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Public Comments


ABA Section of Administrative Law and Regulatory Practice

OIRA Administrator And NGOs Assess First Year Of Data Quality Act
At the October 8, 2003, meeting of the Section, John Graham of OIRA delivered a speech on his appraisal of the first year. Dr. Graham pointed out that the feared inundation of agencies by requests for correction had not materialized and there were no signs of overburdening of the regulatory process or chilling of agency disseminations. He also noted that petitions had been submitted not just by industry, but by all types of groups, and that the two-stage reconsideration process for requests appeared to have fostered corrections. He also observed that, while the law does not apply directly to universities and others submitting data to agencies, as a practical matter such submissions should meet quality standards if those parties hope to have it used by the agency. Finally, he noted that some petitions based on differing interpretation of science might have been more successful if they had focused on portrayal of uncertainty rather than allegations of inaccuracy. Environmental activists who spoke at the meeting indicated they might make increased use of the law, and that it could further polarize debates over the objectivity of science used in environmental regulations. Industry speakers noted their continuing support for increased agency resources to develop updated and sound scientific data, and they commented that interest groups' objections to inclusion on agency advisory panels of researchers who had participated in industry-funded studies impedes the development of new data with industry support.

  • Click to read Dr. Graham's speech.
  • 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.

  • Click to read more, including access to the ABA Section's Policy Letter to key federal agencies on their proposed Data Quality guidelines
  • CRE Regulatory Services

  • House of Representatives

    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.

  • Click to read the Tauzin-Gillmor letter to EPA
  • Click to submit a comment

    Chamber of Commerce

    Information Quality Guidelines: U.S. Chamber of Commerce Issues Checklist of Key Concerns Regarding Agency Implementation of the Data Quality Act
    The U.S. Chamber of Commerce has sought to encourage trade associations, businesses, and others to submit comments to agencies of interest on their proposed Data Quality guidelines. To this end, the Chamber prepared a checklist of key concerns which potential commenters might wish to consider and then provide input. The Chamber's views are also offered on each topic. CRE believes that this list is thoughtful and reasonably comprehensive, so the Center wanted to make it available to its readers.

  • Click to read the Chamber of Commerce checklist on the Agency Implementation of the Data Quality Law.
  • Click to submit a comment

    Office of Management & Budget

    Comments on Proposed Bulletin on Good Guidance Practices

    Comments Submitted to OMB on its Proposed Peer Review Guidelines
    OMB's proposed peer review guidelines would be established under and supplement OMB's government-wide guidelines under the Data Quality Act. CRE is a repository of information under the Data Quality Act. Consequently, as a service to its readers, CRE is posting all comments OMB receives on its proposed peer review guidelines just as CRE posted all comments OMB received on its original government-wide Data Quality Act guidelines.

  • Review comments submitted to OMB on its proposed Peer Review guidelines.
  • Comment on Item

    CRE Catalogs All Comments Submitted to OMB on its Proposed Data Quality Guidelines
    CRE is a repository for information on the Data Quality law. Consequently, as a service to its readers, CRE has posted all of the nearly 100 public comments which OMB received related to the publication of its proposed Data Quality guidelines. The purpose of this section is to provide a forum for the important public policy discussion on this issue.

  • Read more and review public comments submitted to OMB on the Data Quality Guidelines.
  • Comment on Item

    Center for Progressive Regulation

  • Read CPR Letter to EPA/OIRA Challenges Misreading of Data Quality Act.