Consultations with Federal Agencies, Trade Groups, and Trade Publications, Selected Correspondence

Attachment H
Department of Commerce
United States Census Bureau
OMB Information Collection Request
2022 Economic Census
OMB Control Number 0607-0998
Consultations with Federal Agencies, Trade Groups, Corporations, and Consulting Firms:
Selected Correspondence

Shirley Wodynski 
Thu 6/25/2020 2:47 PM
To: ECON Content

Comments for Section 28:
Best thing we can request for Section 28 is:

CC-23830
What % of your revenue is attributed to ceiling installations?
Do you believe that your buildings are being designed with adequate detailing for sound control?
CC-23810
What % of your revenue is attributed to prefabrication?
What do you project for % prefabrication revenue in the next 10 years

Shirley Wodynski
Executive Director
Ceilings and Interior Systems Construction Association
1010 Jorie Blvd, Suite 30
Oak Brook, IL 60523
630-313-6750
Fax: 866-560-8537
shirley.wodynski@cisca.org

Robert Roche 
Tue 6/30/2020 9:58 AM
To: ECON Content

This response is on behalf of CTIA, formerly known as the “Cellular Telecommunications Industry Association,”
with respect to the concepts and questions to be included on the 2022 Economic Census. The response I am
providing is for the wireless industry, otherwise denominated as “Cellular and Other Wireless
Telecommunications (Consolidated),” characterized as IN-5171A.
In particular, I examined the applicability of Item 28, Special Inquiries. I deemed the questions posed therein to be
generally appropriate and applicable. However, I did note that on pages 19-23, of the 2017 Economic Census
form, below CFN: the form indicated in bold: ITEM 28: SPECIAL INQUIRIES – PERCENTAGE OF RECEIPTS FOR
WIRED TELECOMMUNICATIONS CARRIERS.
In fact, at least three of the four questions posed on page 19 would also generally apply to wireless carriers: with
respect to providing (1) broadband internet access, (2) internet telephone service (VoIP) and (3) access to overthe-top / streaming media service. The fourth question – as to providing “multichannel programming distribution
services – video and cable television” – would also apply to at least some wireless providers, which provide either
(a) access to bundled video services, or (b) access to third-party video content providers’ services, in bundled or
unbundled form.

I believe that the questions on pages 20-23 would also then be applicable to wireless providers, and therefore the
bolded subhead noted above, should be revised to read “PERCENTAGE OF RECEIPTS FOR WIRELESS
TELECOMMUNICATIONS CARRIERS.” for this form.
I would deem the remainder of the questions appropriate for the industry.
Having reviewed the output specific to the wireless industry, I likewise deem the questions and aggregate
responses to be appropriate, in terms of developing data that is representative of the industry’s performance.
Thank you. Please do not hesitate to let me know if you have any other questions.
Bob Roche
Robert F. Roche, Ph.D.
Vice President, Research
1400 16th Street NW
Washington, DC 20036
202.736.3255 (office)
202.674.1713 (mobile)

Nick Rigitano 
Tue 7/7/2020 9:04 AM
To: ECON Content

Hi,
Thank you for reaching out to the National Sporting Goods Association. Please find our comments and responses to
your questions in the attached word document.
Feel free to contact me with any additional questions/follow-ups. Thanks.

Best Regards,
Nick Rigitano, Director of Insights and Analysis
National Sporting Goods Association
3041 Woodcreek Drive, Suite 210 ǀ Downers Grove, IL 60515
(847) 296-NSGA (6742), ext. 1080 ǀ F: (847) 391-9827
nsga.org
NSGA Availability During the Coronavirus (COVID-19) Outbreak
NSGA Headquarters is closed until further notice. All NSGA Staff will be working remotely and will be available to answer any
questions or concerns you may have by calling (847) 296-6742 or at info@nsga.org.

3401 Woodcreek Drive, Suite 210
Downers Grove, IL 60515-5419
PH: (847) 296-6742
www.nsga.org

July 7, 2020
US Census Bureau

To whom it may concern,
Please see the below responses from the National Sporting Goods Association regarding the 2022 Economic Census
Questionnaire:
• Do the survey questionnaires and instructions use terms/definitions that are common for your industry? Yes
• Do the survey questionnaires accurately reflect what is occurring in your industry? Yes
• What do your data users need that we are not asking? Sales per square foot of retail space, sales per employee,
percentage of sales that come from an online website.
• What questions are no longer relevant and could be eliminated? None
• Are certain questions difficult to complete? Why? Item 22 due to length of the question and list of possible
answers.
• Are instructions clear and helpful? Yes
• Are there any other comments or opinions with regard to your industry?
It would be best for the sporting goods industry if the Sporting Goods Stores segment would remain separated from
the Hobby, Musical Instrument, and Book Stores segment. Having Sporting Goods Stores reported in aggregate with
the other store categories does not give sporting goods retailers a clear picture of what is happening in their
segment on a monthly basis in the advance monthly sales retail trade report. By the time the monthly retail trade
report is available, the data is less useful given it is 1.5 months old at that point.
3401 Woodcreek Drive, Suite 210
Downers Grove, IL 60515-5419
PH: (847) 296-6742
www.nsga.org

The industry also needs the data from the Economic Census to be released earlier than 4 years after the study is
conducted. The full results for the sporting goods industry from the 2017 survey won’t be released until the end of
2021. Given how quickly the state of retail is changing in recent history, the data loses value to the industry when it
is 4 years old by the time it is released.
The industry also needs breakouts for the store types included in item 17 of the survey (i.e. bicycle shop, golf
specialty, gun shop, fishing tackle, ski/snowboard shop, etc.) to be released. I believe these categories were included
prior to the 2012 Economic Census, and we are not sure why they were stopped. Each of these categories are

specialized and the businesses selling these categories are very different from one another. The leaders of these
businesses do not believe they are in competition with other categories outside their specialty.
Also for item 17 of the survey, we would like to see Ice hockey dealer (retailer or pro shop) added to the list of
establishments. There are numerous establishments throughout the country that fall into this category where ice
hockey is their principal line of business.

Best Regards,
Nick Rigitano
Director of Insights and Analysis
National Sporting Goods Association
847-296-6742 x1080
nrigitano@nsga.org

Serving the sporting goods industry since 1929

2022 Economic Census Comments for MC-32732 Concrete Block and Brick
Manufacturing

Robert Thomas 
Wed 7/15/2020 9:49 AM
To: ECON Content

Thank you for the opportunity to comment. My comments are specifically addressing MC-32732 Concrete Block and
Brick Manufacturing
The title could be reconsidered for the following reasons:
• “Brick” is a term that typically refers to products made from fired clay. There is another category for this
product: MC-32711 Building Material and Refractories. But, because that other category does not include
Brick in the title, you may get brick manufacturing companies incorrectly classifying themselves in MC32732
• The term “Concrete Brick” is still relevant, although manufacturing and sales in this category is far less than
that of Clay Brick. The title of this category separates the terms “concrete” and “brick” – it might be better
to call it “Concrete Block and Concrete Brick” to avoid confusion.
• But – there are other concrete products in this category whose sales and relevance dwarf that of Concrete
Brick, such as concrete pavers, segmental retaining wall units, and other concrete masonry veneery units.
• The term “hardscape products” has evolved to represent landscaping products used to outdoor living
spaces – and this segment has grown tremendously in the past 30 years.
• The term “concrete masonry” might be a better and broader term for the title that “concrete block”. The
industry uses the term CMU – concrete masonry unit. Concrete Masonry would also encompass products
such as concrete brick and concrete masonry veneer units.
Therefore, a suggested revised term for this category: “Concrete Masonry and Hardscape Product Manufacturing”

Page 30 dealing with product codes is a little outdated given the evolution of the industry. This category for
Concrete Block and Brick Manufacturing targets those manufacturers making primarily dry-cast concrete
products. There are two associations that represent these products on the national level: the National Concrete
Masonry Association and the Interlocking Concrete Pavement Institute. The products that we would consider as
relevant in our industry include:
1. Concrete Block, Structural
a. Gray Block
b. Architectural Block (integrally colored block, split block, burnished block, ground-faced block,
glazed block, etc)
2. Concrete Masonry Units, Non-structural
a. Concrete masonry veneer units, architectural
b. Concrete Brick
3. Concrete paving units
a. Interlocking concrete pavers
b. Concrete slabs and patio stones
c. Articulated concrete block, ACB (used for revetments and erosion control)
4. Segmental retaining wall, SRW, units
The terms lightweight, medium weight, and normal weight units are still relevant – but primarily only for the Gray
Block category above.
The terms screen block, slump block, and shadow wall block are marginally relevant today. Those could be included
in the list of architectural block.
Of those “other sales, shipments, receipts, or revenues from this establishment,” I would expect that only two of
them would be relevant to these types of establishments:
#10 – quarrying of sand and gravel – but I would add in “for the purposes of manufacturing” in addition to
for the purpose of construction.
#11 – Wholesaling services for concrete, cement, sand, grael, stone, brick, block, and tile
I would recommend removal of #7 (mining fire clay), #8 (mining clay and shale), and #9 (mining gypsum) – but you
can check past submissions to see how frequently those are listed.
However, there are a number of new services that these manufacturing facilities have been adding:
• Retail sales to the public for hardscape products (concrete pavers, concrete slabs and patio stones,
segmental retaining wall units, stone, tile, etc.)
• Retail sales to contractors for installation of concrete products (construction tools, supplies, mortar, sand,
etc.)
Also – some of these manufacturing facilities may also manufacture other forms of concrete that have their own
designations:
• MC-32731 Ready-Mix Concrete
• MC-32734 Other Concrete Product Manufacturing
There is obviously a great deal of consistency between all of the concrete manufacturing subsections. I have
restricted my comments to those relevant to that subsection most relevant to the industry that our organization
represents. However, I would be happy to support a discussion with those organizations representing other
concrete sections if desired.
Please feel free to contact me about any of the comments above. Thank you again for the opportunity to
comment.

-------------------------------------------------------------------------------Bob Thomas, President
National Concrete Masonry Association
Office, Main: 703-713-1900
Office, Direct: 571-224-0920
Mobile: 571-201-3456
rthomas@ncma.org

2022 Economic Census input

Chris Runyan 
Wed 7/15/2020 2:20 PM
To: ECON Content

There does not appear to be a selection for trade association. The survey for construction is targeted to actual
construction companies and not the trade associations who represent them. Therefore, I have no comments.
Sent from Mail for Windows 10
hielscher74@gmail.com
Wed 7/15/2020 1:33 PM
To: ECON Content

I am no longer associated with MCA. I forwarded this to the association.
Metal Construction Association (MCA)
Karl Hielscher:

From: Carolyn Schnare 
Sent: Thursday, July 16, 2020 2:58 PM
To: Charles F Brady (CENSUS/EMD FED) 
Subject: FW: FEEDBACK REQUESTED: 2022 Economic Census Questionnaire Content [P24966451922]
Hi Chuck,
Jeff and I went through each of the convenience store surveys (c-store and c-store with gasoline).
Is it ok if I share them with you directly rather than through the email below?
I made comments in each of the attached PDFs.
And, I had some questions/observations:
•

It’s hard to compare the sale of goods items on the two surveys on a computer, even with two
monitors, but they seem fairly different in the retail goods for sale sections. I don’t think they should

differ as much as they do, except for the fuel questions. I think of companies that will be doing
hundreds of these surveys who have some store in each category (with and without gas) and it
would be confusing.
•
•

I would think the c-store questions about food/drink should be the same for both (they are not).
Also, consider eliminating all the clothing and construction questions on the plain c-store w/o gas survey).

Happy to jump on the phone and I’m fine if you send this off to others that work on the surveys. I think I answered
most of the questions below within the surveys.
Thank you for the opportunity! Its really interesting to see these!
Best,
Carolyn

Joseph Anderson 
Fri 8/7/2020 1:35 PM
To: ECON Content

Dear U.S. Census Bureau,
The Steel Tube Institute is a non profit trade organization representing steel tube manufacturers. In
reviewing the past census surveys, I did not see any surveys that fit the description of our activities. As
such, we are not planning on responding to your inquiry.
Best regards,
Joseph Anderson
Steel Tube Institute
Executive Director
Office 847-461-1701

Mobile 209-712-8494
janderson@steeltubeinstitute.org

Tucker, Russell J. 
Wed 8/12/2020 2:39 PM
To: ECON Content

Please find attached NRECA’s comments on the 2022 Economic Census. Thank you.
Russell J. Tucker, Ph.D.
Chief Economist | National Rural Electric Cooperative Association
4301 Wilson Blvd., Arlington, VA 22203
o: 703.907.5823 m: 202.365.9015
E electric.coop | T Follow | Y Watch | F Like | I View | in Connect

Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the
intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, copy, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please
contact the sender by reply e-mail and destroy all copies of the original message.

August 12, 2020

Nick Orsini
United States Department of Commerce
Economics and Statistics Administration
Associate Director for Economic Programs
U.S. Census Bureau
Dear Mr. Orsini:
The National Rural Electric Cooperative Association appreciates the opportunity to comment on the development of
the 2022 Economic Census.
The Economic Census has been a valuable tool in demonstrating the unique firm size characteristics of electric
cooperatives as compared to the rest of the electric industry. The U.S. Small Business Administration defines small
entity electric utility businesses by the number of employees in the firm. The Economic Census is essential to

supporting this analytical framework.
At the same time, the Bureau should identify opportunities to reduce the burden imposed on electric co-op staff in
completing the survey document. We recommend eliminating or limiting the questions associated with Item 28:
Special Inquiries. These questions appear to fall outside of the core Economic Census firm size benchmarks. For
example, the 2017 questionnaire included a special inquiry on the cost of electricity. This information is readily
available from the U.S. Energy Information Administration (EIA).
Thanks again for the opportunity to provide input on the development of the 2022 Economic Census. Please let me
know if I can be of additional assistance.
Sincerely yours,

Russell Tucker
Chief Economist
russell.tucker@nreca.coop

Noa Banayan 
Wed 8/12/2020 4:18 PM
To: ECON Content

Hello,
Thank you for the opportunity to comment on the 2022 Economic Census. Please find a letter
responding to the questions sent to PeopleForBikes attached, and additional comments and highlights
on the draft forms.
Please let us know if we can clarify any information we've shared.
Take care,
Noa
Noa Banayan
Federal Affairs Manager
(she/hers)
PeopleForBikes Coalition
1750 K St NW, 2nd Floor
Washington, D.C. 20006
EMAIL: noa@peopleforbikes.org
MOBILE: 508.283.0814
PeopleForBikes.org

Support our vision for the future of bicycling
Give Now to the Tim Blumenthal Legacy Fund.

August 10, 2020
Re: FEEDBACK REQUESTED: 2022 Economic Census Questionnaire Content [P26057786839]
The PeopleForBikes Coalition is the national trade association representing companies that manufacture
and distribute bicycles, bicycle parts and bicycle accessories. Nationwide, PeopleForBikes represents 260
bicycle businesses and more than 7,000 retail locations. The U.S. bicycle industry contributes $88 billion
annually to our economy and employs more than 780,000 Americans. Bicycling moves people efficiently
and keeps people active and healthy.
We appreciate the opportunity to offer comments in regard to the 2022 Economic Census. Please find
responses to the questions below, and comments in the attached survey forms.
Do the survey questionnaires and instructions use terms/definitions that are common for your
industry?
• The bicycle industry doesn’t differentiate between manufacturers and wholesalers as most
companies that fit into one category would also fit into the other. For example, Giant Bicycles has several
manufacturing facilities but also sells complete bikes to retailers. Which survey would a company that does
both complete?
Do the survey questionnaires accurately reflect what is occurring in your industry?
• In the retailer survey there are several questions on method of selling (Item 21). In the bicycle
industry we are seeing an increase in people ordering online and picking up in the store, having the bike
delivered from the store, or having the bike delivered directly to the residence. It isn’t clear which of the
options in these items covers that purchase process. It would be good to be able to estimate sales that
occur online vs. at the physical store location.
What do your data users need that we are not asking?
• In the retailer survey, item 22:
o There is an option for “Retail sales of bicycles, other cycles, all types except children’s
sidewalk bikes and parts and accessories.” Ideally, this would include all human powered unicycles,
bicycles and tricycles, electric bikes, children’s bikes, and stationary bikes.
o We would like to break out bicycle trailers from “retail sales of utility trailers, including
horse/livestock trailers.”

o We would like to break out used bicycle sales from “Retail sales of used home
entertainment, recreation, and culture products, including books, CDs, musical instruments, sporting
goods, bicycles, etc.” This would be especially helpful for the industry.
o We would like to break out bicycle maintenance and repair services from “Maintenance
and repair services for recreational, sports, and fitness equipment including boats, motorcycles, other
sports vehicles, and musical instruments.”
• In the wholesaler/manufacturer survey item 17A: We would like to separate out all bicycles
including all human powered unicycles, bicycles and tricycles, electric bikes, children’s bikes, and
stationary bikes.
• In the wholesaler/manufacturer survey item 22 we would like to explicitly include all human
powered unicycles, bicycles and tricycles, electric bikes, children’s bikes, and stationary bikes.
• In the manufacturer survey, item 18 we would like to break out bicycle parts from “motorcycle and
bicycle parts.”
• In the manufacturer survey, item 22 we would want to include all human powered unicycles,
bicycles and tricycles, electric bikes, children’s bikes, and stationary bikes.
What questions are no longer relevant and could be eliminated?
• For wholesalers/manufacturers, item 22 (method of selling) isn’t useful.
Are certain questions difficult to complete? Why?
• This is a difficult question for us to judge but we could pre-test this survey with some of our
members if we had sufficient notice.
Are instructions clear and helpful?
• Same as above.

Bill Frymoyer 
Wed 8/12/2020 4:57 PM
To: ECON Content
Cc: Ann Wilson ; Mike Jackson 

August 12, 2020
Dear Sir/Madam:
Thank you for the opportunity to respond to questions
posed from the Bureau of the Census regarding the 2022
Economic Census. This response below is for the Original
Equipment Suppliers Association (OESA) and the Motor

Equipment Manufacturers Association (MEMA). Please let
me know if you have any additional questions for us.
Sincerely,
Bill Frymoyer
Vice President, Public Policy
Motor & Equipment Manufacturers Association (MEMA)
202-312-9253
202-309-0888 Cell
bfrymoyer@mema.org

Responses Questions on the 2022 ECONOMIC CENSUS
Submitted by the Original Equipment Suppliers Association (OESA) and the Motor Equipment Manufacturers
Association (MEMA)
• Do the survey questionnaires and instructions use terms/definitions that are common for your industry? Yes.
However, we have heard from our members that they are unfamiliar with the NAICS nomenclature.
•

Do the survey questionnaires accurately reflect what is occurring in you industry? Somewhat. The push
towards electrification is the top priority in the industry. There is not a question that specifically tackles that
issue.

•

What do your data users need that we are not asking?
o Questions have been posed on CAPEX expenditures that are not reported in the data results. This is
useful from a benchmarking standpoint, if you are able to make a comparable estimate based on
firms of the same revenue/employment size.
▪ Again, most of the questions that carry an N response in the data output would be useful to
benchmark against similar firms.
o Questions about R&D expenditures would be helpful.
o Questions about intellectual property value would be helpful.
o Questions about sales and purchases of carbon tax credits would be helpful.
o Cost of duties on imported materials and components would be interesting to see as well.

•

What questions are no longer relevant and could be eliminated?
o There are certain line items that are useless to industry analysts like cost of refuse. However, they
are easy to answer, We may just unaware if there are interested parties for this information.

•

Are certain questions difficult to complete? Why?
o Somewhat. Many of the NAICS 3363 suppliers have diverse revenue streams that are sold outside of
automotive, or outside of manufacturing all together. The composition of revenue detail would be
incredibly time consuming to complete and it seems there could be holes in it, or you could end up
with large gap in information because of lack of space. For example, question 13 only allows for 3
write in industry sectors.

•

Are instructions clear and helpful?
o Yes.

bruce willey 
Mon 8/17/2020 1:10 PM

To: ECON Content

Hi Nick, I’m very sorry this is late, and I hope it can be of use. I was forwarded your email by
Samanthi Martinez, the Executive Director of the Association of Professional Model Makers. I
just now manage to finish my input and get our Board of Directors to provide their input.
Our industry is Model Making Services and that includes Models Design and Fabrication as well as
Developing and Making Prototypes. Model Making Services are mostly done within a company
whose main purpose is something else like product manufacturing, design, architecture,
engineering, film/TV and a few more. They shouldn't be having any problems with the
model making aspect of the questionnaire.
If the Census seeks to capture independent model shops, my input on that is below. Briefly,
Model Shops provide business services similar to Printers, Drafters, Sign-makers etc. If “Model
Making Services” were placed at the same level as those others under the Survey Title “AS5614X - Business Support Services (Enterprise Support)” that would make the Census easier to
complete and would be more accurate.
Your questions:
Do the survey questionnaires and instructions use terms/definitions that are common for your
industry? Yes
Do the survey questionnaires accurately reflect what is occurring in your industry? Yes
What do your data users need that we are not asking? Independent or stand-alone model
shops would want to list their main source of income as “Model Design and Fabrication” and
“Developing and Making Prototypes”.
What questions are no longer relevant and could be eliminated? None
Are certain questions difficult to complete? Why? It would be difficult to find one form that
stand-alone model shops would use.
Are instructions clear and helpful? Yes
Are there any other comments or opinions with regard to your industry? If “Model Making
Services” were placed at the same level as other service providers under the Survey
Title “AS-5614X - Business Support Services (Enterprise Support)” that would make the
Census easier to complete and would be more accurate.
My research:
I checked the pdfs of the Survey Titles that I thought would be relevant to model makers. Three
of them specifically mention “Model Design and Fabrication” and “Developing and Making
Prototypes” as activities under Item 22: Detail of Sales, Shipments, Receipts, or Revenue.
• PS-54140 - Specialized Design Services
• MC-33270 - Machine Shops
• PS-5409X - Specialized Design Services (Enterprise Support)

Other ones I checked and discarded because they didn’t mention models or prototypes are:

AS-5614X - Business Support Services (Enterprise Support)
MC-3399D - All Other Miscellaneous Manufacturing
PS-5404X - Engineering Services (Enterprise Support)
PS-541C3 - Architectural, Engineering, and Related Services, Specialized Design Services, &
Scientific Research and Development Services (Classification)
PS-5413X - Other Professional, Scientific, and Technical Services (Enterprise Support)
PS 5419C - Advertising and Related Services, Photography Services, & Other Professional,
Scientific, and Technical Services (Classification)
My recommendation:
Put a new category “Model Making Services" under the Survey Title AS-5614X - Business
Support Services (Enterprise Support).
Since “Model Design and Fabrication” and “Developing and Making Prototypes” already have
their own separate numbers, they would go under
Item 17: Principal Business or Activity and be repeated under Item 22: Detail of Sales,
Shipments, Receipts, or Revenue just like printers, sign-makers and drafters are.
This would be for independent model shops. Other firms that line-itemed their models and
prototypes would still have to use another Survey Title. Please let me know if I can provide
further assistance.
Thank you.
Bruce

Bruce Willey
503-347-9022
brucewxyz@gmail.com

CSD Director 
Wed 9/16/2020 12:57 AM
To: ECON Content

Greetings,
The date to submit feedback has passed and we are requesting to allow us up to September 24th to
submit.
Our CNMI Statistics Office has been greatly impacted by the pandemic and have lost 50% of it staff we appreciate your understanding.
Justin

AAP Info 

Wed 9/16/2020 4:11 PM
To: ECON Content

Good afternoon Nick Orsini,
Thank you for providing an opportunity for feedback and questions and you work towards developing the 2022
Economic Census survey. I administer AAP’s statistics program and this Economic Census is very helpful to us. Before
providing comments, I will respond to the questions included in the email request. Please contact me with any
follow-up questions or to provide the additional materials requested so that we can complete our analysis.
•

Do the survey questionnaires and instructions use terms/definitions that are common for your industry?
Yes. However, is there a more detailed version of instructions for Book Publishing? The instructions
provided online do not address Items 3, 17, 22, and 28, which are the basis of the comments that follow.

•

Do the survey questionnaires accurately reflect what is occurring in your industry? The survey
questionnaires for Book Publishing do not provide a complete or clear review of the industry.

•

What do your data users need that we are not asking? Please see the comments below.

•

What questions are no longer relevant and could be eliminated? Items 17, 22, and 28 are too limited to be a
complete reflection of the industry.

•

Are certain questions difficult to complete? Why? Items 17, 22, and 28 may be difficult for education and
journal Book Publishers because those markets seem to be excluded.

•

Are instructions clear and helpful? The instructions provided online have limited utility because they do not
address Items 3, 17, 22, and 28.

•

Are there any other comments or opinions with regard to your industry? Yes, see below.

1. Who completes the questionnaire survey? Is it sent to CFOs, heads of HR, other staff?
2. The instructions as for Gross Receipts. We use net revenue for our market analysis reports. How are returns
and operating cost addressed in this questionnaire as operating cost reduces revenues?
3. The instructions do not address Items 3, 17, 22, and 28, which are the basis of the comments that follow.
Can you provide a fuller version of instructions?
4. Form IN-5113-mu
a. Item 3
i. Include a question about the number of imprints or subsidiaries to connect as a
reference point for Form IN-5113-su
b. Item 17
i. Where do journal publishers fit?
ii. Excluding publishing exclusively on the Internet may be a problem for education
publishers that use online, internet-based platforms. Considering the limitations imposed by
the COVID-19 pandemic, could the exclusion of internet be removed or updated?
1. If updating is a possibility, we recommend “Book publishers, including publishing
and printing combined along with online platforms, eBooks, digital audiobooks, and
similar formats.”
iii. What is meant by “internet publisher” and “internet publishing”?
1. Many U.S. publishers sell eBooks that are exclusively on the internet and not
printed. The separation of internet from publishing does not acknowledge that
internet is a channel and tool used by publishers.
c. Item 22 (Selections)
i. Where does journals, audiobooks, eBooks, and platform-based publishing fit?
1. 2 Professional, technical, and scholarly books and journals

2. 2b should be updated to Scholarly books and journals
d. Item 22 (Values)
i. Where does journals, audiobooks, eBooks, and platform-based publishing fit?
1. 2 Professional, technical, and scholarly books and journals
2. 2b should be updated to Scholarly books and journals
3. 14a, b, and c: What are the options?
ii. Is the data (individual or aggregated) collected in Item 22 publicly available? If yes,
where?
iii. Returns – The book publishing industry routinely expects nearly 20% of shipped product
to be returned to publisher for full credit. This is part of the business model of
publishing. How should these returns be treated? Once product is returned a subset is
resold as ‘remainders’. Should that revenue be reported as a deduction in Item 22?
e. Item 28
i. Update 2 to: Internet and online platforms
ii. Update 3 to: Other media, including apps, book and toy sets, CD-ROM/DVD-ROM,
diskette or cassette, microfilm, DVDs, gift sets, multimedia, product bundles, etc.
1. CD-ROM/DVD-Rom is no longer a dominate media. Many publications previously
provided by CD-ROM/DVD-Rom have been updated to internet and online
platforms
iii. Add 4: Downloaded audio
iv. Add 5: Physical audiobooks
v. Add 6: eBooks
vi. Add 7: Instructional Materials
5. Form IN-5113-su
a. Item 17
i. Where do journal publishers fit?
ii. Excluding publishing exclusively on the Internet may be a problem for education
publishers that use online, internet-based platforms. Considering the limitations imposed by
the COVID-19 pandemic, could the exclusion of internet be removed or updated?
1. If updating is a possibility, we recommend “Book publishers, including publishing
and printing combined along with online platforms, eBooks, digital audiobooks, and
similar formats.”
iii. What is meant by “internet publisher” and “internet publishing”?
1. Many U.S. publishers sell eBooks that are exclusively on the internet and not
printed. The separation of internet from publishing does not acknowledge that
internet is a channel and tool used by publishers.
b. Item 22 (Selections)
i. Where does journals, audiobooks, eBooks, and platform-based publishing fit?
1. 2 Professional, technical, and scholarly books and journals
2. 2b should be updated to Scholarly books and journals
3. 14a, b, and c: What are the options?
ii. Is the data (individual or aggregated) collected in Item 22 publicly available? If yes,
where?
c. Item 28
i. Update 2 to: Internet and online platforms
ii. Update 3 to: Other media, including apps, book and toy sets, CD-ROM/DVD-ROM,
diskette or cassette, microfilm, DVDs, gift sets, multimedia, product bundles, etc.

1. CD-ROM/DVD-Rom is no longer a dominate media. Many publications previously
provided by CD-ROM/DVD-Rom have been updated to internet and online
platforms
iii. Add 4: Downloaded audio
iv. Add 5: Physical audiobooks
v. Add 6: eBooks
vi. Add 7: Instructional Materials
1. Education publishers for Prek-12 and higher education industries are also book
publishers. It is not clear whether this survey addresses this market.
d. Item 32 seems a better fit for Form IN-5113-mu or at a minimum should be included in Form IN5113-mu as well.

Sincerely,
Syreeta N. Swann | Vice President, Programs and Administration
AAP | Association of American Publishers | 455 Massachusetts Avenue NW Suite 700 | Washington, DC 20001
1-202-220-4545 (direct) | 1-202-347-3690 (Fax) | info@publishers.org
www.publishers.org

Vai Filiga 
Mon 9/21/2020 4:25 PM
To: ECON Content

Nick,
I am wrapping up the Population and Housing census and I missed the deadline for the economic
census comment period. Any chance of reopening this for comments?
Vai

CSD Director
Thu 9/24/2020 11:05 PM
To: ECON Content
Cc: Fermin Sakisat ; Brieanna Oronigo 

Island Greetings,
Thank you once again for allowing us extra time to review and submit out feedback.
Please see attached document for our feedback.
Regards,
Justin

CENTRAL STATISTICS DIVISION
COMMONWEALTH OF THE NORTHERN MARIANA ISLANDS
P.O. Box 5795 CHRB, Saipan, MP 96950
Tel. (670) 664-3023/45 · Fax (670) 664-3067
http://commerce.gov.mp/divisions/central-statistics/

September 24, 2020
2017 CNMI Economic Census Review Feedback
A review of our field follow-up notes and feedback from stakeholders reveals no major concerns with the 2017
Economic Census of the CNMI. Questions and Instructions for each of the Sectors were clearly worded and
understood.
A few stakeholders had difficulty with the Portal but were assisted by the CSD staff.
All Sectors of the local business are covered in the Census and questions for each of the Sectors are important and
useful.
In future Census, we request to include all Businesses in the Scope of the Economic Census – businesses with and
without employees.
Additionally, we also request that a question on Ethnicity of Ownership be included if possible.
Besides, Gender and Citizenship of Ownership, having more demographic of the local business community helps
with local business planning and policymaking decisions.
The Economic Census is the only source of business data the local government and the local business community
rely on for business planning and policy decision making.

To:

From:
Date:

Bobby Nusz,
Economic Census Assistant Survey
Director Staff Chief
Aya Hamano,
Chief, Program Coordination Office
April 26, 2021

Comments on 2022 ECIA Proposals
Overview
BEA’s largest concerns for the 2022 ECIA are that:
1. Total operating expenses mean the same thing across industries.
2. Respondents know where to report capitalized repairs/improvements, i.e. major repairs or
improvements that increase the value of the equipment or structure that are chargeable to
fixed assets accounts. For GDP, we would prefer that these expenditures be reported within
Capital Expenditures rather than Selected Expenses. For the 2022 ECIA, we are wondering if
there are ways to clarify (e.g. within the instructions) where respondents should include
these expenditures.
More detailed comments/questions by item are included below.

Class of Customer
1. BEA does not use hotels and restaurant class of customer separately, so these could be
combined. We agree that because a lot of the restaurants in the island areas are part of
hotels, the split could be problematic for respondents.
2. The categories “other” and “other services” could be confusing for respondents. BEA would
likely combine the two categories when using the data.

Selected Expenses
1. Within the instructions for “all other operating expenses,” would it make sense to specify
the exclusion of anything included in Item 13 (Capital Expenditures) and also ask to include

routine maintenance and repairs? For example, “Include all the other operating expenses
incurred by the establishment, such as payroll, benefits, utilities, depreciation, computer
and communication services, office supplies, and routine maintenance and repairs. Do not
include capital expenditures included in Item 13, interest, and/or bad debt.”
2. For the Construction form, add a catch-all category for “all other operating expenses” in
case there are items that do not fall under “all other purchased services”. Alternatively,
replace “all other purchased services” with “all other operating expenses” (and eliminate
the sections that separate cost of materials from cost of services).
3. Can Census publish more industries in the selected expense detail table (IA1700SUBJ06)?
For 2017, the table showed Wholesale, Retail, Information, Finance, and Accommodations.
For 2022, can it be published for Utilities and Transportation/warehousing?

Capital Expenditures
1. Suggested capital expenditure instructions for all forms except Manufacturing and
Construction:
ITEM 13: CAPITAL EXPENDITURES
Report expenditures made during 2022 to purchase buildings, structures, and machinery
and equipment that are chargeable to the fixed assets accounts and for which depreciation
accounts are maintained. Include improvements that increased the value of the property or
adapted it for another use (for example, upgrading the heating and air conditioning system,
upgrading kitchen or bathroom facilities, adding universal access improvements, or any
other permanent improvement that would add to the value and useful life of the property).
Also include the cost of buildings or structures and machinery and equipment acquired as
the lessee under capital lease agreements during 2022. Exclude the costs for routine
maintenance and repairs.
2. Suggested capital expenditure instructions for the Manufacturing and Construction forms:
A. Capital expenditures for NEW buildings, structures, machinery and equipment, and jobsite vehicles
Report expenditures made during 2022 to purchase NEW buildings, structures, and
machinery and equipment that are chargeable to the fixed assets accounts and for
which depreciation accounts are maintained. Include additions to construction-inprogress for company-owned projects lasting more than one year, as depreciable assets
should be reported currently rather than once the project has been completed and is in
use. Also include the value of depreciable assets acquired through mergers and
acquisitions. Exclude the costs for routine maintenance and repairs.
Page 2 of 3

B. Capital expenditures for USED buildings, structures, machinery and equipment, and jobsite vehicles
Report expenditures made during 2022 to purchase USED buildings, structures, and
machinery and equipment that are chargeable to the fixed assets accounts and for
which depreciation accounts are maintained. Include improvements that increased the
value of the property or adapted it for another use (for example, upgrading the heating
and air conditioning system, upgrading kitchen or bathroom facilities, adding universal
access improvements, or any other permanent improvement that would add to the
value and useful life of the property). Also include capital expenditures for leasehold
improvements (made to property leased from others). Exclude the costs for routine
maintenance and repairs.

Page 3 of 3

Economic Census of Island Areas Form Comments from BEA for 2022 ECIA
Last updated: February 9, 2021

Summary:
Comments and requested changes are based off a review of the 2017 ECIA forms and are grouped into 7
sections: Class of Customer, Value of Inventories, Construction, Wholesale Trade, Accommodations and Food
Services, Other Form Changes, and Reporting Changes. Reporting Changes were previously requested in
November 2020 but are included here again for convenience.

I. Class of Customer:
1. For the Puerto Rico form for “Other Services,” add the percentage of exports. See the snip below as an
example:

2. The three Manufacturing forms for all the island areas (Puerto Rico, American Samoa, and Selected U.S.
Territories) need to be modified to correct an inconsistency in Item 28: Special Inquiries. Section B of Item
28 asks for the distribution of the value of shipments or contract work for customers located within the
territory. However, the two box headings indicate that the value is reported in Item 5, line A and B
respectively. This is not correct, because Item 5 provides the value of shipments including exports. The box
headings in Item 28B should indicate that the value is reported in Item 28A, line 3. See the snip below for
the current wording:

3. Add “Accommodation and food services” as a class-of-customer item to all the Manufacturing forms (Puerto
Rico, American Samoa, and Selected U.S. Territories).
4. Add “Municipal government” as a class-of-customer item to the Manufacturing form for Puerto Rico.
5. Update “Building contractors, heavy construction, and special contractors” to “Construction contractors” for
all forms for Puerto Rico.
1

6. Update “Restaurants, hotels, food services, and contract feeding” to “Accommodation and food services”
for all forms for Puerto Rico.
7. Update “Restaurants, food services, and nightclubs” to “Food services and drinking places” for all forms for
American Samoa and Selected U.S. Territories.
8. Update “Hotels or other traveler accommodations” to “Accommodation” for all forms for American Samoa
and Selected U.S. Territories.
9. Update “Retailers” to “Retailers for resale” and “Wholesalers” to “Wholesalers for resale” on all three of the
Manufacturing forms.

II. Value of Inventories
1. The table below describes, by industry, requested changes to the form questions for Inventories.

Industry Sector

Change
requested from
2017 form (Y/N)

Description of change

Manufacturing

N

None. Question should remain as is.

Wholesale trade

N

None. Question should remain as is.

Retail trade

N

None. Question should remain as is.

Finance, Insurance, Real Estate,
Rental and Leasing

Y

Add an item for the value of total inventories owned by
the establishment (i.e. no breakout by type)

Accommodation and Food Services

Y

Add an item for the value of total inventories owned by
the establishment (i.e. no breakout by type)

Y

Add an item for the value of total inventories owned by
the establishment (i.e. no breakout by type)

Construction

Y

Add an item for the value of inventories owned by the
establishment for inventories for materials and supplies.
(Exclude work-in-progress and finished units.) See
Example A on next page.

Other Services

Y

Add an item for the value of total inventories owned by
the establishment (i.e. no breakout by type)

Utilities, Transportation, and
Warehousing

2

Example A:

III. Construction
1. Add a line for “All other operating expenses” to item 16 “Selected expenses.” See the snip below as an
example:

IV. Wholesale Trade
1. Add an item for “Shipping and Handling” similar to that on the U.S. forms. See the snip below as an
example:

3

V. Accommodation and Food Services
1. Add a line for “Contract Feeding” to Item 28: Special Inquiries. See the snip below as an example:

VI. Other Form Changes
1. Add “Mining” to name of the form “Utilities, Transportation, and Warehousing,” at least for Puerto Rico.
2. Edit form instructions for Utilities and Manufacturing to state that non-operating income such as interest
should be excluded.

VII. Reporting Changes
Requested change

Industry

Territories Notes

Report cost of resales for
manufacturing sector

Manufacturing

AS, NM,
GU, VI

Currently published for retail and wholesale only for
4 smaller territories. Published for retail, wholesale,
and manufacturing for Puerto Rico.

Report inventories by stage
of fabrication for the
manufacturing sector

Manufacturing

AS, NM,
GU, VI

If it is not possible to publish this, would it be
possible to create a special tab of this for AS and VI?

All

This is at most a reporting change only for
industries that in 2017 have interest included in
total reported OPEX. No change in form or
instructions is needed.

All

This is only if interest receipts are collected. Our
goal is to exclude them from
receipts/sales/shipments when we use them in
estimates of gross output.

All

This is at most a reporting change only. No change
in form or instructions is needed.

Exclude interest from total
operating expenses for all
industries except FIRE
Report interest receipts (if
collected) in a separate
column for all industries
except FIRE
Report interest expenses in
a separate column for all
industries except FIRE

All except FIRE

All except FIRE

All except FIRE

4