Comment on FR Doc # 2026-12725 from Sheila Kannappan

Dear NSF, I write to oppose the proposed NSF rule change in Docket NSF-2026-OTR-0001. I am an astrophysicist and a US citizen. I have served on NSF review panels and won multiple NSF fellowships and NSF grants. The summary of changes in NSF-2026-OTR-0001-0003 states that a key goal of the NSF's rule change proposal is "aligning with proposed revisions to the Office of Management and Budget's (OMB) Uniform Guidance at 2 CFR 200 through the proposed rule published on May 29, 2026". Critically, the OMB's proposed revisions are just that: *proposed*. Over a quarter million independent comments (not form letters) were filed with the OMB in opposition to these proposed revisions, because they are DISASTROUS for US scientific productivity and global leadership. It is premature for the NSF to adopt merely proposed, highly controversial rule changes in advance of their potential revision in response to public comment. The NSF should especially avoid ANY adoption of the following controversial elements of OMB-2026-0034-0001: * discretionary termination (200.340): This rule change would allow political appointees to cancel active grants without due process. If basic astrophysics research grants like mine were abruptly terminated with neither warning nor a meaningful appeal process, student trainees would literally lose stipends in the middle of educational and training programs, so they could not buy groceries much less continue their scientific careers. My grants have often supported first-generation-to-college students who realized the "American Dream" of upward mobility through scientific training. Grant cancellation would likely dash such dreams, impoverishing our economy and our international leadership in science. * alignment with administration priorities (200.202(a) and 200.205): While it is normal for science funding to align with government priorities through the annual budget negotiation process, these two proposed rule changes go too far in privileging the executive branch, for example in allowing presidential priorities to override peer review. If enacted such changes would create a pendulum swing of right-left-right-left with each administration, antithetical to the steady progress of science. Science is uniquely effective precisely because it is NOT answerable to power but instead "speaks truth to power", ever since Galileo told the Catholic Church that the Earth goes around the Sun and not vice-versa. "Heretic" Galileo laid the foundations of modern science, and for centuries since, free inquiry has made science the primary driver of human progress. * shrinking the scientific community (200.202(e), 200.206, 200.220, 200.218, 200.300, 200.450): These proposed rule changes would cripple US science by cutting off international collaboration or enforcing viewpoint conformity. Science is and must remain a project of *all* of humanity. We are smarter together, and our problems are global. Much of my best published work has involved coauthors from other countries, including the UK, Australia, India, and South Africa. Moreover, science is self-censoring -- with data, not politics, doing the censoring. Scientists' reliance on data rather than foregone conclusions offers a crucial antidote to the polarized viewpoints that now plague America. * freezing scientific communication (200.432, 200.454, 200.461). These OMB proposals to restrict funding for dissemination of results via publications or conferences are wholly misguided and would create unmitigated disaster. There is simply no value in having scientists each work separately in their own silos without sharing ideas and results. Every research paper I write requires extensive research on what others have done, not just for comparison, but because people publish useful measurements and derivations that I don't need to reinvent. And even though I read hundreds of papers, the best ideas always come from brainstorming with others at conferences. Please wholly retract the proposed NSF rule change in Docket NSF-2026-OTR-0001, and do not propose another version until the public comment process on OMB-2026-0034-0001 has played out. Thank you, Sheila Kannappan