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 Broad Prohibition on International Scientific Collaboration (§200.220; §200.202(e)) 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. Comment on specific section, Broad Prohibition on International Scientific Collaboration (§200.220; §200.202(e)): The proposed rule prohibits the use of federal funds, including allocable indirect costs, for bilateral or multilateral collaboration with covered foreign countries or affiliated entities, and establishes a “domestic-first” framework requiring case-by-case justification of any international element in research awards. Sustaining LTEOs is foundational science that frequently depends on collaboration within a specialized international community of specialists. A broad prohibition would make such collaboration more difficult, would diminish the scientific strength of the observations for first responders, farmers, the insurance industry, and other users, and would do so in the near-term. These restrictions would accelerate a shift in expertise away from the United States. U.S. scientists have historically led in the design, maintenance and interpretation of LTEO data. Federal awards already require that observational data be openly shared and the proposed rule appropriately leaves that requirement unchanged. However, open access means that data collected in the United States already benefits the international community. And we here in the United States benefit from LTEO data from other countries to increase the overall value of global data. If U.S. researchers are barred from international collaboration, the U.S. risks narrowing its role to that of a data provider while scientific leadership enabled by collaboration would migrate abroad. This concern is not speculative. A recent analysis (Zhu, Y., Cheng, L., Trenberth, K.E. et al. Critical dependence of global ocean heat monitoring on the ocean observing system. Nat. Clim. Chang. 16, 657–660 (2026). https://doi.org/10.1038/s41558-026-02661-6) quantified that reduced U.S. participation in the global ocean observing system would substantially degrade the world’s capacity to monitor key ocean variables, such as ocean heat content. More generally, diminished U.S. participation in LTEOs would allow other nations to exert greater influence over measurement standards and scientific priorities and would accelerate their ability to extract value from observations that the United States collects. Recommendation. OMB should preserve the ability of recipients to collaborate internationally on sustained observational programs, or at minimum provide a categorical accommodation for established international observing partnerships, joint missions, and data-exchange and co-calibration arrangements that underpin long-term records. 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