Comment on FR Doc # 2026-13248

Title VI and Fulbright-Hays Programs fund necessarily long-term endeavors that build American human capacity to understand regions of strategic importance. The importance of deep, local knowledge for diplomacy, military intelligence and business should be obvious, but it is also important in fields such as cybersecurity. In that field, AI cannot take the place of human language capacity; for example, AI cannot accurately translate languages that are not widely used online. Cyberattackers know this, and can communicate in obscure languages without detection if American cybersecurity professionals do not include people trained in such languages. Building language competency is a valuable but long-term process, like pursuing basic science, and both must be supported steadfastly, across changes of political administrations. As a Teaching Fulbright recipient who taught English to East German high school students after the fall of the Berlin Wall, work which has prepared me for volunteer work teaching English to new Americans, I can tell you that there are not enough English language learning materials created for learners who start from an obscure language; that work, too, is supported when the understanding of those languages is supported. The department has not demonstrated that existing regulations impose unnecessary burdens. The proposal repeatedly states that existing regulations are unnecessarily burdensome but does not identify or quantify the burdens, nor explain why targeted amendments would not adequately address those concerns. Existing regulations promote fair competition, and predictability. The proposed changes would eliminate regulations that provide the sole legal guarantees that federal funding be administered through a fair and rigorous review process. 34 CFR Part 662, governing Fulbright-Hays, requires the Department of Education to evaluate the quality of application materials, assess the qualifications of applicants, and seek input from external panels of academic specialists, providing foundational guarantees that applicants will be evaluated based on the merits of their proposals. The role of specialists in the process is absolutely crucial for choosing the most effective, workable, and impactful projects. Institutions make substantial long-term investments in faculty, language instruction, international partnerships, and graduate training in reliance on the stable administration of these programs. The Department argues that rescission is necessary to permit greater flexibility and responsiveness to changing geopolitical circumstances. However, Title VI and Fulbright-Hays programs already provide sufficient flexibility through annual Notices Inviting Applications, competition priorities, and discretionary grant administration. Eliminating expert review from the loop will lead to funding duplicative, insufficiently focused, or poorly researched projects and almost certainly to failure to fund proposals that a nonspecialist has insufficient context to grasp. While it is the work of diplomats to pursue immediate foreign policy objectives, that is not the work of people who are in the position of building expertise and capacity in languages and cultures. The U.S. requires a robust infrastructure for building cross-language, cross-cultural expertise that political appointees may draw upon in their own work, via consultation, and that American business across sectors can also access. That infrastructure depends on steady involvement of subject-specialist experts, working on timelines and institutional knowledge and context beyond political cycles. I urge the Department of Education to retain the existing regulations and not finalize the proposed rule.