Comment on OMB-2026-0034-0001

Keeling Curve Foundation June 25, 2026 Office of Information and Regulatory Affairs Office of Management and Budget Submitted electronically via www.regulations.gov Re: Public Comment on the Proposed Rule, “Regulation for Federal Financial Assistance,” Docket No. OMB-2026-0034 (Fed. Reg., May 29, 2026); Specifically Peer Review Reduced to Advisory Status (§200.205(d)). To the Office of Management and Budget: The Keeling Curve Foundation submits these comments with input from our Science Advisory Council in response to the proposed rule “Regulation for Federal Financial Assistance” (Docket No. OMB-2026-0034), published in the Federal Register on May 29, 2026. The Council comprises scientists with direct expertise in sustained, long-term Earth observations (LTEOs) — the continuous, multi-decadal measurement programs that document change in Earth’s atmosphere, ocean, and land surface including inland waters. Programs of this kind, including the Mauna Loa atmospheric CO₂ record from which our Foundation takes its name, derive their scientific value precisely from uninterrupted continuity maintained across successive administrations, budget cycles, and shifting priorities. Long-term Earth Observations are not isolated scientific exercises. They underpin our national security, human health, economy, and overall well-being. First responders, state and local agencies, national infrastructure, the military, private companies, and countless others rely on LTEOs for timely, accurate information to ensure our nation prospers and is safe in a dynamic Earth system that requires the best scientific evidence and interpretation to make decisions. Consistent with guidance on effective public comment, we do not address every provision of the proposed rule. We rather focus on specific provisions that, in our expert judgment, pose the most near-term risk to US leadership in federal capacity to sustain LTEO records. We list these provisions in order of the severity of their expected impact on LTEO programs, followed by a brief procedural note. A characteristic of LTEOs, relevant to every comment below, is that their value is cumulative rather than immediate, and damage to them is frequently irreversible. A gap of even one to two years in a continuous time series can permanently degrade the scientific value of the entire record: once gaps appear, statistical characterization of variability and long-term trends becomes substantially less robust and, in some cases, intractable. Provisions that introduce discretionary interruption carry consequences for LTEO programs disproportionate to their apparent administrative scope. Specific Section Comments: Peer Review Reduced to Advisory Status (§200.205(d)) The proposed rule requires senior political appointees to conduct a pre-issuance review of every discretionary award, forbids them from routinely deferring to or ratifying peer-review recommendations, and reduces independent expert peer review to advisory status, permitting an appointee to override the scientific community’s judgment without a finding of cause. The rule further conditions awards on compliance with a “Gold Standard Science” benchmark tied to Executive Order 14303 (May 23, 2025) that is not defined in concrete or measurable terms. Because LTEO programs depend on predictable, uninterrupted, multi-year support, subjecting their initiation and renewal to discretionary review — rather than to merit-based evaluation by qualified experts — compounds the fragility described in the preceding section. The absence of a defined standard against which such programs would be assessed adds further uncertainty to funding decisions on which continuous observational records depend. Recommendation. OMB should retain independent expert peer review as the primary basis for discretionary award decisions, and in particular for the renewal of established LTEO programs, and should define any evaluative standard in concrete, measurable terms before it is applied. A document with the Keeling Curve Foundation's full set of comments on the proposed rule is attached. Respectfully submitted, Johno Niles Executive Director, Keeling Curve Foundation