Overview
Title
Notice of Request for Comments on Extension of a Currently Approved Information Collection
Agencies
ELI5 AI
The Rural Business-Cooperative Service wants to check with people if they should keep collecting information about products made from plants rather than oil, to help guide what government buys; they want people to share their thoughts by April 20, 2021.
Summary AI
The Rural Business-Cooperative Service (RBCS) is requesting public comments on extending an existing information collection related to biobased products for federal procurement. This is part of the USDA BioPreferred Program, which aims to encourage the use of biobased products instead of fossil-based ones by federal agencies. Participation is voluntary, and the USDA will collect information from manufacturers and vendors to support this initiative. Comments must be submitted by April 20, 2021, and the requested changes will help improve the program's efficiency and effectiveness.
Abstract
In accordance with the Paperwork Reduction Act of 1995, the Rural Business-Cooperative Service (RBCS) invites comments on this information collection for which approval from the Office of Management and Budget (OMB) will be requested. The intention is to request an extension of a currently approved information collection in support of the Guidelines for Designating Biobased Products for Federal Procurement.
Keywords AI
Sources
AnalysisAI
The document is a notice from the Rural Business-Cooperative Service (RBCS) of the USDA, inviting public comments on extending a current information collection related to the designation of biobased products for federal procurement. This initiative is part of the USDA BioPreferred Program, designed to promote the use of biobased products over their fossil-based counterparts by federal agencies. The information collection is intended to support this goal by gathering data from manufacturers and vendors of biobased products. The submission deadline for comments is April 20, 2021.
General Summary
The notice indicates that the USDA seeks to extend an OMB-approved information collection process, essential for implementing the BioPreferred Program as mandated by various agricultural acts. This program seeks to ensure that federal agencies prioritize purchasing biobased products when feasible. The overall burden estimated for participants is 40 hours per response, with a total annual burden of 8,800 hours, distributed among approximately 220 respondents.
Significant Issues and Concerns
There are several notable concerns within the document:
Lack of Clarity on Selection Criteria: The document does not elaborate on the criteria or process used to select product categories for preferred procurement. This omission might lead to uncertainties about fairness and transparency, as stakeholders may be unaware of how their products could qualify for preferred status.
Burden on Respondents: The estimated 40-hour burden per response could be perceived as excessive, particularly for small businesses. This significant time investment may discourage participation, potentially undermining the program's objective to encourage wide adoption of biobased products.
Future Burden: While the document indicates that the 8,800-hour burden is based on a one-time response requirement, it does not clarify how future additions to product categories might impact this estimate. The absence of such projections could leave stakeholders uncertain about future commitments.
Voluntary Participation: Although participation is voluntary, the document fails to mention potential drawbacks or consequences of non-participation. Understanding these aspects could be crucial for manufacturers and vendors considering whether or not to engage in the program.
Comment Submission Guidance: The document provides minimal instructions for submitting comments via the Federal eRulemaking Portal. This lack of detailed guidance might create confusion and hinder effective public participation in the feedback process.
Technical Language: The use of technical jargon, particularly concerning federal procurement regulations and biobased product designations, might be challenging for those unfamiliar with these terms, potentially deterring broader stakeholder engagement.
Broader Public Impact
This document holds significance for multiple aspects of the public and can potentially impact a wide audience. By promoting biobased products, it supports environmental sustainability, potentially reducing reliance on fossil-based products. This initiative could also stimulate innovation and job creation within the biobased product sector.
Impact on Specific Stakeholders
For manufacturers and vendors of biobased products, particularly those already capable of meeting federal procurement requirements, the program could open valuable market opportunities. However, the significant reporting burden and lack of clarity regarding program engagement could deter smaller businesses.
Federal agencies tasked with procurement face a mandate to prioritize these products, which could necessitate adjustments in acquisition processes and possibly an increase in product costs in the short term. Additionally, consumers benefit from increased availability of biobased alternatives, contributing to environmentally sustainable consumer choices.
In conclusion, while the effort to extend USDA's information collection for biobased products under the BioPreferred Program could yield positive environmental impacts and market benefits, key issues regarding transparency, respondent burden, and communication need to be addressed to encourage broader participation and program success.
Issues
• The document does not specify the criteria or process for how biobased product categories are selected for preferred procurement, which could lead to concerns about transparency and fairness.
• The estimated public reporting burden of 40 hours per response may be considered excessive, especially for small manufacturers and vendors. This could potentially discourage participation in the program.
• The document provides an estimated total annual burden of 8,800 hours, but this is based on a one-time response requirement. The impact of future additions of products or product families on this burden is not clearly addressed.
• Although the document mentions that participation in the BioPreferred Program is voluntary, it does not specify any potential consequences or disadvantages of not participating, which could be helpful for prospective respondents to understand.
• The instructions for submitting comments via the Federal eRulemaking Portal are minimal and lack specific guidance or details, which could result in confusion or deter participation in the comment process.
• The language used in explaining the implementation of the USDA BioPreferred Program is somewhat technical and may not be easily comprehensible to all stakeholders, particularly those not familiar with federal procurement laws or biobased product designations.