Groups Call for Increased Transparency in Rulemaking
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.
Sincerely,
Robert Weissman
President
Public Citizen
On behalf of:
American Association of Law Libraries
AFL-CIO
AFSCME
Association of Research Libraries
Center for Digital Democracy
Center for Effective Government
Center for Media and Democracy
Center for Science in the Public Interest
Citizens’ Environmental Coalition
Citizens for Ethics and Responsibility in Washington (CREW)
Electronic Frontier Foundation
Essential Information
Institute for Agriculture and Trade Policy
National Consumers League
National Employment Law Project
Open the Government
Project On Government Oversight
Public Citizen
Public.Resource.Org
Sciencecorps
Special Libraries Association
Sunlight Foundation
United Steelworkers
US PIRG
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