According to official estimates, the newly proposed federal Benchmark Survey of Foreign Direct Investment in the United States should take only 24 hours to complete -- a mere 1.2 hours per page.
But Mark E. Richardson, executive director of the Business Council on the Reduction of Paperwork, says the survey will take "something more than 100 hours" on average to fill out, ranging from a few hours for a small company to 700 hours for the Fortune 500 corporations that are part of his council.
The survey is, in Richardson's view, a classic example of the need for a new requirement that the Office of Management and Budget is publishing today. OMB wants to require that all federal forms carry an estimate of the amount of time needed to complete them and also tell where to complain if that "burden estimate," as the government calls it, is wrong.
"Of the 120 questions" in the investments survey, Richardson said, "only three call for data the companies normally keep. It refers to SICs, standard industrial classifications, IDs, industrial directives -- they have a whole booklet they'll send you on those -- but the SITCs, standard international trade classifications, nobody in American commerce ever uses them!"
The paper work burden box, which will augment the already required privacy and paper work reduction act notices on federal forms, is the brainchild of Leon W. Transeau, chief of the division of directives and regulatory management of the Interior Department.
"I used to fill out these damn forms in the private sector and I thought they were absurd," he said. "I've been working with OMB for over a year on this and giving speeches on this and I haven't found anyone who isn't ecstatic."
Under the Paperwork Reduction Act, OMB must approve most federal forms that collect information from the public. Agencies already make estimates of the amount of time required to gather and fill in the data. But they have every incentive to make the estimate as low as possible to get the form approved, according to Transeau.
How this may work is illustrated by an example from OMB's own publication, the "Information Collection Budget."
The budget recounts how the Department of Defense almost became the No. 1 paper-work-producing agency because OMB began to count its procurement paper work in 1984. But, according to the budget, "DOD then reviewed thoroughly its initial estimate of the burden imposed by procurement-related recordkeeping and reporting requirements; based on the results of this review, DOD reduced the burden estimate by 163.5 million hours."
Transeau said that "by explicitly placing the burden estimate on the form, bureaucrats will be confronted by the public if the estimate is grossly understated."
"That's one reason for a comment period," OMB spokesman Edwin L. Dale Jr. said. "We have 60 days to hear from the agencies about any estimates of cost." No forms will be recalled for redesign. And as for hiring additional clerks to handle complaint mail, Dale said, "We are prepared to handle it with no new people -- we welcome it."
Dale said that, in addition to proposing the new paper work burden box, proposed rules published today in the Federal Register will call for a 20 percent cut in the amount of time necessary to handle federal paper work, in addition to reductions already made.
Meanwhile, people like Richardson and his clients are talking to the Bureau of Economic Analysis about the new survey on foreign direct investment in the United States. This census, required by law, has not yet been cleared by the department or sent to OMB for review but has been circulated to industry for comment to head off any potential problem.
Richardson said the Commerce Department's Bureau of Economic Analysis is actually one of the government's "best agencies" about listening to the concerns of the businesses who have to complete the forms. But the bureau is caught between congressional pressure to gather information and business pressure to limit collection.