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CRE Comments to OMB

CRE Submits Comments to OMB on its Data Quality Guidelines
CRE has submitted comments to OMB on its OMB-specific proposed Data Quality guidelines. In addition to its letter comments, the Center has attached four 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 OMB's and other agencies' attempts to exempt certain categories of information from the Data Quality Act guidelines' applicability; (3) Comment on EPA's proposed Data Quality guidelines submitted by the ABA Section on Administrative Law and Regulatory Practice, and (4) supplemental comments specifically related to risk issues.

  • Review CRE's comment letter to OMB
  • Read 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's comments on EPA's Data Quality Guidelines
  • Click to review CRE's supplemental comments related to risk issues
  • Comment on Item

    CRE Submits Comments on "Reproducibility" Standard in OMB's Data Quality Guidelines
    CRE submitted comments to OMB on the "capable of being substantially reproduced" standard included in the agency's final Data Quality guidelines. The reproducibility standard was issued on an interim final basis, and OMB accepted additional public comments on that key aspect of the guidelines through October 29, 2001. CRE strongly supports OMB's reproducibility requirement as a standard of care for governmental information. If information is not sufficiently robust that it cannot be reproduced by independent parties across testing environments, it should not be deemed adequately reliable for dissemination to the public. CRE urges OMB to retain this important aspect of the guidelines.

  • Read CRE's Comments to OMB
  • Read CRE's Supplemental Comments to OMB
  • Click to read more about the Data Quality Act and related issues
  • Comment on Item