From 9e24d597958ebcd21c40f8cf69e38f134b2d7cb5 Mon Sep 17 00:00:00 2001 From: hrbrmstr Date: Sun, 23 Aug 2026 10:16:24 -0400 Subject: add: nsf comment --- 2026/nsf-2026-OTR-0001-0002.txt | 1 + 1 file changed, 1 insertion(+) create mode 100644 2026/nsf-2026-OTR-0001-0002.txt (limited to ':') diff --git a/2026/nsf-2026-OTR-0001-0002.txt b/2026/nsf-2026-OTR-0001-0002.txt new file mode 100644 index 0000000..ae68dd3 --- /dev/null +++ b/2026/nsf-2026-OTR-0001-0002.txt @@ -0,0 +1 @@ +I ask NSF to withdraw the draft Guidance on Financial Assistance in full. If NSF does not withdraw the draft, I ask NSF to hold it until OMB completes its rulemaking on 2 CFR 200. I am a security engineer. I work on internet measurement and internet intelligence. I do not hold an NSF award. I write because my field is a direct product of NSF-supported research. The ZMap scanner started in a university laboratory & was the first public result of that work. The authors of the ZMap paper state that NSF grant CNS-1255153 and an NSF Graduate Research Fellowship gave partial support for it. That scanner became a commercial internet intelligence platform. Thousands of defenders now use tools that descend from it. This pattern is common in security. Federal research money produced the transport-layer-security measurements, the botnet studies, and the certificate-ecosystem work that defenders apply each day. The current PAPPG (NSF 24-1), Chapter XII.A.2.a(i), lists the specific situations in which NSF can suspend or terminate an award. NSF wrote that list. NSF owns it. The draft removes the list. Guide 25, Section A, Policies, item 1, keeps only a reference to 2 CFR 200.339 and 2 CFR 200.340. The reference gives no date and no version. The summary of changes for Guide 25 states that the guide aligns the termination provisions with the proposed revisions to 2 CFR 200. Those revisions are not final. OMB published them on May 29, 2026 (Docket OMB-2026-0034, 91 FR 32198). The comment period closed on July 13, 2026. OMB has not published a final rule. This construction has an effect that NSF should state plainly. If OMB changes 2 CFR 200.340, the NSF standard changes at the same moment. NSF holds no further rulemaking. The public gets no further comment period. NSF adopts a standard that it has not read in final form. The proposed 2 CFR 200.340 permits termination when an award does not effectuate program goals, agency priorities, or the national interest as those exist at the time of termination. The proposed text does not define "national interest." An undefined term applied at the moment of termination is not a standard. It is a permission. Guide 25, Section A, Procedures, item 1(a) keeps NSF's authority to suspend or terminate an award immediately to protect the interests of the government. Item 1(e) confirms that NSF will not issue a notice of non-compliance in that case. The recipient gets no statement of the deficiency and no time to correct it. That authority is not new. Its combination with an undefined and self-updating standard is new. The introduction to Section A also gives "changes in priorities" as a common reason to pause or end an award. A change in priorities is not a failure by the recipient. The recipient cannot correct it, cannot predict it, and cannot plan against it. Guide 26 gives review rights. Those rights have less value when the recipient receives no written basis for the action. NSF should not create a path in which an award ends before the recipient learns the reason. Guide 13, Section D, defines Gold Standard Science and cites Executive Order 14303. The section contains one policy sentence. It gives no review criteria, no scoring method, no process, and no point in the award lifecycle at which NSF applies it. NSF staff cannot apply this section in a consistent manner. A proposer cannot show compliance with it. A recipient cannot defend against a claim of non-compliance with it. A standard that no party can measure does not improve science. It supplies a reason for a decision that was made on other grounds. Guide 19 removes the references to Section 504 coordinators, Title IX coordinators, and age discrimination evaluations. The underlying statutes stay in force. Recipients keep the legal duty and lose the guidance that helped them meet it. This change adds risk for recipients and removes no burden from them. I read the primary security literature each week and write about it for practitioners. The results that matter to defenders come from long work. Internet-scale measurement, protocol analysis, botnet study, and post-quantum readiness each need several years before they give an operational result. Short projects do not produce them. An award that a political actor can end at any time is not a basis for a multi-year project. Investigators will choose small and safe work. Universities will admit fewer graduate students. The pipeline that supplies the security industry will narrow. Adversaries do not change their schedule when United States funding priorities change. A reduction in long-horizon defensive research is a national security cost. NSF should weigh that cost in this collection. NSF paid for the research that lets defenders see the internet. The rules in this draft make that kind of research harder to start and harder to finish. I ask NSF to reconsider them. -- cgit v1.2.3