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

Attachment H
Department of Commerce
United States Census Bureau
OMB Information Collection Request
2017 Economic Census
OMB Control Number 0607-XXXX
Consultations with Federal Agencies, Trade Groups, Corporations, and Consulting Firms:
Selected Correspondence

From: Richard Kowalski
Sent: Friday, October 30, 2015 2:14 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Cc: info@ce.org
Subject: Review of 2017 Economic Census questionnaires
Dear Jack Moody,
I am writing you in regards to your letter to Gary Shapiro, President and CEO of the Consumer
Electronics Association, and in regards to the 2017 Economic Census Notice Of Determination And
Request For Comment.
Focusing on your question “What do your data users need that we are not asking?” the
recommendations of the Consumer Electronics Association are as follows. Almost all of these apply to
question 22 of the survey, and represent emerging categories of interest in the consumer electronics
industry.
MC-33371 [PDF]
Special Dies, Tools, Jigs, Fixtures and Mold Manufacturing
• Add 3D printers (aka additive manufacturing) – devices that can make a three dimensional
solid object from a digital model. Used in manufacturing / design settings for prototyping,
but becoming popular in the consumer space. They may also go under Computing and
Office Machines with other printers or peripherals.
MC-33313 [PDF]
Photographic Equipment and Supplies
• Add action camcorders/wearable cameras such as the Go Pro.
MC-33401 [PDF]
Computing and Office Machines
• Add 3D printers (aka additive manufacturing) if they do not fit in elsewhere.
MC-33403 [PDF]
Radio Receivers and Television Sets and Related Equipment
• Would be nice to see more itemization of products in 22.15 if possible.
MC-33407 [PDF]
Clocks, Watches, and Watchcases
• Add smart watches, defined as watches that pair with a mobile device such as a computer
or phone to receive and display information and calls.
MC-33503 [PDF]
Household Appliances
• Add domestic robots used for household chores such as the iRobot Roomba or Ecovacs
Winbot.
MC-33601 [PDF]
Motor Vehicles and Passenger Car Bodies
• Add self-driving vehicles.
MC-33609 [PDF]
Aircraft Industries
• Add unmanned aerial vehicles (UAV) (aka ‘drones’) for civilian use. Examples: 3D Robotics
Solo, DJI Phantom.
MC-33908 [PDF]
Toys, Games, Dolls, and Children's Vehicles, Exc. Bicycles
• Add virtual reality / augmented reality glasses like Oculus VR and Vuzix M100 (these may fit
under question 22.7).
MC-33973 [PDF]
Sporting and Athletic Goods
• Add health and fitness tracking devices such as Fitbit and Jawbone products (aka fitness
bands, wearables).
RT-44103 [PDF] Automotive Parts, Accessories, and Tire Stores
• It would be nice to know which of these stores either sell audio/video equipment for cars
and/or whether they offer installation services.
Thank you for your consideration

From: Frauenheim, Steve
Sent: Saturday, October 31, 2015 11:21 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: 2017 Economic Census
Dear Mr. Moody,
Thank you for allowing the Edison Electric Institute (EEI) the opportunity to provide feedback on the
2017 Economic Census.
Henri Bartholomot of EEI General Counsel and I have reviewed the Utilities Sector Consolidated Report
Forms and we do not have any proposed changes to the form at this time.
Sincerely,
Steve Frauenheim
Manager, Business Information Group
Edison Electric Institute
sfrauenheim@eei.org
202-508-5580
From: McConnell, Anne
Sent: Friday, October 30, 2015 3:48 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Cc: McConnell, Anne
Subject: Economic Census 2017
Your letter to Carter Keithley regarding the Economic Census has been forwarded to me. In reviewing
form MC-33908, the Toy Industry Association (TIA) is providing the following feedback.
With respect to section 22, below are the general toy categories that more closely represent and are
tracked by the traditional toy industry.












Action Figures/Accessories/Role Play
Arts & Crafts
Building Sets
Dolls & Accessories (includes doll clothes, doll houses, doll furniture, doll carriages and
other accessories)
Games & Puzzles (does not include video games and consoles)
Infant / Preschool
Youth Electronics (designed for children, includes robotic toys)
Outdoor & sports toys
Plush
Toy vehicles (powered and non powered)
Other

Note: Video Games & Consoles, Pet Toys and General Book Printing and Binding are not captured as
part of the traditional toy industry.
In addition, we recommend you include a line item for royalties/license fee income. Licensed toys
represented about 30% of toys sold in 2014 (according The NPD Group). They are increasingly popular
given blockbuster movies.
For your record, Carter Keithley retired from the Toy Industry Association in May, 2015. He is
succeeded by Stephen Pasierb as President and CEO.
Please let me know if you have any questions.
Anne McConnell
Senior Director, Market Research & Data Strategy
Toy Industry Association, Inc.
1115 Broadway, Suite 400
New York, NY 10010
email:amcconnell@toyassociation.org
Tel: 646-520-4870
Fax: 212-633-1429

From: Clay Jones
Sent: Friday, October 30, 2015 10:18 AM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: 2017 Economic Census
To: Jack Moody, Assistant Survey Director, Economic Census, U.S. Census Bureau
Dear Mr. Moody,
Thank you for sending the census survey to our office. It was addressed to our President, G.L. Bowen,
but I am the Vice President and General Counsel and have been in charge of reviewing the
information. The forms that would applicable to the members of our association (from 2012) appear to
be pretty thorough. I know you will be making some updates for the 2017 census.
I really only had one comment based on my review: we represent the flooring industry in Georgia as
part of our Association. I reviewed several forms including the “carpet and rugs” form. Perhaps this
information is captured somewhere else in another survey form, and if so, please disregard the
comment. However, while there were references to all types of carpets and rugs (including modular
carpet tiles), I didn’t see references to all types of flooring materials, including hard surfaces. For
example, solid wood, engineered wood, laminate, vinyl, linoleum, ceramic – these types of flooring have
really become part of what is sold by what we used to refer to as “the carpet industry” – we really call it
the flooring industry now because of the diversity of soft and hard flooring surfaces they sell.

Again, you may have included this terminology in another form but I thought you should know that
many in the industry have expanded their product offerings as I’ve described.
If you have any questions, please don’t hesitate to contact me. Good luck with the census!
Best regards,
Clay Jones
Charles B. Jones, III ("Clay")
Georgia Association of Manufacturers
The Hurt Building
50 Hurt Plaza, Suite 985
Atlanta, Georgia 30303
404-688-0555
404-584-0720 (fax)
cjones@gamfg.org
From: Robert Roche
Sent: Wednesday, October 28, 2015 10:24 AM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: 2017 Economic Census Questionnaire
Jack B. Moody
Assistant Survey Director, Economic Census
Economy-Wide Statistics Division
U.S. Census Bureau
Dear Mr. Moody,
Thank you for asking CTIA-The Wireless Association® for comments regarding the content of the 2017
Economic Census questionnaire. CTIA’s CEO, Meredith Attwell Baker, asked me to respond on her
behalf. As requested, I reviewed the previous Census form, specifically OS-81302, “Civic, Social, and
Other Membership Organizations,” as it applies to Business Associations.
After reviewing the questionnaire and the information sheet that provides guidance for completing the
form, I concluded that the form (1) uses terms and definitions that are generally clear and appropriate;
(2) includes the principal questions that are applicable to CTIA; and (3) the instructions provide sufficient
explanation to make possible completion of the requested form.
No additional questions seem necessary to capture the relevant data.
If you have any questions, or require a further response, please do not hesitate to contact me at (202)
736-3255, or rroche@ctia.org.
Again, thank you for requesting CTIA’s input with respect to the 2017 Economic Census.

Robert F. Roche, Ph.D.
Vice President, Research
CTIA-The Wireless Association®
Expanding the Wireless Frontier™
1400 16th Street, NW Suite 600
Washington, DC 20036
http://www.ctia.org
Direct: 202.736.3255 Main: 202.785.0081
Wireless: 202.674.1713 Fax: 202.736.3688
From: Diane Mirowski
Sent: Monday, October 19, 2015 11:08 AM
To: EWD EC17 Association (CENSUS/ OTHER)
Cc: carol; Mary Vigiano
Subject: Survey Response re 2017 Economic Census Questionnaires (EC-G-LGA)
Dear Mr. Jack Moody:
October 27, 2015
Per your request of Nancy Somerville, executive vice president and CEO of the American Society of
Landscape Architects, below are suggestions to clarify form PS-54103, 2012 Economic Census for
Architectural and Landscape Architectural Services, in anticipation of the next census.
We would also like to receive, if possible, all of the results of the 2012 census for this category to better
assess the state of the landscape architecture profession among other like services.
Thank you.
P. 3, Question 19
Box 541 310 00 9, expand to clarify:
2012: Landscape architectural and design services, excluding maintenance and installation.”
SUGGESTED REVISION: “Landscape Architecture and design services, including parks, plazas, campuses,
and residences, but excluding maintenance and installation.”
19.Sports facility design is becoming increasingly specialized. It might be appropriate to include a
category for “sports facilities.”
Parks have been grouped with airports and highways. Parks merit its own category and the other is best
described as “transportation facilities including airports and highways.”
Box 541 320 00 6, suggested edits
2012: “Land use planning and design services, including parks, airports, and highways.
SUGGESTED REVISION: “Land use planning and services, including infrastructure, airports, and
highways.”
Box 54`1 320 00 6, expand to clarify
2012: “Landscape consulting services.”

SUGGESTED REVISION: “Landscape consulting services (include expert witness services).”
Box 541 320 00 B, expand to clarify
2012: “Garden design services”
SUGGESTED REVISION: “Garden design and/or horticultural services”
P. 4, Question 20
Option 5, add to clarify
2012: “All other business firm and organizations (manufacturing, utilities, mining, shopping centers,
office buildings, etc.).”
SUGGESTED REVISION: “All other business firm and organizations (hospitality/resorts, manufacturing,
utilities, mining, shopping centers, office buildings, etc.).”
P. 5, Question 21
This question needs to be clarified, but we cannot figure out what it is you are trying to determine to
suggest any revisions.
P. 6, Question 22
22.2b(2): “Sports facilities” should be separate from hotels and convention centers and should
incorporate stadiums, and possibly arenas.
Line 2c(2), mixed projects may provide misleading results; we suggest breaking this up, adding a new
line item.
2012: “Report receipts from landscape architecture services that consist of a complete project or phase
of a project for recreation or open space projects where activity is not enclosed in a building. Include
fields for football, soccer, baseball; golf courses; ski areas, restoration of wetlands or other natural
areas; and services for parks, greenways or trails. ….”
SUGGESTED REVISIONS:
1) Eliminate restoration options: Report receipts from landscape architecture services that consist of a
complete project or phase of a project for recreation or open space projects where activity is not
enclosed in a building. Include fields for football, soccer, baseball; golf courses; ski areas; restoration of
wetlands or other natural areas; and services for parks, greenways or trails. ….”
2) Add new line item: “Report receipts from landscape architecture services from restoration of
wetlands, rehabilitation of brownfields, and other ecological services.”
Add 22.2d Landscape architectural services for “Environmental Impact Assessments.” Visual and
recreational analysis is a significant portion of work for many landscape architecture offices.
Suggestion for a new question to consider adding:
What was your firm’s ROI for the last fiscal year? (Return on Investment)
This could be summarized by size of firm. Based upon current questions, revenues could be increasing in
firms, but the ROI may not be increasing. The true measure of economic health of landscape
architectural firm or any type of company is the ROI, or ROI times the revenue.

From: kenneth O'Brien
Sent: Thursday, October 22, 2015 7:21 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Cc: Sara Mayes
Subject: Comments
Att: Mr. Jack Moody
Following up on your letter to our President / CEO. Sara Mayes, we have reviewed the forms (
TW48801 TW 48360) and have no further suggestions at this time.
The forms are clear, questions readily answerable and the direction sections clear to the user.
Thanks for including us in the survey.
Best Regards
Ken
Kennneth O’Brien
Chief Operating Officer
Gemini Shippers Association/
Fashion Accessories Shippers Association
137 W. 25th Street, 3rd Floor, New York, NY 10001
(212) 947-3424 Office
(201) 696-2119 Cell
www.geminishippers.com
From: Frederick Lawrence
Sent: Wednesday, October 21, 2015 10:37 AM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: Forms
Dear Sir,
The forms for E&P look ok to me. I have circulated to my colleagues and we have not found anything
that needs correction as of yet.
I believe that the questionnaires and instructions are accurate and relevant to the current state of the
industry.
I am travelling but will get back to you if I find anything that needs to be added.
Best,
Fred
_________________________________
Frederick J. Lawrence
IPAA
Vice President of Economics & International Affairs
(202) 857 4722

From: Susan Chesniak
Sent: Tuesday, October 20, 2015 4:37 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Cc: chesniak@mail.mlahq.org
Subject: 2017 Survey Questionnaire
To Whom it may Concern:
Per your request, below please find comments on existing survey inquiries:
1)

2)

3)
4)
5)
6)
7)

The survey does not use terms/definitions common in our industry (Professional Member
Based Association). In fact, we were unable to find a “Form” that specifically related to
Professional Associations. The closest category for comparison was “Professional, Scientific,
and Technical Services”.
Does not accurately reflect what is occurring in our industry. No questions relating to nonprofit Professional Associations. Question 16 “Selected Expenses” -- no line items accurately
reflect our expenses. Question 19 “Kind of Business Activity” should include Professional
Associations. Question 22 “Detail of Sales, Shipments, Receipts or Revenue” – no line item
accurately reflects our revenues
Users need data on membership statistics, dues, revenue and expense line items that
reflect activity of member based organizations. For example, data on Membership Dues,
Continuing Education, Publications, etc.
Did not find any questions to be no longer relevant. Majority of questions were not
applicable to our organization
Question were only difficult to complete in that majority were inapplicable to our
organization.
Instructions were relatively clear.
As noted above, it would be helpful if the Census was more inclusive of member based
professional associations/organizations.

For your reference, attached please find a pdf of the original letter requesting above information.
Kind regards,
Susan Chesniak
From: Donald Santa
Sent: Tuesday, October 20, 2015 11:33 AM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: Survey on economic census
I’ve received a letter from you requesting comment on the previous forms used for the economic
census. To my knowledge, the Interstate Natural Gas Association of America has not completed these
forms in the past, so we have no basis on which to provide comments that might be used in updating
the forms.

Thank you for soliciting our input.
Donald F. Santa
President and CEO
Interstate Natural Gas Association of America
From: Christopher Runyan
Sent: Tuesday, September 22, 2015 4:23 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: Comments on Census Form #CC-23701
Dear Sir/Madame,
The Ohio Contractors Association represents contractors in the heavy/highway in the State of Ohio. I
have reviewed Census Form #CC-23701 and provide the following comment:
Utilization of prime and subcontracting firms that have a Disadvantage Business Enterprise (DBE)
certification is a major issue here in Ohio and around the nation. To better understand and define the
use of DBE firms, I suggest making the following inquiries:
Are you a certified Disadvantaged Business Enterprise firm?
If so, what percentage of total work that you performed in calendar year XXXX was
credited as DBE-eligible by either your firm as a prime contractor or by a prime contractor
when you firm provided subcontracted services?
 What North American Industry Classification System Code(s) have been assigned to your
firm?



Thank you for the opportunity to comment.
Respectfully yours,
Christopher L. Runyan, P.E.
President
crunyan@ohiocontractors.org

From: Diane Mirowski
Sent: Monday, October 19, 2015 11:08 AM
To: EWD EC17 Association (CENSUS/ OTHER)
Cc: carol; Mary Vigiano
Subject: Survey Response re 2017 Economic Census Questionnaires (EC-G-LGA)
Dear Mr. Jack Moody:
I am responding on behalf of Ms. Carol Lombardini, President, Alliance of Motion Picture and Television
Producers, to your letter, received on October 5, 2015, regarding comments on the usefulness of
existing inquiries for inclusion in the 2017 Economic Census questionnaires. We have reviewed the 2012

Census Form for Independent Artists, Writers, and Performers (Form No. AE-71105) and Classification
Form (Form AE-71191). Please find below our responses in bold-face font to your survey questions.
(1) Do the survey questionnaires and instructions use terms/definitions that are common for your
industry? Yes.
(2) Does the questionnaire accurately reflect what is occurring in your industry? Yes.
(3) What do your data users need that we are not asking? Operating costs other than payroll. The
Census form requests information regarding the cost of payroll and employment and the total
receipts received in connection with business activities. Without information as to other operating
costs associated with business activities, the overall economic picture is incomplete.
(4) What questions are no longer relevant and could be eliminated? None.
(5) Are certain questions difficult to complete? Why? No.
(6) Are instructions clear and helpful? The instructions at the beginning of the form states that the
reporting unit is for an establishment, defined as "a single physical location where business is
conducted or where services or industrial operations are performed." Motion picture (feature film
and television) production is not limited to a single physical location. By limiting the reporting unit for
the form to a single physical location, a large portion of motion picture production would be excluded.
(7) Are there any other comments or opinions with regard to your industry questionnaire? No.
Best,
Diane P. Mirowski
Vice President, Research and Labor Economics
Alliance of Motion Picture and Television Producers
15301 Ventura Blvd., Bldg. E, Sherman Oaks, CA 91403
direct 818.935.5966 | fax 818.285.4450
From: ron@giuntinicompany.com
Sent: Monday, October 12, 2015 3:32 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: Comment on form OS-81103 Commercial, Industrial, and Electronic Equipment Repair and
Maintenance services
I was requested to comment on the improvement of the subject form.
This area of the census is deeply flawed. I have worked in the area of
industrial repair/maintenance for 35 years. I have been engaged by the
US Int. Trade Commission to assist them in harmonizing many of the
terms in this area.
You are understating the activity in this area materially. Employee
wise there are at least 50-75% more individuals involved and the

revenues in this area are an estimated $300 billion/year.
Much of the economic activity in this sector is supplied by the
product support/aftermarket enterprises of machine builders and their
key suppliers/manufacturers; I suspect that this fact is not captured
in this sector. Also 30-50% of all light vehicles sold are classified
as fixed asset as short-term rental, operating lease of company
fleets. The maintenance of these vehicles should be in the industrial
sector not motor vehicle.
Also note that the military employs much commercial products and their
products are managed/maintained by service organizations.
I believe that our government can do a much better job of reporting
this space. The investment community, government policy makers and
many others would benefit from a fresh approach at collecting data for
this area.
Do not hesitate to contact me if you have any questions.
Regards,
Ron Giuntini
Practice Leader, Business Case Development for Commercial and Military
Product Support/Aftermarket Solutions
Giuntini & Co.
570.713.4795
ron@giuntinicompany.com
www.giuntinicompany.com
From: Steven Pedracine
Sent: Wednesday, October 7, 2015 4:12 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: 2012forms/CC23803
Census Bureau,
This is in review of the captioned form.
The Minnesota Lath and Plaster Bureau is recognized as an education and technical spokesman for the
lath and plaster industry. It provides services to architects, the construction community and the public
on a variety of matters relating to the plaster trades. We are here specifically to promote plastering on
behalf of the signatory union plastering contractors of the Twin Cities.
The form captioned above does not pertain to the relevance of the Minnesota Lath and Plaster Bureau
as we do not engage in lathing and plastering work, but as an ancillary entity.
The only issue I have found that may be of interest to your questionaire is that in item 22 you segregate

"plastering, lathing, or fresco contractor" from "stucco contractor." Both plastering and stuccoing are
crafts within the same trade. I would not even consider "fresco" as part of plastering because it is more
an art than a craft within the plastering trade. Other crafts within "plastering" include: veneer plaster,
venetian plaster, fire proofing, ornamental plaster and exterior insulation finish systems.
Sincerely,
Steven Pedracine
Steven Pedracine CSI, CDT, CEI
Minnesota Lath & Plaster Bureau
Executive Director
10600 University Ave. NW, Suite 3
Coon Rapids, MN 55448
phone: (763) 757-MLPB (6572)
cell: (612) 708-2444
e-mail: steve@mnlath-plaster.com
www.mnlath-plaster.com
From: Magi Plis
Sent: Wednesday, October 7, 2015 4:04 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: Review of Previous Census Forms, Inter-Industry Conference on Auto Collision Repair
Good afternoon,
Per the US Census Bureau’s request, please see the below comments to the 2012 Educational Services
Form (ED-61101). Below is the link of the 2012 survey reviewed for our industry.
https://bhs.econ.census.gov/2012forms/ED61101.pdf
INFORMATION COPY TO REPORT DO NOT USE
bhs.econ.census.gov
Form ED-61101 (11-16-2011) Page 2 CONTINUE ON PAGE 3 61101028 2 PHYSICAL LOCATION Continued (Mark "X" only ONE box.) B. Is this establishment physically located ...
Do the survey questionnaires and instructions use terms/definitions that are common for you
industry? – YES
Does the questionnaire accurately reflect what is occurring in your industry? – YES
What do your data users need that we are not asking? – N/A
What questions are no longer relevant and could be eliminated? – NONE
Are certain questions difficult to complete? Why? – YES, #7 Employment and Payroll, Letter A.
Number of employees for period including March 12. Do they mean the pay period up to March 12,
2015 or just in March 2015?
Are instructions clear and helpful? – YES

Are there any other comments or opinions with regard to your industry questionnaire? – NO
Should you have any questions or need additional information please contact me at 847-463-5229.
Kind Regards,
Magi Plis
From: John J. Kelly
Sent: Thursday, October 1, 2015 3:02 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: US Census Bureau Survey
Dear Sirs:
As requested in your recent letter, my comments are as follows:
• I find that the information and layout contained in Form OS-81302 is much more useful and relevant
than the information and layout contained in Form SA-81300E which is the form we typically receive and
are asked to submit.
• In Form SA-81300E the issues are as follows:
Sales, Receipts or Revenue
• It may be useful to separate out membership dues or specify that this is considered part of program
revenue as this can be a major income source
E-Commerce
• Many organization now get a majority of their revenue via internet/web transactions. This is not
typically tracked separately so being able to report an accurate amount separately is challenging.
John J. Kelly
President
JEDEC
From: Jackie Leach
Sent: Monday, September 28, 2015 12:12 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Cc: Mike Kane
Subject: Economic Census Questionnaire
Good Afternoon Jack:
I reviewed the census forms applicable to Western Region and the questions appear to be relevant and
appropriate to Western’s business.
Regards,
Jacquelyne Leach
Comptroller

Western Regional Off-Track Betting Corporation
8315 Park Road
Batavia , New York 14020
work: 585 343-3750 x221
fax: 585 343-6873
email: jleach@westernotb.com
From: Calvin Schnure
Sent: Friday, September 25, 2015 1:06 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Cc: Mike Grupe
Subject: NAREIT response to U.S. Dept of Commerce letter on Economic Census for REITs
Dear Sirs,
This email is in response to the letter from Jack B. Moody to Steven Wechsler, President and CEO of
NAREIT, regarding the 2017 Economic Census questionnaires.
NAREIT®, the National Association of Real Estate Investment Trusts®, is the worldwide representative
voice for REITs and publicly traded real estate companies with an interest in U.S. real estate and capital
markets. We represent a large and diverse industry including both equity REITs, which own commercial
properties, and mortgage REITs, which invest in mortgage securities, both residential and commercial.
NAREIT has reviewed the questionnaires for the 2017 Economic Census per the letter from Mr. Moody,
which requested comment on the sections applicable to REITs.
Overall, we find that the forms and instructions for Equity REITs are clear and are relevant. The forms for
Mortgage REITs, however, are less clear, and do not appear to have questions covering commercial
mortgages.
Equity REITs

Equity REITs are clearly identified in the FAQ for “RE-53160 Real Estate Lessors”;

Equity REITs should file form RE-53190, “Real Estate Lessors Classification” and also form
RE-53160, “Real Estate Lessors”;

Equity REITs of several types (including apartment, office, hotel, senior housing,
industrial, shopping malls) are clearly identified in the form; and

The form RE-53160 requests information on relevant concepts for Equity REITs: gross
rents, and sales of real property or buildings, and also employment and payroll.
Mortgage REITs
The forms for Mortgage REITs, however, are somewhat more difficult to identify:

The FAQ under Real Estate notes that mortgage REITs would be classified under Sector
52, Finance and Insurance.

The instructions for Finance and Insurance sector, however, are somewhat unclear as
they do not specify mortgage REITs as a type of firm in this sector. Our understanding of the
NAICS classification scheme indicates that mortgage REITs fall under 525: Funds, Trusts and
Other Financial Vehicles; 525990: Other Financial Vehicles. We could not locate this option

on the menu included in the questionnaire. The closest category that we could find was
“Nondepository Credit Intermediation”.

Form FI-52205 is required for Finance and Insurance, Nondepository Credit
Intermediation. There is no option for “Mortgage REIT” under “Kind of business” (question
19). Presumably, mREITs would select the first option, which is “Mortgage banker,
mortgage company, or loan correspondent” or perhaps “Nonfederal secondary market
firm”, or perhaps “Other nondepository credit—specify: ”

The form should specify whether the mortgage REIT is primarily involved in lending to
support residential real estate or commercial real estate;

The items requested for this category identify interest income from residential
mortgages. There is no category for commercial mortgages.
Please feel free to contact me is you have further questions about our comments.
Best regards,
Calvin Schnure
Senior Vice President, Research & Economic Analysis
NAREIT
202-739-9434
From: Scott Williamson
Sent: Monday, September 21, 2015 9:33 AM
To: EWD EC17 Association (CENSUS/ OTHER)
Cc: Joseph Sieverling
Subject: 2017 Economic Census Questionnaire
Thank you for the opportunity to comment on the questionnaire. My comments are applicable to the
P&C insurance industry only.
Form FI-52451 Question 19
Reinsurance Carriers 0701-524 130 00 4: I recommend striking “and liability”. This is redundant with
“and casualty” in the previous item (0701-524 130 00 5) and could create confusion. If the purpose of
survey item is to measure mono-line and or financial reinsurance, it may be appropriate to ask for
financial guaranty and mortgage guaranty in addition to surety and fidelity.
Form FI-52451 Question 26
26 Special Inquiries A-Direct Losses Incurred and Administrative Expenses Activity 8 Property and
Casualty Reinsurance: There are no direct losses with respect to reinsurance--there can only be
assumed, ceded or net losses. I recommend either changing the heading for Question A to say “Gross
Losses” instead of “Direct Losses” or delete activity 8. For this same reason, it may be appropriate to
delete “including reinsurance” from Activity 10 (All other activities”.

26 Special Inquiries B-Direct Premiums Earned: There are other types of property and casualty lines of
business than the 7 types listed. I recommend including an item for “all other direct premiums earned”
so that the Total for item 8 reflects all direct premiums earned by the filer.
Note that both 26 A and 26 B are for Direct insurance. However only 26 A includes items for
reinsurance. 26 A and 26 B should be more closely coordinated, and it should be clarified whether the
reporting basis is Gross (direct plus assumed reinsurance) or Direct.
Please contact me if you have any questions concerning these comments,
Best regards,
W. Scott Williamson, MBA, ARe
Vice President &
Director of Financial Analytics
202.783.8311
From: Jeff Kurowski
Sent: Friday, September 18, 2015 4:05 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: comments from RVDA
September 18, 2015
To:

Jack B. Moody, Assistant Survey Director, Economic Census

From: Jeff Kurowski, Director of Industry Relations, RVDA
Thank you for providing the opportunity to offer suggestions for improving the 2017 Economic
Census. RVDA uses Economic Census data to update members and the RV industry on the economic
impact of RV retailing across the country. It is a valuable resource for the national RV dealers
association and state RV associations. It is within the RV rental sector where RVDA believes the next
economic census can be improved.
Specific Comments to Improve the Survey:
In the 2012 Economic Census, the rental of recreation vehicles (RVs) was tracked under two products
and services codes: Truck, utility trailer and RV rental and leasing (Code 52520), and Rental or lease of
recreation vehicles (Code 29922). Where RVDA believes the improvement can be made is by separating
RV rental and leasing from Code 52520.
My understanding is Code 29922 includes the retailers whose primary business is selling RVs, with RV
rentals being one of several different auxilary sources of revenue. Meanwhile, Code 52520 includes
businesses primarily involved in renting RVs and/or utility trailers or trucks. I know from checking their
websites that the national, multi-location RV rental businesses only rent RVs. They also sell to retail
buyers, as a side business, the RVs that were used by customers during several rental seasons, but they

do not rent or sell utility trailers or trucks. Also, there are several single location companies primarily
involved in renting RVs, but not renting utility trailers or trucks. Consequently, it appears the businesses
involved in renting RVs can be separated from those renting trucks and/or utility trailers.
But would the sample size be too small? According to the 2012 Economic Census, RV dealers rented RVs
from 300 locations (establishments) for total revenue of almost $1.7 billion, while the companies renting
trucks, utility trailers and RVs operated from 1,104 locations for total revenue of almost $3.8 billion. I
cannot say this with certainty, but those numbers suggest the volume done by the companies whose
primary business is RV rentals is large enough to be tracked as a separate business within the rental
sector.
RV rentals is a segment of the RV industry that is growing in importance, and separating RV rentals from
the rental of trucks and utility trailers would provide more precise data, and would allow RVDA to better
follow trends within that sector.
Again, thank you for the opportunity to comment on the Economic Census. Please contact me directly
at (703) 591-7130 (x 121) or jkurowski@rvda.org if you have any questions.
From: Glenn B. Gastwirth, DPM
Sent: Thursday, September 10, 2015 4:02 PM
To: EWD EC17 Association (CENSUS/ OTHER)
Subject: comments regarding 2017 Economic Census Questionnaire
The American Podiatric Medical Association (APMA) appreciates the opportunity to comment on the
content that will be used in the 2017 Economic Census questionnaires. Using the 2012 Economic Census
questionnaire, we would like to make the following suggestions:
1. Question #19 Kind of Business or Activity (page 3), “Physician services ( include physicians with the
degree of M.D. or D.O.)” should include DPMs. Podiatrists universally provide physician services to their
patients. DPMs receive compensation from the Medicare program through the Medicare Physician Fee
Schedule. DPM services are universally reported using CPT codes “…the most widely accepted medical
nomenclature used to report medical procedures and services under public and private health insurance
programs.”
2. Question #22 Detail of Sales, Shipment, Receipts or Revenue (page 5). All references to ICD-9 codes
should be changed to ICD-10 codes.
3. Question #26 Personnel by Occupation. Question # 1 should be changed as follows: Doctors/
Allopathic Physicians-licensed practitioners having M.D. degree.
APMA will be happy to assist the US Department of Commerce in achieving a high response rate from
podiatrists if you give us advance notice of the release of the census questionnaires.
Glenn B. Gastwirth, DPM
Executive Director and CEO
American Podiatric Medical Association
9312 Old Georgetown Road
Bethesda, Maryland 20814
301-581-9250

Mr. Jack B. Moody
Assistant Survey Director, Economic Census
U.S. Census Bureau

Washington, DC 20233-0001
Dear Mr. Moody:

Thank you for the opportunity to review the 2012 Economic Census forms. After our
review, we have these comments and suggestions for the 2017 form:
FORM AE-71303
1) In Section 19 - Kind of Business or Activity
a. Remove “exhibitions” from Amusement parks, exhibitions and other
attractions. It does not make sense in this context.
b. The description for 713 120 002 should include bowling as in “go-kart
track, bowling, etc.”
c. We feel 713 120 00 5 (Family fun center, children’s entertainment, or
children’s party center) is very vague and should be combined with 713
120 002
d. The description for 713 110 20 1 should be changed to “Amusement
park or theme park which could include a water park and/or kiddie
park
e. The description for 713 990 80 E should include these new attraction
categories in the examples to be more comprehensive: inflatables,
ziplines, trampoline center, bowling center.
f. For 777 713 01 1, the descriptions should be “other parks or
attractions.”
g. For the coin machine operator, it needs to be noted that machines
often take dollars, an issued card, debit cards and/or credit cards.
2) In Section 22 - DETAIL OF SALES, SHIPMENTS, RECEIPTS, OR REVENUE –
Continued
a. For description 3., it should read “carnival games” as rides are covered
in description 4
b. It is suggested that description 6. be split into two: “Other amusement
park and arcade rides, and attractions” and “Other games.”
c. For description 12.a. add “online” as a media option
d. For description 14.b. add an example of other such as wheelchair,
strollers, lockers, etc.

e. Description 16 for “Rental of coin-operated amusement
machines” is a little confusing. Is this rental of the coinoperated machine to another business or a consumer?

FORM AE-71302
1) In Section 19 - Kind of Business or Activity
a. There are several descriptions in AE-71303 that overlap with this form. For
example, 713 120 001 “Arcade or video game arcade,” 713 120 002 “Family
entertainment center…,” and 713 990 80 E “Single amusement attraction…”
i. Is it the intention of Census, to have them in both categories knowing
they may get the wrong form? If so, is the data combined correctly when
reporting the results?
ii. It seems less confusing to pull 713 120 001, 713 120 002 and 713 990 80
E from AE-71302 and have them only in AE-71303.
2) In Section 22 - DETAIL OF SALES, SHIPMENTS, RECEIPTS, OR REVENUE – Continued
a. For description 18., it should read “carnival games” and rides should have its
own line.
We would be happy to discuss any of our comments as needed.
Sincerely,

Melissa Teates
mteates@iaapa.org
571-210-4326

October 30, 2015
Jack B. Moody
Assistant Survey Director, Economic Census
Economy-Wide Statistics Division
U.S. Census Bureau
4600 Silver Hill Road
Washington, DC 20233
Mr. Moody,
The American Optometric Association (AOA) represents 33,000 doctors of optometry and
optometry students. Doctors of optometry serve patients in nearly 6,500 diverse communities
across the country, and in 3,500 of those communities are the only eye doctors. The AOA
appreciates the opportunity to provide comments in preparation for the 2017 Economic Census.
We feel the changes recommended below are necessary to ensure accuracy and eliminate
misinformation.
Form HC-62104 (Office of Physicians and Other Health Practitioners)
On the current form, page 3, question 19 relates to the kind of business that is conducted at the
location. It is common practice to use the term “doctor(s) of optometry” rather than
“optometrist(s)” and we recommend this language revision be made. Additionally, the Bureau
has doctors of optometry incorrectly categorized as “Other health practitioners” on the current
census form. Doctors of optometry are recognized as physicians under the Medicare program1
and, for consistency throughout the federal agencies, the AOA recommends that doctors of
optometry be appropriately listed under “Physician services.” We also recommend that the
additional inaccurate language which states, “Include physicians with the degree of M.D. or
D.O.” should be removed or the degree of O.D. should be added.
On the current page 5, question 22 needs to be updated to reflect the transition made to ICD-10
on October 1, 2015. On page 5, we also recommend that one entry be added to represent
“Diseases of the Eye and Adnexa (H00-H59).” Additionally, on the current page 8, question 26,
the term “optometrists” should be replaced with “Doctors of Optometry.”
Form HC-62109 (Outpatient Care Facilities)
On the current page 4, question 19 and current page 9, question 26, we recommend that the term
“optometrists” be replaced with “doctors of optometry.”

1

http://www.ssa.gov/OP_Home/ssact/title18/1861.htm#act-1861-r

Form HC-62190 (Classification Form - Ambulatory Health Care Services)
We recommend for question 19 on pages 3 and 4, “optometrists” should be replaced with
“doctors of optometry.” Additionally, for the reasons stated previously, doctors of optometry
should be appropriately listed under “Physician services” and we recommend that the additional
inaccurate language which states, “Include physicians with the degree of M.D. or D.O.” should
be removed or the degree of O.D. should be added.
Thank you for the opportunity to comment on these forms in anticipation of the 2017 census. If
you have any questions, please contact Rodney Peele, Associate General Counsel Public Policy
at rpeele@aoa.org
Sincerely,

Steven Loomis, OD
President, American Optometric Association

Economics & Housing Policy
1201 15th Street NW
Washington, DC 20005
D 202 266 8383
T 800 368 5242 x8383
dcrowe@nahb.org

October 29, 2015
Jack B. Moody
Assistant Survey Director, Economic Census
Economy-Wide Statistics Division
U.S. Census Bureau
Washington, DC 20233–0001
Re: 2017 Economic Census Questionnaires.
Dear Assistant Director Moody:
On behalf of the National Association of Home Builders (NAHB), I would like to
thank you for inviting NAHB to comment on the questionnaires for the 2017
Economic Census, and to provide specific comments and recommendations on
the questionnaires for two sectors of the U.S. economy.
NAHB is a Washington-based trade association representing more than 140,000
member firms involved in building and remodeling single-family and multifamily
housing, land development, operating and managing residential rental properties,
and other aspects of residential construction. NAHB and its members are thus
frequent users of information from the Economic Census, especially information on
the Construction and Real Estate and Rental and Leasing sectors. For this and
other reasons, NAHB has been a strong supporter of the Economic Census over
the years.
In this letter, NAHB is providing two major sets of recommendations on
questionnaires that fall within its field of expertise: 1) questionnaires for the
Construction sector (CC-23601 to CC-23804), and 2) the questionnaire for Real
Estate Lessors (RE-53160).
1. Questionnaires for the Construction sector (CC-23601 to CC-23804)
There are six questionnaires for the construction sector, and all are similar. On
page three of each questionnaire, Question 5 Part A asks the construction
establishment to report sales, receipts, or revenue for construction work. The
footnote to the question asks the establishment to exclude cost of land other than
site preparation. This is potentially confusing to small builders and developers with
land costs, and It is asking a lot of them to understand the note and appropriately
net out these costs.

Jack B. Moody
U.S. Census Bureau
October 29, 2015
Page 2

Home builders that build on owner’s or investor’s land (NAICS categories 236115
and 236116) do not typically buy land themselves and are therefore likely to report
the value of construction work properly in Question 5A. For-sale home builders
(NAICS 236117), however, build new homes on land they own and control. When
they sell new homes, the land is included with the sale of homes and land costs
are reflected in home sale revenues reported on the financial statements. Asking
them to exclude cost of land other than site preparation can be confusing, as they
may have purchased a developed lot and have no idea what site preparation
performed by another establishment costs.
For more than 40 years, NAHB has collected income statement information from
single-family builders in its Cost of Doing Business (CODB) surveys. Appropriate
income statement line items for the survey are identified in consultation with
builders, and with reference to NAHB’s official chart of accounts
(www.nahb.org/chart). As currently structured, the survey first asks builders to
report gross revenue (free of any expense or cost), and then specifically asks for
land costs, and direct and indirect construction costs separately. After collecting
these data, NAHB subtracts the three categories of cost, to come up with an
industry benchmark for gross profit. In our experience, a significant share of
builders have difficulty filling out the form accurately; even when each line item is
described in detail and specific references to the chart of accounts are provided.
We find it difficult to believe that a questionnaire asking builders to interpret a
particular type of cost correctly and perform a non-standard calculation themselves
could be more accurate.
Establishments that perform land subdivision (NAICS 237210) face similar issues
when filling out Form CC-23701. These establishments will generally know the
revenue they realize from selling subdivided lots with a fair degree of accuracy, but
will virtually never think of this as being net of land acquisition costs.
In short, NAHB believes many construction establishments, especially for-sale
home builders and land developers, do not accurately subtract land costs when
reporting receipts in Question 5A.
We find evidence that this was in fact the case in the 2012 Economic Census.
Using data for the construction sector recently released from this Census, NAHB
subtracted costs from the value of construction work done, and labelled the
residual profit. The following chart summarizes the results of these calculations.

Jack B. Moody
U.S. Census Bureau
October 29, 2015
Page 3

The chart shows a residual profit that seems reasonable and is generally
consistent with NAHB’s internal data for new single-family except for-sale builders,
residential remodelers, and specialty trade contractors. However, the residual
profit for for-sale builders and land subdivision—the establishments that virtually
always have substantial land acquisition costs—are unrealistically high. We see
no reasonable way to explain these numbers, other than builders and developers
sometimes inappropriately including land costs when they report construction
receipts in Question 5A.
Therefore, on the questionnaires for the construction sector in the 2017
Economic Census, NAHB recommends that the Census Bureau 1) eliminate
the footnote in Question 5A that asks establishments to exclude costs of
land other than site preparation when reporting construction receipts, and 2)
add a separate question on land acquisition costs that the Census Bureau
may use itself after the data are collected to net out value of construction
work done by the establishment.
2. Questionnaire for Real Estate Lessors (RE-53160)
Your letter soliciting input on the questionnaires specifically asks if the terms and
definitions used are common for the industry. In that regard, NAHB would like to
comment on terms used in Question 19 (Kind of Business) on page 5 of
questionnaire RE-5310 (for Real Estate Lessors).
The first two sections of Q19 ask the establishment to identify its principal
business activity by checking one of the subcategories under the headings
“Lessors of residential properties” or “Lessors of nonresidential properties.”

Jack B. Moody
U.S. Census Bureau
October 29, 2015
Page 4

In the residential real estate industry, the term lessor is seldom used, especially as
a means to identify the owner of a property. If owners of multifamily rental
properties were to use the term lessor, they would most likely mean by it someone
employed by the owner to help lease up the property. In the nonresidential sector,
the term lessor is somewhat more common and less confusing, but the term
property owner is still more common and easier to understand.
Therefore, on the questionnaire for real estate lessors in the 2017 Economic
Census, NAHB recommends that, in Question 19 (kind of business), the
Census Bureau replace the heading “Lessors of residential properties” with
“Owners of residential rental properties,” and “Lessors of nonresidential
properties” with “Owners of nonresidential rental or leased properties.”
Moreover, NAHB recommends that the word “Lessor” be replaced with
“Owner” in all subcategories that appear under one of these headings.
Thank you for the opportunity to comment on this important data collection effort.
If you have any questions about NAHB’s comments, please contact Paul Emrath,
NAHB’s Vice President of Survey and Housing Policy Research (202-266-8449,
pemrath@nahb.org).

Best regards,

David Crowe
Chief Economist

DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
7500 Security Boulevard, Mail Stop N3-01-21
Baltimore, Maryland 21207-0512

October 30, 2015
Dear Jack Moody:
Thank you for your invitation to submit comments regarding the content of the 2017 Economic
Census Questionnaires. The Economic Census is a critical component of the Nation’s statistical
system and provides extremely valuable information regarding national, regional, and state level
economic activity. The Office of the Actuary relies heavily on the results of the Economic
Census as the primary data source used to benchmark estimates of health care spending in the
National Health Expenditure Accounts (NHEA) and we are happy to provide the following
comments and suggestions for your consideration:
1. In the health sector, purchases of goods and services are largely paid for by third party
payers such as private and publically provided health insurance and programs. The
composition of these payers by type of good and service is critically important for the
development of the NHEA. Recent changes in the way health care is financed and paid
for including the impacts of the Affordable Care Act, have made it even more important
to have detailed data and information related to the payers and programs that pay for
health care. We recommend the addition of the following question to the 2017
Economic Census for forms HC-62104-HC62110, HC-62190,HC-62201,HC-62301,HC62390, and HC-62402 forms.
Estimate the level of patient care revenue reported in 22, line 1, from:
Medicare
Medicaid
DOD
VA
CHIP
Workers Compensation
Other Government Programs
Private Health Insurance
Medicare Managed Care Plans
Medicaid Managed Care Plans
Property and Casualty Insurance
Out of Pocket
Other Sources – please specify
2. We also recommend that the 2017 Economic Census collect information on retail health
care clinics that are owned and operated by retail stores and as such are included in the
Economic Census in NAICS 44 and 45. This important and rapidly growing segment of
the health care industry is difficult to estimate because the establishments providing these
health care services are classified in the NAICS as retail and not health care

establishments. Direct collection of these products in the 2017 Economic Census would
provide valuable information to supplement the data collected in NAICS 62.
Retail health care clinics are included in several places in the NAICS. Retail health care
clinics usually follow one of three models:
1) clinics owned by an independent company that operates within a retail store
2) clinics owned and operated by the retail store that they are located in
3) clinics owned and operated by a hospital, physician group, or other health care
provider. [i]
Retail clinics that are owned and operated by an independent company whose primary
activity is to provide freestanding urgent and clinical care are classified in the health
sector and are included in NAICS 621493. Clinics that are owned and operated by other
health care providers such as hospitals and physicians groups are also included in the
health sector and are classified by the primary activity of the establishment such as
NAICS 622 (if the clinic is located in the hospital) or NAICS 6211 (if located in a
physician office). However, retail clinics that are owned and operated by a retail store
are currently included in NAICS 44 and 45 (Retail trade) and not in the health sector
(NAICS 62). These clinics are appropriately classified by the primary activity (retail
sales) of the establishment and would be best identified by an expansion of the product
level detail for these industries in the Economic Census.
3. On the 2017 Economic Census forms, it’s not clear that the preferred reporting period is
for the calendar year (January-December). The reporting period is asked for at the end of
the form in the certification section. We suggest moving this up to the front of the form
and wording it in a way that states that calendar year is preferred. Perhaps something
similar to the statement used in the Service Annual Survey “Calendar year data is
preferred. If it is not available, please report for the fiscal year that includes at least six
months of data for the 2017 calendar year”
4. In section 22 (Detail of sales) for the line “e. All other resale of medical equipment and
supplies “we recommend adding a section for the respondent to describe what is being
reported in this line.
5. For Question 22 on the Physician and Other Health Practitioners Questionnaire, it would
be helpful to request an estimate of “revenue from hospitals”. Payments to physicians by
hospitals are often reported as physician revenue and paid for out of hospital revenue, and
in order to eliminate double counting of this revenue in the NHEA we remove an
estimate of this revenue from physician spending. The direct collection of this data in
the Economic Census would improve this adjustment.
6. How will the 2017 Economic Census handle bundled payments for health care services
that are provided by establishments in different NAICS categories?
Thank you again for the opportunity to comment on content of the 2017 Economic Census
questionnaire. If you would like to further discuss any of our comments, suggestion, or
questions please don’t hesitate to contact me.

Sincerely,

Aaron Catlin
Deputy Director, National Health Statistics Group
Office of the Actuary
Centers for Medicare & Medicaid Services

November 18, 2015
Jack B. Moody
U.S. Department of Commerce
Economics and Statistics Administration
U.S. Census Bureau
Washington, D.C. 20233-0001
Email: ec17association@census.gov
Form MC-33613
The survey questionnaire and instructions use common terms/definitions that are common to the
marine manufacturing industry, and it accurately reflects the production occurring in our
industry. NMMA does not recommend any changes.
Form MC-33320
The survey questionnaire and instructions use common terms/definitions that are common to the
marine manufacturing industry, and it accurately reflects the production occurring in our
industry. In Section 22, Question 7 could be considered confusing due to the exclusion of marine
engines; while marine engines are addressed in Question 12, the explicit exclusion could
preclude a recipient from finishing the survey. Perhaps more clarity before Question 6 could be
beneficial.
Form RT-44102
The survey questionnaire and instructions use common terms/definitions that are common to the
marine manufacturing industry, and it accurately reflects the production occurring in our
industry. NMMA recommends the department connect with the Marine Retailers Association of
the Americas (MRAA), if it has not already done so, to yield more complete feedback on this
form.

Sincerely,

Michael Lewan
Government Relations Manager
National Marine Manufacturers Association