Public Comment Regarding: Additional comments on OMB Guidance on "Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies," on paragraphs V.3.B, V.9, and V.10, on the "capable of being substantially reproducible" standard.
|Vanester M. Williams, Department of Transportation
Text of comment:
Per request, below is the Department of Transportation's comments on the
standard "capable of being substantially reproduced."
Reproducibility is a basic tenant of the scientific method. If the data
used in an analysis are publicly available at the time of dissemination or
become available afterwards, affected persons or their agents can redo the
analysis. If the new results are substantially different from the
disseminated results, the affected persons can seek correction under III.3.
If the data are not publicly available, the situation is murky. The agency
may agree to have an independent group redo the analysis, but it is not
clear if the agency has to. If so, there are cost implications. If not,
the standard becomes a Catch 22.