COMMENT BY: "Group of 29 Concerened Business Representatives and Owners"
SUBJECT: In favor of proposed revision to OMB Circular A-110
DATE: March 29, 1999

Dear Sir:

The undersigned 29 companies strongly request that the Office of Management and Budget act expeditiously to amend and adopt Circular 110 as directed by the Omnibus Appropriations Act for Fiscal Year 1999. Under this Act, Congress has mandated federal agencies to ensure that all data produced under a grant or agreement with an Institution of Higher Education, Hospital, or Other Non-Profit Organization, be made available to the public under the Freedom of Information Act, ("FOIA"). For the first time, an agency that receives a FOIA request for data used to develop a policy or rule would be required to provide this data from its files. If the data is not in the agency’s file, as is often the case, the agency must obtain the data from the federal recipient of the award and make the data available to the citizen requesting it.

Too often, we are placed in a situation where we must revise our way of doing business at considerable cost because of rules or policies that agencies have developed from data or studies to which we have had little or no access. In the past, some agencies have selectively provided partial or incomplete information to justify a self-serving policy position that could not have been supported if a complete view of the data had been made available. Even when the rule or policy is totally justified by a fair review of the data, the lack of access to the information promulgates the perception of subjective or biased interpretation. Requiring this data to withstand the "light of day" can only add to the integrity of the process and quality of the results.

As responsible business owners and representatives, we feel the health and safety of our employees and patrons are of utmost concern. Because of this, it is important to us that the rulemaking process does not take place in a vacuum or with data that cannot be viewed by the very people that must live by its results. In this age of reinventing government, giving business the access to the information that is the foundation of an agency’s policies would not only seem in everyone’s best interest but just plain "good business".

With Kindest Regards,

The Owners, Representatives, and CEO’s of the following businesses,

Wayne E. Alter. Jr. C.
Chairman and CEO
Dynamark Security Centers, Inc.
Hagerstown, Maryland

Virginia Kirkpatrick
President/Owner President
CVK PersonnelManagement& Training Specialists
St. Louis. Missouri

Anthony L. Vest
President
Management Programs Corporation
Cloudland, Georgia

Paula Brown
President
JB Chemical Company, Inc.
North Las Vegas, Nevada

William Frederick Lewis
President and CEO
Prospect Technologies
Washington, D. C.

Deborah A. Warner
President
Infusion Specialists. Inc.
Jenks, Oklahoma

William J. Bandy, Jr.
President
Environmental Design Group, Inc.
Akron, Ohio

Kevin Linehan
Owner
Standard Beauty Supply, Inc.
Omaha, Nebraska

Eugene J. Wigglesworth
President and CEO
Midas, Inc.
Vancouver, Washington

Ronald R. Collins
President
JCM Industries, Inc.
Nash, Texas

Elizabeth Lisboa-Farrow
President and CEO
Lisboa, Inc.
Washington, D.C.

Kenneth R. Wolfe
President
Kohlhepp, Wolfe and Associates P.S.C.
Fort Mitchell, Kentucky

Mark Cordova
President
Centennial Bolt, Inc.
Denver, Colorado

Ronald R. Lyons
President/CEO
Alliance, Ohio

James Wordsworth
President
J.R.’s Stockyards Inn
McLean, Virginia

Maura W. Donahue
Vice President
DonahueFavret Contractors, Inc.
Mandeville, Louisiana

Vimu Rajdev
President
RAJEX, Inc.
San Jose, California

Brad Ytterberg
Partner
Edward Jones
St. Louis, Missouri

Edmund Evans
CEO
TTI Maumee Equipment, Inc.
Perrysburg, Ohio

Mary Jane Rebick
Co-owner, Executive Vice President
Copy Systems
Little Rock, Arkansas

Thomas Zoretich
President
Quick Test
Jupiter, Florida

Paul Finkle
President
Western Employers Associates
San Rafael, California

Robert V. Sallada
President
Anderson Business Environments
Charlottesville, Virginia

James P. Ghiglieri, Jr.
President
Alpha Community Bank
Toluca, Illinois

Guy J. Spencer, Jr.
CEO
The Spencer Companies. Inc.
Huntsville, Alabama 35804

Barbara Hayward
President
Hayward International
Washington, D.C.

Larry Stanley
CEO
Empire Bolt and Screw, Inc.
Spokane, Washington

Scott L. Holman
President/Owner
Bay Cast, Inc
Bay City, Michigan

Roland A. Vaughan, P.E.
President and CEO
Sherlock, Smith and Adams, Inc.