the agency’s estimate of the burden; (iii) how to enhance the quality, utility, and clarity of the information to be collected; and (iv) minimize the burden of the collection of information on those who are to respond. Advance Notice of Proposed Rulemaking. This optional step entails publishing the agency's initial analysis of the subject matter, often asking for early public input on key issues. Any data or communications regarding the upcoming rule would be made available to the public for review. Occasionally, a board of potentially affected parties is comprised to do give-and-take bargaining over rulemaking subject-matter which would otherwise result in deadlocked opposition by an interested party. This is commonly called "negotiated rulemaking", and results in more custom-tailored proposed rule. An ANPRM can be a useful opportunity for the agency to collect some of the information and feedback it needs for later steps. If the rule is “economically significant” under Executive Order 12,866, then the agency must prepare a Regulatory Impact Analysis under OMB Circular A-4 before the agency publishes a Notice of Proposed Rulemaking. Any rule that imposes or modifies any “information collection” burden on the public must be submitted to the Director of OMB, with “objectively supported” estimates, no later than the time of a Notice of Proposed Rulemaking. As part of this submission, the agency must certify or demonstrate (depending on the setting), and provide a record in support of the certification, that: (a) the information to be collected “is necessary for the proper performance of the functions of the agency”; (b) the agency is not seeking “unnecessarily duplicative” collection of “information otherwise reasonably accessible to the agency”; (c) the agency “has taken every reasonable step to ensure that the proposed collection of information … is the least burdensome necessary”; and (d) the regulations are “written using plain, coherent, and unambiguous terminology.” Proposed Rule. In this step, the agency publishes the actual proposed regulatory language in the Federal Register; in which a discussion of the justification and analysis behind the rule is printed, as well as the agency's response to any public comment on the advance notice. Public comment. Once a proposed rule is published in the Federal Register, a public comment period begins, allowing the public to submit written comments to the agency. Most agencies are required to respond to every issue raised in the comments. Depending on the complexity of the rule, comment periods