uc/item/0gr9367z Tue, 1 Sep 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/06g5v1tp This comment letter responds to the Department of Commerce Bureau of Industry and Security (BIS)'s proposed amendments to the Export Administration Regulations originally issued on July 29, 2024. UC supports BIS’s proposed amendments to the Export Administration Regulations as a careful effort to advance national security and foreign policy goals while recognizing the need to protect academic research and collaboration. UC endorses AUECO and COGR recommendations seeking additional exclusions for routine academic activities and clearer definitions of Military-Support End Users and Intelligence End Users to avoid unnecessary disruption to international research while still safeguarding critical technologies. https://escholarship.org/uc/item/06g5v1tp Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/9vw6z5h0 This comment letter responds to NIH Office of Laboratory Animal Welfare (OLAW)'s RFI (NOT-OD-23-063) on updating NOT-OD-05-034, Guidance on Prompt Reporting of Noncompliances to OLAW. UC supports OLAW’s effort to clarify reporting expectations and reduce administrative burden while maintaining animal welfare protections, but raised concerns that the proposed reporting exception for injuries among socially housed animals is overly broad and ambiguous. UC recommends removing the exception or narrowing and defining the covered species, situations, injury severity, separation period, reporting detail, and rationale to avoid unnecessary reporting and misinterpretation. https://escholarship.org/uc/item/9vw6z5h0 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/9st228b4 This comment letter responds to the National Institutes of Health (NIH)'s Pause on New Submissions to the NIH Human Embryonic Stem Cell Registry and Request for Information on Reducing Reliance on Human Embryonic Stem Cells in NIH-Supported Research. The University of California (UC) opposes reducing reliance on human embryonic stem cells (hESCs) at this time, arguing that hESCs remain essential research tools and critical benchmarks for evaluating alternative stem cell technologies. UC recommends that any future transition be evidence-based, adequately funded, and phased in gradually, while also urging NIH to continue accepting new hESC lines into the Registry to support scientific progress, reproducibility, and clinical translation. https://escholarship.org/uc/item/9st228b4 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/9gk3c9s4 This comment letter responds to the California Institute of Regenerative Medicine (CIRM)'s Third Notice of Proposed Regulation Amendments regarding the revised CIRM Intellectual Property (IP) Policy. The University of California (UC) expresses support for CIRM’s continued revisions to the policy, recommends adoption of “Option A” for the definition of “Collaborator,” and commends CIRM for its collaborative engagement with stakeholders throughout the rulemaking process. https://escholarship.org/uc/item/9gk3c9s4 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/9bs081jb This comment letter responds to a Senate Health, Education, Labor and Pensions (HELP) Committee letter, dated September 29, 2023, that seeks input on modernizing the NIH. UC urged Congress to modernize NIH carefully by preserving peer-driven, broad-based scientific participation while avoiding sweeping mandates that could disrupt the biomedical research enterprise. UC recommended incremental, piloted reforms that support early-career scientists, reduce administrative burden, reform IDeA eligibility, protect full F&A cost recovery, improve clinical-trial diversity, strengthen research workforce diversity, and maintain essential research methods where no adequate alternatives exist. https://escholarship.org/uc/item/9bs081jb Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/99n0x1kk This comment letter responds to the National Institutes of Health, Office of Laboratory Welfare (NIH/OLAW)'s Request for Information on proposed guidance to assured institutions on cephalopod care and use. UC expresses concern on whether OLAW has the authority to expand the application of the U.S. Government Principles or revise the PHS Policy on Humane Care and Use of Laboratory Animals (PHS Policy). UC recommends several changes to the proposed language to allow for PI input when developing institutional cephalopod policies and SOPs, as well as allowing for flexibility with cephalopod care staff qualifications. https://escholarship.org/uc/item/99n0x1kk Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/93x6z1b4 This comment letter responds to the NIH Notice NOT-OD-23-091, "Request for Information on the NIH Plan to Enhance Public Access to the Results of NIH-Supported Research". UC supports NIH’s plan to eliminate publication embargoes and expand public access, but emphasizes that implementation must reduce author burden, preserve equitable publication opportunities, and address open-access costs for early-career, under-resourced, and underrepresented researchers. UC recommends automated multi-repository deposits, continued and supplemental funding for publication and data costs, accessibility guidance for figures, pressure on excessive publisher fees, institutional infrastructure support, open licensing tools, and broader adoption of persistent identifiers and open metadata. https://escholarship.org/uc/item/93x6z1b4 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/8k93x8wq This comment letter responds to the U.S. Geological Survey (USGS) request for comments on Helium Supply Risk. UC emphasizes that helium is essential for patient care and federally funded research because MRI, NMR, MEG, and other ultra-cold scientific instruments depend on reliable liquid helium supplies and can be damaged or taken offline by shortages. UC warns that repeated shortages and rising costs threaten healthcare, research, and U.S. strategic capacity, and recommends federal policies to protect, expand, and maintain affordable domestic helium production for the research community. https://escholarship.org/uc/item/8k93x8wq Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/8910f379 In California, transportation plays a key role in community college access because many community college districts have satellite campuses, have limited transportation options, and tend to not have on-campus housing. To better understand the mobility challenges students face accessing community colleges and provide potential policy strategies to overcome these challenges, the researchers interviewed local transportation agencies, community college administrators, and students at five California community colleges between September 2022 and October 2023. Participants were asked about available transportation options for community college students, typical student travel patterns, and the resources needed to support improved community college transportation access. Small group discussions with students focused on student travel patterns, mobility challenges, and opinions on potential strategies to improve access. In addition, we reviewed state legislation on student transportation... https://escholarship.org/uc/item/8910f379 Mon, 31 Aug 2026 00:00:00 +0000 Shaheen, Susan https://orcid.org/0000-0002-3350-856X Broader, Jacquelyn Cohen, Adam Wolfe, Brooke https://orcid.org/0009-0007-9429-4992 https://escholarship.org/uc/item/7p32b22n Analysis of California Senate Bill 331: Hearing Aids - Letter https://escholarship.org/uc/item/7p32b22n Mon, 31 Aug 2026 00:00:00 +0000 California Health Benefits Review Program https://escholarship.org/uc/item/7br0n9jb This comment letter responds to NIH's RFI on a proposed simplified review framework for NIH research project grant application. UC supports NIH’s goals of reducing administrative burden and reputational bias in peer review, but questioned whether the simplified framework would actually reduce funding disparities for underrepresented groups. UC recommends real-time outcomes monitoring, robust training and guidance for reviewers and applicants, more diverse study sections, greater funding-transparency data, and added review criteria for team diversity and health-disparities relevance. https://escholarship.org/uc/item/7br0n9jb Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/79k487nr This comment letter responds to the U.S. Department of Education's revised Information Collection Request (ICR) on Foreign Gifts and Contracts Disclosures under Section 117 of the Higher Education Act (HEA). The University of California (UC) strongly opposes the Department’s use of an emergency review process and argues that the revised reporting requirements exceed statutory requirements, impose substantial administrative burdens, and create significant privacy and confidentiality concerns. UC recommends that the Department withdraw the emergency review request, delay implementation, and limit reporting requirements to those expressly required by Section 117. https://escholarship.org/uc/item/79k487nr Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/74v35572 This comment letter requests that OMB extend the comment period for the proposed revisions to the Guidance for Grants and Agreements by 60 days. OMB's Proposed Rule on Guidance for Grants and Agreements was published in the Federal Register on February 9, 2023 and only provided a 30-day comment period. https://escholarship.org/uc/item/74v35572 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/7388t27t This comment letter responds to the U.S. Department of Education's proposed information collection requirements for implementing Section 117 of the Higher Education Act (HEA) regarding disclosure of foreign gifts and contracts. The University of California (UC) supports transparency in foreign relationships but expresses concern that the proposed requirements substantially exceed the statutory requirements of Section 117, impose significant administrative and compliance burdens, raise privacy and confidentiality concerns, and introduce unclear reporting obligations. UC recommends scaling back the proposal, clarifying key definitions, protecting confidential information, maintaining the existing reporting threshold, and pursuing implementation through a more robust rulemaking and stakeholder engagement process. https://escholarship.org/uc/item/7388t27t Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/726964qq This report explores opportunities for employing autonomous driving technology to dampen stop-and-go waves on freeways. If successful, it could reduce fuel consumption and emissions. This technology was tested in an on-road experiment with 100 vehicles over one week. Public stakeholders were engaged to assess the planning effort and feasibility of taking the technology to the next level: a pilot involving 1000+ vehicles over several months. Considerations included the possible geographical boundaries, target fleets of vehicles, and suitable facilities such as bridges or managed lanes. Flow smoothing technology may improve the user experience and operations of managed lanes or bridges, however it may require external incentives such as reduced tolls to entice the traveling public to use it. This must be matched with other goals such as verifying vehicle occupancy. It might be possible for some hybrid solution that addresses both challenges to provide a way forward. A concept of... https://escholarship.org/uc/item/726964qq Mon, 31 Aug 2026 00:00:00 +0000 Patire, Anthony D., PhD https://orcid.org/0000-0002-3109-4164 Dion, Francois, PhD Bayen, Alexandre M., PhD https://orcid.org/0000-0002-6697-222X https://escholarship.org/uc/item/6th4n833 This comment letter responds to OMB's request for comments on OMB's Proposed Rule on Guidance for Grants and Agreements issued on February 9, 2023. UC supports OMB’s implementation of Build America, Buy America requirements but said the proposed guidance lacks clarity on when BABA applies to federal awards that are not primarily infrastructure projects. UC recommends adding language specifying that BABA applies only to infrastructure-project spending under covered awards, not to non-infrastructure spending, to reduce compliance costs, avoid conflicting “Buy America” rules, and prevent project delays. https://escholarship.org/uc/item/6th4n833 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/6bk2s9gf This comment letter responds to the National Institutes of Health (NIH)'s Request for Information on developing consent language for research using Digital Health Technologies. UC expresses concern that NIH’s sample consent language is too long, too complex, duplicative, and includes issues beyond informed consent, such as DHT terms of use, data ownership, and third-party sharing. UC recommends shortening and simplifying the language, removing technical or out-of-scope content, aligning consent with data management and IRB materials, and offering guidance without a template. https://escholarship.org/uc/item/6bk2s9gf Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/5dt1t3xd This comment letter responds to the Office of Science and Technology Policy (OSTP) RFI on the proposed Research Security Program Standard Requirements, published March 7, 2023. UC supports stronger research security standards but said implementation is not feasible without federal funding, clearer scope, and more time, especially for institutions managing broad federally funded research portfolios. UC recommends limiting requirements to risk-based federally funded science and engineering R&D, funding compliance costs, extending implementation to at least two years, narrowing travel and training obligations, clarifying cybersecurity expectations, and simplifying export-control and covered-individual definitions. https://escholarship.org/uc/item/5dt1t3xd Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/5bv354tk This comment letter responds to the U.S. National Science Foundation (NSF)'s proposed Guidance on Financial Assistance (GFA), which would replace the current Proposal and Award Policies and Procedures Guide (PAPPG). The University of California (UC) urges NSF not to finalize the draft guidance in its current form, expressing concern that it introduces significant policy changes affecting merit review, international collaboration, research security, publication and data-sharing requirements, indirect cost recovery, award administration, and termination authorities. UC recommends substantial revisions to preserve merit-based funding decisions, support international scientific collaboration, maintain allowable research dissemination costs, protect award stability and institutional flexibilities, reduce administrative burden, and provide a transparent, prospective implementation process. https://escholarship.org/uc/item/5bv354tk Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/5999016j Analysis of California Assembly Bill 1570: Diagnostic Imaging https://escholarship.org/uc/item/5999016j Mon, 31 Aug 2026 00:00:00 +0000 California Health Benefits Review Program https://escholarship.org/uc/item/52s372wx This comment letter responds to the Office of Management and Budget (OMB)'s proposed revisions to the Regulation for Federal Financial Assistance (Uniform Guidance). The University of California (UC) urges OMB to withdraw the proposed rule, arguing that it would weaken merit-based research funding, restrict international scientific collaboration, limit dissemination of federally funded research, expand agency authority to suspend or terminate awards, and significantly increase administrative and compliance burdens. If OMB proceeds, UC recommends substantial revisions to preserve peer review, support research collaboration and public access, maintain allowable research costs, protect award stability, and ensure a prospective, well-planned implementation process. https://escholarship.org/uc/item/52s372wx Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/5193z036 This comment letter responds to the California Institute of Regenerative Medicine (CIRM)'s proposed amendments to its Intellectual Property (IP) Policy, including the addition of Section 100650 to the California Code of Regulations. The University of California (UC) expresses significant concern that the proposed policy imposes overly broad intellectual property, data-sharing, licensing, and commercialization obligations that extend beyond CIRM-funded research and could discourage research collaborations, technology transfer, commercialization, and scientific dissemination. UC recommends narrowing the policy's scope, limiting obligations to technologies directly resulting from CIRM-funded projects, preserving academic freedom and open scientific exchange, and avoiding retroactive application of new requirements to existing awards. https://escholarship.org/uc/item/5193z036 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/4rw9g2k6 This comment letter responds to the National Institutes of Health (NIH)'s Request for Information on the Draft NIH Controlled-Access Data Policy and Proposed Revisions to the NIH Genomic Data Sharing (GDS) Policy. The University of California (UC) supports NIH’s goals of strengthening participant protections, harmonizing data-sharing requirements, and promoting responsible data stewardship, but recommends substantial clarification and additional stakeholder engagement before finalization. UC expresses concern about ambiguous policy scope, implementation costs, consent requirements, security obligations, and treatment of de-identified, legacy, and genomic data, and urges NIH to adopt clearer, risk-based, and operationally feasible approaches. https://escholarship.org/uc/item/4rw9g2k6 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/4bm8874s This comment letter responds to the California Institute for Regenerative Medicine (CIRM)'s proposed adoption of Section 100505 (CIRM Award Management Policy). The University of California (UC) generally supports the proposed policy but recommends revisions to ensure facilities and indirect cost reimbursement accurately reflects the true costs of conducting research, simplify implementation timelines for existing awards, clarify liability and indemnification provisions, and provide more practical requirements for returning unobligated funds, in order to promote fair, efficient, and sustainable research administration. https://escholarship.org/uc/item/4bm8874s Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/49w3t150 This comment letter responds to the Office of Science and Technology Policy (OSTP)'s RFI on proposed changes to Dual Use Research of Concern (DURC) and Potential Pandemic Pathogen Care and Oversight (P3CO) policies. UC supports updating DURC and P3CO oversight but warns that a broad risk-based framework could overburden institutions, dilute attention from the highest-risk research, and slow important biomedical, surveillance, vaccine, and in silico work. UC recommends maintaining a clear list-based approach, combining related biosafety programs where efficient, giving federal agencies a larger role in risk assessment, preserving rapid-response pathways, and providing detailed guidance, training, examples, decision trees, and agency contacts for institutions. https://escholarship.org/uc/item/49w3t150 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/47w4329h This comment letter requests that NASA extend the comment period for the "New Conflict of Interest and Conflict of Commitment Policy for Recipients of NASA Financial Assistance Awards" by 60 days. NASA's proposed policy was published in the Federal Register on January 30, 2023 and only provided a 30-day comment period. https://escholarship.org/uc/item/47w4329h Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/3pm6d220 This comment letter responds to the National Institutes of Health (NIH)'s request for comment on the NIH Electronic Application System for discretionary Certificates of Confidentiality (CoC). The University of California strongly supports NIH’s continued issuance of discretionary CoCs and recommends reinstating the existing electronic application system without changes, emphasizing that these protections are vital for safeguarding sensitive research participant data, supporting ethical human subjects research, and maintaining public trust while minimizing administrative delays. https://escholarship.org/uc/item/3pm6d220 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/3gg7b6cs This comment letter requests that OMB extend the comment period for the proposed revisions to 2 CFR, Subtitle A, Chapters I and II (Uniform Guidance) by 60 days. OMB's proposed revisions to the Uniform Guidance was published in the Federal Register on February 9, 2023 and only provided a 30-day comment period. https://escholarship.org/uc/item/3gg7b6cs Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/36w0q7bp This comment letter responds to the National Aeronautics and Space Administration (NASA)'s proposed Reporting Requirements Regarding Findings of Harassment, Sexual Harassment, Other Forms of Harassment, or Sexual Assault. The University of California (UC) supports NASA’s goal of addressing harassment and ensuring oversight of federally funded projects, but recommends revisions to align NASA’s requirements with existing National Science Foundation (NSF) policies, protect privacy and due process, clarify reporting obligations, and reduce administrative burden and confusion created by inconsistent federal agency requirements. https://escholarship.org/uc/item/36w0q7bp Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/3656b1x3 This comment letter responds to the California Institute of Regenerative Medicine (CIRM)'s Second Notice of Proposed Regulation Amendments concerning the revised CIRM Intellectual Property (IP) Policy. The University of California (UC) expresses appreciation that CIRM addressed many concerns raised in UC’s earlier comments, but recommends several additional clarifications to improve the policy’s implementation, including narrowing and clarifying the definition of collaborators, correcting inconsistencies in publication-related materials provisions, aligning public-access requirements with NIH standards, facilitating material-transfer requests, and clarifying appeal procedures under CIRM’s march-in rights framework. UC’s recommendations are intended to promote research collaboration, technology transfer, and practical compliance with the policy. https://escholarship.org/uc/item/3656b1x3 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/3591b3jz This comment letter responds to the Food and Drug Administration (FDA)'s guidance document, Investigator Responsibilities – Safety Reporting for Investigational Drugs and Devices. The University of California (UC) expresses concern that the guidance appears to require investigators to report all IND safety reports and certain serious adverse events to Institutional Review Boards (IRBs) as unanticipated problems. UC recommends that FDA clarify that only safety reports meeting the established criteria for an unanticipated problem should be submitted to IRBs, preserving a risk-based approach that focuses oversight on actionable safety concerns and avoids overwhelming investigators and IRBs with excessive reporting. https://escholarship.org/uc/item/3591b3jz Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/2s80v71k This comment letter responds to the National Science Foundation (NSF)'s proposed revisions to the Proposal and Award Policies and Procedures Guide (PAPPG). The University of California (UC) generally supports the proposed updates but expresses concern that expanded Current and Pending Support and Biosketch requirements would increase administrative burden, create ambiguity regarding disclosure obligations, and lack consistency with other federal agencies. UC recommends greater federal harmonization, development of a common disclosure system, clearer definitions and accountability standards, and implementation approaches that reduce burden on researchers and institutions. https://escholarship.org/uc/item/2s80v71k Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/24b9t00t This comment letter responds to the Office of Science and Technology Policy (OSTP)'s Request for Information on Accelerating the American Scientific Enterprise. The University of California (UC) strongly supports policies that strengthen U.S. research competitiveness and recommends stable and predictable federal research funding, preservation of the Bayh-Dole Act, strong intellectual property protections, expanded technology transfer and commercialization programs, streamlined research administration, and sustained investments in scientific talent, infrastructure, and regional innovation ecosystems to accelerate the translation of research into societal and economic benefits. https://escholarship.org/uc/item/24b9t00t Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/1dn5f0vm This comment letter responds to the Office of Management and Budget (OMB)'s Proposed Rule to revise sections of 2 CFR, Subtitle A, Chapters I and II (the Uniform Guidance). UC expresses support for OMB’s burden-reducing changes but said the rule still leaves uncertainty and unrecovered costs around indirect-cost rates, agency IDC limits, outdated caps, DS-2 reporting, COI scope, and subaward rules. UC recommends clearer language, stronger enforcement of negotiated IDC rates, eliminating or updating outdated requirements, clarifying procurement COI, and preserving administrative flexibility. https://escholarship.org/uc/item/1dn5f0vm Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/19t30344 This comment letter responds to the National Institutes of Health (NIH)'s Request for Information on Maximizing Research Funds by Limiting Allowable Publishing Costs. The University of California (UC) expresses concern that blanket bans or caps on publication costs could restrict researchers' ability to publish in the most appropriate venues and disproportionately burden investigators with fewer resources; instead, UC recommends transparent, federally coordinated negotiations with publishers to reduce publication costs while preserving author choice, research visibility, and broad dissemination of federally funded research. https://escholarship.org/uc/item/19t30344 Mon, 31 Aug 2026 00:00:00 +0000 UC Office of President https://escholarship.org/uc/item/0rw2x9gj This comment letter responds to the Education Department (ED)'s request for comments on the collection of information required under Section 117 of the Higher Education Act (HEA)(20 §U.S.C. 1011f), as published in the Federal Register on December 27, 2022. UC is concerned that ED significantly underestimates the burden of HEA Section 117 foreign gift and contract reporting, noting that the PEBC portal’s manual-entry process is cumbersome, repetitive, and far more time-consuming than the agency’s estimate. UC recommends allowing single-file uploads, reducing repetitive screens and manual data entry, auto-populating institutional fields, improving review and correction features, expanding institutional access to submitted data, and aligning login requirements with the six-month reporting cycle. https://escholarship.org/uc/item/0rw2x9gj Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/0jb4d1dd Analysis of California Assembly Bill 1843: Communicable Diseases: Hepatitis B and C https://escholarship.org/uc/item/0jb4d1dd Mon, 31 Aug 2026 00:00:00 +0000 California Health Benefits Review Program https://escholarship.org/uc/item/0656t0dh Advanced air mobility (AAM) is a broad concept that enables consumers access to air mobility, goods delivery, and emergency services through an integrated and connected multimodal transportation network. AAM can provide short-range urban, suburban, and rural flights of about 50-miles and mid-range regional flights up to a several hundred miles. State law delegates responsibility for oversight in aviation primarily to the California Department of Transportation (Caltrans). This white paper presents an overview of the state of the market, such as the aircraft under development and forecast market growth and discusses factors that could facilitate the development of AAM or pose risks to its deployment or to the public, including the safety and the regulatory environment, airspace and air traffic management, security, environmental impacts, weather, infrastructure and multimodal integration, workforce and economic development, social equity, and community engagement and social acceptance.... https://escholarship.org/uc/item/0656t0dh Mon, 31 Aug 2026 00:00:00 +0000 Cohen, Adam, MS Shaheen, Susan, PhD https://orcid.org/0000-0002-3350-856X https://escholarship.org/uc/item/7mz0z9qv Do electric vehicles (EVs), and the expansion of curbside charging infrastructure in particular, undermine efforts to reduce vehicle travel? As EVs gain market share, decisionmakers may be less inclined to support policies such as bicycle lanes and reduced parking if they compete for space with EV chargers. We find no evidence, however, of policy substitution. Surveys in Los Angeles indicate that public support for policies to reduce driving is not swayed by the availability of EV charging. Furthermore, interviews in North American cities reveal that local officials are cautious about locking in scarce curbspace for EVs, and universally prioritized curb uses such as bicycle and bus lanes, street trees, and parklets. In our sample of early adopter cities, EV charging is not currently diminishing the political will for policies to reduce driving. However, this caution has slowed the rollout of curbside charging in North America. https://escholarship.org/uc/item/7mz0z9qv Fri, 28 Aug 2026 00:00:00 +0000 Millard-Ball, Adam https://orcid.org/0000-0002-2353-8730 Law, Jasmine https://escholarship.org/uc/item/6qh313h9 BACKGROUND: Safe passage interventions aim to enhance public safety and improve access to community resources, including public parks, in underserved communities. However, no studies have directly compared community- and police-led safety interventions with respect to park-based moderate to vigorous physical activity (MVPA). To address this gap, we compared associations between Community-led Safe Passage Services (SPS) and the Los Angeles Police Department Community Safety Partnership (CSP) program with MVPA in South Los Angeles public parks. METHODS: We conducted structured observations of 3997 park users across 8 SPS and 9 CSP parks in South Los Angeles using the System for Observing Play and Recreation in Communities and the Physical Activity Resource Assessment. We applied t tests, analysis of variance, and hierarchical linear models to examine MVPA across park intervention types. RESULTS: Overall, MVPA was higher in SPS parks (P < .001). Black, male, teen, and adult park... https://escholarship.org/uc/item/6qh313h9 Fri, 28 Aug 2026 00:00:00 +0000 Douglas, Jason A Huo, Shutong Ruiz Malagon, Juan Carlos Delgado, Valeria Ramos, Melissa Owens, Ben Taco Orange, Kevin Twin https://escholarship.org/uc/item/6p03t9fz This white paper reconsiders the equity of road pricing by distinguishing between fairness and affordability—two concepts that are otherwise often conflated. A fair price assigns costs in proportion to the burdens a user imposes on others; an affordable price is one that users can pay without hardship. While both are important, these are distinct objectives, and treating them as interchangeable can obscure judgments about whether pricing is morally or ethically correct. Applying this framework suggests congestion pricing is more equitable than flat VMT charges because it better aligns payments with the social costs of driving. While congestion pricing may raise affordability concerns for some users, these concerns can be addressed through targeted redistribution of toll revenues. By contrast, unpriced roads and poorly targeted charges allow drivers to impose substantial external costs on others, undermining fairness even as they appear more affordable. https://escholarship.org/uc/item/6p03t9fz Thu, 27 Aug 2026 00:00:00 +0000 Manville, Michael, PhD https://escholarship.org/uc/item/6gh3f3qw This white paper examines the successes and failures of road pricing strategies in California and the United States, with implications for congestion pricing across California. It evaluates nine case studies spanning feasibility studies, operational HOT lane programs, and the country's first large-scale cordon pricing zone. We address the conditions that favor pricing, barriers, outcomes, and how costs and benefits are distributed using case studies in Los Angeles, San Diego, San Francisco, San Mateo County, Alameda County, New York City, and Northern Virginia. We find that successful pricing programs have sustained political champions, state enabling legislation, and benefits visible to identifiable users. Revenue allocation, not toll structure, is the primary determinant of whether pricing is regressive or progressive. No pricing program reviewed was repealed after implementation. We conclude that advancing road pricing in California will require clear state leadership and supportive... https://escholarship.org/uc/item/6gh3f3qw Wed, 26 Aug 2026 00:00:00 +0000 Huang, Emma Barry, Erin Schank, Joshua L., PhD Terplan, Egon, PhD https://escholarship.org/uc/item/8b52q3s4 The first asphalt concrete long-life (AC Long Life) project was constructed in Los Angeles County on Route 710 (LA-710) near Long Beach in 2001/2004 and is now over 20 years old. Four more AC Long Life projects have been completed in California since then, three between 2011 and 2014 (TEH-5, SIS-5, SOL-5), and one in 2021/2022 (SAC-5). The goal of these AC Long Life projects was to achieve design lives of 30 years or 40 years (the standard Caltrans asphalt pavement design life was 20 years at the time). Measures taken to achieve those lives included the use of performance-related specifications for job mix formula approvals, higher compaction requirements, and the use of a three-layer asphalt concrete system for structural capacity. These measures required additional costs. Calculations indicate that the longer lives will result in life cycle cost reductions if they achieve the design lives. Hence, periodic performance evaluations are important, which is the purpose of this technical... https://escholarship.org/uc/item/8b52q3s4 Tue, 25 Aug 2026 00:00:00 +0000 Wu, Rongzong Lea, Jeremy Harvey, John Guada, Irwin Rahman, Mohammad https://escholarship.org/uc/item/6291s66s Analysis of California Assembly Bill 1887: Prescription Drug Coverage for Rare Diseases https://escholarship.org/uc/item/6291s66s Tue, 25 Aug 2026 00:00:00 +0000 California Health Benefits Review Program https://escholarship.org/uc/item/0vk9j24v California is transitioning heavy-duty freight trucks from diesel to battery-electric vehicles to help meet its climate and air quality goals. Unlike passenger vehicles, electric trucks require much larger batteries and high-powered chargers, creating concentrated demands on the electric grid. At the same time, freight carriers operate under strict schedules that leave little flexibility in when and how long trucks can charge. As freight electrification expands, coordinating truck operations, charging infrastructure, and grid planning will become increasingly important. https://escholarship.org/uc/item/0vk9j24v Tue, 25 Aug 2026 00:00:00 +0000 Jaller, Miguel, PhD