Groups Call for Increased Transparency in Rulemaking

POGO joins Public Citizen and other open government groups in calling for a change at the Office of the Federal Register that would require that standards incorporated in proposed and final rules be available for free on the Internet.

January 31, 2014

By POGO Staff

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To:

January 31, 2014
Ms. Amy Bunk
Director of Legal Affairs and Policy
Office of the Federal Register
800 North Capitol Street, N.W., Suite 700
Washington, D.C. 20001
Re: Comments on NPRM, Incorporation By Reference, Docket Number: OFR-13-0001

Dear Ms. Bunk:

It is imperative that the law be readily accessible for all to read and use. That is a central requirement of our democratic system. Accordingly, we strongly believe that standards incorporated by reference into federal regulations should be widely available to the public, without charge, and that such standards should be deemed in the public domain rather than subject to copyright restrictions.

Collectively, our organizations work on a range of public policy issues, including health, safety, consumer protection, the environment, open government, and civil rights. Allowing free access to standards incorporated by reference will strengthen the capacity of organizations like ours to engage in rulemaking processes, analyze issues, and work for solutions to public policy challenges. Such open access to standards will help protect public safety, promote economic opportunity, increase access to justice, and strengthen citizen participation in our democracy.

We ask the Office of the Federal Register to issue a final rule that goes beyond the NPRM and requires that standards incorporated by reference in proposed rules and in final rules be available for free on the Internet.

Signed by: