June 4, 2003
                              
BY FACSIMILE

Mr. Stanton D. Anderson
Office of Information Technology and E-Government
Office of Management and Budget
Washington, DC  20503

          RE:  Draft Small Business Paperwork Relief Task
     Force Report


Dear Mr. Anderson:

     This letter provides comments from the Office of
Advocacy regarding the "Draft Report of the Small Business
Paperwork Relief Task Force," (Draft Report), which the
Office of Management and Budget (OMB) published on May 9,
2003.  The Small Business Paperwork Relief Act of 2002 (Pub.
L. 107-198) created the Task Force, which is composed of
federal agencies, including the Office of Advocacy.  The law
requires the Task Force to submit a report to Congress on
paperwork burden relief by June 28, 2003.

     Congress established the Office of Advocacy under Pub.
L. No. 94-305 to advocate the views of small business before
Federal agencies and Congress.  Because Advocacy is an
independent entity within the U.S. Small Business
Administration (SBA), the views expressed by Advocacy do not
necessarily reflect the position of the Administration or
the SBA.  Our comments on the Draft Report are made in light
of our role as small business advocate.

     Advocacy commends OMB for managing the completion of
the Draft Report within the very short timeframe required by
the Act.   OMB's leadership enabled several diverse Federal
agencies to work together expeditiously to research current
paperwork burdens and to evaluate paperwork relief
strategies.

     Advocacy believes that OMB's efforts would be improved
if the Draft Report would more fully address the pressing
paperwork concerns of small business.  Small business
representatives have told Advocacy that the Draft Report
does not place sufficient emphasis on:  (1) ensuring that a
single point of contact is established within each agency,
(2) developing a usable catalogue of government-wide
paperwork requirements, (3) finding ways to eliminate
unneeded or duplicative paperwork requirements, and (4)
encouraging agencies to waive penalties for first-time
paperwork violators.

     Advocacy hopes that the final draft of the Task Force
report will fully address these four critical issues, which
have been repeatedly communicated to Advocacy by small
business representatives.  We believe that agencies, with
assistance from Advocacy and OMB, can and should take
reasonable, positive steps to alleviate the paperwork burden
on small business.  The Office of Advocacy applauds this
step forward and stands ready to assist OMB and the Task
Force in preparing a report to Congress that will go even
further to address the issues of concern to small business.
If you have any questions regarding these comments, please
feel free to contact Keith Holman at (202) 205-6936 or
keith.holman@sba.gov.

Sincerely,

Thomas M. Sullivan
Chief Counsel for Advocacy


Keith W. Holman
Assistant Chief Counsel