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  • NOAA Submits Revised Space-Based Data Collection System Agreement for OMB Review and Public Comment

NOAA Submits Revised Space-Based Data Collection System Agreement for OMB Review and Public Comment

  • By: Learn Laws®
  • Published: 03/26/2026
  • Updated: 03/26/2026

The Department of Commerce announced in the Federal Register on March 26, 2026, that it will submit an information collection request to the Office of Management and Budget for review and clearance under the Paperwork Reduction Act of 1995. This request pertains to the National Oceanic and Atmospheric Administration's Space-Based Data Collection System agreements, specifically for the Geostationary Operational Environmental Satellite system. The move follows a prior 60-day public comment period that began on December 22, 2025, and now opens an additional 30-day window for feedback. This development highlights ongoing efforts to streamline federal data collection processes while supporting environmental monitoring, with implications for government agencies, researchers, and other users who rely on satellite-based systems for gathering critical data on weather, oceans, and ecosystems.

Background on NOAA's Data Collection System

NOAA operates the Geostationary Operational Environmental Satellite (GOES) Data Collection System (DCS) to facilitate the gathering of environmental data. As outlined in the Federal Register notice, this system supports applications in meteorology, oceanography, hydrology, ecology, and remote sensing of Earth resources. The majority of users are government agencies and researchers, with much of the collected data shared with the World Meteorological Organization through the Global Telecommunication System for use in the World Weather Watch Program.

The system's excess capacity allows NOAA to extend access to other qualified users, provided they meet specific criteria established under 15 CFR part 911. This regulation, authorized by 15 U.S.C. 313, which details the duties of the Secretary of Commerce, ensures that the DCS is not used when commercial alternatives are available. The information collection in question involves the System Use Agreement (SUA) form, which applicants must complete to gain approval. This form captures details such as the agreement's duration, authorized uses, equipment standards, operational protocols, and compliance with international and federal regulations, including those from the International Telecommunication Union and the Federal Communications Commission.

Historically, NOAA's DCS included both the GOES system and the Polar-Orbiting Operational Environmental Satellite (POES) system, known as Argos. However, the notice specifies that the Argos system is being removed from this collection because it is no longer administered by NOAA. This revision narrows the focus to the GOES DCS, reflecting changes in administrative responsibilities and potentially reducing the overall scope of the information collection.

Key Details of the Information Collection Request

The submission to OMB, identified by Control Number 0648-0157, is described as a regular submission for revision and extension of an existing collection. It estimates 225 respondents annually, with an average response time of 0.5 hours, resulting in a total annual burden of 113 hours. The affected public includes not-for-profit institutions, federal, state, local, or tribal governments, and for-profit organizations. Responses are required annually, every three years, or every five years, depending on regulatory needs, and are obligatory for obtaining or retaining benefits.

The SUA form itself does not have a specific number but serves as the primary tool for applications. It ensures that users demonstrate a lack of commercial alternatives, outline government interests in the data, and commit to standards for data formats, reporting frequencies, and delivery schedules. NOAA emphasizes that it does not approve agreements if commercial services can meet user needs, as per 15 CFR part 911. This criterion aims to prevent unnecessary reliance on government resources.

Public comments are invited to help assess the impact of these requirements and minimize reporting burdens. The notice directs commenters to submit feedback via www.reginfo.gov within 30 days of publication, focusing on the collection's necessity, accuracy of burden estimates, and ways to enhance data quality and clarity.

Legal and Policy Context

The Paperwork Reduction Act of 1995 requires federal agencies to obtain OMB approval for information collections to reduce unnecessary paperwork on the public. This process includes public comment periods to ensure transparency and efficiency. In this case, the 60-day comment period in December 2025 allowed initial input, and the current 30-day period builds on that foundation.

Relevant legal precedents underscore the importance of such reviews. For instance, cases like the 1980 Supreme Court decision in Industrial Union Department v. American Petroleum Institute emphasized the need for agencies to justify regulatory burdens based on substantial evidence. While not directly related, this principle influences how agencies like NOAA approach information collections, ensuring they are tailored to essential needs without overreach.

Politically, this notice aligns with broader federal efforts to modernize data systems amid advancing satellite technology. The involvement of the Department of Commerce, under which NOAA operates, reflects ongoing priorities in environmental policy and international data sharing. Different perspectives emerge here: proponents, including environmental researchers, view the DCS as vital for global monitoring efforts, while critics might argue that reliance on government systems could stifle commercial innovation in satellite data services. Government officials, as represented in the notice, prioritize efficient use of excess capacity for public benefit.

Implications and Perspectives

In the short term, approval of this revised collection could facilitate smoother access to the GOES DCS for eligible users, supporting real-time environmental data collection that informs weather forecasting and disaster response. Long-term, it may influence how NOAA allocates satellite resources, especially as climate change intensifies the need for robust data networks.

From a user perspective, the requirement to justify non-commercial needs ensures equitable access but could pose barriers for smaller organizations. Federal agencies benefit from standardized agreements that comply with ITU and FCC rules, reducing risks of international disputes over spectrum use. Researchers highlight the system's role in programs like the World Weather Watch, where data integration enhances global models.

Potential challenges include evolving technology that might render parts of the SUA outdated, or shifts in commercial satellite capabilities that could further limit approvals. Debates may center on balancing government oversight with innovation, without endorsing privatization over public systems.

Forward-Looking Conclusion

This OMB review process underscores NOAA's commitment to maintaining an effective DCS while adhering to paperwork reduction mandates. Key takeaways include the focused revision to the GOES system and the invitation for public input to refine the process. Moving forward, possible trajectories involve OMB approval leading to extended agreements, potential regulatory updates to 15 CFR part 911, or further integrations with international data standards. Ongoing debates may explore expanding access amid technological advances, addressing burdens on respondents, and ensuring the system's role in environmental stewardship without overextending federal resources.

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