Comment from Mark Taylor

Comment on OMB-2026-0034: Regulation for Federal Financial Assistance, 91 Fed. Reg. 32198; Proposed §§ 200.219 and 200.432 I write on behalf of Apogee Exhibits an employer the Live event industry (such as trade shows, conferences )based in Canandaigua NY. Apogee respectfully urges the Office of Management and Budget to withdraw proposed §§ 200.432 and 200.219 in full. Business and professional events—including conferences, meetings, conventions, trade shows, exhibitions, academic gatherings, and more—help people exchange knowledge, build partnerships, conduct business, solve problems, and advance important work in communities across the United States. They also drive demand for restaurants, hotels, travel services, and Main Street commerce nationwide. Proposed § 200.432 would make it harder for federal award recipients and subrecipients to participate in conferences that are necessary to the successful performance of federally supported work. Current regulations already require conference costs to be necessary, reasonable, allowable, documented, and tied to the federal award. That is an appropriate and workable standard. The proposed change would instead require conference attendance to be expressly approved and included in the original award terms and conditions. In practice, this would create needless barriers for researchers, educators, workforce professionals, nonprofit organizations, state and local governments, and other recipients whose conference needs often emerge after an award begins. Relevant conferences are not always known when a grant application is submitted or an award is issued. A research abstract may be accepted months later. A new federal policy, technical challenge, public-health issue, workforce need, or other development may make a particular meeting essential to carrying out the funded work. Requiring recipients to predict every possible conference in advance, or seek a formal award modification later, would add bureaucracy, delay participation, and reduce the effectiveness of federal investments. Proposed § 200.219 is also deeply concerning. This provision would use federal grant regulations to govern decisions involving event services such as access to facilities, security, crowd management, insurance, fees, and other logistical support. These are complex operational and safety decisions that should remain with the professionals closest to the facts: venue operators, event organizers, official service providers, public-safety officials, risk managers, insurers, and local authorities. Every event distinct risks. Decisions about security, staffing, insurance, entrances and exits, crowd flow, loading, credentialing, traffic, and emergency procedures depend on the specific facility, expected attendance, event design, simultaneous activities, public-safety conditions, and other real-time factors. A vague national standard cannot account for those differences. We support lawful expression and the fair, viewpoint-neutral administration of public facilities where those standards apply. However, proposed § 200.219 is not a narrow federal cost rule. It would create uncertainty for public and non-public venues alike, invite grant-compliance disputes over routine event operations, and risk undermining the ability of venues and organizers to make sound, safety-driven decisions. OMB should retain the current, workable rules governing conference costs and should not use federal financial assistance regulations to federalize venue management and event services decisions. For these reasons, I respectfully urge OMB to withdraw proposed §§ 200.432 and 200.219 in full. Sincerely, Mark Taylor President and CEO Apogee Exhibits