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 Section: Conference Attendance Conditioned on Express Pre-Approval (§200.432) 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. Comment on specific section: Conference Attendance Conditioned on Express Pre-Approval (§200.432): Under current rules, conference attendance connected to the work of an award is a standard allowable cost. The proposed rule eliminates that presumption, making attendance allowable only if expressly approved by the agency and written into the terms and conditions of the award at the time of issuance. The financial savings from restricting attendance in this manner would be minimal, while the cost to scientific collaboration would be considerable. Large, recurring society meetings, such as the annual Fall Meeting of the American Geophysical Union, can be anticipated and written into awards at the outset. The greater harm falls on smaller, targeted meetings that are not planned years in advance but are convened in response to a particular scientific situation as it arises. LTEO programs depend on this kind of timely exchange within a small community of specialists for methodological peer critique, calibration of approaches, and coordination that sustains data continuity. Requiring such meetings to have been foreseen and pre-approved at award issuance would impede the collaboration on which these programs rely. Recommendation. OMB should retain conference attendance connected to the scientific work of an award as a standard allowable cost, or at minimum permit conferences to be added during the period of performance through a streamlined process rather than only at the time of award. 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