Comments to OMB
CRE Submits Comments to OMB on its Data Quality Guidelines
CRE's comment letter to OMB
Read CRE's Generic Comments attachment
Click to review Legal Memorandum on proposed agency exemptions to the Data Quality Act Guidelines
Click to review the ABA's comments on EPA's Data Quality Guidelines
to review CRE's supplemental comments related to risk issues
Comment on Item
CRE has submitted comments to OMB on its OMB-specific proposed Data Quality
guidelines. In addition to its letter comments, the Center has attached
four papers: (1) a set of CRE Generic Comments to all agencies on their
Data Quality guidelines which discuss a variety of important cross-cutting
issues; and (2) a Legal Memorandum challenging OMB's and other agencies'
attempts to exempt certain categories of information from the Data Quality
Act guidelines' applicability; (3) Comment on EPA's proposed Data Quality
guidelines submitted by the ABA Section on Administrative Law and Regulatory
Practice, and (4) supplemental comments specifically related to risk issues.
CRE Submits Comments on "Reproducibility" Standard in OMB's Data Quality Guidelines
Read CRE's Comments to OMB
Read CRE's Supplemental Comments to OMB
Click to read more about the Data Quality Act and related issues
Comment on Item
CRE submitted comments to OMB on the "capable of being substantially reproduced" standard included in the agency's final Data Quality guidelines. The reproducibility standard was issued on an interim final basis, and OMB accepted additional public comments on that key aspect of the guidelines through October 29, 2001. CRE strongly supports OMB's reproducibility requirement as a standard of care for governmental information. If information is not sufficiently robust that it cannot be reproduced
by independent parties across testing environments, it should not be deemed adequately reliable for dissemination to the public. CRE urges OMB to retain this important aspect of the guidelines.