Public Comment of the Open Environmental Data Project Re: OMB-2026-0034, Regulation for Federal Financial Assistance (91 FR 32198)

This document is the public comment submitted by the Open Environmental Data Project (OEDP) in response to the U.S. Office of Management and Budget's proposed rule, "Regulation for Federal Financial Assistance" (Docket OMB-2026-0034; 91 FR 32198), which would revise the government-wide Uniform Guidance for federal grants (2 CFR Part 200). Submitted July 8, 2026, the comment focuses on four sets of provisions and offers a constructive alternative for each: the restriction on research examining disparate impacts (§ 200.218); the treatment of publication and open-access fees as unallowable costs (§§ 200.421, 200.461); restrictions on "issue advocacy" and public communication of research (§ 200.450(c)(1)(iv)); and the political pre-issuance review and expanded termination authority (§§ 200.205(b), 200.340–200.343). The comment argues that these provisions would degrade scientific quality, conflict with longstanding statutory and policy commitments to public access to federally funded research, exceed OMB's statutory authority, and raise concerns under the First Amendment and the Administrative Procedure Act. It is shared here as a public reference and as an example for other organizations and individuals preparing their own comments.