II.9 Responses to Anticipated Criticisms

The following section addresses a number of criticisms that have been raised in the media and elsewhere relating to the new federal data access law and OMB's proposed revisions to Circular A-110. We have set forth responses to these criticisms, where appropriate with reference to specific mechanisms that CRE recommends OMB adopt. The criticisms are not presented as an exhaustive list of all possible objections that could be made regarding the new law or OMB's proposed revisions, nor are the responses intended as a rebuttal to the myriad issues that may arise during implementation of the new federal policy. The discussion instead provides a means of focusing on the primary objections that opponents of data access have raised and sets forth CRE's picture of the how the data access program should work.