OIG REVIEW OF IMPACT OF REQUIRED REPORTING

UNCLAS BRIDGETOWN 000084

SENSITIVE
SIPDIS
DEPT PASS TO OIG/ISP - AMB. DAVID ZWEIFEL
DEPT PASS TO WHA/CAR

E.O. 12958: N/A
TAGS: AMGT ASIG PHUM
SUBJECT: OIG REVIEW OF IMPACT OF REQUIRED REPORTING

REF: STATE 9541


1. (SBU) Embassy Bridgetown appreciates the OIG's interest in the
impact of mandated reporting on Post resources and welcomes the
opportunity to provide feedback. The 65 annual reports cited
reftel tracks closely with our February, 2009 OIG inspection
report, but in fact under-reports the number of annual reports we
compile. Combining the reporting specifically requested by
Congress and the reporting that must be done to feed into other
Congressionally or institutionally mandated reporting, we compile
for our six countries some 84 mandated annual reports (see attached
list). Adding Embassy Grenada into the mix, whose single FTE
officer processes ten annual reports, and the proliferation of
overlapping annual resource planning documents such as the MSP, we
prepare close to 100 mandated reports each year. With the
five-member POL/ECON section responsible for the bulk of that
reporting, this constitutes a crushing burden that significantly
curtails our ability to produce timely political and economic
analysis and in-depth reporting throughout the region. We would
welcome a rationalization of this workload to free us up to do more
pol/econ reporting and analysis, outreach, and commercial
development in the region.




2. (SBU) While planning documents were not part of the reftel
inquiry, we would urge the Department to look at a way to
rationalize the annual CBJs, PPR reports, and MSPs, all of which
track very similar data but have slightly different time horizons,
and which require significant duplicative preparation efforts by
State, AID, and (at this Post) MILGROUP personnel. It would also
help to have clearer and complementary guidelines for these
reports, as the data requests especially from the F bureau seem to
change every year.




3. (SBU) Special Circumstances: This Embassy, with support from a
one-officer Embassy in Grenada, is responsible for relations with
seven countries. Under existing regulations, that means we are
responsible for seven times the mandated reporting load of a
typical Embassy. Moreover, we have no permanent presence in five
of those countries, which means that we can only collect data and
investigate HRR, TIP, and other reports during infrequent reporting
trips, which are hindered by a lack of travel and representational
funding. In addition, the Embassy has been without a full-time
Narcotics Affairs Officer since 2006, this even though
counter-narcotics is our number one MSP priority. This makes
preparation of the INCSRs problematic and data collection difficult
owing to a lack of established contact networks. This needs to be
rationalized.




4. (SBU) We support the recent OIG recommendations for simplifying
these many reporting requirements, whether by coordination of
deadlines, timelines, and guidelines, the preparation of an omnibus
report once a year, or an amalgamation of mandated reports into
logical subgroups. As the OIG noted, even though these countries
have parliamentary democracies, clean elections, high respect for
human rights and generally professional police forces, post
"staggers under the load of annual reports,...each based on a
separately defined statute and different reporting schedules and
standards, some in conflict."




5. (SBU) Recommendations: A "short form" for these countries would
be useful and save us significant drafting and editing time,
especially as year-to-year changes are generally limited. With
regard to TIP reporting, the Department should seriously reconsider
the appropriateness of watchlisting these assistance-dependent
micro-states absent a significant and unattended trafficking
problem, as negotiating text and decisions with Washington takes up
an inordinate amount of time and discredits the excellent anti-TIP
work being done in real problem countries.




6. (SBU) Additional responses below keyed to questions in para 3 of
reftel:



a. Which mandated reports require the most time and attention from
Department personnel at your Embassy?

Our six human rights reports and fourteen INCSR reports take up the
most time and attention for data gathering. The G/TIP report is by
far the most resource-intensive, however, primarily the portion
requiring negotiation with Washington over final text, which has
involved the reporting officer, section chief, and Chief of Mission
over the course of several months.



b. What section or unit is assigned responsibility for gathering
information and preparing these reports?



The Pol/Econ section has the lead for all 84 reports. For the
INCSRs, a Narcotics Affairs Office subordinated to Pol/Econ has
primary responsibility. . In Grenada, the sole American officer and
two LES specialists prepare the reports. These are reviewed by
Bridgetown's Pol/Econ staff and DCM.



c. How many employees are involved in preparing and submitting each
report? Please specify Department direct hire staff, local
employees, eligible family members, contractors or other.



For the HRR, IRF, TIP, CBTPA, Transparency, Expropriation, Sugar
Quota, and Libertad Act reports, each of three section officers is
responsible for preparing the reports for two countries. They are
assisted by the section's only LES and an RSO investigator as his
time allows. The Embassy's protocol LES and the section's OMS also
support the drafting process by producing diplomatic notes that
must accompany requests for information in keeping with local
practice. The section chief and Chief of Mission review the
reports.



For the INCSRs, the NAS LES has primary responsibility for data
collection with cooperation from the Barbados DEA office, LEGATT
and IRS Investigator; the NAS LES and a Professional Associate
Position EFM draft the responses, and the section chief and Chief
of Mission clear them.



For the Child Labor reports (both versions) and the Labor and Child
Labor portions of the HRR and TIP reports, the deputy section chief
collects data and writes the reports; the section chief and Chief
of Mission clear.



d. How many person hours (by report and employee category) are
required to prepare each of the mandated reports? What proportion
of the Embassy or Mission's total personnel or other resources does
this represent?



In Barbados: difficult to pinpoint hours if we include data
collection as part of the preparation time, as each officer and the
sole pol/econ LES try to incorporate HRR, TIP, Labor and IRF data
collection into every reporting trip to an off-island. Overall, we
estimate that about 40 percent of the total person-hours of the
pol/econ section are dedicated to mandated annual reporting, along
with 7-10 percent of DEA, LEGATT, IRS, and RSO's time.



In Grenada, LES staff devoted approximately 12 hours to research
and 12 hours to draft the HRR report. However, the LES staff also
collects information throughout the year that facilitates
subsequent research. The American Officer devoted approximately 24
hours to analyze, fact-check, revise and negotiate text with
Washington. The other reports generally required 3 hours of work
by LES to research, 5 hours of work by LES to draft, and
approximately 4 hours of work by the American Officer to revise,
analyze, fact-check and negotiate each report.

e. Does required reporting, as it is currently being produced,
support and reinforce other mission goals or divert resources from
them?



This is a mixed bag. The INCSR process is useful and contributes
to our knowledge on narcotics and money laundering activities and
government efforts - with a NAS in place, this would be even more
useful. The HRR can be of occasional benefit, judiciously referred
to, to encourage better responsiveness from and professionalization
of local law enforcement, but is otherwise unremarkable as there
are very few human rights concerns in the Eastern Caribbean. The
TIP report has proven almost wholly counterproductive, threatening
development assistance sanctions against countries that need it
most and on the basis of non-specific allegations difficult to back
up with facts. The disconnect between the tier status assigned and
credible facts to back them up has had extremely negative
implications for our overall mission goals in the region, and has
negatively affected broad perceptions of the United States in the
region. Our overall credibility and the credibility of our
mandated reports as a whole have suffered as a result. We have
expended enormous energy with Washington and host governments
trying to rationalize this report, and we have ended up devoting
far more time and effort to this than the issue warrants for the
region, which in turn skews our reporting profile and keeps us from
other reporting. It also has the unintended consequence of damaging
our access to data sources once they feel they have been unfairly
targeted, which makes it harder to collect data for other reports.



Other reports are duplicative and/or overlapping, especially Child
Labor reporting, which we do four times for four separate but very
similar reports. Transparency Reports have similarly eaten up a
disproportionate share of resources recently, with what we believe
to be little justification and even less practical effect aside
from delaying much-needed training opportunities for local law
enforcement. In Grenada, manpower constraints result in the annual
reports providing most of post reporting on a particular theme.



f. What resource measures has the Embassy taken (redirecting
personnel to this instead of other duties, hiring additional local
staff or eligible family members, requesting additional fulltime
positions) to fulfill requirements for mandated reporting?



In the absence of a full-time NAS funded by INL, we have hired an
EFM under the Professional Associates Program to staff the NAS
position and we have requested a new NAS in every MSP starting in

2007. In addition, the duties of the NAS procurement assistant
were expanded to include more data collection and drafting
responsibilities for the INCSR. In October, 2007, Pol/Econ hired
an LES to assist with all six portfolios (there was not an LES
position for Pol/Econ previously). Also in October, 2007, the
section was reorganized along geographic vice functional grounds,
which streamlined the reports process somewhat. The Embassy has
consistently requested additional funding for travel and
representational expenses to allow us to travel to the five
countries where we have no permanent presence, so far with very
modest results. We also requested an additional position in the
IRS investigator's office, which will help speed data collection
and clearance of the INCSR (part 2).



Grenada: None when there is someone (often EFM) in the NAS
position. In 2006 and 2007, the LE staff spent about 10 hours
collecting and reviewing data, while the officer spent 30-40 hours,
drafting the questionnaires (LE staff from NAS office sent the GOG
incomplete lists of questions to be answered) and drafting the
reports, responding to Bridgetown queries, and finalizing the
reports. Should the NAS position continue to be filled, Grenada
will do less on these reports. However, in 2008, Bridgetown NAS
requested assistance from Grenada LE staff in getting the response
from the GOG; this amounted to perhaps two to three hours work.



g. Which parts of the process (information gathering, analysis,
drafting, internal editing, negotiation of text with Washington)
consume the most resources?

Answered above. In addition, the multiple iterations of the HRR
and TIP report add significantly to preparation time.



h. How clear and helpful are Department instructions for preparing
each of these reports?



Directions appear confusing to staff members who do not follow a
particular issue on a continuing basis. Minor changes in
directions each year, without clear guidance on the changes, itself
requires re-reading the entire set up instructions, which
exacerbates the confusion. The TIP report has considerable flaws in
methodology, evidentiary standards, and burden of proof issues.
This undermines posts' ability to explain the process and can
confuse not only staff but also host government officials about
what is wanted.



i. What percentage of the Embassy's overall reporting on an issue
such as human rights or trafficking in persons does the annual
required draft represent? Does your post submit reporting cables
on these issues throughout the year, or gather and discuss
information but submit it formally primarily in the required annual
draft?



Given the volume of mandated reporting, we have little time to do
any spot or analytical reporting on these issues. What little time
we do have is spent on travel to our off-islands, outreach, other
pol/econ reporting for seven countries, visitor support,
representation, etc. In Grenada, such reports generally consist of
80-90 percent of post reporting on particular issues.



j. Do other mission agencies besides the Department make
significant contributions to the preparation of mandated reporting
in these areas?



Answered above - DEA, IRS, LEGATT, and RSO all contribute to one or
more of our reports. Washington counterparts could usefully
contribute to the process by raising issues they spot in the media
through the course of the year for us to follow up, as there are
many demands on our time. Grenada frequently taps Embassy
Bridgetown and its agencies for guidance, assistance, review and
negotiation of reports.




7. (SBU) Responsible Officers: The following are the Embassy
officers responsible for mandated annual reporting:



Antigua and Barbuda, St. Kitts and Nevis reports (all): Rick
Switzer; Barbados, Saint Vincent and the Grenadines reports (all):
Jamal Al-Mussawi; Dominica, St. Lucia reports (all): D.R.
Seckinger; Grenada reports (all): Bernard Link; INCSR reports: Al
Razick; Child Labor reports: Jake Aller




8. (SBU) We thank the Department again for the opportunity to
contribute to this discussion, and look forward to working with the
OIG and others to improve the current structure.
HARDT