Overview
Title
Agency Information Collection Activities; Submission to the Office of Management and Budget (OMB) for Review and Approval; Comment Request; Foreign-Trade Zones Applications
Agencies
ELI5 AI
The Department of Commerce wants to hear from people about how they collect information from companies that want special trade areas, called foreign-trade zones, which help businesses save money. They ask everyone to share their thoughts by the end of May 2025, so they can understand if the process is good or if it needs fixing.
Summary AI
The Department of Commerce, through the International Trade Administration, is seeking public comments on their proposal for updating information collection from businesses applying for foreign-trade zone (FTZ) status. These applications allow businesses to request new or modified zone statuses and assess the economic impact of these zones. The information collected helps evaluate the necessity and effectiveness of these zones, as well as the burden on the public. People have until May 30, 2025, to send their comments, which will become part of the public record.
Abstract
The Department of Commerce, in accordance with the Paperwork Reduction Act of 1995 (PRA), invites the general public and other Federal agencies to comment on proposed, and continuing information collections, which helps us assess the impact of our information collection requirements and minimize the public's reporting burden. The purpose of this notice is to allow for 60 days of public comment preceding submission of the collection to OMB.
Keywords AI
Sources
AnalysisAI
The recent notice from the Department of Commerce, disseminated through the International Trade Administration, presents an opportunity for public participation in shaping the procedures concerning foreign-trade zones (FTZ) applications. These applications allow entities like local and state governments or not-for-profit institutions to apply for FTZ status or modify existing zones. The document highlights the organization's efforts to streamline information collection while minimizing the reporting burden on the public. Public comments are open until May 30, 2025, and these will play a vital role in refining the FTZ application and assessment process.
General Summary
At its core, this notice seeks feedback on the information collection process associated with FTZ applications. The Department of Commerce is focused on evaluating the necessity and utility of the information required from applicants and gauging how these zones' economic impact is assessed. It invites the public to submit written comments addressing the practicality and necessity of these data collection efforts.
Significant Issues and Concerns
Several areas within the notice could lead to questions or concerns from the public:
Cost and Time Estimates: The document provides an estimated total annual cost to the public of $133,400 without detailing how this figure is derived. This lack of transparency might lead to skepticism regarding the legitimacy of these costs. Similarly, the broad range of estimated time per response (from 3.5 to 131.0 hours) lacks clarity about what circumstances result in the longer durations.
Data Privacy: Although the notice acknowledges that personal identifying information might become public, it does not offer robust assurances or protocols for protecting individuals' privacy. This could be troubling for those concerned about the dissemination of their private information.
Application Details: The specific requirements and processes for different types of applications, such as new zones or subzones, are not detailed enough. This vagueness might result in confusion for those planning to apply.
Form and Submission Process: The absence of an associated form number and inadequate guidance on email submission security or formatting might lead to misunderstandings about the correct procedure for submitting applications or comments.
Impact on the Public
The broader public, including local governments and businesses considering FTZ applications, may find this notice has significant implications. For one, the solicitation of comments invites stakeholders to influence the future processes that could streamline applications and thereby reduce bureaucratic hurdles. Effective participation could lead to more efficient handling of FTZ applications, potentially fostering economic development through these zones.
Impact on Specific Stakeholders
Specific stakeholders like businesses directly engaging in foreign trade could experience both positive and negative effects:
Positive Impacts: If the information collection process is improved based on public feedback, businesses may benefit from reduced time and costs associated with applying for or modifying FTZ statuses. An efficient and transparent procedure could enhance business operations under the FTZ framework.
Negative Impacts: Concerns regarding data privacy and clarity of application requirements could deter some stakeholders from participating in the process or providing input, ultimately limiting the effectiveness of public consultations.
In conclusion, while this notice offers a platform for improvements in FTZ-related processes, addressing the highlighted concerns could reinforce stakeholder confidence and engagement, enhancing the efficacy and integrity of the system.
Financial Assessment
The document under review from the International Trade Administration includes a mention of financial implications, specifically highlighting the Estimated Total Annual Cost to the Public, which is $133,400. This estimate addresses the financial burden associated with complying with the information collection requirements set forth by the Foreign-Trade Zones Board under the Paperwork Reduction Act.
Financial Estimates and Uncertainties
The $133,400 figure is intended to represent the total annual cost to entities applying for Foreign-Trade Zone status or related modifications. However, the document does not provide a breakdown or detailed explanation of how this figure was derived. This omission raises questions about the accuracy and justification of the cost estimate, one of the identified issues in the document. Without an understanding of the underlying assumptions or the methodology used to arrive at this number, stakeholders may find it challenging to assess whether this cost is reasonable and reflective of the actual expenses incurred during the application process.
Time Allocations and Cost Assessment
In addition to the monetary estimate, the document states the Estimated Time per Response ranges from 3.5 to 131.0 hours. Such a broad range suggests variability in the complexity or scope of applications submitted, which can subsequently affect the cost to the public. However, similar to the cost estimate, there is a lack of clarity regarding what specific circumstances account for the higher end of this time commitment. This lack of specificity may lead to further difficulties in assessing the associated financial burden. More detailed information about the time required for different types of applications could improve transparency and enable potential applicants to better prepare for the financial and labor costs involved.
Reporting and Cost Implications
The mandatory nature of this reporting obligation suggests that firms or organizations seeking foreign-trade zone status have no choice but to incur these costs. The document notes this requirement is pursuant to the Foreign-Trade Zones Act of 1934, as amended. Yet, the lack of detailed guidance on expected costs creates ambiguity, potentially impacting an organization’s financial planning and decision-making process when applying.
Overall, the document highlights a clear financial reference concerning the cost of compliance but lacks the necessary detail for stakeholders to fully understand or anticipate the financial implications associated with the Foreign-Trade Zones applications. Addressing the issues identified could greatly enhance the document’s utility and clarity, providing stakeholders with a more comprehensive view of potential costs.
Issues
• The document does not provide detailed information on how the estimate of 'Estimated Total Annual Cost to Public: $133,400' was calculated, which could affect understanding if the costing is accurate or justified.
• The range of 'Estimated Time per Response: 3.5 to 131.0 hours' is very broad, without specific clarification as to what types of applications warrant the longer response times, which could be clearer.
• The exact nature of the information to be collected for each type of application (new zone, subzone, etc.) is not fully detailed, which may cause confusion regarding application requirements.
• There is no mention of how the Department intends to handle comments requesting the withholding of personal identifying information from public review, other than stating it cannot guarantee to do so, which may concern some individuals about privacy.
• While the document invites email submissions, it does not detail specifics on email security or guidance on submission formatting, which could help improve the clarity and utility of the collection process.
• The document does not explain why there is no form number associated with the collection, which might lead to confusion about the application submission process.