Information Quality and the Law, or, How to Catch a Difficult Horse

Comments On OMB Peer Review Guidelines Available On CRE Website
The Office of Management and Budget solicited public comment on its proposed guidelines establishing peer review standards for federal agencies. The comment period for non-government entities ended December 15, 2003. These comments are now available on the CRE website. Federal agencies have another month to submit comments.

Law Firm Files Data Quality Act Petition Related To Asbestos Litigation
The law firm Morgan, Lewis & Bockius (MLB) filed a Data Quality Act Request for Correction with EPA regarding EPA's "Guidance for Preventing Asbestos Disease Among Auto Mechanics" (the Gold Book). This EPA document provides guidance to auto mechanics on the hazards of asbestos exposure during auto repair, and on how to avoid the hazards, in particular during brake repair. MLB asks EPA to discontinue any further dissemination of the Gold Book, and to "notify the public, through EPA's website or otherwise, that the Gold Book is outdated from a scientific and regulatory perspective." MLB argues that the Gold Book violates Data Quality Act Standards because it relies on inadequate/inappropriate data and literature; because it is outdated; and because its preparation, funding, review and approval are undocumented and cannot be verified or evaluated. Several juries have relied heavily on the Gold Book in awarding large verdicts to plaintiffs claiming injury from asbestos exposure during brake repair. MLB's Request for Correction is important because it is one of the first uses of the Data Quality Act with regard to information that has been introduced as expert evidence in litigation. EPA as not yet responded to MLB's Request for Correction.

CRE Comments on Atrazine Frog SAP

EPA conducted a three-day Science Advisory Panel on atrazine's endocrine effects on amphibians: i.e., frogs. CRE's comments on the SAP reiterated the points made in CRE's Data Quality Act Petition on this issue. First, EPA cannot regulate atrazine for wildlife endocrine effects until there are accurate, reliable and reproducible tests for such effects. Second, there are no such tests at this time. EPA agrees with these points based on its response to CRE's DQA Petition and based on EPA's White Paper for the SAP. The SAP's review of this issue is important because it may be the first SAP review of test reproducibility and reliability issues under the Data Quality Act. The SAP's report on this issue should be out by the end of July.

CRE Responds to CPR Letter to EPA and OMB Alleging CRE Misuse of Data Quality Act

On May 19, two academic members of the Center for Progressive Regulation wrote to EPA Administrator Whitman and OIRA Administrator Graham complaining that CRE was attempting to misuse the DQA when it filed comments with EPA rebutting comments on a biosolids rulemaking submitted by NRDC and a Cornell University project director. They alleged that the CRE comments constituted a DQ "complaint" which was an attempt to "quell scientific debate" and "pick-off" or "censor" comments "outside the normal confines of the rulemaking process." The CPR letter also argued at length that both OMB and CRE have misinterpreted the DQA as applying to information disseminated as part of rulemaking proceedings. The CRE response explains how the CPR assertions are inaccurate and reflect a misunderstanding of the CRE comments and the Data Quality legislation and guidance.

Einstein's Lectures on Electricity and Magnetism Demonstrate the Role of Data Quality and Transparency in Illuminating Complex Subject Matter

Lecture notes by Albert Einstein for a course on electricity and magnetism demonstrate that careful attention to Data Quality and transparency are essential for disseminating information about complex scientific issues. However, the lectures also demonstrate that, when requisite care is given to Data Quality, even difficult topics become accessible to a wider audience, thus expanding the ability of stakeholders to participate in the discussion. The following quote concerning continuously distributed electricity, following a discussion of the generalized form of Gauss's theorem, provides a lucid example of how Einstein carefully dealt with the use of assumptions. "So far we have assumed that electricity is unalterably bound to small bodies (treated as points). But the character of experience favors the assumption that electricity is spatially distributed. We must generalize our investigations in this sense." (p.6)

	Click to read English translation of Einstein lecture notes from the Albert Einstein Archives, The Jewish National and University Library, The Hebrew University of Jerusalem, Israel
	Click here for CyberActivist.US

OMB Urged to Include DOT's Data Quality Guidelines In Regulatory Analysis Guidelines
CRE recommended OMB include the statistical portion of DOT's Data Quality guidelines in OIRA's government-wide regulatory analysis guidelines. CRE advocates use of these statistical guidelines (Appendix A of the DOT Data Quality guidelines) by all agencies in their regulatory analyses because the guidelines constitute a "best practice" that promotes transparency throughout the analytic process. The guidelines also contain analytic principles for employing sound statistical methods, identifying and correcting errors, and ensuring clarity of work products. CRE's comments were in response to OMB's request for comment on their Draft 2003 Report to Congress on the Costs and Benefits of Federal Regulations.

The Data Quality Act Applies to Rulemakings
There recently has been discussion in several contexts as to whether the Data Quality Act in general, and its administrative correction process in particular, apply to information disseminated by agencies during rulemakings. CRE examined this issue during OMB's and the agencies' development of Data Quality Guidelines. Based on the text of the Data Quality Act, the relevant legislative history, and common principles of statutory construction, the Act and the administrative correction process clearly do apply to rulemakings and to all other information publicly disseminated by agencies subject to the Act. CRE's memorandum on this issue can be accessed below.

CRE Raises Data Quality Act Issues in EPA's PFOA Review
EPA solicited public comment on the Agency's proposed negotiation of Environmental Consent Agreements (ECAs) requiring additional testing for Perfluoroctanoic Acid (PFOA). EPA's Federal Register notice explained that one of the primary purposes of these ECAs is to develop data necessary to perform a PFOA risk assessment. EPA acknowledges that the development of these data will require accurate and reliable tests for many different media. CRE's comments stressed the Data Quality Act requirements for these tests. In particular, CRE emphasized the need for validating reproducible tests for PFOA in human and animal blood. The Data Quality Act requires validation of these tests before EPA can disseminate PFOA risk information based on human or animal blood levels. There currently are no validated PFOA blood tests that have been demonstrated to be reproducible among different laboratories.

CRE Files Comments on ESA Consultation
EPA, the Fish and Wildlife Service, and the National Marine Fisheries Service sought public comment on how to improve their consultations regarding pesticides under the Endangered Species Act. CRE's comments on this Advanced Notice of Proposed Rulemaking emphasized two points. First, all ESA determinations must be based on accurate and reliable data and are subject to the Data Quality Act. Second, EPA should be the lead agency in the consultation process.

EIA Sets the Standard for Data Quality Act Compliance
CRE recently had the pleasure of visiting the Energy Information Administration's website: http://www.eia.doe.gov/. This website is a model of how to disseminate information in a user-friendly manner that complies with both the letter and spirit of the Data Quality Act. In addition to publishing its own Data Quality Act Guidelines, EIA also revised its Standards Manual to conform to the new Data Quality Act standards. This remarkable Standards document states clear and essential requirements for insuring data quality. For example, with regard to the difficult issue of model validation, EIA's Standards Manual specifies in detail the steps necessary before the model can be used. Documentation of these steps is required to be placed on EIA's website for every model. EIA's Standards Manual also imposes rigorous requirements before any proprietary models are used.

Seafood Company Files Data Quality Act Petition with FWS
According to a Portland Press Herald article dated April 17, 2003, Fjord Seafood filed a Data Quality Act petition with FWS and the National Marine Fisheries Service challenging listing of Maine's wild Atlantic Salmon under the Endangered Species Act. Among other arguments, Fjord's Petition claims that the Services withheld from the public information critical to the listing. Several environmental groups, including the U.S. Public Interest Research Group, the Maine Chapter of the Sierra Club and the Conservation Law Foundation, have filed oppositions to the Petition. To the best of CRE's knowledge, this is the first Data Quality Act petition that has been formally opposed by third parties.

ABA Panel Predicts Major Data Quality Act Issues
On October 17, 2002, the ABA's section of Administrative Law and Legislative Practice held an Administrative Law Conference that included a panel discussion on "Learning to Live With the Data Quality Act." This very balanced panel included proponents of the Act (including CRE's own Jim Tozzi); opponents of the Act; and OMB officials charged with administering the Act. At the time of the panel, no Data Quality Act petitions had yet been filed. Yet, the panel and public comments remarkably predict two of the major issues raised by subsequently filed Data Quality Act Petitions: i) reproducibility of influential scientific information; and ii) application of the Petition process to ongoing public comment proceedings. The panel transcript is a valuable resource in understanding the Data Quality Act and its potential impacts on the administrative process.

CRE, in First-Ever Use of Data Quality Guidance for Third Party Submissions, Issues Rebuttal to NRDC Comments on EPA Biosolids Proposal
In its Watchdog Watch role, CRE has sent supplemental comments to EPA which warn that the NRDC comments on its draft risk assessment for land-applied biosolids cannot be used because, under both the OMB and EPA Data Quality guidance, they contain substantial inaccuracies, omissions, and biases, and lack reproducibility. The NRDC comments argued that the draft risk assessment under-estimated risks from dioxin and related compounds.

DOT's Data Quality Guidelines Set Benchmark Standard for Pre-Dissemination Review
An important component of the Data Quality Act is the requirement for agencies to initiate review processes for ensuring the data disseminated to the public meets the standards promulgated pursuant to the Data Quality Act. This pre-dissemination review takes place throughout the development and analysis of information disseminated by an agency. By effectively ensuring that disseminated information meets data quality standards, the agency will minimize the use of "requests for correction" after data is disseminated. DOT's Data Quality Guidelines have established a benchmark for pre-dissemination review that should serve as a model for other agencies. In particular, the DOT guidelines establish: 1) rigorous and detailed statistical principles and guidelines; and 2) the positive duty of the Department to consult with stakeholders on Data Quality issues.

EPA Acts on Atrazine Data Quality Petition
EPA has announced its position on atrazine's purported endocrine effects on wildlife in response to the Data Quality Act Petition filed in November by the Triazine Network, the Kansas Corn Growers Association and CRE. This Petition argued that EPA's FIFRA/FQPA Environmental Risk Assessment for atrazine violated both EPA's own DQA Guidelines and Government-wide ICCVAM guidelines by concluding that atrazine causes endocrine effects in frogs and other wildlife when there are no validated tests for those effects. EPA concluded that the Agency's ecological risk assessment "does not suggest that endocrine disruption...be regarded as an regulatory endpoint at this time."

EPA-CRE Disagreement on the Use of Unvalidated Tests
The Bureau of National Affairs (BNA) reported on a speech made by an EPA policy official in which he stated that the agency could utilize unvalidated tests as a basis for rulemaking. CRE argues that preventing federal government reliance on unvalidated data is precisely the reason that the Data Quality Act was enacted.

Status Of Data Quality Act Petitions
In addition to the three earlier filed Petitions, BMW filed a new Data Quality Act Petition requesting correction of information on several EPA data bases regarding BMW's RCRA compliance. EPA has also initially denied the Chamber of Commerce's Petition. While there has been no formal response to the four Senators' Petition, Administrator Whitman has sent them a discouraging letter regarding it.

• The first Petition requested that EPA's IRIS listing for barium be revised. EPA initially denied this Petition on January 30, 2003. The Petitioner Chemical Products Corporation can now file an administrative appeal.



• The second Petition, filed by CRE and agricultural groups, requested correction of EPA's FIFRA/FQPA environmental risk assessment for atrazine to clarify that there can be no reliable data on atrazine's purported endocrine effects on wildlife until there are properly validated tests for such effects. On January 30, 2003, EPA sent Petitioners a letter which said that EPA will respond to their Petition in EPA's atrazine interim IRED. The IRED, which became available on February 20, granted much of the relief sought by the Petition. The Petitioners are the Triazine Network, the Kansas Corn Growers Association and CRE.



• The Chamber of Commerce filed a petition seeking correction of the minutes for an EPA SAB meeting held on October 1, 2002. In a letter dated March 5, 2003, EPA initially denied the Chamber's Petition on the ground that the SAB was not subject to the Data Quality Act.



• The Competitive Enterprise Institute has filed Data Quality Petitions with NOAA and OSTP related to global climate change. The CEI Petitions seek withdrawal of the National Assessment on Climate Change, which is the inter-agency technical document that underlies most of the federal Government's recent statements about global climate change.



• Four US Senators have also filed a petition to EPA regarding NPDES for Oil and Gas Construction Activity. EPA has not formally acted yet on the Senators' Petition. However, in a letter dated March 7, 2002, Ambassador Whitman disagreed with most of the flawed data arguments in their Petition. EPA has also published the final rule in question, and the Senators' Petition had requested that the final rule not be published.



• BMW's Petition requests correction of EPA's Enforcement Compliance History Online database; EPA's Sector Facility Indexing Project database; and other EPA compliance databases. BMW claims that these databases erroneously show BMW as being in Significant Non-Compliance (SNC) with RCRA. BMW claims that these SNC listings for it are based only on alleged violation of an EPA guidance memorandum which is now being judicially reviewed by the D.C. Circuit.

CRE Interpretive Bulletin No. 1
One of CRE's mandates is to promote efficiency in agency actions. Since most agencies have finalized their Data Quality guidelines, CRE will be providing recommendations for improving the efficiency of the federal Data Quality program. CRE will communicate its recommendations through Interpretive Bulletins. Prior to finalizing the Bulletins, CRE will post them in draft on this site for public comment. CRE requests the views of its readers with respect to topics that should be addressed through the Bulletins. The first CRE Interpretive Bulletin concerns an issue raised by a number of persons who, although supportive of the Act, are concerned about the potential for correction petitions to over-burden agencies. Basically, the issue could be described as the difference between a "Win-at-the-Agency" approach and a "Win-in-Court" strategy. In the former, a petitioner asks the agency to correct only those determinative issues that affect an outcome, while the latter approach develops a comprehensive list of issues, with varying degrees of significance, with the intent to develop a complete record for eventual judicial review.

• Click to review the CRE Bulletin
• Submit comments on draft Interpretive Bulletin

Assessing the Future Impact of the Data Quality Act on Federal Agencies
A panel sponsored by the American Bar Association will convene at the Ritz-Carlton on Thursday, October 17th, at 3:00p.m. The meeting, which will mark the inception of Federal agencies' compliance with OMB guidelines specified under the Data Quality Act, will include:

	Program Chair and Moderator:
	Wendy Wagner, Joe A. Worsham Centennial Professor of Law, University of Texas School of Law, Austin, TX
	Speakers:
	Fred Anderson, Cadwalader, Wickersham and Taft, Washington, DC
	Dr. John Graham, Administrator, Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, DC
	David Hawkins, Natural Resources Defense Council, Washington, DC
	Sid Shapiro, Rounds Professor of Law, University of Kansas and The Center for Progressive Regulation, Lawrence KS
	Jim Tozzi, Board of Advisors, The Center for Regulatory Effectiveness, and Former Deputy Administrator; OIRA, OMB, Washington, DC

Panelists will review and assess the requirements of the guidelines, and assess the potential impact of the requirements on agencies in the immediate and long-term future.

CRE Comments on EPA's Proposed Data Quality Guidelines for Third-Party Submissions
EPA's Draft Assessment Factors for Evaluating the Quality of Information from External Sources explains how EPA will apply Data Quality Act standards to information submitted to EPA by parties outside the Agency. CRE's comments on this very important document identified several shortcomings. One of CRE's major concerns is EPA's proposed use of a long list of EPA documents to determine whether third-party submissions comply with the Data Quality Act. CRE's comments explain that many documents on this list do not comply with the Data Quality Act. Consequently, they should not be used as a yardstick for Data Quality Act compliance.

EPA Proposes New Data Quality Act Guidelines for Third-Party Submissions and Announces a September 20 Public Meeting on the Proposal
Much of the "information" disseminated by EPA is generated by third parties outside of the Agency: e.g., public comment in rulemakings and outside research. In the September 9th Federal Register notice, EPA proposed Data Quality Act guidelines for third-party information submissions. The notice provides EPA's proposed standards for determining whether third-party submissions are of sufficient quality to be used by the Agency. It includes appendices identifying the risk assessment methods, models, and guidance documents EPA will use to determine whether third-party submissions comply with the Data Quality Act Standards. Yet many of these methods, models and guidance documents themselves may violate the Data Quality Act Standards. EPA's website states that written comments must be postmarked by September 30.

OMB Affirms Requirement for Timely Agency Responses to Data Quality Complaints During Rulemakings
In a September 5th memorandum from Office of Information and Regulatory Affairs (OIRA) Administrator John Graham, OMB thanked federal agencies for the significant progress they have made in developing their draft Data Quality guidelines. The OMB memo also provided additional guidance on process issues so as to promote uniformity across agencies. Among the guidance provided by OMB was specific recommended language to ensure that agencies respond to Data Quality Act complaints during rulemakings in a timely fashion.

Watchdog Watch: NRDC Expresses Views on CRE's Regulatory Watchdog Role
CRE is launching a new feature entitled "Watchdog Watch" to review the activities of organizations whose primary activity is to either participate directly in a wide range of regulatory proceedings or, through their website, to significantly influence the participation of other persons in such rulemakings. To this end, the Center has reviewed comments submitted by the Natural Resources Defense Council (NRDC) to EPA on the agency's proposed Data Quality Act guidelines, spelling out in some detail the document's strengths and areas of potential improvement. However, of comparable concern to NRDC was CRE's emerging preeminence as a "Regulatory Watchdog," which not only tracks the regulatory activities of federal agencies, but also monitors the regulatory activities of special interest groups. In future Watchdog Watch articles, CRE will present an analysis of statements and positions taken by such groups.

Additional Agencies Issue Proposed Data Quality Guidelines
In recognition of the importance of the Data Quality Act, CRE is pleased to report that additional agencies have now issued proposed Data Quality guidelines for public comment (click on "Data Quality Guidelines by Agency" box to access guidelines). While in some cases, these proposals may be late, the agencies have nevertheless worked to comply with the statute. CRE also applauds various Bureaus within the Department of the Interior for preparing their own Data Quality guidelines, which further refine earlier, Department-wide guidelines. The Center believes that further detail and specificity in guidelines at the sub-agency level will not only increase transparency but result in smoother functioning of the standards and procedures put in place pursuant to the Act. Comment deadlines for these new guidelines are set forth below.

Failure to Withdraw Flawed Proposals and Drafts Raises Cross-cutting Data Quality Issue
In its recent memorandum to all federal agencies on Data Quality issues, OMB indicated concern with situations where agencies continue to disseminate information for an unusually long time which does not meet the new Data Quality Act standards. OMB recognized that even though such information may be labeled as "draft" or"proposed," if it remains outstanding for an extended period, it can have deleterious effects which should be remedied. However, apparently, none of the agencies have addressed this issue in their draft Data Quality guidelines. Agency guidelines should state that once it becomes apparent that a proposal or draft is flawed, or final action is deferred due to recognized problems with the proposal or draft, it will be unequivocally withdrawn rather than being consigned to indefinite status as a deferred proposal, draft, or interim position. If the problems are later resolved, the agency can then issue a new proposal or draft.

National Academies Publish Transcript of Data Quality Workshop
The National Academies' Science, Technology, and Law Program has now made the transcript available from its Data Quality Workshop held May 30, 2002. This was the third and final session on this topic, and the purpose of this open, public meeting was to discuss newly-issued draft agency-specific guidelines, issued to conform with OMB's government-wide Data Quality guidelines. The NAS meeting was attended by over 200 participants, and CRE believes that the exchange of ideas at the meeting was useful to federal agencies as they seek to finalize their Data Quality guidelines.

CRE Reader Reports on Serious Data Quality Problems with Department of Education Information Related to Special Education
A retired member of the Professional Advisory Board to a chapter of the Tourette Syndrome Association recently wrote to CRE to make the Center and its readers aware of serious deficiencies in the quality of information issued by the U.S. Department of Education (USDOE) related to special education data, which this official labels as "blatantly inaccurate." Much of this bad information continues to be used by the Department in making regulatory and policy decision, despite the fact that these information problems were cited in studies issued by the Department's own Inspector General. If such reports are indeed true, this is just the type of situation that Congress intended the Data Quality Act to remedy.

ABA Section on Administrative Law Issues Policy Letters to Agencies on Data Quality Guidelines
The American Bar Association's (ABA) Section on Administrative Law & Regulatory Practice has issued Policy Letters to eight key federal agencies on their Data Quality guidelines. While not representing the ABA as a whole, the Section's comment letters provided insightful recommendations on the process and procedural aspects of the proposed guidelines related to correction of information. For example, in its letter to EPA, the Section challenges the agency on several points, including: EPA's attempt to prohibit corrections during the pendency of an open rulemaking proceeding; the agency's suggestion (contrary to the statute) that it may elect to not correct certain information due to "Agency priorities, time constraints or resources"; or limits on subjecting models to the correction process. In light of the ABA Section's considerable expertise in matters of administrative law, CRE urges agency officials to carefully review and adopt the recommendations set forth in these important Policy Letters.

Washington Legal Foundation (WLF) Article Seeks Increased Judicial Review of Agency Science
Alan Raul and Julie Zampa, of Sidley Austin Brown & Wood LLP, recently authored a WLF Legal Backgrounder entitled "Deeper Judicial Scrutiny Needed for Agencies' Use of Science." This thought-provoking article analyzed new ground broken by the Tozzi v. DHHS case in terms of expanding judicial review of federal agencies' use of science. Data Quality Act guidelines are also discussed as a positive step to improve transparency of agency decisionmaking and the quality of agency science. However, the article notes that courts have adopted very inconsistent approaches in conducting reviews of agency science, with some serious and probative, but others overly deferential. The authors conclude that the Tozzi case took a valuable step by increasing availability of judicial review, one which courts must build upon by exercising these enhanced powers so as to review agency science in a more consistent, predictable, and probative manner.

FCC Issues Study on Horizontal Concentration in the Cable Industry with Data Quality Implications
The Federal Communications Commission (FCC) recently released a study examining the extent to which different levels of horizontal concentration among multichannel video program distributors might affect the flow of video programming to consumers. This study, utilizing experimental economics, was designed to supplement an ongoing FCC rulemaking proceeding, examining, among other things, the subscriber (horizontal ownership) limits that apply to cable operators. CRE believes that this study, based upon experimental economics, could have a significant impact on FCC regulatory activities, and consequently, it is subject to the Data Quality Act guidelines. CRE is considering conducting a review of this document to determine whether it complies with the Data Quality guidelines.

DOE Proposed Data Quality Guidelines Break New Ground on Two Important Issues
The Department of Energy's (DOE) proposed Data Quality guidelines were issued late, but in at least two respects, they were worth the wait. First, DOE proposes to apply Data Quality Act standards to its Information Collection Requests (ICRs) submitted to OMB for approval under the Paperwork Reduction Act (PRA). In DOE's own words, "... for all proposed collections of information that will be disseminated to the public, DOE Elements should demonstrate in their PRA clearance submissions to OMB that the proposed collection of information will result in information that will be collected, maintained, and used in a way consistent with the OMB and DOE information quality guidelines." Second, DOE proposes a detailed application of the Safe Drinking Water Act (SDWA) risk assessment standards to ecological as well as human health risk assessments. CRE commends DOE, and urges the public to file comments supporting DOE's proposals on these two issues. Comments are due to the agency by August 22, 2002.

CRE Applauds Decision of EPA's SAB to Form Data Quality Act Committee
CRE understands that the Executive Committee of EPA's Science Advisory Board (SAB) has decided to create a new committee on EPA's development of Data Quality Act guidelines. Important issues to be addressed by the SAB Committee include reproducibility and third-party information submissions. CRE believes that this approach will provide EPA with a source of strong and independent scientific expertise as it tackles ongoing information quality issues covered by the Data Quality Act guidelines. The Center urges other federal agencies to consider, as appropriate, establishing independent Data Quality Committees to advise the agencies regarding their Data Quality Act guidelines and issues raised thereunder.

Lawmakers Provide Comments on EPA's Proposed Data Quality Guidelines
Congressmen W.J. "Billy" Tauzin and Paul Gillmor recently issued a comment letter to EPA regarding the agency's proposed Data Quality guidelines, with special focus was on statements related to risk assessments. According to the letter, "EPA's proposal would be inconsistent with law and it leaves completely open-ended loopholes for EPA not to follow the SDWA principles or any principles of objectivity." The comments also take EPA to task for failing to state a reasonable rationale for treating human health risk assessments differently from other forms of risk assessment (e.g. drinking water, environmental health and safety). CRE urges EPA to carefully consider the viewpoints of Members of Congress who helped pass the Data Quality Act.

University of Colorado Newsletter Offers Exchange of Views on Data Quality Act
The University of Colorado's Center for Science and Technology Policy Research recently published articles in its Ogmius Newsletter offering an exchange of views on the Data Quality Act and its impact on the role of science in policymaking. One article was authored by CRE Advisory Board Member, Jim Tozzi, and an editorial response was provided by Chuck Herrick of Stratus Consulting. The Center supports such efforts to explore such key policy issues so that the Data Quality Act's implementation is both effective and workable.

DOE Energy Information Administration Seeks Comments on Testing and Research Questionnaire to Improve Data Quality
The Department of Energy's Energy Information Administration is seeking public comments on its voluntary survey entitled "Generic Clearance for Questionnaire Testing and Research" as part of its form clearance request to OMB under the Paperwork Reduction Act. The survey is used in a variety of settings to determine how to best modify questionnaires in order to improve the quality of the data generated, and CRE strongly supports DOE's efforts in this regard. However, the Center believes that DOE should also factor in the standards set forth in OMB's and the Department's Data Quality Act guidelines. Both the survey and the guidelines serve the same goal, and to the extent that survey information is disseminated, the guidelines already apply.