PAPPG comments and responses

Exhibit 2

Number

1

Comment Source

University of Illinois at
Urbana-Champaign

Topic & PAPPG Section

Separate Sections for Intellectual Merit &
Broader Impacts
Chapter II.C.2d(i) and Exhibit II-1

2

University of Illinois at
Urbana-Champaign

3

University of Illinois at
Urbana-Champaign

4

CHORUS

Collaborators & Other Affiliations
Chapter II.C.1e

Miscellaneous Comment
Public Access Plan
Miscellaneous Comment
Public Access Plan

5

CHORUS
Miscellaneous Comment

Public Access Plan
6

CHORUS
Miscellaneous Comment

Public Access Plan
7

CHORUS
Miscellaneous Comment

Preliminary Proposals
8

COGR
Chapter I.D.2

Comment

NSF Response/Resolution

Clarify the discrepancy between the wording of the requirements for the project description’s contents (II.C.2d(i)), and
the Proposal Preparation Checklist (Exhibit II-1).  The policy section does not address having “Intellectual Merit” as a
The checklist has been corrected to clarify NSF
required separate section within the narrative.  Whereas the Checklist says “Project Description contains, as a separate requirements.
section within the narrative, sections labeled “Intellectual Merit” and “Broader Impacts.”
Remove ambiguity from Chapter II.C.1e.  Collaborators & Other Affiliations Information (third bullet):  “A list of all
persons (including their organizational affiliations, if known), with whom the individual has had an association as thesis
advisor, or with whom the individual has had an association within the last five years as a postgraduate-scholar
NSF has revised this language to address the
sponsor.”  [emphasis added]. Does the requirement, “within the last five years”, apply only to postdocs, or to both
concern identified.
postdocs and graduate student advisees? The ambiguity could be avoided by separating the single item into two
separate ones—one for former graduate students and one for postdocs.
Increase the font size of NSF solicitations, preferably matching the NSF requirements for proposal documents. 
Currently, NSF solicitations are published in very small font that is difficult to read.
In moving ahead, we urge NSF to continue to maintain and develop public-private partnerships. Such efforts will help
the NSF contain costs, reduce the burden on researchers and their institutions, and ensure sustainable, broad public
access to scholarly communication.
We are pleased to note that the Plan voices a strong commitment to ongoing consultation and collaboration with the
diverse array of stakeholders in the scholarly communications community. That commitment has been evident in
CHORUS’ discussions with NSF over the past two years and we look forward to continuing to work with the NSF and
other stakeholders to achieve our shared goal.

A user can adjust these settings manually on their
computer. As such it is not necessary for the
Foundation to take further action.
NSF thanks you for your comment.

NSF thanks you for your comment.

CHORUS is involved with a number of initiatives (the CrossRef–DataCite Pilot, SHARE, and the RDA-WDS Publishing
Data Services Working Group, and potentially, the RMap Project, Dataverse, Figshare, and Dryad) to investigate tools
and services that support researchers with their data management plans and help funding bodies with compliance
NSF thanks you for your comment.
tracking. We believe the need to develop and evolve data standards is critical. We therefore strongly encourage NSF to
actively partner with some or all of these organizations, which are already overseeing the development of standards
that deploy existing tools (e.g., DOIs, CrossRef’s FundRef, and ORCID).
CHORUS is very interested in working with NSF and other funding agencies, publishers, data archive managers, and
other stakeholders on developing mechanisms to connect articles and related datasets, for example, via developing
NSF thanks you for your comment.
publishers’ systems to enable authors to submit their data to an appropriate archive and simultaneously link this to an
article.
The PI then forwards the proposal to the appropriate office at his/her organization, and the Authorized Organizational
Representative (AOR) signs and submits the preliminary proposal via use of NSF’s electronic systems.
NSF has always required certifications to be
submitted by the AOR. As such, there is no change
The existing requirements do not limit personnel to that of only the AOR in providing proposal certifications. Given the to this policy.
volume of proposals reviewed, we request that the current language remain.

In submission of a proposal for funding by the AOR, the AOR is required to provide certain proposal certifications. This
certification process will concur concurrently with the submission of the proposal.
Submission Instructions
9

COGR
Chapter I.G.2

Proposal Certifications
10

COGR
Chapter II.C.1d

Biographical Sketches
11

COGR
Chapter II.C.2f(ii)

The revision of this section removes the ability to designate separate authorities
to SRO’s in FastLane for personnel other than the AOR to submit certain certifications. Additionally, it removes the
current requirement to provide the required AOR certifications within five (5) working days following e-submission of
the proposal. We request that the current language remain as is which allows more flexibility to meet required
deadlines and reduces the burden of the AOR and the ability to make mistakes during peak deadline times.
The AOR must use the "Authorized Organizational Representative function" in FastLane to sign
and submit the proposal, including the proposal certifications. It is the proposing organization's responsibility
to assure that only properly authorized individuals sign in this capacity.
We request that the current language remain which makes clear that SRO’s can be authorized to
electronically submit the proposal after review by the AOR.

A biographical
sketch (limited to two pages) is required for each individual identified as senior personnel.
“Other Personnel” biographical information can be uploaded along with the Biosketches for Senior Personnel
in the Biosketches section of the proposal.
It is not clear that whether biosketches for non-senior personnel should be uploaded with the biosketches
of the PI or with other senior/key personnel? Do the instructions to upload or insert individual
biosketches only apply to senior/key personnel?

For consistency with government-wide
requirements already established in Grants.gov,
NSF is making a policy change to require
certifications to be submitted at the time of
proposal submission. This also is consistent with
the policies established by the other 25 grant
making agencies of the Federal government.
For consistency with government-wide
requirements already established in Grants.gov,
NSF is making a policy change to require
certifications to be submitted at the time of
proposal submission. This also is consistent with
the policies established by the other 25 grant
making agencies of the Federal government.

Language has been revised to clarify that
biosketches for all personnel must be uploaded in
a single file as an other supplementary document.

…All project support from whatever source (e.g., Federal, State, local or foreign government agencies, public
or private foundations, industrial or other commercial organization, or internal institutional resources) must be
listed. The proposed project and all other projects or activities requiring a portion of time of the PI and other
senior personnel must be included, even if they receive no salary support from the project(s). The total award
amount for the entire award period covered (including indirect costs) must be shown as well as the number of
person-months per year to be devoted to the project, regardless of source of support.

Current and Pending Support
12

COGR
Chapter II.C.2h

While we recognize that current and pending support documentation has long been a requirement of
NSF and other federal agencies, requiring this documentation at proposal submission adds additional
administrative burden when the likelihood of being funded is unknown. We therefore ask that only
those with favorable scientific review outcomes being considered for NSF funding be asked to submit
current and pending support information. Providing this information post submission or at the time that
the proposal has been selected for funding also means that the information will be more current,
benefitting both NSF and the institution. In addition, we recommend that the request to have internal
institutional resources identified, be limited to internal funds allocated toward specific projects. This will
eliminate the unnecessary burden of reporting routine new faculty start-up packages that may include
general equipment and space and/or voluntary time and effort dedicated toward another project or
endeavor. We are further seeking confirmation that an institution can include zero (0) person months in
appropriate situations who may commit to contribute to the scientific development or execution of the
project, but are not committing any specific measurable effort to the project.

Language incorporated.

Proposing organizations are responsible for identifying NSF-funded life sciences proposals that could
potentially be considered dual use research of concern as defined in the US Government Policy for Institutional
Oversight of Life Sciences Dual Use Research of Concern.

Dual Use Research of Concern
13

COGR
Chapter II.D.14b

If the proposing organization identifies the proposal as dual use research of concern, the associated box must
be checked on the Cover Sheet. (See also AAG Chapter VI.B.5 for additional information.)
We are requesting clarity on the use of identifying NSF-funded life sciences that could “potentially” be
considered dual use research of concern as described above vs the “identification” of DURC as implied
by the second paragraph. We request that the DURC determination be consistent with the USG
Policy that requires institutions to provide notification to the USG funding agency of any
research that involves one or more of the 15 listed agents and one or more of the seven listed
experimental effects as defined in Section 6.2 of the USG Policy within thirty (30) calendar days of the
institutional review of the research for DURC potential.

NSF has removed the DURC checkbox from the
Cover Sheet. Certification language regarding
DURC has been added to the listing of AOR
certifications for compliance with governmentwide requirements.

14

COGR

…NSF awards are not expected to result in research that falls within the scope of this Policy. If, however, in
conducting the activities supported under an award, the PI is concerned that any of the research results could
Life Sciences Dual Use Research of Concern
potentially be considered Dual Use Research of Concern under this Policy, the PI or the grantee organization
should promptly notify the cognizant NSF Program Officer.
AAG, Chapter VI.B.5b

Language has been revised for compliance with
government-wide requirements.

See comments to Chapter II. D.14(b) above.

Reporting Requirements
15

COGR
AAG, Chapter II.D

Public Access Plan
16

Our membership has noted the difference in reporting dates between programmatic reporting (90 days)
and financial reporting (120) days. We appreciate the change NSF has made in the AAG to revise the
financial reporting from 90 days to 120 days but further request your consideration to reflect the same
dates for programmatic reporting. This would allow institutions to reconcile charges for publications of
its subrecipients while giving more time to incorporate the programmatic results into the prime
recipients final programmatic report.

Language has been revised to change the due date
of final reports and project outcomes reports to
within 120 days following the end date the award.

We appreciate the significant efforts the NSF has made with the release of its Public Access plan and its
recognition that managing investigator research data that result from Federal investments is a major challenge. We
are grateful that the NSF’s plan will be carried out in an incremental fashion allowing all stakeholder groups to
collaborate on this important initiative.
NSF thanks you for your comment.

COGR
AAG, Chapter VI.D.2

While the challenges our members will face to monitor and manage various agency plans will be rough, we do
appreciate NSF’s continued willingness to engage stakeholder groups and coordinate with other Federal
agencies to identify infrastructure capabilities, resolve outstanding and shared concerns, and develop best
practices and standards.
1) Maintain commitment to proceed carefully, incrementally, and in close consultation with stakeholders to avoid
unintended consequences

17

Association of American
Publishers / Division of
Professional and
Scholarly Publishing

18

University of Wisconsin
Madison

Public Access Plan

When to Submit Proposals and Format of
the Proposal
Chapter I.F and Chapter II.B

1. NSF thanks you for your comment. 2. NSF
thanks you for your comment. Comments have
been requested on NSF's implementation of the
2) Ensure flexible approach to managing unique discipline communities to sustain the quality, integrity, and availability
Public Access requirement in the PAPPG, and not
of high-quality peer-reviewed articles reporting on scientific research
on the Plan itself. 3. NSF thanks you for your
comment. Comments have been requested on
3) Expand on opportunities to minimize administrative and researcher burdens and costs by using flexible approaches
NSF's implementation of the Public Access
and public-private partnerships
requirement in the PAPPG, and not on the Plan
itself. 4. NSF thanks you for your comment. The
4) Keep flexible data requirements that recognize the unique research practices of different fields, and encourage
NSF policy on data sharing and data management
collaborative private sector solutions that minimize costs and burdens
plans remains unchanged. 5. NSF thanks you for
your comment. The NSF policy on data sharing and
5) Ensure adequate resources are available to support allowable costs for access to publications and data
data management plans remains unchanged. 6.
NSF thanks you for your comment.
6) Continue clear communication and engagement with scholarly community
We are thankful for the consistency in the use of the 5 PM submitter’s local time deadline and proposal
formatting requirements. Regardless of the solicitation or the directorate issuing the solicitation,
institutions will know what to expect and manage proposals accordingly. Such consistency reduces
administrative burden on institutions and investigators, and we are grateful for that.

Thank you for your comment. No action required.

19

20

21

University of Wisconsin
Madison

University of Wisconsin
Madison

University of Wisconsin
Madison

Collaborators & Other Affiliations
Chapter II.C.1e
Project Description
Chapter II.C.2d(iii)
Biographical Sketches
Chapter II.C.2f(ii)

We welcome the separation of the information on collaborators and other affiliations. Doing so makes
it easier to comply with the biosketch page limit. This also allows us to be more thorough with
collaborator and other affiliation information, especially for those researchers who are very active
collaborators.

Thank you for your comment. No action required.

That the Project Description must not contain URLs and must be self‐contained helps create a level
playing field in that all proposers must adhere to the same page limits. We appreciate this clarification
and emphasis.

Thank you for your comment. No action required.

When biosketches for non‐senior personnel will be included, should they be appended to the PI or
another senior/key person’s biosketch? Does the instruction to upload or insert individual biosketches
only apply to senior/key personnel?

Language has been revised to clarify that
biosketches for all Other Personnel and Equipment
Users must be uploaded in a single file as an other
supplementary document.

1) The proposed requirement is that Current and Pending Support include project support from internal
institutional resources. We are seeking more clarity regarding this proposed requirement. A variety of
internal institutional resources may be available to support an investigator.
Internal institutional resources may be awarded for a specific research project. In such cases,
researchers have competed for resources to support a project with a specific scope of work.

22

University of Wisconsin
Madison

Current and Pending Support
Chapter II.C.2h

Internal institutional resources may also be used to support multiple projects. Resources may be made
available in a variety of ways, for example, start‐up packages or fellowships that can be used to support
a faculty member’s research program as a whole. Such funding may be used at the discretion of the
researchers – to purchase supplies or equipment, or to help pay for personnel.
Another possible use of internal institutional resources would be to support faculty salaries in addition
to or in lieu of using a grant to pay for a faculty member’s time and effort on a project.
Given the variety of ways in which internal institutional resources may be used, would NSF be able to
specify what types of situations warrant inclusion on a current and pending support document?
2) We are seeking confirmation that a PI or other senior personnel can list zero person months on a
project. This may be appropriate, depending on the source of funding and the purpose of the project,
e.g., an equipment grant. That certain awards would not require effort is supported by OMB
Memorandum 01‐06, which states that “some types of research programs, such as programs for
equipment and instrumentation, doctoral dissertations, and student augmentation, do not require
committed faculty effort, paid or unpaid by the Federal Government...”
3) In lieu of requesting that the Current and Pending support information be provided at the time of
proposal, NSF may wish to consider asking for it to be submitted only if an award is being contemplated,
a JIT approach similar to NIH. This approach might decrease administrative burden for the senior
personnel and the proposing organization as well as for NSF and its reviewers

1) COGR language incorporated from comment
#12. 2) NSF recognizes that there may be
confusion regarding a PI's or other senior
personnel's responsibilities as it relates to
reporting on projects where there is funding, but
no time commitment. NSF plans to address this
issue in a future issuance of the PAPPG. 3) Given
the significance of this request, NSF will consider it
in a future PAPPG.

The language in the second paragraph of GPG Chapter II.D.14.b states that the proposing organization is
responsible for identifying proposals that could “potentially be considered dual use research of
concern” [emphasis added]. But, the final paragraph in this section indicates that the proposing
organization must check the appropriate box if it “identifies the proposal as dual use research of
concern” [emphasis added].
There are two issues with these paragraphs. First, the final paragraph implies (intentionally or not) that
the proposing organization has already made a judgment whether or not the proposal is DURC, whereas
the second paragraph does not. The two paragraphs convey different messages, but should convey the
same message.
23

University of Wisconsin
Madison

Dual Use Research of Concern
Chapter II.D.14b

Second, the likelihood that a proposal would be identified as DURC is small because the chance that it
would be put before the Institutional Review Entity (IRE) prior to submission is small. Given the
administrative burden associated with the review for DURC and proposal success rates, it is possible that
an investigator may notify the Institutional Review Entity of the potential of DURC only after a proposal
is awarded. If an IRE does not make a determination prior to proposal submission, then the proposing
organization will not be able to identify a proposal as DURC or check the box on the Cover Sheet.
We would prefer that the language in the final paragraph convey the same message as the language in
the second paragraph. Another alternative, consistent with USG policy, is that NSF could simply be
notified in the event that research has been reviewed and the IRE has made a determination whether or
not the research meets the definition of DURC. Consistency with the USG policy may relieve
administrative burden.

24

25

26

27

University of Wisconsin
Madison

University of Wisconsin
Madison

University of Wisconsin
Madison

University of Wisconsin
Madison

Dual Use Research of Concern
AAG, Chapter VI.B.5

Project Reporting and Grant Closeout
AAG, Chapter II.D.2,3.5 and Chapter III.E
Basic Considerations
AAG Chapter V.A

The language in the AAG states that the PI or grantee organization should promptly notify the NSF
Program Officer if “any of the research results could potentially be considered Dual Use Research of
Concern” [emphasis added]. The United States Government (USG) DURC policy requires us to contact
the USG funding agency only after the review of the research has occurred and a determination has
been made. The language in the AAG suggests that NSF is imposing a requirement which may create an
additional burden and is not part of the USG policy and procedures.
We note that the lack of uniformity in deadlines between programmatic reports (90 day deadlines) and
financial reporting (120 days) may cause confusion. We note that the lack of uniformity in deadlines
across Federal agencies may cause confusion, as well. Our recommendation would be to harmonize
these deadlines as much as possible.

Language has been revised for compliance with
government-wide requirements.

Language has been revised to change the due date
of final reports and project outcomes reports to
within 120 days following the expiration of the
award.

This chapter opens with a statement that “expenditures…must conform with NSF policies where
articulated in the grant terms and conditions…” We appreciate the addition of this language and the
comment that “NSF policies that have a postaward requirement are implemented in the grant terms and
conditions.”

Thank you for your comment. No action required.

In the second paragraph of this section, “de minimus” [sic] is misspelled.

Noted and corrected.

Indirect Costs
AAG, Chapter V.D.1b

28

University of Wisconsin
Madison

Public Access

We understand the importance of the public access policy. However, the administrative burden to
comply with this policy for two dozen separate agencies is daunting. The requirements across the agencies differ in
terms of what should be submitted, how compliance will be monitored, and when the implementation will occur.
Agencies also are using a variety of repositories, which will require institutions to learn new systems and procedures.
All of these factors accumulate and signify larger workloads.

Chapter VI.D.2c and VI.E.
Our institution, like others, has devoted significant time and resources to learning how to use the PubMed Central
system. We understand how it functions and have in-house expertise to help faculty members with questions and
submissions. We encourage NSF to consider allowing use of an established, familiar system such as PubMed Central.

See backup documentation for additional details:
1) Embargoes and Petitions
29

Wiley & Sons

Public Access
2) Implementation and Repositories
3) Digital Data Sets

NSF Grantee Relationships
30

CalTech
Introduction. D

Preliminary Proposals
31

CalTech
Chapter I.D.2

Voluntary Committed Cost Sharing
32

CalTech
Chapter II.C.2g(xi)

Conference Proposals
33

CalTech
Chapter II.D.9

NSF thanks you for your comment. NSF’s public
access initiative is part of a US government-wide
activity initiated by the Office of Science and
Technology Policy (OSTP) that is consistent with
NSF’s primary mission of promoting the progress
of science and helping to ensure the nation’s
future prosperity. Comments have been requested
on NSF's implementation of the Public Access
requirement in the PAPPG, and not on the Plan
itself.
NSF thanks you for your comment. Comments
have been requested on NSF's implementation of
the Public Access requirement in the PAPPG, and
not on the Plan itself. NSF describes its approach to
requesting a waiver to the 12-month embargo (or
administrative interval) in Section 7.5.1 of the
Public Access Plan
(http://www.nsf.gov/publications/pub_summ.jsp?
ods_key=nsf15052).

The discussion regarding Cooperative Agreements and the circumstances in which they should
be used is very well written and quite helpful. There are many within the research community,
on both the awarding and awardee sides, who have not had a clear understanding of the
purposes of the Cooperative Agreement and the ways in which Cooperative Agreements differ
from Grants and Contracts. This discussion will be very useful, particularly when working with
the Audit community.

Thank you for your comment. No action required.

We are very supportive of your decision to require that preliminary proposals be submitted through the Authorized
Organizational Representative (AOR). It is extremely helpful for the central research administration office to become
aware of the interest of a PI in submitting a proposal for a specific NSF program at the earliest possible time. By
requiring the preliminary proposal to go through the AOR, we can become aware of
potential issues that must be addressed internally before the full proposal is due.

Thank you for your comment. No action required.

We are very well aware of NSF's position on Voluntary Committed Cost Sharing: it is not allowed unless it is an
eligibility requirement that is clearly identified in the solicitation. Nevertheless, we also realize that there
may be instances when investigators insist on the need to include voluntary committed cost sharing in their proposals.
You have now provided a mechanism whereby that can be done, while staying within the overall NSF policy on
Thank you for your comment. No action required.
voluntary committed cost sharing. The requirement not to include voluntary committed cost sharing in the budget or
budget justification is very clear and will be easy to follow. Declaring that these resources will not be auditable by NSF
will also make things easier for the post-award financial administration of the resulting grant.
The additional information on allowable costs associated with Conference Proposals is helpful because it removes the
ambiguity surrounding potentially allowable or not allowable costs in connection with conference grants. Clarity on
this topic, particularly with regard to food and beverage costs associated with intramural meetings, is appreciated. It Thank you for your comment. No action required.
will make It easier for everyone, investigators, departmental research
administrators, and post-award financial staff to understand when such costs are not allowed.

NSF's adoption of the language in the Uniform Guidance on the long term disengagement of the PI will be of great
assistance to investigators and research administrators, alike. When Federal agencies adopt uniform
practices with regard to situations such as the absence or disengagement of Pies, it makes it easier for everyone
involved to understand and follow the requirements. The notion of "disengagement is a reflection of the significant
changes that have occurred as a result of modern communications technology. It is a reality that we live with and the
use of "disengagement as a criterion for having to notify and involve the sponsor will reduce some of the
administrative burdens associated with post-award administration.

Thank you for your comment. No action required.

We would appreciate your consideration of making these reports due 120 days after the end of the award, rather than
the 90 day time period in the draft PAPPG. This would bring the reporting and closeout
requirements associated with the technical aspects of the grant in line with the reporting and closeout requirements
associated with the financial aspects of the grant: 120 days after the end date of the award.

Language has been revised to change the due date
of final reports and project outcomes reports to
within 120 days following the expiration of the
award.

NSF's adoption of the requirement for the closeout process to be completed within 120 days after the end of the
project is greatly appreciated. Despite our best efforts, we have long had difficulty with the 90 day requirement for
financial closeout, particularly when our award includes subawards. Giving us an added 30 days to complete this task
should reduce the number of late closeouts and also reduce the instances when revised closeout activities are
required. We hope that other Federal agencies will join NSF and NIH in
recognizing the benefits of providing a more reasonable amount of time to complete the closeout
process.

Thank you for your comment. No action required.

Informal Resolution of Grant Administrative
The revision of this section is appreciated. Although the use of this procedure is extremely rare, it is helpful if
Disputes
everyone can be clear on just how the process is supposed to work. This should save time and aggravation when it is
necessary to resolve administrative disputes.
AAG, Chapter VII.B

Thank you for your comment. No action required.

Long Term Disengagement of the PI
34

CalTech
AAG, Chapter II.B.2a

Project Reporting
35

CalTech
AAG, Chapter II.D.3

Grant Closeout
36

CalTech
AAG, Chapter II.D.5

37

CalTech

38

Cold Spring Harbor
Laboratory

Current and Pending Support
Chapter II.C.2h

39

American Society of Civil
Public Access
Engineers

40

UC Riverside, Bourns
College of Engineering

Preliminary Proposals
Chapter I.D.2

We encourage the NSF to seize the opportunity to lessen the administrative burden for investigators and
institutions by not having them submit current and pending support at the time of proposal submission.
Only those with favorable scientific review outcomes being considered for NSF funding should be asked
to submit current and pending support information. This information will be more up to date if acquired
later in the application process. In addition, we recommend that the requirement to have internal
institutional resources identified, be eliminated. This will remove the unnecessary burden of reporting
routine new faculty start-up packages that may include general equipment, facilities and/or voluntary time
and effort not dedicated toward a specific project or endeavor.
The trend for Federal research funding agencies seems to be toward determining how much unrestricted
support investigators may have available so that this information can potentially be used to sway funding
decisions and final award budgets. With stagnant and decreasing federal research funding, additional
institutional support for investigators and postdoctoral fellows is essential in order to help their research
continue and make ends meet. We strongly encourage the NSF to break with this trend that puts
investigators and institutions in a vicious circle in which their efforts to help support and sustain research
may negatively impact their ability to secure Federal research funding. We urge the NSF to modify the
proposed PAPPG text accordingly to eliminate the requirement to report internal institutional resources.

1) Given the significance of this request, NSF will
consider it in a future PAPPG. 2) COGR language
incorporated from comment #12.

ASCE is primarily concerned that the plan calls for a 12-month embargo, which would seriously impact the ability of
ASCE to recover our cost. Compared to many areas of science and technology, civil engineering research moves at a
NSF thanks you for your comment. Comments
more sedate rate. As such, civil engineering journals remain “fresh” for a longer period, selling over a longer period,
have been requested on NSF's implementation of
and taking a correspondingly longer time for ASCE to re-coop our cost. ASCE believes that a 12-month embargo would
the Public Access requirement in the PAPPG, and
impede ASCE’s ability to continue to produce the high-quality journals that we currently do.
not on the Plan itself. NSF describes its approach to
requesting a waiver to the 12-month embargo (or
The NSF plan includes conference proceedings, which many times are expanded and published as journal articles.
administrative interval) in Section 7.5.1 of the
Again, this leads to duplicate versions of results.
Public Access Plan
Once again, thank you for the opportunity for ASCE to comment on the proposed Policies and Guidelines. ASCE, like
(http://www.nsf.gov/publications/pub_summ.jsp?
other engineering and scientific societies, fulfills its role in the advancement of engineering by determining through
ods_key=nsf15052).
the peer review process what is worthy of publication. While supporting open access, we must be careful not to lose
the “value-added” by peer review is what sets apart top-flight research from mediocre work.

The change requiring submission of pre-proposals by the authorized representative adds some burden to the
proposer, and thus partially defeats the purpose of reducing unnecessary effort.

It is vital that an institution be aware of
commitments being made in a preliminary
proposal. As such, AOR submission will be
beneficial to the submitting organization.

41

UC Riverside, Bourns
College of Engineering

Format
Chapter II.B.

Removing guidance information from the GPG is a very bad idea. Instead of streamlining the content, this would
create an incomplete set of instructions. We need all of the guidance in one place for two reasons: (1) not everyone
involved with the proposal necessarily will be working in Fastlane, and (2) considerable work is done before upload,
and finding unexpected instructions in Fastlane could create emergencies. Please don’t let NSF become NIH, where
the answer to every question is six links and four obsolete documents away. Put all of the instructions where we can
find them.

NSF has added the language back into the
guidance.

You should consider updating the formatting requirements. The fonts you identify were selected years (decades?) ago,
and are optimized for print. All proposal submission and most proposal review now takes place on the screen, so you
should consider allowing fonts that are optimized for the screen. These might include Calibri and Cambria.
42

43

UC Riverside, Bourns
College of Engineering

UC Riverside, Bourns
College of Engineering

Format
Chapter II.B.1

Collaborators & Other Affiliations
Chapter II.C.1e

Minor changes have been made to formatting
The standards regarding lines per inch and characters per line should be deleted; specifying font size and singleguidelines.
spacing should be sufficient. When a proposal is converted from, say, Word to PDF, it shrinks slightly. Moreover, since
Fastlane distills Word documents and redistills PDFs, the proposer has no actual control over the final PDF version. This
rule makes the proposer responsible for something that is ultimately out of his/her control.

This will be an excellent change if implemented properly. I would strongly recommend specifying an NSF-wide format
Thank you for your comment. NSF will explore the
for this information. Our experience has been that even within an individual directorate (CISE), the requirements for
viability of such a suggestion.
this list vary. Today, a list produced for one proposal might require significant reformatting for the next proposal. It
would be nice to eliminate the need for this extra work.
Even though Fastlane is being phased out, three changes to the cover page would be nice:

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UC Riverside, Bourns
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Cover Sheet
Chapter II.C.2a

1. Improve the Performance Site page programming. Often, each line must be entered and saved before the next line
Thank you for your suggestion, however upgrades
can be entered. Ideally, you could pre-populate this with information on the institution.
to FastLane are not feasible at this time. 3)
Clarifying language has been added.
2. Make it possible to go to the remainder of the cover page before the first section is completed.
3. Add a legend indicating that the Beginning Investigator box is for BIO proposals only.

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UC Riverside, Bourns
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UC Riverside, Bourns
College of Engineering

Project Summary
Chapter II.C.2b

Content
Chapter II.C.2d(i)
Project Description
Chapter II.C.2d(ii)

This is a good place to point out sloppy language throughout the GPG. If you want the project description written in
the third person, instruct us to do that. The words “must” and “should” do not mean the same thing, and here you say
“should.” The word “should” appears 265 times in this document. How many of those times do you really mean
“must” or “shall”?
Statements like the following are of no value whatsoever: “Additional instructions for preparation of the Project
Summary are available in FastLane.” What instructions? Where? If I don’t track them down, will I be in danger of
submitting a non-compliant proposal?

Thank you for your comments.

What does “relation to longer-term goals of the PI's project” mean? What is the PI’s project? It is not this proposed
project, because then you would be asking how this proposal relates to this proposal.

Language has been revised.

The prohibition on URLs seems extreme, and it is a step in the wrong direction. As you point out, the reviewers are
under no obligation to look at them, so no harm is done in including them.

Thank you for your comments.

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UC Riverside, Bourns
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UC Riverside, Bourns
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UC Riverside, Bourns
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UC Riverside, Bourns
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UC Riverside, Bourns
College of Engineering
UC Riverside, Bourns
College of Engineering
UC Riverside, Bourns
College of Engineering

Results from Prior NSF Support
Chapter II.C.2d(iii)

References Cited
Chapter II.C.2e

Biographical Sketches
Chapter II.C.2f(ii)

Equipment
Chapter II.C.2g(iii)
Special Information/International
Conferences

This should be eliminated from NSF proposals. The program officer (and, indeed, the public) already has access to all Project reports are not publicly available and
of this information via project reports. A more effective use of space, time, and energy would be to invite the proposer therefore is essential information for use by the
reviewer in assessing the proposal.
to describe how this proposed project relates to prior or concurrent work.
GPG Chapter II.C.2.d(iii)(d) already specifies that a
complete bibliographic citation for each
Since URLs are prohibited in the project description, it is likely that some URLs (to examples of outreach projects, for
publication must be provided in either the
example) will end up in the References Cited list. Now we are at risk of disqualification since a URL does not contain all
References Cited section or the Results from Prior
of the items each citation must have.
NSF Support section of the proposal, to avoid
duplication.
We would strongly recommend that NSF provide a template for the entire biographical sketch. This will leave no
question as to what can be included and what cannot. The instructions have a list of information that can’t be
included, but this is not exhaustive. What about honors and awards, for example? If a bio sketch contains everything
required, in the order specified, plus a section on honors and awards, is it compliant or not? Today, the answer varies
from program officer to program officer.
As noted earlier, the elimination of the conflict list from the bio sketch is an excellent decision.
The instructions on Other Personnel and the notation that biographical sketches cannot be uploaded as a group
appear to be at odds. If someone is an Other Person rather than an Other Senior Person, how will it be possible to
upload a biographical sketch?

The term information technology systems should be defined, especially since NSF funds research on information
technology systems.

1) Upon review of this comment, NSF cannot
validate the reviewer comment, as the instructions
in that section do not contain a list of information
not to include. 2) Language has been revised to
clarify that biosketches for all personnel must be
uploaded separately.

2 CFR 200 (Uniform Guidance) does not define
information technology, and as such NSF is
consistent with government-wide requirements.

This is a good change, but it belongs in the instructions for the Cover Page, not the instructions for the supplementary Instructions have been added to the Cover Sheet
documents.
section.

Chapter II.C.2j
Collaborative Proposals
A definition of “within a reasonable timeframe” would be helpful.

Noted.

The language “may be appropriate or not appropriate” is wishy-washy. Why not just say allowable and unallowable?

Comment incorporated.

Chapter II.D.5
Conference Grants
Chapter II.D.9

Are we to interpret the definition this way, removing the “such as” so as to broaden the definition beyond the
examples mentioned?:
“Participant support costs means direct costs for items in connection with conferences, or training projects.”

Participant Support Costs
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University of Virginia
Chapter II.C.2g

1) Yes. 2) NSF deliberately revised the definition of
participant support for consistency with the
Previous guidance from NSF included the “such as” examples mentioned as well as “and other costs related to
conferences and meetings” but the new guidance removes that “and other costs” part and appears to limit PSC to the Uniform Guidance. Significant clarity has been
added in the conferences section to highlight the
items used as examples.
types of costs that may be appropriate for
I am asking because conferences can include other costs such as venue rental, poster supplies, etc. that aren’t part of inclusion in a conference budget, of which
what is listed after “such as” and we are trying to determine what part of a conference should be considered PSC and participant support is one.
which parts should not.
Any idea how we should interpret the new definition?

NSF thanks you for your comment. NSF’s public
access initiative is part of a US government-wide
activity initiated by the Office of Science and
Statutory authority for the collection may also be an issue because there is no clear authority given by Congress for the Technology Policy (OSTP) that is consistent with
US Public Access program. It was created by an Executive Branch memo. NSF needs to address this issue.
NSF’s primary mission of promoting the progress
of science and helping to ensure the nation’s
1) The strangeness of the NSF request. What is strange is that the collection of articles under Public Access has nothing future prosperity. NSF has formally implemented
to do with the proposal and award process, which is the subject of the PAPPG.
its Public Access requirement in the PAPPG.
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Inside Public Access

Public Access
2) The burden of mandatory data sharing
3) The issue of burden estimating

Comments have been requested on NSF’s
implementation of the Public Access requirement
in the PAPPG and not on the plan itself.

4) Vague requirements create complexity
The NSF policy on data sharing and data
management plans remains unchanged.