Only four supportive submissions are included Public Submission Documents of the Docket Folder Summary for the proposed changes to the Scheduling letter and itemized listing.
The public comments contain sound detailed arguments and overwhelmingly encourage OFCCP to revise or reconsider completely the proposed changes. Concluding statements, from a wide range of interested parties include:
“It is impossible to accept OFCCP’s assertion that the requirements are “less burdensome than those currently in effect”
“… the new compliance responsibilities proposed for federal contractors and subcontractors will significantly undermine rather than further the objective of Executive Order 13563 to promote “economic growth, innovation, competitiveness and job creation”
“… OFCCP has significantly underestimated the burdens the new requirements will place on contractors, and overestimated the benefits to be derived by the agency.”
“ …the proposed changes and additions to the Scheduling letter and itemized listing represent an opaque effort to dramatically change policy and place significant burden on contractors”
“ … urges the OFCCP to abandon or significantly modify its proposal”
“ OFCCP has proposed changes that would be intensively burdensome for federal contractors and subcontractors and that would provide a level of data unnecessary to the fulfillment of the OFCCP’s mission”
“OFCCP is seeking more than an extension of OMB’s approval of the information previously requested in the Itemized Listing of its compliance evaluation scheduling letter. Instead, OFCCP is seeking to materially change the Itemized Listings of its scheduling letter by: (1) adding to the list of information requested and (2) significantly revising how information previously requested is to be submitted.”
The current Scheduling Letter and Itemized Listing expires September 30, 2011.
