Comment on FR Doc # 2026-12725 from Erika Lin

I am writing to express my opposition to the NSF's updated Proposal and Award Policies and Procedures Guide, NSF-2026-OTR-0001-0002. This change aligns with the OMB's Regulation for Federal Financial Assistance rule, which aims to give political appointees oversight over federal grant funding. Peer review is the heart of our scientific system. It requires experts who are SPECIALISTS IN THEIR SUBFIELDS (not just their disciplines in general) to make nuanced judgment calls regarding the quality of research proposals and methodologies. To give political appointees the final word on such matters will completely undermine this process. As a cancer survivor and a university professor, I cannot stress enough the importance of the rigor of peer review. It is crucial that research be evaluated by experts with decades of training in particular relevant subspecializations. You don't ask your dentist for advice about your brain tumor. You don't ask your heart surgeon to operate on your cataracts. Specialized expertise is crucial. This kind of rigor in peer review is what enables us to have new treatments for medical conditions as well as innovative solutions to other public problems, such as climate change. Do you want to have this summer's air quality problems become so common that you have to live your life indoors forever? Can't we study better solutions to wildfires? But what if political appointees decide this kind of research is troubling? Without peer review's rigorous standards, everyone's quality of life will decline. The NSF's updated Proposal and Award Policies and Procedures Guide will completely compromise the value and validity of research findings by interfering with the peer review process. The ultimate cost, financially not just in terms of human lives, will be enormous. Moreover, in interfering with research projects developed and implemented in conjunction with colleagues around the world, the proposed rule completely goes against how the best research is done. Experts rely on other experts, no matter whether they are based in the US or abroad. There are often only a handful of people who really understand the intricacies of a specific kind of research. The whole world should be working together to solve problems like cancer and climate change--these are things that affect us all across national borders! The NSF should not allow non-specialists to arbitrarily declare that talented experts who have unique experience and knowledge in a certain subfield be restricted (or, worse, banned entirely) from participating in specific research projects. As well, the limitations being imposed on communications and publishing make no sense. Are we no longer going to be allowed to share our research with colleagues, so as to learn and grow from their expertise? Last but certainly not least, the NSF rule's regulatory changes and new information collection policies are a major infringement on speech and academic freedom at universities and other independent research institutions. The proposed rule change attempts to codify unprecedented political overreach. I oppose it strongly.