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Emergency Clearance of Y2K Surveys under the Paperwork Reduction Act

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May 1, 1998


FROM: Donald R. Arbuckle
Acting Administrator and Deputy Administrator
Office of Information and Regulatory Affairs
SUBJECT: Emergency Clearance of Y2K Surveys under the Paperwork Reduction Act

As you know, the Office of Information and Regulatory Affairs (OIRA) is working closely with the new President's Council on Year 2000 Conversion, chaired by John Koskinen, to coordinate the Federal government's response to this critical management issue. Recently, John asked the agencies to reach out to those outside the federal government -- State and local government, businesses, grantees and contractors -- and to ask them about their readiness for the year 2000. Some agencies plan to issue surveys or make telephone contact with these parties.

Such surveys or telephone calls -- otherwise known as information collections -- are covered under the Paperwork Reduction Act of 1995 (PRA). Because of the critical importance of the year 2000 issue, I want to assure you that we are prepared to provide, on an expedited basis, 6-month emergency approval for any such information collection.

Your PRA clearance officer should make a request for an emergency clearance, describing the urgency of the year 2000 information collection and requesting waiver of the 60-day and 30-day notices in the Federal Register. Such information collections are likely to be one-time, quick turn-around efforts; consequently, I do not foresee the need for you to submit in your clearance package any documentation beyond the information collection and a brief justification statement. Nor would there be any public purpose served by conducting an after-the-fact public notice.

To help us identify and process these year 2000 information collections, I ask that you identify these requests clearly as Y2K surveys so that we can quickly identify and process them. I also request that you try to allow at least two weeks for emergency review. If this is not possible, however, we will do everything we can to accommodate your schedule, and I have asked my staff to make every effort to conduct PRA reviews to meet your schedule.

Each agency's OIRA Desk Officer will review Y2K information collections, and any questions about the specifics of your survey should be addressed to that analyst. However, I have asked Virginia Huth of my staff (202-395-6929) to coordinate these reviews, and serve as our Y2K survey ombudsperson. If you or your staff have any general concerns involving a year 2000 information collection, please feel free to call her. Finally, please call me if any problems appear to be developing so that we can resolve them immediately.

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