Comment on FR Doc # 2026-12725 from Fred Oswald

NSF is a federal agency established by Congress “to promote the progress of science; to advance the national health, prosperity, and welfare; and to secure the national defense.” My comments are provided in the spirit of this Congressional mandate. [G8.Authorities] I am OPPOSED to this revision. Although the GFA Summary of Changes states that “no significant changes are made to Proposal Processing and Merit Review,” the proposed revisions to 2 CFR 200.205 provide that senior agency appointees must ensure that discretionary awards advance the President’s policy priorities. This takes a much narrower focus, one with both political and practical barriers, than America’s history of investing soundly in both basic and applied science to ultimately strengthen national wellbeing and prosperity. In the 1970s, for example, NSF invested in studies of visual and cognitive processing in psychology, which were not necessarily forecasted to have any short-term practical use. And yet this very work was the foundation for today’s advances in AI and machine learning that are breaking new ground in cybersecurity, financial modeling, and the development of next-generation drug treatments, to name a few areas. Many areas of scientific advancement may seem unimportant now, maybe silly even, but then become vitally important later. Examples include curiosity-driven mathematics that contribute to cryptography, and the exploration of bacterial defenses that led to the CRISPR gene-editing tool. The GFA also cites 2 CFR Part 200, which states that peer review remains advisory and does not replace agency discretion. Because 2 CFR Part 200 supersedes the GFA, this provision could significantly tilt the balance from scientific peer review toward political discretion in funding decisions. Scientific investment and advancement require more time and steadier hands than being directed by the Republican and Democratic winds of political influence. This is not to say that scientific peer review is perfect; it is not. In fact, there is a rapidly growing area of research called metascience, where scientific peer review and the process of conducting research is actually a research topic in and of itself, in the attempt to improve it (e.g., see the Congressionally mandated National Academy of Sciences report, “Reproducibility and Replicability in Science”) [G25.A.Term 2] I am OPPOSED to this revision because "broader discretionary authority" opens the door for agencies to cancel active, peer-reviewed projects midstream simply because political or presidential priorities change. Moreover, active grants require investing in resources that would be wasted by cancellation (e.g., expensive equipment, hiring graduate students, and multi-year planning). The investments and commitment to scientific progress, and the careers of scientists, get deeply disrupted. Broad termination powers shift ultimate control to political appointees and devalue independent scientific consensus. Maybe this is in fact the goal, but it is done at the peril of America losing its dominant status in the sciences to other countries. [G12.A.Term 1] I am OPPOSED to this revision, for reasons related to the above. Here, conference attendance would be viewed as allowable only if expressly approved by the agency. Further, publication costs are viewed as not inherently necessary to carry out the core programmatic objectives of most federal awards. Although I appreciate the spirit of the concerns being addressed, the timing and judgment required for approving conferences and travel would be far too slow. Alternatively, scientists would likely benefit from receiving timely, relevant information about new conferences, outlets, and opportunities for the appropriate dissemination of their work. This approach might bolster intra- and inter-disciplinary scientific communication and networking. But as it stands, the revision would stand to stifle scientific communication and advancement that is core to our dominant scientific standing internationally.