Association of Public Data Users
Opportunities for public comment
APDU Committee Representative Guidelines
COPAFS
2010 Census Advisory Committee
APDU Representative Expectations - Position Description
Opportunities for Public Comment on Federal Data Collections:
What You Need to Know
Every federal data collection effort must be reviewed and approved by the Office of Management and Budget (OMB) before it can be implemented. (Approvals for existing surveys have to be renewed every three years.) As part of the review process, the public is given two opportunities to comment—a 60-day window as the statistical agency is preparing its submission to OMB and a 30-day window after it submits the package.
The statistical agencies and OMB take public comments seriously. These letters play two roles. First, letters that say a data collection is important are used to help ensure that the data collection continues—this is a particularly valuable role in these tight budget times. Second, letters can bring about improvements in survey language and data collection methodology. It’s not uncommon for changes to be made in response to public comment.
The APDU listing of current comment opportunities gives you the information you need to obtain the draft survey and supporting documents. For a pre-submission (60-day) opportunity, you e-mail the project lead at the statistical agency at the address given. For a post-submission (30-day) opportunity, you click on the web link in the right column of the APDU listing, to OMB’s Reginfo.gov. Once on the Reginfo web page, select “All” to see the links for the draft questionnaire and other documents submitted for approval. Then click on “View Supporting Statement and Other Documents” to get the supporting statements that explain the what, why, and how.
There is no standard format for writing a comments letter. You can organize it in the way that makes sense to you. If all you want to do is say you think a particular survey is important, one paragraph is sufficient. All letters sent are part of the public record. If you write a letter to the agency, as part of its submission to OMB it has to say how it responded to your suggestions.
The federal data user community, and the statistical system itself, will benefit to the extent that data users let the statistical agencies and OMB know what they think of proposed data collections. APDU encourages you to take regular advantage of this opportunity. You can have an impact. Please feel free to contact us at info@apdu.org with any questions.