Comment on FR Doc # 2026-13248

The Department of Education's rationale that full regulatory rescission is required to achieve administrative flexibility, workforce readiness, and national competitiveness is fundamentally flawed. The Department already has authority to advance evolving national priorities within the current regulatory architecture, since existing procedural rules do not prevent it from modernizing its Request for Proposals (RFP). Eliminating the regulations creates severe institutional instability, destroys public accountability, and undermines the long-term national security and educational infrastructure of the United States. Using the Language Resource Centers (LRC) Program (34 CFR Part 669) as a case study, this comment demonstrates why total deregulation is not in the nation's best interest. I submit this comment in my individual capacity as a concerned citizen. My perspective is informed by firsthand experience administering federal funds as Director of a National Foreign Language Resource Center (NFLRC) and witnessing both the extraordinary national impact of the LRC network and the acute damage caused when established funding cycles were abruptly disrupted in 2025. The views expressed are my own and do not represent the official position of the University of Hawai‘i at Mānoa or any other institution. I identify my former role solely to establish the basis of my knowledge. The following are my reasons for opposing total rescission of the regulations: 1. Procedural rules are NOT a barrier to modernization The Department’s primary justification, that it must strip away regulations to pivot quickly toward priorities such as workforce readiness, is incorrect. The existing framework establishes broad parameters for eligibility, evaluation, and purpose while leaving ample room for the agency to tailor grant competitions. Programmatic modernization should occur through the RFP process, not through wholesale elimination of transparent oversight rules. 2. Authorized under 20 U.S.C. § 1123 during the presidency of George H. W. Bush, the Language Resource Center national network has served as a critical pillar of America's educational and geopolitical infrastructure. LRCs address national language capabilities that no single school district, university, or state can handle independently. Their value is cumulative and cannot be measured within a single budget year. They create lasting capacity through (1) resource creation: developing free open educational resources that remain available for years; (2) professional development: building long-term educator expertise in languages of national interest; and (3) systemic research: advancing language assessments and instructional practices that support evidence-based education and influence national pedagogy. Multi-year educational grants rely on a predictable sequence of development, implementation, evaluation, and dissemination. Abruptly ending support before a cycle concludes, as the Department unwisely did in 2025, diminishes the value of previous federal investments. Funding disruptions have directly resulted in (1) incomplete instructional materials; (2) canceled professional development for hundreds of teachers; (3) unfulfilled obligations to institutional partners; and (4) immediate loss of specialized staff, accumulated expertise, and trusted collaborations. If this level of damage can be inflicted within a regulated program, the public must imagine the consequences of rescinding regulations without specifying what will replace them. Eliminating the rules while leaving the replacement framework blank creates a dangerous regulatory vacuum. The proposed rule suggests a shift toward contracts, subgrants, and elimination of peer review to save costs. This flawed fiscal rationale confuses minor administrative savings with destruction of high-yield federal investments. Independent peer review is vital to ensure awards are based on merit, feasibility, and national need rather than political preference. Furthermore, university-based centers are not mere vendors delivering transactional, short-term products; they are institutions that cultivate sustained national expertise over decades. I respectfully request that the Department of Education: 1. Withdraw the proposed rescission of 34 CFR Part 669 and instead pursue targeted amendments if specific provisions genuinely require updating. 2. Affirm a commitment to maintaining a national network of competitively selected, university-based Language Resource Centers rather than replacing them with centralized contracts or less effective intermediary organizations. 3. Provide a public comment period with explicit details if the Department intends to fundamentally alter service-delivery mechanisms, such as shifting from grants to contracts. 4. Establish a formal continuity plan before enacting structural changes that threaten to dismantle existing national language capacity.