Comment on FR Doc # 2026-12205

Comment of Krishna Chaitanya Balusu, Individual. Re: Notice-MVAC-2026-01; Docket No. 2026-0331 I am a contributor to the OpenTelemetry GenAI semantic conventions, an IEEE Senior Member, and the author of "AgentTelemetry: A Fault Detection Benchmark and Toolkit for LLM Agent Observability" (AIware '26, DOI: 10.1145/3805760.3814931). I submit this comment in a personal capacity; the views expressed are my own and do not represent any employer or organization. The attached document contains my full comment on draft GSAR clause 552.239-7001, "Basic Safeguarding of Data Within Large Language Model Artificial Intelligence Systems (LLMs)" (91 FR 36559, June 17, 2026), in GSA's requested format (paragraph, concern, suggested language, citations). It addresses paragraphs (f)(4), (h), (f)(5), (e)(4), and (j)(2), and it responds primarily to GSA's Question 2 (clarity of the Government data ownership and protection and contractor accountability requirements), with Section II also bearing on Questions 3 and 4 (flowdown roles and implementation). I support the clause's core objectives, and my recommendations are intended to strengthen its practical verifiability, not to reduce its protective intent. Summary: 1. Paragraph (f)(4): the intermediary-step audit trail should be structured, machine-readable telemetry generated by the system's orchestration or instrumentation layer, rather than solely a narrative summary produced by the same model being audited. It should conform to open, vendor-neutral telemetry semantics (for example, the OpenTelemetry GenAI semantic conventions) applied consistently across the four supply-chain roles defined in paragraph (a)(2). Suggested language for a new (f)(4)(iv) is included. 2. Paragraphs (h) and (f)(5)(iii): the audit trails produced under (f)(4) should be expressly included in the data-portability enumeration in (h)(1) and in the logs preserved under (f)(5)(iii), so that audit history survives a transition to another vendor and supports incident reconstruction across the entities in the supply chain. 3. Paragraph (e)(4)(ii)(E): content-free audit logging is technically sound and implementable today, because the conventions' message-content attributes are Opt-In and are not captured by default. The clause should state how compliance is achieved. Suggested language is included. 4. Paragraph (j)(2): the Government's automated-assessment rights should extend to validating the audit channel itself, by seeding benign, known faults in a test environment and verifying that they appear in the records delivered under (f)(4). The common thread: a safeguarding obligation is only as verifiable as the system is observable. Respectfully submitted, Krishna Chaitanya Balusu