Comment on FR Doc # 2026-12725 from Markus Hoffmann

To whom it may concern, I, Markus Hoffmann, Ph.D, Professor at SUNY Brockport, NY, a principally undergraduate institution (PUI), am commenting on the intended guideline change for NSF programs that article processing charges (APCs) for open access publication will become illegitimate expenses for NSF grants. Current APCs are typically about $4,000. For context, recently the entire annual budget for supplies and equipment at SUNY Brockport for the Department of Chemistry and Biochemistry has fallen below $15,000. At best (and even that is highly questionable), our funds could support one APC in a year where we are lucky to have no unexpected expenses. I am currently an NSF grant holder and publish 2-3 articles per year where I would need to acknowledge the support of NSF and thus, as per recently changed requirements, must publish the articles in an open access format with associated APCs. So, what would be my options? Finding other internal sources? At SUNY Brockport there are some small dollar programs such as the scholarly incentive grant, but in dollar amount these do not exceed $1000 and they are typically meant to support the start of new research not the dissemination of completed research. The library will not be able to stop subscriptions to journals to free up money because the journals are of international scope and therefore not all articles will be open-access articles. At best, there might be one-time support I could muster to find internally but nothing campus wide on an ongoing basis. I could just pay for the APC myself. The current NSF grant I have supports me for 1.5 months of summer salary. (I could have asked for 2 months but did not do that to keep my proposal competitive by showing a high percentage of the budget paid in support of students.) Importantly, if I were to use my own money, it would indirectly mean that I use my NSF summer salary for APC charges. My summer salary, however, comes with additional indirect costs, which are substantial, to the best of my knowledge currently amounting to 55 cents for every dollar spent on my salary. Thus, NSF would indirectly pay 55% more to get the articles published for open access. Clearly, stopping the coverage of APC charges is counterproductive as this change will likely cause new knowledge not becoming publicly available. The whole purpose of research is to gain new knowledge for the public good. This proposed budget change will discourage research altogether. Not everyone is like me who devotes the summer months, where I have no academic obligations, to conduct research with undergraduates, which also helps them become professional. Why would I keep doing that if I must come up with my own money to publish the new results and findings?