[House Hearing, 109 Congress]
[From the U.S. Government Publishing Office]
REDUCING THE PAPERWORK BURDEN ON THE PUBLIC: ARE AGENCIES DOING ALL
THEY CAN?
=======================================================================
HEARING
before the
SUBCOMMITTEE ON REGULATORY AFFAIRS
of the
COMMITTEE ON
GOVERNMENT REFORM
HOUSE OF REPRESENTATIVES
ONE HUNDRED NINTH CONGRESS
FIRST SESSION
__________
JUNE 14, 2005
__________
Serial No. 109-42
__________
Printed for the use of the Committee on Government Reform
Available via the World Wide Web: http://www.gpoaccess.gov/congress/
index.html
http://www.house.gov/reform
______
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22-572 WASHINGTON : 2005
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COMMITTEE ON GOVERNMENT REFORM
TOM DAVIS, Virginia, Chairman
CHRISTOPHER SHAYS, Connecticut HENRY A. WAXMAN, California
DAN BURTON, Indiana TOM LANTOS, California
ILEANA ROS-LEHTINEN, Florida MAJOR R. OWENS, New York
JOHN M. McHUGH, New York EDOLPHUS TOWNS, New York
JOHN L. MICA, Florida PAUL E. KANJORSKI, Pennsylvania
GIL GUTKNECHT, Minnesota CAROLYN B. MALONEY, New York
MARK E. SOUDER, Indiana ELIJAH E. CUMMINGS, Maryland
STEVEN C. LaTOURETTE, Ohio DENNIS J. KUCINICH, Ohio
TODD RUSSELL PLATTS, Pennsylvania DANNY K. DAVIS, Illinois
CHRIS CANNON, Utah WM. LACY CLAY, Missouri
JOHN J. DUNCAN, Jr., Tennessee DIANE E. WATSON, California
CANDICE S. MILLER, Michigan STEPHEN F. LYNCH, Massachusetts
MICHAEL R. TURNER, Ohio CHRIS VAN HOLLEN, Maryland
DARRELL E. ISSA, California LINDA T. SANCHEZ, California
GINNY BROWN-WAITE, Florida C.A. DUTCH RUPPERSBERGER, Maryland
JON C. PORTER, Nevada BRIAN HIGGINS, New York
KENNY MARCHANT, Texas ELEANOR HOLMES NORTON, District of
LYNN A. WESTMORELAND, Georgia Columbia
PATRICK T. McHENRY, North Carolina ------
CHARLES W. DENT, Pennsylvania BERNARD SANDERS, Vermont
VIRGINIA FOXX, North Carolina (Independent)
------ ------
Melissa Wojciak, Staff Director
David Marin, Deputy Staff Director/Communications Director
Rob Borden, Parliamentarian
Teresa Austin, Chief Clerk
Phil Barnett, Minority Chief of Staff/Chief Counsel
Subcommittee on Regulatory Affairs
CANDICE S. MILLER, Michigan, Chairman
GINNY BROWN-WAITE, Florida STEPHEN F. LYNCH, Massachusetts
CHRIS CANNON, Utah WM. LACY CLAY, Missouri
MICHAEL R. TURNER, Ohio CHRIS VAN HOLLEN, Maryland
LYNN A. WESTMORELAND, Georgia
Ex Officio
TOM DAVIS, Virginia HENRY A. WAXMAN, California
Ed Schrock, Staff Director
Erik Glavich, Professional Staff Member
Alex Cooper, Clerk
Krista Boyd, Minority Counsel
C O N T E N T S
----------
Page
Hearing held on June 14, 2005.................................... 1
Statement of:
Koontz, Linda D., Director, Information Management Issues,
U.S. Government Accountability Office; Kimberly T. Nelson,
Assistant Administrator and Chief Information Officer, U.S.
Environmental Protection Agency; Patrick Pizzella,
Assistant Secretary for Administration and Management, U.S.
Department of Labor; Daniel P. Matthews, Chief Information
Officer, U.S. Department of Transportation; Kevin Barrett,
certified industrial hygienist [CIH] and certified safety
professional [CSP], Barrett Operational Safety and Health
Management Services; and Sean Moulton, senior information
policy analyst, OMB Watch.................................. 8
Barrett, Kevin........................................... 87
Koontz, Linda D.......................................... 8
Matthews, Daniel P....................................... 49
Moulton, Sean............................................ 102
Nelson, Kimberly T....................................... 34
Pizzella, Patrick........................................ 70
Letters, statements, etc., submitted for the record by:
Barrett, Kevin, certified industrial hygienist [CIH] and
certified safety professional [CSP], Barrett Operational
Safety and Health Management Services, prepared statement
of......................................................... 89
Koontz, Linda D., Director, Information Management Issues,
U.S. Government Accountability Office, prepared statement
of......................................................... 10
Matthews, Daniel P., Chief Information Officer, U.S.
Department of Transportation, prepared statement of........ 51
Miller, Hon. Candice S., a Representative in Congress from
the State of Michigan, prepared statement of............... 4
Moulton, Sean, senior information policy analyst, OMB Watch,
prepared statement of...................................... 105
Nelson, Kimberly T., Assistant Administrator and Chief
Information Officer, U.S. Environmental Protection Agency,
prepared statement of...................................... 37
Pizzella, Patrick, Assistant Secretary for Administration and
Management, U.S. Department of Labor, prepared statement of 72
REDUCING THE PAPERWORK BURDEN ON THE PUBLIC: ARE AGENCIES DOING ALL
THEY CAN?
----------
TUESDAY, JUNE 14, 2005
House of Representatives,
Subcommittee on Regulatory Affairs,
Committee on Government Reform
Washington, DC.
The subcommittee met, pursuant to notice, at 2:06 p.m., in
room 2247, Rayburn House Office Building, Hon. Candice S.
Miller (chairwoman of the subcommittee) presiding.
Present: Representatives Miller, Brown-Waite, and Lynch.
Staff present: Rosario Palmieri, deputy staff director;
Erik Glavich, professional staff member; Joe Santiago, GAO
detailee; Alex Cooper, clerk; Krista Boyd, minority counsel;
and Cecelia Morton, minority office manager.
Mrs. Miller. Good afternoon, I am going to start the
hearing. I think our ranking member Mr. Lynch will be here in
any moment.
So we will call the Subcommittee of Regulatory Affairs to
order. I would certainly like to welcome you all to today's
hearing. Of course we are going to be talking about the efforts
of Federal agencies to reduce the paperwork burden imposed on
the public.
Today's hearing is the second, actually, by this
subcommittee regarding this subject. On May 25th we examined
efforts with the Internal Revenue Service to reduce the burden
on taxpayers, which was a very interesting hearing, I think.
The IRS actually accounts, they say, for roughly 80 percent of
the paperwork burden, but there are certainly many more
agencies that have to force individuals and businesses to take
considerable amounts of time filling out forms and complying
with governmental regulations.
Excluding the Department of Treasury, the Federal
Government imposes nearly 1.6 billion hours of burden on the
public, with five agencies imposing more than 100 million hours
of burden.
Much of the information collected by Federal agencies is
unnecessary, some might say extremely burdensome. And agencies
and the Federal Government--we all need to work together to do
a better job to ensure that unnecessary functions are not
unnecessarily burdensome. In response to increases in
government-imposed burden, Congress passed the Paperwork
Reduction Act [PRA] in 1980. However, the burden imposed on the
public has continued to increase throughout the years.
Congress amended the PRA in 1995, and they established
burden reduction goals of 5 to 10 percent for the first 5 years
of its enactment. Furthermore, the 1995 PRA set annual
paperwork reduction goals that reduced burden thereafter to
the, ``maximum practicable opportunity.''
Despite the intent of Congress, the burden has not
decreased, unfortunately. The non-Treasury paperwork burden now
exceeds 1996 levels. It is projected to increase even further.
Of course, Congress has not been without blame. We all have to
take a good look in the mirror sometimes, obviously, because
according to the OMB the non-Treasury burden has increased by
nearly 85 million hours over just the past 3 years because of
required program changes.
In a post-September 11th world, many new regulations of
course are necessary to ensure the safety of the Nation.
Congress has passed several laws that have obviously increased
the burden. However, Federal agencies as a whole have not done,
I think, as good a job as they possibly could in reducing
burden in areas that are under their discretion. In fact, there
are a lot of discretionary agency actions and not statutes
passed by Congress that have increased the non-Treasury
paperwork burden imposed by the public, some estimate by as
much as 51 million hours, as well over the past 3 years.
So we are very pleased today to have the Chief Information
Officers of the EPA, of Department of Labor, of the Department
of Transportation here with us here.
Together these three agencies alone account for over 557
million hours of burden. We tried to put that into terms of
what does it even mean. Difficult to get your mind around those
numbers. To put it into perspective, that would mean 279,000
employees would have to spend 40 hours per week for 50 weeks
per year just filling out paperwork for these three agencies
alone. Obviously this is a task of reducing the burden, a very
difficult task. And our witnesses, I am sure, will attest to
that.
But we also need to always think of the term ``customer
service.'' Customer service cannot be a novel concept for any
level of government, Federal, State, local, what have you. We
need to think in terms of our customer and who we are servicing
and do the very best that we can for them.
The intent of Congress was very clear when it passed in
1995 the PRA. And since burden is imposed by an agency, it is
also the agency's responsibilities to work with us to minimize
that burden. We will be looking at that today.
We are also pleased to have with us today Linda Koontz of
the GAO. Her testimony will provide the subcommittee with
insights, very vital insights, I am sure, into efforts by
Federal agencies to reduce burden through compliance with the
PRA and beyond, in fact, what is actually required by law.
In preparation for this hearing, both Chairman Tom Davis of
the Government Reform Committee and I requested the GAO to
assess agency compliance with the PRA.
[Note.--The GAO report entitled, ``Paperwork Reduction Act,
New Approach May Be Needed to Reduce Government Burder on
Public,'' may be found in subcommittee files.]
Mrs. Miller. The GAO has concluded that the governmentwide
industry CIOs generally have reviewed information collections
and certified that they have met the standards outlined in the
PRA.
However, its analysis also showed that CIOs certified
collections even though support for those standards was often
missing or partial. This is somewhat troubling, because without
support from agencies showing the standards are met, or the
attempts are being made to meet them, Congress and the public
has a hard time being completely confident that the highest
degree of attention was focused on minimizing the burden.
So I certainly want to thank each of our witnesses today.
We are looking forward to your input.
Obviously, every hour spent by an individual or a business
completing paperwork for the Federal Government is an hour that
could be spent doing something else, perhaps more productive,
and excessive and unnecessary burden imposed on individuals and
businesses hurts job creation. It certainly hinders our ability
to be competitive in a global marketplace as well.
I think America's businesses should have the absolute
confidence that their government is doing all it can to provide
economic expansion. And oftentimes, unfortunately, that old
saying I am from the government, I am here to help you is a
choking grain of truth, I think.
So at this time I would like to recognize the distinguished
ranking member of the subcommittee, Congressman Stephen Lynch,
for his opening remarks.
[The prepared statement of Hon. Candice S. Miller follows:]
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Mr. Lynch. Well, thank you, Madam Chairwoman.
First of all, I would like to thank you, Madam Chairwoman,
for convening this hearing to examine what agencies are doing
to decrease the amount of paperwork that Americans are forced
to do in compliance with various laws administered by these
agencies.
Information collection, I think, if done efficiently, can
be one of the most important and most powerful and necessary
tools of the Federal Government. Information gathering enables
our government to collect taxes, administer programs and
enforce the law. Some collections are also used to provide
important information to the public.
For example, under the EPA's Toxic Release Inventory
businesses are required to report information about the toxic
chemicals they release into our air and water. EPA then makes
that information publicly available, and this holds polluters
accountable and it enables members of the public to find out
about the toxic chemicals being released into their
neighborhoods and their towns.
It also has been an effective tool to discourage companies
from polluting and to tighten their operating procedures. They
do that voluntarily under the threat of disclosure. Without the
government mandate to publish that information, and without
accurate information, there would be a built-in inefficiency
that future companies and successor companies are forced to pay
the cost of the damage done by their predecessors.
While it is critical for agencies to collect certain
information in order to do their jobs, it is also very, very
important that the process be as easy as possible without
losing necessary information.
When an agency requests information from the public,
individuals and businesses have to spend time and effort
gathering that requested information and then filling out the
required forms. Everyone can agree that information requests
should be clear and simple and should be available
electronically.
Today we will have the benefit of hearing from the Chief
Information Officers from EPA, the Department of Labor and the
Department of Transportation. I am looking forward to hearing
from each of you what your agencies are doing to improve how
information is collected.
I have also had a chance to look at the GAO report that
Madam Chairwoman referred to earlier, and I am concerned as
well about the compliance factor in terms of meeting the 10
standards, which are, I believe, fair and reasonable in
reducing paperwork to all respondents, both businesses and
individuals.
In the report being released today on agency compliance
with Paperwork Reduction Act, GAO highlighted the efforts that
have been made by the IRS and EPA. According to GAO, these
agencies have devoted significant resources to reducing the
burden on individuals in businesses and have proactively
involved stakeholders in the review of certain information
collections.
GAO also reports that the EPA has made burden reduction a
priority because of the high visibility of the agency's
information collection and because, among other reasons, the
success of the EPA's enforcement mission depends on information
collections being properly justified and approved. GAO quotes
an EPA official saying that information collections are the
lifeblood of the agency and its work.
Because regulatory agencies such as the EPA and the DOL and
the Department of Transportation cannot function without
information, it's important to reduce that paperwork, not cut
to the bone, and focus instead on making information
collections more efficient while maintaining the agency's
ability to collect the information they need to do their job
and that allow the agencies the freedom to do just that.
I want to thank Madam Chairwoman again for her help and her
leadership on this issue and convening this hearing. I also
want to thank the witnesses for being here today, and I look
forward to your testimony.
Thank you, Madam Chairwoman.
Mrs. Miller. Thank you.
It's the practice of the Government Reform Committee to
swear in all of our witnesses, so if you could all stand please
and raise your right hands.
[Witnesses sworn].
Mrs. Miller. As we begin with the witnesses today, we ask
you to try to keep your oral testimony to 5 minutes. I won't be
right on the money with that. But in the interest of time, if
you could watch the little boxes in front of you. When the
yellow light comes on that means you have 1 minute remaining,
and of course the red light means 5 minutes are up. If you have
not concluded by then I would ask you to try to sort of wrap it
up by that time.
Our first witness, Linda Koontz, is the Director of
Information Management Issues at the U.S. Government
Accountability Office. Mrs. Koontz is responsible for issues
concerning the collection user and dissemination of government
information in an era of rapidly changing technology. Among
many of her official duties Mrs. Koontz has lead responsibility
for information technology management issues at various
agencies, including the Department of Veterans Affairs and
Housing and Urban Development and the Social Security
Administration. Ms. Koontz has a BA Degree, Bachelor's from
Michigan University, ``Go Green,'' and is a Certified
Government Financial Manager and a member of the Association
for Information and Image Management Standards Board.
We certainly look forward to your testimony, Ms. Koontz.
STATEMENTS OF LINDA D. KOONTZ, DIRECTOR, INFORMATION MANAGEMENT
ISSUES, U.S. GOVERNMENT ACCOUNTABILITY OFFICE; KIMBERLY T.
NELSON, ASSISTANT ADMINISTRATOR AND CHIEF INFORMATION OFFICER,
U.S. ENVIRONMENTAL PROTECTION AGENCY; PATRICK PIZZELLA,
ASSISTANT SECRETARY FOR ADMINISTRATION AND MANAGEMENT, U.S.
DEPARTMENT OF LABOR; DANIEL P. MATTHEWS, CHIEF INFORMATION
OFFICER, U.S. DEPARTMENT OF TRANSPORTATION; KEVIN BARRETT,
CERTIFIED INDUSTRIAL HYGIENIST [CIH] AND CERTIFIED SAFETY
PROFESSIONAL [CSP], BARRETT OPERATIONAL SAFETY AND HEALTH
MANAGEMENT SERVICES; AND SEAN MOULTON, SENIOR INFORMATION
POLICY ANALYST, OMB WATCH
STATEMENT OF LINDA D. KOONTZ
Ms. Koontz. I thank you, Chairwoman Miller and members of
the subcommittee. I am pleased to be here today to discuss the
implementation of the Paperwork Reduction Act. As you know, the
primary goals of the act are to minimize the government
paperwork burden on the public while maximizing the public
benefit and utility of the information collections that the
government undertakes.
In May 2005, OMB provided its annual PRA report to the
Congress. According to this report, the paperwork burden
imposed by all Federal information collections shrank slightly
in fiscal year 2004. The total burden was estimated at 7.971
billion hours, which is a decrease of about 1.6 percent from
the previous year's estimate of about 8.099 billion hours.
Different types of changes contributed to the overall
change in the total burden estimates, according to OMB. For
example, some of the decrease, about 156 million hours, arose
from adjustments to the estimates, including changes in
estimation methods and in the population of respondents. In
addition, agency burden reduction efforts led to a decrease of
about 97 million hours. These decreases were partially offset
by increases in other categories, primarily an increase of 199
million hours arising from new statutes.
However, there are limitations in the government's ability
to develop accurate burden estimates, which means that the
degree to which agency burden hour estimates reflect real
burden is unclear, and so the significance of small changes in
these estimates is also uncertain. Nonetheless, these estimates
are the best indicators of Federal paperwork burden that we
have, and they can be useful as long as we keep the limitations
in mind.
To help achieve the goals of minimizing burden while
maximizing utility, the PRA includes a range of provisions,
including a requirement for Chief Information Officers to
review and certify that information collections meet certain
standards. Government-wide, we found that agency CIOs generally
reviewed information collections before they were submitted to
OMB and certified that the required standards in the act were
met.
However, in reviewing 12 case studies we found that CIOs
provided these certifications despite often missing or
inadequate support from the program offices supporting the
collections. Further, although the law requires CIOs to provide
support for certifications, agency files contained little
evidence that CIO reviewers had made efforts to improve the
support by program offices. Numerous factors have contributed
to these problems, including a lack of management support and
weaknesses in OMB guidance.
As a result the CIO reviews appear to be lacking in the
rigor that Congress envisioned and have not been shown to
reduce burden. On the other hand, alternative approaches to
burden reduction suggest promising alternatives to the current
review process outlined in the PRA.
Specifically, IRS and EPA have used additional evaluative
processes that focused specifically on reducing burden. These
processes are targeted resource intensive efforts that outreach
to stakeholders. According to these agencies, their procedures
led to significant reduction in burden to the public while
maximizing the utility of the information collections.
In summary, government agencies often need to collect
information to perform their missions. The PRA puts in place
mechanisms to focus agency attention on the need to minimize
the burdens that these collections impose while maximizing the
public benefit and utility of government information
collections. But these mechanisms have not succeeded in
achieving the ambitious reduction of goals set forth in the
1995 amendments. Achieving real reductions in the paperwork
burden is an elusive goal, as years of PRA reports attest.
Although the CIO reviews required by the act as currently
implemented seems to have little effect, targeted approaches to
burden reduction such as those used by the IRS and EPA could be
effective. These agencies' experience also suggest that to make
such approaches successful requires top level executive
commitment, extensive involvement of program office staff with
appropriate expertise and aggressive outreach to stakeholders.
Indications are that this would be more resource intensive
than the current process and in fact such an approach may not
be warranted at agencies that do not have the level of
paperwork issues that face IRS and similar agencies.
Consequently, it is critical that any efforts to expand the
use of the IRS and EPA models consider these factors. In a
report that is being released today we recommend that the OMB
and agencies take steps to improve reviewing processes in
compliance with the act. We also suggested that the Congress
may wish to consider mandating pilot projects to target some
collections for rigorous analysis along the lines of the IRS
and EPA approaches. By taking these steps, we believe that
government can make further progress in realizing the vision
reflected in the PRA.
Chairwoman Miller, this completes my statement. I would be
pleased to answer questions at the appropriate time.
[The prepared statement of Ms. Koontz follows:]
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Mrs. Miller. Thank you.
At this time I would like to recognize another member of
our committee, Ginny Brown-Waite from Florida, for an opening
statement.
Ms. Brown-Waite. Thank you very much, Madam Chairwoman. I
appreciate your holding this hearing today to assess the
paperwork burden imposed on the American public by regulatory
agencies. I just came from lunch with a road builder who does a
lot of Federal work and with somebody involved in the
construction industry, you know, they certainly bent my ear
about the paperwork both at the State and at the Federal level,
which often seems to be duplicative.
The Paperwork Reduction Act was an important piece of
legislation that stated Congress', unfortunately, unambiguous
objective to reduce the paperwork burden on the public.
However, since passage of this legislation the paperwork burden
imposed by agencies has increased rather than decreased.
The three agencies represented at today's hearing single-
handedly account for 557.4 million hours of the total burden
imposed on the public by the Federal Government in 2004. To put
this figure into perspective, 279,000 employees would have to
spend 40 hours a week, 50 weeks a year filling out paperwork
just for these three agencies. Many believe that this time
could be better spent.
The reason for the steady rise in the paperwork are
manifold, and part of the blame can be placed squarely on
Congress for passing legislation that causes agencies to
administer more paperwork.
I am here today to learn more about how agencies determine
what paperwork is essential to the performance of their duties
and how Congress can help agencies to reduce their paperwork
burden. I look forward to hearing the remainder of the speakers
and appreciate you all being here and certainly appreciate you,
Madam Chairwoman, for holding this hearing.
Mrs. Miller. All right. Our next witness is Kimberly T.
Nelson. November 30, 2001, Ms. Nelson was sworn in as Assistant
Administrator for Environmental Information and Chief
Information Officer at the EPA.
Since assuming her current role at the EPA Ms. Nelson has
been instrumental in expanding the CIO's role with the agency
and has overseen the creation and implementation of several
major initiatives, including the Central Data Exchange, the
release in 2003 of the first ever draft report on the
environment, and has been leading the implementation of the
agency's enterprise architecture.
She also serves on the Executive Council of the Federal CIO
Board and acts as both the co-chair of both the CIOs Council
Architecture and Infrastructure Committee and the Federal
Government-wide e-Rulemaking Committee as well.
Thank you for your attendance today, and we look forward to
your testimony, ma'am.
STATEMENT OF KIMBERLY T. NELSON
Ms. Nelson. Thank you, Madam Chairwoman, and to your
colleagues for the opportunity to be here today. As you are
probably aware, EPA is responsible for implementing and
enforcing eight major environmental statutes that protect our
land, air and water as well as the Superfund law, which
includes the Emergency Planning and Community Right-to-Know
Act.
Over the last three decades our laws have dramatically
improved human health and the environment. Citizens are better
able to boat, swim and fish in thousands of miles of formerly
contaminated rivers and streams. Industrial waste areas have
been cleaned up and returned to productive use, and our air is
the cleanest it has been since the establishment of EPA. Total
emissions of six principal air pollutants have been reduced by
54 percent from 1970 to last year. Enforcement of the
environmental laws by both the Federal Government and our
States has been critical to these achievements.
Assuring compliance with these statutes requires EPA to
collect information from the public. As new regulations
develop, so does the need for collecting information associated
with implementing the regulations, which usually translates
into an increase in burden.
Over the past 4 years, though, EPA's burden on the public
has leveled a bit with the total burden of hours imposed by the
EPA on the public between 140 and 146 million hours.
To put these numbers in perspective, which you have done
when you opened up the meeting today, EPA's burden on the
public is less than 2 percent of the total Federal Government
burden, and we now rank sixth in terms of the Federal
Government.
EPA is very proud of the culture that we have that's
developed over the years in terms of reducing burden. From the
outset, our programs develop regulations and information
collections, seeking the least burdensome approach to
collecting the information while retaining the integrity of our
environmental mission.
EPA complies with the Paperwork Reduction Act by first
ensuring through an independent review that the 10 standards
you mentioned specified in the act are met and that the
analytical processes to derive those burden estimates are
sound. We ensure that the requirements for burden reduction are
understood by our program offices through guidance measures and
consultation, and we track all the information collection
requests, and we notify the program offices of their impending
need to respond in a timely manner.
The fact that we have had only two violations in the past
4\1/2\ years speaks to the success of the program that we have
in place today. We ensure the practical utility of the
information we collect by considering statutory requirements,
industry practice, past regulatory requirements and
opportunities for further reduction and reporting burden. We
believe that we have taken steps to reduce the burden above and
beyond what is required, including taking advantage of
information technology to do so.
One of the things I am most proud of is some of the work
that we are doing with our State partners, which has released
the Toxic Inventory State Exchange Pilot. This pilot reduces
the times and the resources expended by regulated facilities to
submit annual reports to the EPA and to the United States.
Beginning this year facilities in Michigan, South Carolina and
in Virginia are able to use the TRI-ME software to report
simultaneously to the EPA and the States via the Internet using
our Central Data Exchange.
This is an important notion, because Representative, you
mentioned that often there's duplication between the Federal
Government and States. This is a law that requires a facility
to submit two reports at the exact same time. What we are doing
is putting into place that they only have to submit one. The
CDX will then electronically forward the information on to the
States, which enables the facilities to submit the reports only
one time.
It streamlines the submittal process for the facilities and
the data acceptance and processing for both the EPA and the
States. The simultaneous reporting also will greatly enhance
our data quality and allow the EPA and the United States to
share information much earlier in a release cycle. Very soon,
we are going to be pleased to have Indiana join that list of
States, and we expect next year another 10 to 20 additional
States.
Some of the other things we are doing that might be of
interest, we have in the Toxic Release Inventory Program a
modernization effort that will help increase the amount of
electronic reporting and a major regulatory burden reduction
effort that consists of two proposed rules that will come out
this year. Those rules will eliminate duplication and possibly
allow a no-significant change option, which means that a
facility will be able to submit a very simplified streamlined
report if they haven't had significant changes in their
releases.
In our Research Conservation Recovery Act program we also
have a burden of reduction effort that will include 150
regulatory reporting changes that we expect to be promulgated
later this year. We expect that to significantly reduce or
eliminate a lot of the recordkeeping and burden associated with
the hazardous waste program. By only asking for the most
critical information needed to run that hazardous waste
program, we believe that we can ensure that environmental
expenditures are devoted to environmental protection rather
than generating unnecessary paper.
You have already mentioned our Central Data Exchange. We
believe that provides that single portal through which all
States, regulated facilities, tribes and others can provide
data to EPA simplifying that process. Right now we have 19
different kinds of collections coming into one single portal
both by States and industry using a fully electronic approach.
One of those examples that we put in place last year was
our stormwater form, which reduces the burden by nearly one-
third while reducing the processing time by an average of 33
days, a very significant savings by taxpayers. EPA's Small
Business Division has convened an agencywide work group to
identify and develop the best approaches across the agency to
reduce further paperwork burden on our small businesses, and we
are very much looking forward to the progress of that group as
the year rolls out.
You have my testimony. I have submitted more complete
information there that describes some of our compliance
activity, and I look forward to answering any questions you
might have.
Thank you again.
[The prepared statement of Ms. Nelson follows:]
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Mrs. Miller. Thank you so much. Our next witness is Daniel
Matthews. He is the Chief Information Officer of the Department
of Transportation, was appointed to his position in March 2003.
As CIO, Mr. Matthews is responsible for providing advice and
guidance on how to best use information technology resources
and ensuring that the Department of Transportation investments
in technology are sound ones.
CIO Matthews is a veteran of the U.S. Air Force, having
served from 1971 to 1975, and worked in logistics and computers
there. We certainly look forward to your testimony.
You have the floor, sir.
STATEMENT OF DANIEL P. MATTHEWS
Mr. Matthews. Thank you, Madam Chairwoman. Madam Chairwoman
and members of the subcommittee, thank you for the opportunity
to appear today to discuss the Department of Transportation's
compliance with the Paperwork Reduction Act [PRA].
DOT is improving the information collection and management
processes, but we also face some challenges. To put things in
context, as of May 31, 2005, the Department of Transportation
had 376 approved active information collections which totaled
over 253 million burden hours.
Of the DOT's information collections, one, truck driver's
hours of service account for 65 percent, 160 million hours, of
DOT's public burden hours. The remaining 366 information
collections account for 35 percent.
DOT's process requires the program officials with the
Operating Administrations first validate the need for an
information collection in response to a new requirement, a
public law or a new rule. If the Operating Administration or
the DOT/PRA compliance officer determines that the collection
is overly burdensome on the public or does not comply with any
of the 10 PRA standards, the information collection request
package is returned to the originator with suggestions for more
complete compliance with the PRA. What is important about the
process is that it allows DOT at various checkpoints to
determine the need for and the practical utility of the
information it proposes to collect.
It is in everyone's interest that DOT ensure that all of
our information collection activities impose the minimum
possible burden on the public and that the information gathered
is of the utmost utility. It is in the best interest of the
Operating Administrations to keep their information-gathering
burdens to a minimum by ensuring that the program office is
collecting only the information necessary for the proper
performance of the program function and then only to the
frequency that is needed.
Also, the Department works with the Operating
Administrations to ensure that the information gathered
satisfies the program's needs and the collection methods used
are sound and appropriate.
As to what steps DOT is taking to reduce the reporting
burden, I first note that the majority of the Department's
information collections are in response to enacted laws that
are intended to ensure the safety of the traveling public. As a
result, the reality of making annual percentage decreases and
collection burden hours is a challenging task.
For example, as I noted earlier, one collection alone
imposes 160 million hours, 65 percent of DOT's total public
burden hours. This collection is the Federal Motor Carrier
Safety Administration Hours of Service Rule, a rule which has
been in effect since the late 1930's and has been revised and
issued in final form several times. The Hours of Service
regulations require certain commercial motor vehicle drivers to
prepare and maintain a record of duty status. DOT expects to
publish a newly revised final rule no later than September 30,
2005.
But beyond the Hours of Service collection, and considering
the other 93 million burden hours, DOT is taking steps to
reduce that burden above and beyond what is required by the
law.
Agencies such as the Federal Railroad Administration are
demonstrating that information technology can and does reduce
burden. For instance, FRA grants waivers to railroads to
capture and retain hours of duty data in an electronic form.
Converting paper to electronic records has been a longstanding
and important initiative to improve the performance of this
vital safety program while reducing the burden on affected
railroads. This not only saves the railroads paper and storage
costs, but it also serves to reduce the paperwork burden which
to date has saved over 772,000 hours.
Finally, DOT has initiated a cross-agency approach to
institutionalize substantive burden reductions. DOT is focusing
on several critical strategies to achieve reductions. Improving
the efficiency of information collections, reducing the burden
per response, promoting where feasible the use of electronic
reporting, making adjustments where possible to the frequency
of the collection and creating partnerships internal to DOT and
with other Federal agencies to ensure there is no duplicative
reporting and to maximize data sharing.
Again, I thank you for the opportunity to comment on this
important topic, and I look forward to answering any questions
that you may have.
Thank you, Madam Chairwoman.
[The prepared statement of Mr. Matthews follows:]
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Mrs. Miller. Thank you, Mr. Matthews.
Our next witness is Mr. Pizzella. Am I pronouncing it
correctly?
Mr. Pizzella. Pizzella.
Mrs. Miller. Pizzella. He was confirmed as Assistant
Secretary for Administration and Management by the U.S.
Department of Labor on May 9, 2001. As Assistant Secretary of
Labor, Mr. Pizzella serves as the principal adviser to the
Secretary of Labor in the Administration and Management
Programs of the Department and as the Department's Chief
Information Officer and Chief Human Capital Officer. He is a
native of New Rochelle, NY.
Mr. Pizzella has served in both the private and the public
sectors. He is the former Policy Coordinator for the General
Services Administration, and he was also selected in 2004 as 1
of the 25 top doers, dreamers and drivers by Government
Technology Magazine.
We did a little research on you. We thank you for your
presence here today and look forward to your testimony.
STATEMENT OF PATRICK PIZZELLA
Mr. Pizzella. Thank you. Good afternoon, Chairwoman Miller,
Ranking Member Lynch and Congresswoman Brown-Waite. Thank you
for inviting me here to discuss the Department's efforts to
reduce paperwork burdens through compliance with the Paperwork
Reduction Act and through burden reduction initiatives beyond
what is statutorily required of the Department. I appreciate
this opportunity to discuss the Department's responsibilities
under PRA and our efforts to provide relief and fair treatment
to all business owners and individuals.
The Department is committed to reducing the burden that
America's businesses and individuals deal with every day as a
result of Federal regulations and paperwork. The PRA is an
important tool for the Department in all Federal agencies to
use in reducing unnecessary burdens on the American public.
In carrying out the Department's broad and varied mission,
the Department of Labor enforces more than 180 Federal laws. In
administering these laws and related programs, the Department
actively seeks to minimize the paperwork burden it imposes on
the American public while maintaining its mission and
fulfilling its statutory and programmatic responsibility.
The Department has also successfully adopted the Office of
Management and Budget's zero tolerance policy for PRA
violations, and this is something we are very proud of because
this is an indication of the responsible and fair
administration of the PRA and because it's also just good
customer service.
Following the PRA requirements for review and approval
provides a regular fresh look at our information collection
practices, helping us keep them up to date and relevant. The
Department remains committed to the goals of the PRA and
continues to explore and implement new ways to reduce burden
hours imposed on the public.
To this end, since fiscal year 2002 the Department has
submitted 12 burden reduction initiatives to OMB, several of
which have already resulted in a reduction of approximately
221,000 burden hours. These initiatives involve three main
burden reduction strategies: One, a comprehensive evaluation
and updating of regulation; two, streamlined information
collections and, third, a deployment of automated collection
techniques.
The Department takes the PRA very seriously. The PRA
requires each agency head to designate a senior official to
carry out the responsibilities of the agency under the PRA. At
the Department, as the Chief Information Officer, I report
directly to the Secretary and am responsible for ensuring
agency compliance with the PRA.
Accordingly, as CIO, I established an independent process
to evaluate proposed information collections and issued
internal policy for implementing the Department's information
collection management program. Through its vigorous internal
review process, the Department aggressively controls the amount
of burden it imposes on the American public and ensures
practical utility of its information collections with five main
strategies in mind: The review of rulemaking actions; assessing
the use of technology; routine review of information collection
activities; burden reduction initiatives; and, finally,
business public consultation.
Through a rigorous internal review process and aggressive
burden reduction strategies, the Department of Labor is
committed to reducing the paperwork burden on the American
public. In addition, the Department has a very strong program
of compliance assistance to help all businesses comply with
those requirements we place on them.
That concludes my prepared testimony. I look forward to
answering your questions.
[The prepared statement of Mr. Pizzella follows:]
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Mrs. Miller. Thank you, sir.
Mr. Pizzella. Thank you.
Mrs. Miller. Our next witness is Kevin Barrett. He is
testifying today on behalf of the Synthetic Organic Chemical
Manufacturers Association [SOCMA]. Mr. Barrett is a certified
industrial hygienist and also a certified safety professional.
He has worked for the chemical industry for about 16 years. He
has been a member of the SOCMA for at least 10 years, and as a
member of that he has chaired the Employee and Process Safety
Committee for 5 years.
Mr. Barrett, we welcome you today and look forward to your
testimony, sir.
STATEMENT OF KEVIN BARRETT
Mr. Barrett. Good afternoon, Madam Chairwoman and members
of the subcommittee. Thank you for the invitation to testify on
our experience with the Paperwork Reduction Act.
My name is Kevin Barrett, and I am currently an industrial
hygiene and safety consultant. I worked in the chemical
industry for 18 years, and as a consultant I continue to
provide support to chemical and industry clients.
I am testifying here today on behalf of the Synthetic
Organic Chemical Manufacturers Organization [SOCMA], a trade
association representing the interests of custom and specialty
chemical manufacturers, 70 percent of whom are small
businesses. My comments today focus on two particular
weaknesses in implementing the Paperwork Reduction Act,
specifically the cumulative effect of numerous regulatory
requirements on affected facilities and the inaccurate
calculations of the burden required by specific regulations.
Federal regulators have made significant strides in
assessing and reducing the readily identifiable burdens, but
regulatory burden still weighs on the chemical industry in
terms of both cost and paperwork. We have picked all of the
metaphorical low-hanging fruit of paperwork burden reduction
and must now retire.
What I mean by the cumulative effect of regulatory
requirements is the number of records and reports a facility is
responsible for, including both overlapping and separate
requirements imposed by State and Federal regulators.
In many cases, States are free to impose tougher standards
on industry than are imposed by the Federal Government. The
results are often regulatory strategies with similar goals but
very different requirements. Consider the experience of one
typical SOCMA member company.
This company is a small single-plant committee with
approximately 110 employees and only one full-time employee
dedicated to environment, health and safety issues. It is
subject to over 150 State and Federal environmental
regulations, must keep records to satisfy 98 different
regulatory requirements and is obligated to submit at least 48
environmental reports per year. Alone, any one of these
requirements seems unbearable. Only when they are aggregated is
the extent of the regulatory burden clear, especially when it
all falls on the shoulders of a single environmental health and
safety professional.
In addition to not capturing the burden associated with
cumulative requirements, the act enables agencies to be overly
conservative in their assessment of a burden imposed by a
particular regulatory requirement. This consistent
underestimating of regulatory burden prevents Congress, the
Federal regulators and interested citizens from understanding
the full scope of the regulatory burden imposed on an industry.
One prime example of both cumulative effects and
underestimating burden is the EPA's toxic release inventory
reporting requirements. This rule has been a major focus of
EPA's burden reduction efforts over the past several years and
EPA has claimed positive results. At the time of the EPA's last
information collection request to the Office of Management and
Budget, the burden for repeat filers dropped from 47.1 hours to
14.5 hours.
In contrast, one SOCMA member, who is a repeat filer, spent
approximately 250 hours completing his TRI report in 19--excuse
me, in 2003. Additional requirements imposed by the State add
another 80 hours to this total.
A second example of an agency's underestimation of
reporting burden is evident in OSHA's lockout/tagout burden
calculations. This rule addresses the safety of work on
equipment that, if unexpectedly energized during servicing or
maintenance, could cause injury. In their most recent
information collection request to the Office of Management and
Budget, OSHA calculated the burden of compliance with this
program anywhere between 15 seconds and 80 hours. The low-end
estimates do not appear realistic.
Specifically ensuring compliance with each written lockout
procedure requires an annual inspection of that procedure,
which must be documented in the written certification for each
occurrence. In addition, the training provisions require
written certifications and any retraining performed.
Considering these and the other requirements, one SOCMA
member calculated the low end of the annual burden for lockout/
tagout at about 7 hours per facility. Again this does not sound
like much, but it is almost a full day's work and is
significantly more than 15 seconds. If aggregated over 818,532
respondents identified by OSHA and if every respondent spends
the minimum 7 hours, OSHA would need to double their estimate
of burden hours.
In conclusion, focusing attention on the Paperwork
Reduction Act provides a promising opportunity for OSHA, the
EPA and the regulated community to reassess existing
requirements, specifically the problems caused by the
cumulative effect of numerous regulatory requirements and
inaccurate calculation of burden. We hope that agencies
actively engage the regulated community on future burden
reduction efforts in order to enhance American small business
competitiveness in the global economy.
Thank you for your invitation to present our views today. I
am happy to answer any questions you might have.
[The prepared statement of Mr. Barrett follows:]
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Mrs. Miller. Thank you, Mr. Barrett.
Our last witness today is Sean Moulton. He has been the
Senior Policy Analyst for OMB Watch since early 2002. Mr.
Moulton specializes in environmental information and right-to-
know issues.
Before joining OMB Watch, Mr. Moulton was a political
analyst at Friends of the Earth. His background in
environmental issues and policy analysis is extensive. We
certainly welcome you here today, sir.
Mr. Moulton.
STATEMENT OF SEAN MOULTON
Mr. Moulton. Thank you for the opportunity to testify here
today on the Paperwork Reduction Act.
My name is Sean Moulton. I am Senior Information Policy
Analyst at OMB Watch, a nonprofit research and advocacy
organization that works to encourage a more open and responsive
and accountable Federal Government.
OMB Watch cares greatly about the life cycle of government
information from collection to dissemination to archiving.
Accordingly, we have been involved in each reauthorization of
the Paperwork Reduction Act since it was enacted.
I have provided written testimony that I would ask to be
included in the record, and I will use this opportunity to
summarize some of those points.
Mrs. Miller. Without objection.
Mr. Moulton. Thank you. The point I would like to emphasize
most is that we must keep in mind the importance of
information, the benefits of information. The Paperwork
Reduction Act and the discussions that surround it focus
primarily on viewing paperwork and information collection, I
would say, as a burden. Information has always been the fuel
that powers the engine of progress for the government, whether
it is for environment, government spending or health and safety
regulations.
Eliminating or weakening collections of information to
achieve an arbitrary reduction goal, as the PRA requires, Is
shortsighted and I would say irresponsible. We began collecting
this information to fill a need. While it is reasonable to try
to minimize the work associated with that collection, we should
not do so in a way that we fail to fulfill the original need.
It is striking that the PRA only mandates disclosure of
burden for the collection and not the benefits of what that
information achieves. As a result, the debates on PRA are often
one-sided. Congress hears from those filling out the paperwork,
who are the first to complain, but seldom hears from those who
use the information and benefit. The users often know little of
PRA.
I would like to highlight one example of the importance and
use of information, one that has been raised earlier, the TRI
program. As mentioned earlier, TRI has been an enormously
successful and sufficient method in promoting significant
reductions in pollution. Since reporting began in 1988, the
original 299 chemicals that they began tracking have been--the
releases of those chemicals have dropped 59 percent. As new
chemicals have been added, reductions have continued to be
seen. The TRI list in 1998 had grown to 589 chemicals, and in
the 6 years that we have had data on those chemicals we have
seen 42 percent reduction.
One might think that with a track record like this, TRI
would be immune to significant changes or cuts, but as Ms.
Nelson testified, the agency is considering significant changes
to TRI reporting because of the TRI's demand for burden
reduction. Each of the burden reductions being considered by
EPA, including the no significant change, we would say
represents a significant loss of information to the public.
This is burden reduction at any means necessary, burden
reduction by reducing the amount or accuracy of information.
In the interest of time, I will highlight some of the
recommendations I made in my written testimony. I would
recommend that the PRA be refocused as Congress goes forward
with another round of reauthorization. The real strength of the
PRA is its potential to help government manage its information
resources.
Unfortunately, the theme of reducing paperwork no matter
the repercussions conflicts with a strong law of managing
information resources. I would urge that Congress make
appropriate changes to clearly establish that the primary
purpose is to improve management of government information.
The first change I would recommend would be to rename the
law the Information Resource Management Act or similar title to
reflect a new purpose.
I would also suggest that Section 3505(a) be eliminated.
This is the section in which Congress has mandated annual
burden reduction goals. I am not against reducing reporting
burdens, but any burden reduction must be examined within the
context of the purpose and use of information. Given the
information age in which we live, the growing need to know
more, it simply may not be possible to collect the data we need
and to reduce burden at the same time.
Congress should rebalance the PRA with less emphasis on
burden reduction and more emphasis on filling information gaps
and improving the quality and timeliness of the information we
collect.
There are legitimate methods to minimize reporting burden
without compromising information, and the PRA should emphasize
those as well. The most widely noted one would be electronic
reporting. Several people have talked about that.
I would also like to make a point about the public access
and dissemination under PRA. Under like burden reduction, it
has received too little attention. Prior to the 1995
reauthorization, PRA did not even contain a definition of
public information, nor was dissemination included in the
purpose of the law.
Dissemination of information to the public promotes the use
of data. It promotes the improvement of data. It squeezes the
maximum amount of benefit out of that data. Without use the
information serves little purpose. Many users of the government
data currently must resort to the lengthy and laborious process
under Freedom of Information Act to obtain their information.
Congress should make FOIA a vehicle of last resort. This could
be achieved by including a provision in the PRA that requires
government agencies to publicly disseminate in a timely manner
all information they collect unless that information would be
exempt under FOIA.
Finally, I would like to make two points about the
politicization of PRA. A major weakness of the Paperwork
Reduction Act has been susceptibility to manipulation. It
creates a back door for achieving politically motivated goals
with regard to the regulatory process. Many believe that OIRA
has used its paperwork authority to interfere with substantive
agency decisionmaking.
Another problem has been the imbalance of attention that
the paper has gotten at agencies from OIRA. I apologize, OIRA
is the Office of Information Regulatory Affairs. For instance
in 1999, EPA's paperwork burden was less than 2 percent of the
total government burden. Yet the agency had six OIRA desk
officers there. At the same time, Treasury constituted, as it
does now, over 80 percent of the paperwork burden from
government but only had one desk officer.
We would recommend that Congress mandate that OIRA assign
staff to agencies in proportion with the amount of paperwork
burden those agencies produce. We would also recommend that
OIRA be required to publicly explain and justify any
information collection request that it alters to clients or
delays.
I thank the committee for the opportunity to testify here,
and I look forward to answering any questions on this issue.
Thank you.
[The prepared statement of Mr. Moulton follows:]
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Mrs. Miller. Thank you very much, Mr. Moulton. I thought
your remarks were interesting, all of you. I am not sure quite
where to start. A lot of interesting testimony here today.
My personal thought is one of the filters we need in order
to look at the PRA again is a good, clear, analytical analysis,
I think, of the cost benefit of not only the regulation itself
but the paperwork requirement that we have for collecting all
of this data and what we are going to get out of it.
It has been interesting to me, as the Chair of this
committee, and some of the different hearings that we have had.
You have had Small Business Association testifying that the
regulatory burden that the government has placed on small
businesses, about $7,000 per employee, just to comply with
government regulations, which is quite a bit of money, a little
bit of change in your blue jeans, I think. You hear the
National Association of ufacturers say that with our regulatory
burden that we have, the structural costs of our manufactured
goods here in our country are 22 to 23 points higher than any
of our foreign competitors, including Canada, what have you,
principally based on the regulatory burden that we do place on
them.
I was interested to hear Mr. Barrett talk about 70 percent
of your group are small businesses. You mentioned--I was
listening to the one example you gave where they had 98
different forms they had to fill out from State and Federal
Governments about the Toxic Release Inventory, which is
something this committee hears quite a bit about as well.
Is there an ability now--I think this is to Mr. Barrett and
Ms. Nelson--is there an ability now for agencies to file online
with the Toxic Release Inventory, where they could report
online for the Federal requirements as well as the States? Is
that one of the things that you have done?
Ms. Nelson. There is. As I have mentioned, we have
something that is called TRI-ME, it is the Toxics Release
Inventory Made Easy software akin to TurboTax, which allows
somebody to walk through the report and be prompted for the
correct information. Last year we had about--almost--over 80
percent of the TRI forms come in electronically. The numbers
keep getting higher and higher each year. So we are seeing
great success there.
But what is more important is the example I just mentioned
in my testimony where the current law requires a facility to
submit two reports at the same time to a State and EPA. Keep in
mind that law was passed almost 20 years ago when things came
in via paper. Under an agreement with four States, with
Michigan and South Carolina, Virginia and then Indiana added to
the mix, those reports that are being submitted now, that are
due July 1st, the facilities in those States have the option to
say when I submit this report it counts as my State submission,
which means when EPA gets it we automatically take that
information, and using our exchange network, a network we are
using to share information with States and tribes, we
automatically feed that information back to the States.
As to why that is significant, Representative Brown-Waite
mentioned that oftentimes the forms are different. So even
though it is the same law that requires the submission of the
information, States may change the forms and add information to
it.
We think with the States getting this option they will be
less likely to do that because they won't have to build their
own information systems. They won't have to build their own
electronic systems that have to authenticate and identify and
receive those reports electronically, which means there will be
more standardization between the States and the Federal
Government.
Facilities submit the report one time, and it's much easier
to reconcile those reports when there are errors. And often
there are errors that come in from the facilities. So we think
it is a real streamline process that benefits everyone.
Mrs. Miller. I am not surprised to hear Michigan is one of
the States on the leading edge there with technology. They
always weren't many times in the area.
Ms. Nelson. They are one of the leaders in the area all the
way around. So we thank you.
Mrs. Miller. Mr. Pizzella, from the Department of Labor,
you mentioned in your testimony, you said that you had
identified unequivocally some of your key goals. You had said
that your Department had identified 12 different initiatives to
reduce burden. I wonder if you could give us one or two
specific examples of what some of those 12 initiatives are and
what kinds of goals you are hoping to achieve with that and
what you are--perhaps an example of some of your best practices
with those initiatives, if they are working?
Mr. Pizzella. Sure. We have an example of using technology
and prove how the public does business with the Department in
our initiative on e-grants. The Department's e-grants
initiative is an enterprise-wide response to the President's
management agenda for an electronic government by streamlining
and automating the application process for Federal and grant
programs.
Previously, the DOL agencies used it for a variety of
processes, some automated, some manual. There was no central
depository in the Department, and we decided to put our arms
around it, make it a little bit unified. We are currently
implementing that in an effort to eliminate redundancy and
disparity of data collection that takes place. We hope to
improve the efficiency and simplify the application procedures.
That is one that we are in the process of implementing. It also
has governmentwide implications, because some of my colleagues
are involved in that same effort.
Another example is the Bureau of Labor Statistics. They
have a quarterly consensus and wages program. It also reports
to the Federal Employment in Wages. I guess the acronym, for
those of you who follow that, is RFEW. Also BLS has an
initiative to again simplify this process by going from manual
to automated. A collection in the past has been very paper
intensive, very manual, and they have now been pursuing an
automated one in which Federal agencies are very responsive and
also the private sector implementing that. Those would probably
be the two best examples I could cite right now for the
Department.
Mrs. Miller. Thank you. Talking about paperwork
extensively, I guess that leads me to my next question to Mr.
Matthews. You indicated that 65 percent of the burden in your
Department is principally from truck drivers trying to monitor
from their logbooks, I suppose, what their time is on the road
and whatever information that you are gathering from there.
I heard that an estimate of the burden in order to fill out
a logbook was 3 minutes, and you had determined that it should
really be 6 minutes and that the truck drivers might actually
tell you it is actually 10 or 15 minutes.
I am not sure if any of that is actually true, having
talked to some of the truck drivers that I know. But is there a
way electronically to--I mean, if that's a huge majority of the
burden that you have in your Department, is there a way to use
an electronic keyboard? And when you do get the information
currently in a paper format, how is it transmitted from the
chicken coops back to you?
Mr. Matthews. Starting with the first part of the question,
Madam Chairwoman, if I could, the use of electronics is done
for hours of service in other modal operations. For instance, I
mentioned Federal railroads collects hours of service
electronically from railroad and conductors. Certainly that
technology is extensible to other modes of transportation.
The Department of Transportation has looked at using
electronic collection in submission of information in the other
modes. In some cases the people responsible for doing the
paperwork submissions would prefer not to have electronic
submission, but rather continue to fill out logbooks for
whatever particular reasons that they seek.
For the hours of service that you asked about, the
Department of Transportation currently has an open rulemaking
going on to ascertain public comments about the revision to
that rule. So we look forward to comments from the public and
will use those comments to revise, amend and republish that
particular legislation.
Currently, those paper records are sent in manually to the
Department of Transportation if summarized by or collected by
companies and then submitted to the Department of
Transportation. That is true for all hours of service
submissions, including pilots, who also have a similar
requirement to log the number of hours that they are flying
aircraft.
Mrs. Miller. I see. The rule you are talking about, that is
the one you testified that is coming out in the fall of this
year?
Mr. Matthews. Yes. It is due out September 30th of this
year.
Mrs. Miller. All right. I will at this time recognize the
ranking member, Representative Lynch for his questions.
Mr. Lynch. Thank you. Again, I thank you for your
testimony. I think, Madam Chairwoman, I have an initial
question that sort of came out through the GAO report. I just
wanted to ask Ms. Koontz and also Mr. Moulton, because you both
sort of brought it up in your remarks.
One of the 10 standards that we have within the PRA, I
think it's standard No. 9, says ``the collection should use
effective and efficient statistical methodology.'' In the GAO
report it says that the method that we are using within OMB to
measure the burden that we are trying to reduce, that is
limited in itself. So we are counting up all these billions of
hours? It sounds like people in America do nothing but
paperwork. But based on the assessments I have heard this
morning, maybe we don't want to reduce paperwork. We will have
massive unemployment.
But, really, can you sort of give me a fix on the accuracy
on the way we are measuring burden? Because there seems to be a
big swing here. It either takes 15 minutes or it takes 8 hours,
same thing. They have sort of a wide range of possibilities
there.
Is there a way that we can tighten this up to say this is
how much time it is taking, and the idea here, if we do this
right, this is what our reasonable expectation should be in
terms of reducing a certain amount of paperwork?
I was just trying to get my arms around that whole part of
this. You know, how much of this is overstated and what is
really accurate here? Ms. Koontz.
Ms. Koontz. We didn't look in depth at agency estimation
methodology, but we do know from studying this for a number of
years that the burden estimates are just that, they are
estimates. There isn't necessarily a consistent way of
measuring this from agency to agency. So we always view the
burden estimates as having a number of limitations.
As I said in my statement, it's probably OK to use them as
an estimate, but you have to keep in mind what the limitations
are.
I understand that IRS, for example, has gone through a lot
of work. They are not here today, but they have gone through a
lot of work to actually refine their burden estimation
methodology. You may have heard from them in the previous
hearing that the subcommittee held.
Efforts like that might be helpful. I think they have to be
balanced, however. You could spend a lot of time and money
deciding what number to put on this. It doesn't necessarily
then actually reduce the burden of anyone who is actually
reporting. We just have a better number. So I think, yes, we
maybe need to do more than the actual burden is. We have to
balance that with, also, efforts to make sure that we have
fewer people filling out less paperwork.
Mr. Lynch. That is fair enough. Thank you.
Mr. Moulton.
Mr. Moulton. Yes. I think this is certainly a case, as you
have categorized, of fuzzy math. The burden hours are generated
from a very complex equation. It's not based on actually
surveying, anyone actually filling out the paperwork.
Very often the paperwork burden hour is generated
initially. Common sense would tell us that as you continue to
refile you are going to see a significant reduction in how long
it takes you to fill out that paperwork. But we often don't see
in a lot of the burden estimates of that level or that
attribute taken into account.
But I agree that what we really need to focus on,
regardless of the fuzzy number, I think, is whether or not the
burden is useful, whether or not it provides us with enough
information or important enough information that regardless of
the burden we are doing it as efficiently as we can. It is
taking as long as it takes. We are going to see a range of
hours it takes people. Some people fill it out faster than
others. I think what we need to focus on is, is the information
important and useful to us?
Mr. Lynch. All right. Thank you. I agree. As I see it, you
know the standard that could probably be most helpful is indeed
just that, that we are not gathering needless information or
information that has low utility at the end of the day, as
opposed to something that I do believe is important, which is
if people are dumping chemicals, you know, toxic substances out
the back door of their factory or releasing that into our
treatment systems, they should probably report that to the
general public. We shouldn't limit the access of the public to
that type of information.
Ms. Nelson, you have testified that the EPA will, I don't
know if it is this summer or later this year, introduce a
couple of measures to make it easier. I am concerned that maybe
some of the proposals would have an effect of eliminating
access to important information.
For example, one option, at least discussed, I am not sure
if it is part of this proposal, would raise the reporting
thresholds for small to medium-sized businesses. That may sound
good, but what they intend to do, I think, if I am reading it
correctly--say there are two businesses that emit the same
quantity of toxic chemicals but one is a larger business while
the other is a smaller business, under the approach you are
suggesting the larger business will have to report its toxic
chemical releases, but the smaller businesses will not?
While the other is a smaller business and you are
suggesting that the larger business will have to report its
toxic chemical release--and I'm not sure of that. Because I
think, in some cases, it has no bearing on the amount of damage
this caused; and the concern I have is that the public will
only find out about the toxins released by the larger company.
That is not necessarily a good thing, in my estimation, at the
end of the day; and I wonder if you could comment on that.
Ms. Nelson. Sure. This year, I did say we will have two
proposed rulemakings. The reason we decided to have two, we
based it on stakeholder interest that we had a couple of years
ago and decided that some of the changes we could make were
relatively minor in nature and that we should process those a
little faster. In fact, we put those out for comment last
January. We received 30 comments on an EPA TRI package, which
is pretty miraculous; and we're moving forward with those.
Those changes are really eliminating duplicate information that
was being collected, and we felt we could use our enterprise
architecture to collect the information one time and use it for
multiple programs. That was one rule.
The rule you're referring to, sir, is the more substantive
burden reduction rule; and, quite frankly, we have not made any
decisions yet internally within the agency as to what will be
included in that rule. I did mention one option we are looking
at is no significant change option. But what you're referring
to is changing the thresholds, and we have not made any
decisions within the agency as to whether we would do that or
not.
The reason we are pursuing in all likelihood one of the
options, the no-significant-change option, is we have often
heard from industry that though there are changes, their
releases change very little from year to year, which is why Mr.
Barrett's number about the estimate being so high for one
particular industry is a little surprising, although it just
may be an anomaly in one industry.
But we are proposing the no-significant-change option
because that way we can reduce the burden on industry if, in
fact, things are generally the same but still provide the
information to the community. You've touched on a very
important point with the TRI program. It is not simply a matter
of the agency getting the information for its use, but the TRI
program started out as a community right-to-know program. The
purpose was for citizens to know what is happening in the
community.
So we're walking a very fine balance with these burden
reduction rules of how do we eliminate redundant, duplicative
information, maybe information that isn't really needed or used
by anyone, with the fact that many, many people across the
country want to know what is happening in their community. So
we are really trying to focus not on reduction of information
to citizens but where can we still provide the same level of
information to citizens but reduce information that might not
be of use to the consumers of the information, or information
we can provide because we have it from other sources.
Mr. Lynch. I know you said it is not final, but I don't
think that asking the information from a smaller company is
regarded as redundant just because we are asking for the same
information from a larger company.
Ms. Nelson. No, it would not be. As I said, that proposed
rule is not out yet, so what you're suggesting there is not
something that is being considered by EPA.
Mr. Lynch. That is good news. So we are not going to assume
that a small company doesn't have to report just because
they're only polluting a little bit?
Ms. Nelson. That is correct. That is correct.
Mr. Lynch. The other--Madam, should I come back for a later
round?
Mrs. Miller. Go ahead.
Mr. Lynch. Another option that I have heard of is for
changing the program to raise the reporting thresholds for
certain chemicals or certain types of facilities that represent
a smaller portion of Nationwide emissions so that, because
they're a smaller proportion, even though their amount might be
significant but because of a Nationwide emission level they're
only a small player in that.
Again, I have a similar concern about the impact on a local
neighborhood. A very small company that turned out to have a
leak in one of their petrochemical storage tanks, it leaked out
into the neighborhood, and now I have a lot of young women with
lupus and young people with cancer, and there are all kinds of
chemicals under their homes. A small company wouldn't have come
up on anybody's radar screen, and is probably a very small
percentage of emissions Nationwide and contamination Nationwide
but an enormous and tragic impact to a very small community. So
just concerned about whether or not that proposal, in doing a
proportion of the analysis nationally, whether that is an
effective way to limit polluters.
Ms. Nelson. I don't think you'll see a proposal like that
either.
Mr. Lynch. That is great, Madam. I yield back, Madam
Chairwoman.
Mrs. Miller. OK, I recognize Representative Brown-Waite.
Ms. Brown-Waite. Thank you very much, Madam Chairwoman.
I remember the old cartoon where it says we have met the
enemy, and it is us. So I would ask each of the chief
information officers, what can Congress do in conjunction with
your agencies to reduce the burden imposed as required in the
various statutes?
And I would ask a second question; and that is, have you
ever gone to Congress to say, you know, while you have asked us
to collect this data, we really don't use it for anything and
don't see any real future use for it?
So have you been proactive in helping to reduce the
paperwork by asking for some relief? And I will start with Ms.
Koontz.
Ms. Koontz. Was that a question for the chief information
officers.
Ms. Brown-Waite. Yes.
Ms. Koontz. I'll pass to a chief information officer then.
If you want me to come back and talk about some of the things
that GAO believes Congress can do, I'll do that as well.
Ms. Brown-Waite. I will ask Ms. Nelson.
Ms. Nelson. In terms of your first question, what can
Congress do to help reduce the burden, one of the things I
would ask is perhaps we have a dialog about the benefits of
using technology today versus when the law was first passed.
I know there are some that are reluctant to say simply
submitting a report electronically is not really a reduction in
burden, but I think there are things going on today where in
fact the use of technology can be a tremendous reduction in
burden. One of them I alluded to, things like creating turbo-
tax-like systems.
But the second is--let me give you an example. For
instance, we currently have a situation today where under the
current Paperwork Reduction Act we would have to submit an
information collection request for a situation we have where a
safe drinking water program needs additional information from
the States. We generally are responsible and we are made aware
from the States of violations in drinking water. We get general
information about those violations. We don't get specific
information on the contaminants.
Both the Safe Drinking Water Association, the association
that represents all safe drinking water administrators across
the country, and EPA want to share this information so we can
more effectively manage a program. But getting this information
from the States would require an ICR, which would be about a 2-
year process. That is a significant burden on taxpayers to put
that through the process when in fact the States are voluntary
willing to share that information. They want to give that to
EPA.
Using the technology that we have in place, this exchange
network that we're building, this is very simple computer-to-
computer communications because they have the information
already. The States have it. They collect it. This is simple
computer-to-computer communications with really a few seconds
worth of computer time to share the information, but it will
take us 2 years to process that information collection request,
just to get that information when the States want to share it
with us. I think as we look to burden in the future, we need to
think a little bit differently about situations like that and
how technology can help us.
In addition, you know, to answer your second question, how
we approach Congress, I would very much like to come to
Congress in the future on this TRI issue.
Because, for instance, that example I gave you, the law
currently says a facility shall report simultaneously to a
State and EPA. We may be stretching the law a little bit here
with what we're doing, although we think we're on safe grounds
because when a facility submits that report to EPA they are
saying this constitutes my State filing as well. There may be
some who question whether that is legitimate or not, but we
felt it was important to demonstrate the fact that technology
exists today that allows a facility to submit one time and we
can automatically get that or within 24 hours get that
information back to the States with a huge savings to taxpayers
at the State level because they don't have to create
duplicative systems in 50 States to collect that information.
That didn't exist when that law was passed almost 20 years ago.
I think they're the kinds of things we have to take into
consideration. So we wanted to demonstrate the fact that we can
do that, and we would like to come back to Congress as that is
an example of the kinds of things we can do in the future.
Ms. Brown-Waite. If I could just ask a followup question of
Ms. Nelson, can you think of one report that you're aware of
that your agency has--and I'm going to add this to the list for
the others, too--one reporting requirement that your agency has
that you know that when you all get these reports they get
filed away in a box and probably no one has ever looked at
them?
Ms. Nelson. I can certainly speak from some of my State
experience. Let me say that, because I did spend 14 years in a
State Environmental Protection Agency, in the environmental
field the vast majority of all environmental reporting happens
at the State level, not the EPA. EPA gets its information then
from the States, which get it from the facilities.
In a particular situation for discharge monitoring reports,
we received 60,000 of those a year in the State of
Pennsylvania. Only about 25 percent of those ever made it into
an information system because of the volume. We could not
afford to pay staff to do all the data entry to get those into
an information system; and, quite frankly, if they're not in an
information system, the likelihood that you're examining all of
those is pretty slim. So, yes, I would say a good percentage of
those may have been eyeballed but certainly not the kind of
analysis we're doing.
I will point to the chairman's State once again, though,
with funding from EPA, the State of Michigan has last year
became one of the first States to fully automate the submission
of those discharge monitoring reports from facilities fully so
that the monitoring data goes from the facility to the State
and into EPA's information systems. That is a huge success.
Because that program that collects those discharge
monitoring reports--that is the system which is called the
Permit Compliance System--is the second-largest information
collection in the entire country. We may rank sixth in terms of
agencies, but that particular collection itself for the PCS
system is the second largest in the Federal Government, second
only behind the tax collection, the IRS tax collection. So that
demonstration which is real, not just a pilot demonstration for
the State of Michigan, is one that we're looking to replicate
across the country and for Michigan alone has saved hundreds of
thousands of dollars in that agency and resulted in much higher
quality today that we can use and analyze.
Ms. Brown-Waite. Mr. Matthews.
Mr. Matthews. What can Congress do to help reduce the
paperwork burden working with ICIO? I do believe looking to
technology and how it can be employed would be useful.
The fact of the matter is, it is my opinion in the Federal
Government that agencies have a stove-pipe requirement. They
have vent systems based in that stove-pipe. Perhaps it is time
to take a look at best practices horizontally in organizations,
not just, say, in DOT but DOT and EPA, and how do we leverage
them and, as Ms. Nelson mentioned earlier, reach out to State
and local agencies so that we can consolidate governmental
reporting of information across the government. I do believe
that it is time to have a conversation about how technology can
help do that.
Have we at the DOT come to Congress requesting relief? I do
know that we come up here frequently asking for clarification
on laws that have been proposed and what data needs to be
collected. We also come to talk about our intention in
collecting the data in seeking comments. But, typically, the
agencies themselves would engage in that conversation. The
departmental PRA responsibility may or may not be aware of that
conversation that has gone on. So I do think that DOT does come
up to have conversations. Perhaps establishing a centralized
checkpoint on those conversations would be useful.
Then, do we have any stuff in the box that we don't take a
look at? I promise you if I was aware of it I would be seeking
an end to it with some dispatch. As a citizen who is loath to
fill out any single piece of paperwork to tell anyone about me
or my family, I would pursue that with a vengeance; and I would
encourage anyone, if they're aware of it, to let me know and I
will go after it at the DOT.
Thank you very much.
Mr. Pizzella. Thank you.
Let me first say that my colleagues, Kim and Dan and
myself, we through the CIO Council work to coordinate our
efforts in the executive branch to try to push e-government
initiatives and reduce sort of the manual processes that have
been in place for years and move toward a more electronic
processing of information and so forth.
I thought about your question about how people read these
reports, and what bounded in my mind immediately is how many
times I call an agency head in the department where my office
is reviewing a submission for Congress; and I will say, you
know, I saw something in here and I'm wondering if you think
this might need to be clarified a little more before we send it
up. And I on more than one occasion have heard that comment,
which report is that? And I'll tell them the report; and they
will say, nobody reads that anyway. So I think there is some
skepticism on our end of the reports being read by anybody,
whether it is Congress or the citizens in some cases.
What can Congress do regarding PRA? I guess they could
maybe consider a little bit more the PRA implication of laws
they're passing and maybe working in conjunction with the
departments that are most affected by that.
Last, you should know and you probably do know this, that
in the agencies when there is internal debate about whether or
not this report may make sense that we're providing to Congress
or this report is necessary, the very phrase ``Congress
requires'' is sort of a debate-ending sentence. In a discussion
of people, many of them very talented and capable professionals
within the Civil Service structure, who are questioning why
we're doing X, Y and Z and somebody says, look, Congress
requires this, it sort of drives them to complete the project,
make the submission on time, try and sort of take a thorough
review and try to make an argument back to Congress.
I guess my final suggestion would be that perhaps together
we can work some type of agreement, maybe even a sort of
reverse data call where Congress asks the agencies or
departments to tell us which reports you think are probably
least useful to provide and maybe we can have an honest dialog.
I suppose we have to coordinate amongst the various parts of
the executive branch, we have to coordinate on things like
that, but I bet there is a font of information there.
Ms. Brown-Waite. Thank you very much.
Mrs. Miller. One thing I guess would I say, we certainly
want to encourage you all to be extremely creative as much as
you know you can, as you say if you know of a report you would
be after it. But maybe you do know of some reports, as you
think about it, that aren't being read; and of course utilizing
technology as well is absolutely critical as we try to move
away from some of this paperwork.
My job since I came to Congress has almost been
administrative in nature. At one point in my career I was a
county treasurer in my county. I can remember going in there my
first week. We were trying to do an operational audit of all
the different paperwork. They were reconciling all this. We are
the third-largest county in all of Michigan. We were
reconciling all the bank books. They had their little lights on
with their pencils. Unbelievable, quite frankly.
But I remember this huge stack of paper in this closet, and
they were--you watched them every other day moving it off to
somewhere. I don't know where they were moving it to. And I
said to this woman, what are those reports? Well, I'm doing
this and this and this. Where do they go to and who reads them?
And she said, I really don't know. I said, we are just not
going to do that anymore. And she said, we can't do that
because ``they'' will be upset. I said, who do you think
``they'' are? You are looking at ``they.'' We're not doing that
any more.
So I guess I would simply encourage you to all be as
creative as you can, and I would be looking for some specific
instances or recommendations from any of you. I'm sure this
committee will find very fertile ground here on things that you
think require some legislative initiative, but oftentimes I
think it can be in the rulemaking, promulgating rules to
eliminate some indicia requirements and forms.
Again, I think this subcommittee and entire committee would
be very receptive to working with you in those regards. You
live it every day. We have a lot of other things we are trying
to focus on here, but I think we would be very receptive to
listening to some specific recommendations on what Congress can
do to help you.
I have a question to Mr. Barrett. I think I may have cut
you off. Do you have any particular response to Ms. Nelson from
the EPA about some of the different comments she was making
about compliance and what your industry's experience has been
and if you have any comments on whether that's being helpful or
not.
Mr. Barrett. Thank you very much.
I think the question that you posed was with respect to the
TRI reporting. I think SOCMA members--SOCMA folks have
canvassed their membership and there is a lot of support for
what EPA is doing in terms of automating the TRI reporting and
that is certainly a step in the right direction. It is my
understanding that EPA claims a 25 percent reduction as a
consequence of electronic reporting, but, in actuality--and
I've seen this myself within the ocean realm primarily--the
vast majority of the work that goes into completing forms that
goes into all this paperwork happens before you ever pick up a
piece of paper or ever sit at the computer. It is having
meetings, pulling the information together, doing a lot of
calculations.
So in the particular instance of the TRI report that was
mentioned in my testimony, the individual indicated that in
that company it took 250 hours to complete the TRI requirement
but 10 hours to do the actual paperwork. So there is a lot of
background work that goes into actually developing that piece
of paper.
That is something that needs to be borne in mind, and that
carries through to all aspects of regulatory reporting. There
is an awful lot that goes on behind the scenes that isn't
normally captured and oftentimes I think is not necessarily
reflected in the estimates that come out of the various
agencies.
Mrs. Miller. One of the things that we're talking about
here is the GAO report that we're releasing here. Obviously,
these burden estimates, as you talk about, are very difficult
certainly not a fine science, that is for sure. I don't know if
they could--they should call them estimates or guesstimates, I
suppose. But they cannot be guesstimated in a vacuum. You have
to talk to real people who are the end users of all these forms
and what their personal experiences have been, individuals or
businesses or what have you.
I'm noticing that the report states that only 37 percent of
the collections government-wide were in compliance with the
PRAs actually to consult with the public on the proposed
collection. So I am just wondering--perhaps we could have a
comment. How can that compliance be better and have we made it
too restrictive to reach out to actual people?
Ms. Koontz. I think what we saw in our review was that few
of the four agencies that we looked at in detail had complied
with the requirement to otherwise consult beyond publishing a
notice in the Federal Register. However, the reason that this
occurred was because OMB's guidance states that agencies are to
otherwise consult only when the collection merits such
attention. Our feeling was that did not meet the requirements
of the act. OMB disagrees. They believe that their
interpretation is correct. We have agreed to disagree on this.
But I think what it means is that possibly this is
something that the Congress might want to clarify during
reauthorization, and that is what are their expectations as to
consultation beyond the public comment period that is allowed
in the Federal Register notice. So that is the principal reason
that agencies did not feel that they were required to do this,
and that is not why it didn't happen.
We did talk to a number of agencies who did consult with
the groups. They published proposed rules on their Web site.
They conducted focus groups, they worked with professional
organizations, and in many cases they were able to give us
examples where that helped shape the collection in a
significant way.
However, I do think it is a fair question also about
whether it is appropriate to consult directly on every single
collection. Agencies pointed out to us that in many cases
collections are renewals, longstanding collections. These have
been out in the public for a long period of time, and they're
not sure that is the cost-effective approach, to do it on each
and every collection. So I think it is something that probably
merits some more debate and attention as we move forward on
PRA.
Mrs. Miller. OK. Mr. Lynch.
Mr. Lynch. Thank you.
Ms. Nelson, just to clarify this, I guess what I had read
earlier was a stakeholder review that the EPA conducted, and I
do believe that the EPA requested comments on whether higher
reporting thresholds for small businesses would actually become
a rule or be proposed by EPA and whether higher reporting
thresholds for categories of facilities or classes of chemicals
with small reportable amounts would be no longer disclosed by
those facilities. Is that--are these coming out as rules
proposed? I don't know I don't want to----
Ms. Nelson. No, you are correct. They are part of a
stakeholder dialog that we held 2 years ago where we put a lot
of issues out on the table electronically to receive input in
terms of various options. We used the stakeholder input that we
got through that process to help us formulate our proposed
rules, one of which has already been proposed and is ready to
be final, the second of which has not been proposed yet. And we
are still having those conversations within the agency as to
which options we should move forward with.
So we have not decided within the agency which of those
options will go out in the proposed rulemaking. We still need
to consult with the administrator on what those final options
will be. We do feel fairly confident that one of them will be--
at least there is a proposal--the no-significant-change option,
which means that your releases didn't change much from last
year.
Mr. Lynch. I understand.
Ms. Nelson. But the other options are all still under
discussion, so there's no decision made and no proposal on the
street yet.
Mr. Lynch. And I understand the no-significant-change
option really goes to the redundancy of the information already
provided.
Ms. Nelson. Well, I wouldn't say redundant as much as
trying to make it easier in the industry. If my processing
hasn't changed and my releases haven't changed too much since
last year, I'm just going to certify that you can use the
numbers we gave you last year because for all intents and
purposes my releases are the same as last year.
That way, the public still knows everything in terms of
what releases have been in their community and they have a
general idea. Because we're looking at generally, how do you
determine what no significant change is? A 5, 10, 15 percent
change? But the public still has all the information they have
had in the past. But it is much less burdensome on the industry
in terms of not having to fill out the complete set of TRI
forms. They can just certify my releases are essentially the
same as last year.
Mr. Lynch. Thank you.
Mr. Moulton, I know earlier we heard from each of the CIOs
in terms of what Congress can do. I read your testimony, and
you mentioned OIRA and the allocation of officers that are with
various agencies and how sometimes that is not proportionate to
the amount of paperwork that they're producing. Do you have a
response to other things Congress could be doing to make sure
that the focus is not politicized, as you've described in Roman
numeral V of your report?
Mr. Moulton. Sure. I do think that all the CIOs' emphasis
on using technology is a good one, and I think Congress can
encourage that and maybe even put a little pressure on the
agencies. Or maybe the better phrase would be to give them a
bit more authority and feeling that they can push forward more
aggressively on implementation of technology.
In terms of the politicization of the PRA, I think that
what Congress needs to do is make sure if what we're really
after is a reduction in paperwork and we have a few agencies
producing the lion's share of that paperwork, even if the three
agencies here made the reductions relative to their own
paperwork burden of 10 percent or 5 percent of the year, it
would be swallowed up by the IRS. So if IRS has the lion's
share, then we should be focusing a great deal more attention,
as this committee did by having them here for their own panel a
few weeks ago, which I applaud. But I think we need to mandate
that attention be paid or special attention be paid on the IRS
and that proportional attention be paid on the agencies as you
move down the tiers of how much burden they impose on people
with their paperwork.
Mr. Lynch. Thank you, Madam Chairwoman.
Mrs. Miller. Thank you very much for coming.
You know, talking about the IRS, I made this comment to Mr.
Everson during that hearing. I would just share this with you
as well.
When I was a kid, my dad was an aeronautical engineer,
worked on a Redstone with Wernher Von Braun at the beginning of
the rocket program; and he said it was very exciting times
until the Federal Government got involved in the process and
with all the paperwork that they always had to fill out. Daddy
used to say that they would never shoot off a missile until the
paperwork equaled the weight of the rocket.
So I think here we are today still looking at what we can
do, but I certainly appreciate all of your attendance today.
Certainly as Congress moves toward renewal of PRA we will
certainly take into consideration many of your comments. They
have been very insightful and helpful to the Congress here. We
also will be looking forward to receiving specific suggestions,
as we talked about, from many of you as we talk about what we
can do to assist you in expediting some of these different
processes that we have currently in place.
With that, the meeting will be adjourned. Thank you.
[Whereupon, at 3:43 p.m., the subcommittee was adjourned.]
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