CRE Comments
to
Office of Science and
Technology Policy
CRE Submits Additional Supplemental Comments to OSTP on its Data Quality Guidelines
CRE has provided further supplemental written comments to OSTP on its proposed Data
Quality guidelines. These comments raise additional points on handling correction
requests and also discuss the definition of the term "utility."
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to to review CRE's additional supplemental comment letter to OSTP
Click to submit a comment
Data Quality Act:
CRE Submits Supplemental Comments to OSTP on its Data Quality Guidelines
The Office of Science and Technology Policy's (OSTP) proposed Data Quality
guidelines impose statutes of limitation for filing administrative correction
petitions. Petitions that are not filed within very short periods of time
after the information is disseminated could never be filed at all. These
deadlines for filing petitions are so short that they would in effect
deny the right to file a Data Quality petition to anyone who does not
follow OSTP on a daily basis. CRE does not believe that Congress intended
to restrict Data Quality petitions in this manner. CRE's comments urge
OSTP not to impose these statutes of limitation for filing petitions.
In addition, CRE's comments ask OSTP to address the issue of how the Data
Quality guidelines apply when interagency committees, comprised of several
federal agencies, disseminate information. OSTP is an appropriate agency
to address this issue because it is involved in several of these interagency
committees. CRE's comments propose an approach to this issue.
Click
to review CRE's comment letter to Office of Science and Technology Policy
Click
to review CRE's Generic Comments attachment
Click
to review Legal Memorandum on proposed agency exemptions to the Data Quality
Act Guidelines
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to review the ABA comments on EPA's Data Quality
Click to submit a comment
Data Quality Act:
CRE Submits Comments to Office of Science and Technology Policy on its
Data Quality Guidelines
CRE has provided written comments to the agency on its proposed
Data Quality guidelines. In addition to its letter comments,
the Center has attached two 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 the OMB's and other agencies' attempts
to exempt certain categories of information from the Data Quality
Act guidelines' applicability.
Click
to review CRE's comment letter to Office of Science and Technology Policy
Click
to review CRE's Generic Comments attachment
Click
to review Legal Memorandum on proposed agency exemptions to the Data Quality
Act Guidelines
Click to submit a comment
CRE Requests Withdrawal Of The National Assessment On Climate Change On Federal Data Quality Act (FDQA) Grounds
CRE has requested that the United States Global Change Research Program
and the Office of Science and Technology withdraw the First National
Assessment on Global Climate Change because it violates the objectivity,
utility and reproducibility requirements of the Data Quality Act and
OMB's guidelines implementing the Act. More specifically, the National
Assessment violates the Act and OMB's guidelines.
Read CRE's request for withdrawal of the National Assessment
Comment on Item
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