Comment from Destenie Nock

I am a professor at Carnegie Mellon University. [200.340] I oppose the proposed expansion and codification of discretionary authority to terminate active federal awards when an agency or pass-through entity concludes that termination is in its interest, including when an award no longer effectuates current agency priorities or the national interest. Scientific research requires long-term planning. Principal investigators hire graduate students and postdoctoral researchers, build partnerships, acquire data, develop models, and make commitments based on the reasonable expectation that an awarded grant will continue if the research team complies with the terms of the award. The proposed rule would make those commitments much harder to undertake responsibly. The concern is not that grants should continue regardless of performance. Federal agencies already need tools to respond to misconduct, noncompliance, or failure to meet award requirements. The concern is that a project could be terminated after it has been competitively awarded and responsibly managed because political priorities have changed. That erodes the science integrity. In energy-systems research, some of the most important questions require longitudinal data, sustained collaboration with communities or utilities, and careful analysis over multiple years. A research team cannot responsibly promise continuity to project partners or trainees if funding may disappear midstream for reasons unrelated to the scientific quality or responsible management of the work. This instability would fall heavily on trainees and early-career researchers. Graduate students and postdoctoral researchers make career decisions based on funded projects. They relocate, build technical expertise, and devote years to research questions that often serve the public interest. A sudden termination can disrupt a dissertation, delay a degree, eliminate a salary, or push a talented researcher out of the field entirely. OMB argues that recipients can account for this risk when deciding whether to accept an award.⁵ But a system in which researchers must assume that a responsibly managed federal award may be terminated because priorities changed is not a stable foundation for scientific progress. It would discourage ambitious research, weaken the training pipeline, and make it harder for the United States to retain talented researchers. I urge OMB to limit mid-award terminations to clearly defined circumstances, such as misconduct, noncompliance, a failure to meet award requirements, or circumstances specifically authorized by statute. A change in political priorities should not, by itself, be sufficient reason to terminate a responsibly managed scientific award.