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May 1, 1998
MEMORANDUM FOR CHIEF INFORMATION OFFICERS
Donald R. Arbuckle
Acting Administrator and Deputy Administrator
Office of Information and Regulatory Affairs
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.