OINV External Feedback Survey

Questionnaire Planning and Design Document

Questionnaire of the Trade Community on web-based/extraction-enabled collection of information

The U.S. International Trade Commission (USITC) is implementing a questionnaire to gather user input to aid in evaluating the prospects of expanding web-based collection of information in anti-dumping and countervailing duty investigations. Input on the utility, benefits, and challenges could improve information gathering, streamline processes, and enhance efficiency and transparency.

A. The Survey Population

This will be a voluntary, web-based questionnaire. The population likely will include trade counsel alerted to the survey through several means. The principal avenue will be through email notifications to the agency’s pre-existing list of self-subscribing entities as well as a list of organizations that USITC staff believes may have an interest in the survey. In addition, information on how to participate in the survey will be featured on the USITC’s internet home page (www.usitc.gov).

B. Field Testing

In end of May early June 2019 the USITC field tested the survey with regard to scope and clarity of questions. Individuals with the organizations presented in the table below were identified as participants for field testing of the survey.

Name	Organization
Kathleen Cannon	Kelly Drye & Warren LLP
Alan Price	Wiley Rein LLP
James R. Cannon, Jr.	Cassidy Levy Kent (USA) LLP
Julie C. Mendoza	Morris Manning & Martin, LLP
Gregory Spak	White & Case
Matthew R. Nicely	Hughes Hubbard& Reed LLP
Bruce Malashevich	Economic Consulting Services LLC
Chris Cloutier	Schagrin Associates
David Spooner	Barnes & Thornburg

The following table presents comments from field test participants and actions taken in response to those comments. Comments on the survey were received from Mr. Nicely.

Field Tester	Recommendation	Comment/Solution
Matthew Nicely	The survey looks good, but the web-based collection process raises some concerns for me that might not get addressed in the survey, given that the survey seems mostly focused on the process of filling out the questionnaires, not so much the effect that process might have on our advocacy work surrounding the questionnaire responses. So, a few questions: Will this make it more or less difficult to attach additional documents to a questionnaire response? Also, for those represented by counsel, what about counsel’s ability to review prior to submission? Will there be a way to print or otherwise share a response before pressing send? Will the site allow a response to stay in draft form for a period of days? (Note that often several members of a company’s staff will play a role in preparing a response, not just one person.) And finally, given that many of us aggregate the data prior to receiving the staff report (due to limited time, and in order to collect data in ways the Commission might choose not to), will the responses be made available in a way that allows our staff and/or consultants to access the individual responses in the same way as previously?	Revised survey questions to reduce questionnaire specific comments, and revised to include features across different collection vehicles in addition to challenges and benefits.

C. Reporting Burden and Projected Cost

Total number of survey respondents: (No.) Not to exceed 100

Frequency of response: (No.) 1

Average completion time per survey: (hours) 0.50

Total burden: (hours) 50 hours

Total cost: (dollars) $3,750 (50 hours X $75/per hour)

Note: The hourly cost estimate reflects the average similarly-situated USITC employee hourly cost.

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