Emergency Request

December 15, 2020
Mr. Joseph Nye
OMB Policy Analyst
Office of Information and Regulatory Affairs
New Executive Office Building
Washington, D.C. 20530
RE: Emergency Clearance for Collection of Law Enforcement Agencies Certified Due to
Executive Order 13929
Dear Mr. Nye,
The COPS Office is requesting an emergency clearance to collect lists of certified law
enforcement agencies from independent credentialing bodies. The COPS Office is only
requesting basic information on law enforcement agencies that have been certified as outlined in
Executive Order (EO) 13929 on Safe Policing for Safe Communities. Certification is required for
law enforcement agencies seeking Department of Justice discretionary funding beginning in
fiscal year 2021. This letter requests emergency approval of the data to be collected from the
independent credentialing agencies by January 15, 2021, in accordance with 44 U.S.C. § 3507
and 5 C.F.R. § 1320.13, which permits such expedited approvals when “a collection of
information is needed prior to the expiration of time periods established under this subchapter;
and is essential to the mission of the agencies” and “use of normal clearance procedures is likely
to prevent or disrupt the collection of information or is reasonably likely to cause the agency to
miss a statutory or court ordered deadline.” See 44 U.S.C. §§ 3507(j)(l) and 3507(j)(2).
This emergency processing is essential because compliance with normal clearance
procedures would cause a mandated deadline to be missed. Per guidance from the Attorney
General in response to Section 2 of the EO, titled Standards of Certification on Safe Policing for
Safe Communities, the independent credentialing bodies are required to track in a database the
agencies they have certified and provide this list to the COPS Office on or before January 31,
2021. Law enforcement agencies are required to be certified in order to receive fiscal year 2021
DOJ discretionary funds. These lists will be used to verify funding eligibility.
List Collection is Essential to the Mission of the COPS Office
On June 16, 2020, President Donald J. Trump issued EO 13929 on Safe Policing for Safe
Communities. The EO’s goal is to ensure that law enforcement agencies continue striving to
provide transparent, safe, and accountable delivery of services to communities. This delivery will
enhance community confidence in law enforcement and facilitate the identification and
correction of internal issues before they result in injury to the public or to law enforcement
officers. The COPS Office is the component within DOJ that is responsible for advancing the
practice of community policing, which begins with a commitment to building trust and mutual
respect between police and communities.

The expedited approval of the list collection is essential to the mission of the COPS
Office because the collection of these data from independent credentialing bodies is necessary to
determine whether law enforcement agencies are eligible for DOJ discretionary funding. The
COPS Office was established under the authority of the Attorney General to implement Title I of
the “crime bill,” the Public Safety Partnership and Community Policing Act of 1994 (the Act).
The Act authorizes the Attorney General to make grants to States, units of local government,
Indian tribal governments, other public and private entities, and multi-jurisdictional or regional
consortia thereof to increase police presence, to expand and improve cooperative efforts between
law enforcement agencies and members of the community, to address crime and disorder
problems, and otherwise to enhance public safety. All COPS Office funding is discretionary and
the majority of applicants are law enforcement agencies. Since 1994, the COPS Office has
invested more than $14 billion to help advance community policing.
Approval is Necessary to Collect the Information and Achieve Compliance with
Established Deadlines
Approval of the data collection is necessary before the expiration of the 60-day and 30day notice periods, because it is the only way to achieve compliance with the mandatory
deadline. The Standards of Certification on Safe Policing for Safe Communities state “beginning
in 2021, on or before January 31 of each year, independent credentialing bodies must provide the
names of each certified law enforcement agency to the Director of the COPS Office or his
delegate.” The independent credentialing bodies have already begun outreach to the COPS
Office on how to fulfill this requirement.
In order to reduce burden on the independent credentialing bodies, the COPS Office has
provided a list of ten data elements that would be requested in order to assist credentialing bodies
in building their agency database (see attached). All requested data are non-PII. The independent
credentialing bodies are collecting this information as part of the certification process.
Emergency Clearance Provides a Temporary Measure to Allow Lists to be Collected within
the Time Limits While the Data Collection Undergoes the Normal Clearance Procedures
Finally, the COPS Office request for emergency clearance should be granted because it is
a temporary measure to allow independent credentialing bodies submit their lists within the
required time limit, while the data collection undergoes the normal clearance procedures. If
additional comments are received during the PRA clearance process, the data collection form can
be amended.
Thank you for your prompt consideration of this request. Please contact Shelley Hyland,
Supervisory Program Specialist, Research and Technical Assistance Division, Community
Policing Advancement Directorate, by email [email protected] or by phone at (202)
598-1826 if you have any questions or need additional information.
Sincerely,
Phil Keith
Director
Office of Community Oriented Policing Services

List of Data Elements to be Collected
The information being requested includes the following on each law enforcement agency
certified:
1. Originating Record Identifier (ORI): This number is assigned by the FBI for crime
reporting purposes. The COPS Office uses ORI as one of the primary linking methods to
application and reporting documents.
2. Employer Identification Number (EIN): A number assigned by the IRS for tax
reporting purposes. This number is one of two primary linking identifiers within
JustGrants, the DOJ system for applying for award funding.
3. Data Universal Number System (DUNS): A unique nine or thirteen digit sequence
recognized as the universal standard for identifying and keeping track of entities
receiving federal funds. Only agencies that have applied for federal funding will have a
DUNS number. This is the other linking identifier within JustGrants.
4. Agency name: Name of law enforcement agency.
5. City: City where law enforcement agency is located.
6. State: State where law enforcement agency is located.
7. Zip: Zip code where law enforcement agency is located.
8. Title of Chief Executive: Title of the law enforcement agency’s chief executive (e.g.,
sheriff, chief of police, commissioner).
9. Chief Executive Name: Full name of the law enforcement agency’s chief executive
10. Date Certification Issued: Date law enforcement agency received certification for EO
13929