Comment from Destenie Nock

I am an Associate professor at Carnegie Mellon University. I am commenting on [200.461] because I oppose the proposal to make publication costs, including article-processing charges and open-access fees, presumptively unallowable unless specifically required by statute or approved in advance by the agency on a case-by-case basis. [200.432] I oppose the proposed requirement that conference-attendance costs be allowable only when participation is expressly approved by the federal agency and included in the terms and conditions of the award. Scientific research is not a process in which every valuable opportunity can be predicted at the moment a grant is issued. Over the course of an award, researchers may be invited to present new results, participate in workshops, respond to emerging events, join interdisciplinary collaborations, or share findings with practitioners and policymakers. These opportunities often arise because the research itself has produced important and unexpected insights. In my field, conferences and workshops are where researchers test ideas, receive technical critique, identify limitations, learn about new methods, and connect with utilities, regulators, public agencies, and community partners. For researchers working on energy systems, these forums can shape how evidence reaches the institutions making decisions about infrastructure and how those costs are passed onto the general public. The proposed requirement would be especially burdensome for graduate students, postdoctoral researchers, and early-career investigators. Conference participation is often an essential part of professional development. It is where trainees receive feedback, build networks, and begin to establish independent research identities. A rule that requires every conference opportunity to be anticipated and written into the initial terms of an award would reduce flexibility and disproportionately limit opportunities for researchers who have the least access to alternative sources of funding. I urge OMB to withdraw the proposed revision to Section 200.432. Reasonable conference-attendance costs that advance the goals of an award should remain allowable under established institutional and agency policies. The proposed language creates a direct tension with the federal government’s public-access goals. The August 2022 Office of Science and Technology Policy memorandum, Ensuring Free, Immediate, and Equitable Access to Federally Funded Research, directed agencies to update their public-access policies so that publications arising from federally funded research would be made freely and immediately available to the public (see attachment). The proposed rule acknowledges that a general public-access requirement would not, by itself, authorize publication costs. This places researchers in an untenable position. Scientists would be expected to make federally funded work publicly accessible while being unable to reliably budget federal funds for the costs required by many publication venues. Case-by-case approval does not solve the problem. Publication decisions often occur years after an award is issued, after results are known and after the appropriate journal has been identified. Requiring researchers to seek discretionary approval at that stage creates delay, uncertainty, and administrative burden. In my work, publication is a key part of the research process. It is how findings are scrutinized, improved, and made available to the public. Research on energy affordability, infrastructure resilience, and household experiences is particularly important to utilities, regulators, and policymakers who may not have access to subscription journals. Restricting publication support risks suppressing the scientific record and limiting the public return on taxpayer-funded research. It is necesseary for the public. I urge OMB to retain the existing allowability of reasonable publication costs, including article-processing charges and open-access fees, when those costs support the dissemination of work produced under a federal award.