CRE Homepage About The CRE Advisory Board Newsletter Search Links Representation Comments/Ideas
Reg Week Archives
Data Access
Data Quality
Regulation by Litigation
Regulation by Information
Regulation by Appropriation
Special Projects
CRE Watch List
Emerging Regulatory Issues
OMB Papers
Abstracts and Reviews
Guest Column
Voluntary Standards Program
CRE Report Card
Public Docket Preparation
Interactive Public Docket
Electronic Regulatory Reform
Consumer Response Service
Site Search

Enter keyword(s) to search


c/o Suite 700, 1250 H Street N.W., Washington, D.C. 20005
202-942-7617 (V) 202-942-7668 (F)

June 7, 1999

Leave a Comment

Dear Appropriations Member:

Except for two who are now federal judges and are thus precluded from joining us, we the undersigned constitute all of the Administrators of OMB's Office of Information and Regulatory Affairs (OIRA) who served during the Reagan and Bush presidencies. We urge you to oppose the Price Walsh amendment to rescind the Aderholt-Shelby provision in last year's omnibus appropriations bill directing OMB to issue rules requiring agencies to make public at reasonable cost and through Freedom of Information Act procedures, data which results from publicly-funded research and which is used to develop policies and rules.

We realize, of course, that researches have a proprietary interest in their work and are reluctant sometimes to share data with others. And we realize that if the mandate of the Aderholt-Shelby provision is carried out researchers may be less anxious to do work for the federal government and thus the contractual costs of such work may rise. But this would simply reveal the length to which such researchers will go to deny the public's right to know and would not represent an increase in the real costs of such research.

Moreover, we realize that certain objections have been raised concerning potential loss of privacy and (legitimate) intellectual property. In our opinion such objections are altogether groundless, as the Freedom of Information Act, through which the OMB requirements would have to operate, provides specific protections against the release of data in such instances.

The simple truth is that the data at issue have been bought and paid for by the American people, and they deserve to have access to it. Moreover, the essence of the scientific method is replication, wherein others may analyze, evaluate, and duplicate the results of the research to establish its true credibility. We are aware that in the past certain agencies have relied on the results of studies where the analysis and underlying data have not been subject to public scrutiny. We believe such situations to be wholly contrary to the principles of good government and destructive of the public's trust in government.

Carrying out the Aderholt-Shelby provision will greatly improve the transparency of government and result in public policies that are more targeted and more supportable. We respectfully urge you to support the Aderholt-Shelby language and to vote against the Price-Walsh amendment.


James C. Miller III
(OIRA Administrator, 1981)

Christopher DeMuth
(OIRA Administrator, 1981-1983)

Wendy Lee Gramm
(OIRA Administrator, 1985-1987)

James B. MacRae, Jr.
(Acting OIRA Administrator, 1989-1992)