Comment on FR Doc # 2026-13248

As someone who has been familiar with these programs from many perspectives--as a Fulbright-Hays and Title VI grantee, a former Title VI center director, a product of a Title VI center, and, most importantly, a scholar who draws continually on the human and intellectual capital these programs have produced--I strongly oppose the proposed wholesale rescission of the existing regulations. Title VI and Fulbright-Hays were consciously and explicitly designed not simply to respond to the needs of a particular moment, but to build and sustain a durable national capacity in foreign languages, area studies, international research, overseas training, and the dissemination of international knowledge. Their statutory purposes expressly include producing trained personnel and research, developing a pool of international experts to meet national needs, strengthening instruction in less commonly taught languages, and supporting access to research and training abroad. Over many decades, these programs have constructed an infrastructure for scholarship, teaching, language training, and international understanding unequalled anywhere in the world. That infrastructure consists not merely of individual grants, but of faculty expertise, language programs, libraries, graduate training, overseas relationships, and institutional networks that take years to build and can be quickly weakened or lost. Its value often becomes most apparent only when a new political, economic, diplomatic, or security need suddenly arises. The Department argues that rescission would permit the programs to respond more readily to current events, changing geopolitical circumstances, and administration priorities. But that flexibility carries a serious danger: it would make programs designed to create long-term national capacity increasingly vulnerable to the short-term and shifting concerns of the moment. The strength of Title VI and Fulbright-Hays lies precisely in sustaining knowledge and expertise before an immediate need makes their importance obvious. Rescission would be like redesigning an automobile to get through the next traffic light before it turns red, without regard to whether it can complete the journey. The Department also understates the reliance interests involved. The relevant reliance interest is not an expectation that any particular institution will continue to receive a competitive grant. It is the much broader national and institutional investment made in response to a stable federal framework. Universities have built programs, hired faculty, trained students, developed language offerings, assembled research collections, and created international partnerships on the understanding that these activities form part of an enduring national commitment. Eliminating that framework altogether, without replacing it with protections for the long-term purposes of the programs, would be contrary to their intent and damaging to their ability to meet long-term national needs. I therefore urge the Department not to proceed with full rescission.