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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."

  • Click 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
  • Click 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
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