FR 2021-00520

The Department of Defense (DoD), specifically through its Defense Threat Reduction Agency (DTRA), has put forward a proposal aimed at gathering information from individuals involved in nuclear tests. This proposal is currently open for public commentary until February 12, 2021, as it is under review by the Office of Management and Budget (OMB). The main purpose of this information collection is to facilitate the recognition of service, verify participation in nuclear tests, and collect data necessary for evaluating radiation exposure among military veterans and civilians. This data ultimately supports the issuance of the Atomic Veterans Service Certificate (AVSC) and the processing of claims for radiogenic disease compensation through the Department of Veterans Affairs (VA) and the Department of Justice (DOJ).

Significant Issues and Concerns

One of the notable concerns with this document is the omission of any mention of the budget or total cost associated with this information collection effort. Without financial transparency, it becomes challenging for stakeholders to assess whether the resources allocated are being used efficiently, or if there is potential for wasteful expenditure.

Moreover, the document vaguely describes the use of collected information, beyond its application for awarding the AVSC and processing compensation claims. This lack of clarity could lead to privacy concerns and questions regarding data usage transparency, especially considering the sensitivity of the information being collected.

The document also refers to several forms (DTRA Form 150, 150A, 150B, and 150D) yet fails to provide explanations of their specific purposes. This may result in confusion among respondents, who may not understand why multiple forms are necessary or what distinct information each form solicits.

Additionally, terms such as "radiogenic disease compensation" may not be readily understood by the general public, potentially limiting accessibility and comprehension of the document's implications. The notice further lacks detail on the processes of "recognition" and "verification" related to the collected information, which might appear ambiguous or incomplete to stakeholders.

The notice's indication that public comments will be made available online without change could also raise privacy concerns. Even though the text mentions that personal identifiers will be included, the lack of clarity about how personal information is protected may discourage individuals from freely submitting comments.

Public and Stakeholder Impact

From a broader perspective, this proposal might positively impact eligible veterans and civilians who participated in nuclear tests by officially recognizing their service and facilitating access to potential health-related compensations. By addressing the health impacts of radiation exposure, the information collection can support epidemiological studies, thereby contributing to better understanding and management of health issues among veterans.

However, the lack of clarity and transparency surrounding the collection and use of personal data, as well as potential financial oversight, could negatively affect public trust. This distrust could lead to decreased participation in the information collection program, ultimately hindering the DoD's goals of recognition and compensation.

Specific stakeholders, such as veterans applying for the AVSC or filing claims for compensation, may bear the brunt of any inefficiencies or mismanagement resulting from the information collection processes. Ensuring that these processes are executed transparently and efficiently is essential to safeguard their interests and ensure the successful implementation of the proposal.

In summary, while the DoD's proposal has the potential to deliver significant benefits to a specific subset of the population, addressing the outlined concerns is crucial to maximize public participation and ensure positive outcomes for all stakeholders involved.