FR 2025-00288

The document titled "Submission for OMB Review; Comment Request" is a formal notice from the Department of Defense (DoD) seeking approval from the Office of Management and Budget (OMB) to collect information. This data collection falls under the guidelines provided by the Paperwork Reduction Act. Essentially, the DoD wishes to use Defense Logistics Agency (DLA) Form 2536 to evaluate the compliance capabilities of businesses intending to purchase defense materials. These potential buyers must demonstrate that they can adhere to relevant laws and regulations before any sale is finalized.

Significant Issues and Concerns

While the intent of collecting this information is straightforward, there are a few points of concern that merit discussion:

• Vagueness in Evaluation Criteria: The document does not clearly spell out the specific criteria or standards used to assess the buyers' compliance capabilities. This lack of detail could lead to uncertainty and inconsistency in the evaluation process.

• Average Burden Per Response: The document specifies a 90-minute burden for respondents, which could be considered lengthy. Such a substantial time commitment might discourage participation or lead to incomplete compliance.

• Lack of Justification for Revision: The proposal is labeled as a revision, yet it does not provide a detailed rationale for the changes. Understanding the motivation behind the revision could benefit stakeholders in evaluating the necessity and impact of these updates.

• Non-Specific Target Audience: Although the document mentions "business or other for-profit" entities as the affected public, this broad classification lacks precision. More detailed segmentation could help potential respondents identify whether the notice applies to them.

• Consequences of Non-Compliance: There is no mention of potential repercussions should the information not be collected or should respondents fail to comply. Clarifying these consequences could ensure higher compliance rates and adherence to the regulations.

Impact on the Public

For the general public, this notice might seem like an internal administrative procedure; however, its broader implications could impact various stakeholders:

• Business Impact: For businesses, particularly those involved in the resale or processing of defense materials, complying with this information request is essential. It may impose an additional administrative burden, potentially requiring resources for successful compliance.

• Regulatory Assurance: On a positive note, these measures help maintain a regulatory framework that ensures defense materials are handled by compliant entities, thus safeguarding national security interests.

• Potential Barriers: The perceived complexity and time required to complete the DLA Form 2536 might act as a barrier, particularly impacting smaller businesses that may lack the resources to engage in such formalities.

Impact on Specific Stakeholders

Specific stakeholders, such as potential buyers of defense materials, could see both positive and negative impacts from this notice:

• Positive Impacts: By weeding out entities that are not fully compliant or ill-equipped to handle defense materials responsibly, the policy ensures that only credible parties engage in such transactions. This safeguards the integrity and safety of defense material transactions.

• Negative Impacts: The comprehensive nature of the information request could deter businesses, especially those smaller in scale, due to the perceived administrative and time burdens. These entities might feel marginalized or overburdened by the requirements, possibly discouraging participation altogether.

In summary, while the notice serves a critical purpose in upholding legal and safety standards within defense material transactions, there are notable concerns and potential areas for improvement in clarity, justification, and audience specification that could enhance its effectiveness and reception among stakeholders.