CSS Letter Requesting Extension of Data Quality Guidelines Comment Period

The Citizens for Sensible Safeguards (CSS) coalition sent a letter to OIRA Administrator John Graham requesting an extension to the deadline for filing comments on federal agency data quality guidelines. Below is a copy of the letter. May 24, 2002 Dr. John Graham Administrator Office of Information and Regulatory Affairs Office of Management Budget Old Executive Office Building 17th Street and Pennsylvania Ave., NW Washington, D.C. 20503 Dear Dr. Graham: On behalf of Citizens for Sensible Safeguards, a broad-based coalition of organizations representing health, safety, civil rights, and environmental concerns, I am writing to request a 60-day extension in the public comment period for draft data quality guidelines recently issued across federal agencies. Members of our coalition have expressed interest in submitting comments, but have indicated that the 30-day comment period provided by agencies is an insufficient amount of time. These guidelines are enormously complex and have significant, far-reaching implications. They deal not just with the correction of data, but also standards for dissemination, agency risk analysis, peer review of information, and much more. As a coalition, we are just beginning to digest the range of possibilities that might flow from these guidelines. Moreover, each agency has proposed its own unique guidelines, and the public is being asked to respond to them all at once. We are interested in carefully reviewing each of these guidelines and providing comments to multiple agencies. Thirty days is simply an inadequate amount of time to fully examine variation across agencies and offer comprehensive feedback. We understand that OMB has set Oct. 1, 2002, as the deadline for agencies to issue final guidelines. Yet public involvement and full consideration of viewpoints should not be sacrificed in this effort. The statute specifically instructs that agencies issue final guidelines within one year of OMB’s implementing guidelines. OMB did not fully complete its guidelines until Jan. 3, 2002, and published an additional correction on Feb. 22, 2002. Agencies should be given a year from this date to finalize guidelines, allowing a sufficient amount of time to incorporate public viewpoints. We are sure you share our concern that the public be given time to adequately review and respond to agency data quality guidelines. This cannot be accomplished within the 30-day window, which is now almost over. Accordingly, we ask that you immediately instruct agencies to extend their comment periods by 60 days, issuing a public announcement to this effect. Sincerely, /s/ Gary D. Bass Chairman cc: The Honorable Joseph Lieberman Chairman Senate Committee on Governmental Affairs The Honorable Fred Thompson Ranking Member Senate Committee on Governmental Affairs Committee The Honorable Dan Burton Chairman House Committee on Government Reform The Honorable Henry Waxman Ranking Member House Committee on Government Reform The Honorable Sherwood Boehlert Chairman House Committee on Science The Honorable Ralph Hall Ranking Member House Committee on Science
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