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RR RUEHWEB

DE RUEHWN #0084/01 0351819
ZNR UUUUU ZZH
R 041818Z FEB 10
FM AMEMBASSY BRIDGETOWN
TO RUEHC/SECSTATE WASHDC 0280
INFO RUEHGR/AMEMBASSY GRENADA
RUEHWN/AMEMBASSY BRIDGETOWN

UNCLAS BRIDGETOWN 000084 
 
SENSITIVE 
SIPDIS 
DEPT PASS TO OIG/ISP - AMB. DAVID ZWEIFEL 
DEPT PASS TO WHA/CAR 
 
E.O. 12958: N/A 
TAGS: AMGT ASIG PHUM
SUBJECT: OIG REVIEW OF IMPACT OF REQUIRED REPORTING 
 
REF: STATE 9541 
 
¶1. (SBU) Embassy Bridgetown appreciates the OIG's interest in the 
impact of mandated reporting on Post resources and welcomes the 
opportunity to provide feedback.  The 65 annual reports cited 
reftel tracks closely with our February, 2009 OIG inspection 
report, but in fact under-reports the number of annual reports we 
compile.  Combining the reporting specifically requested by 
Congress and the reporting that must be done to feed into other 
Congressionally or institutionally mandated reporting, we compile 
for our six countries some 84 mandated annual reports (see attached 
list).  Adding Embassy Grenada into the mix, whose single FTE 
officer processes ten annual reports, and the proliferation of 
overlapping annual resource planning documents such as the MSP, we 
prepare close to 100 mandated reports each year.  With the 
five-member POL/ECON section responsible for the bulk of that 
reporting, this constitutes a crushing burden that significantly 
curtails our ability to produce timely political and economic 
analysis and in-depth reporting throughout the region.  We would 
welcome a rationalization of this workload to free us up to do more 
pol/econ reporting and analysis, outreach, and commercial 
development in the region. 
 
 
 
¶2. (SBU)  While planning documents were not part of the reftel 
inquiry, we would urge the Department to look at a way to 
rationalize the annual CBJs, PPR reports, and MSPs, all of which 
track very similar data but have slightly different time horizons, 
and which require significant duplicative preparation efforts by 
State, AID, and (at this Post) MILGROUP personnel.  It would also 
help to have clearer and complementary guidelines for these 
reports, as the data requests especially from the F bureau seem to 
change every year. 
 
 
 
¶3. (SBU) Special Circumstances:  This Embassy, with support from a 
one-officer Embassy in Grenada, is responsible for relations with 
seven countries.  Under existing regulations, that means we are 
responsible for seven times the mandated reporting load of a 
typical Embassy.  Moreover, we have no permanent presence in five 
of those countries, which means that we can only collect data and 
investigate HRR, TIP, and other reports during infrequent reporting 
trips, which are hindered by a lack of travel and representational 
funding.  In addition, the Embassy has been without a full-time 
Narcotics Affairs Officer since 2006, this even though 
counter-narcotics is our number one MSP priority.  This makes 
preparation of the INCSRs problematic and data collection difficult 
owing to a lack of established contact networks.  This needs to be 
rationalized. 
 
 
 
¶4. (SBU) We support the recent OIG recommendations for simplifying 
these many reporting requirements, whether by coordination of 
deadlines, timelines, and guidelines, the preparation of an omnibus 
report once a year, or an amalgamation of mandated reports into 
logical subgroups.  As the OIG noted, even though these countries 
have parliamentary democracies, clean elections, high respect for 
human rights and generally professional police forces, post 
"staggers under the load of annual reports,...each based on a 
separately defined statute and different reporting schedules and 
standards, some in conflict." 
 
 
 
¶5. (SBU) Recommendations:  A "short form" for these countries would 
be useful and save us significant drafting and editing time, 
especially as year-to-year changes are generally limited.  With 
regard to TIP reporting, the Department should seriously reconsider 
the appropriateness of watchlisting these assistance-dependent 
micro-states absent a significant and unattended trafficking 
problem, as negotiating text and decisions with Washington takes up 
an inordinate amount of time and discredits the excellent anti-TIP 
work being done in real problem countries. 
 
 
 
¶6. (SBU) Additional responses below keyed to questions in para 3 of 
reftel: 
 
 
 
a. Which mandated reports require the most time and attention from 
Department personnel at your Embassy? 
 
Our six human rights reports and fourteen INCSR reports take up the 
most time and attention for data gathering.  The G/TIP report is by 
far the most resource-intensive, however, primarily the portion 
requiring negotiation with Washington over final text, which has 
involved the reporting officer, section chief, and Chief of Mission 
over the course of several months. 
 
 
 
b. What section or unit is assigned responsibility for gathering 
information and preparing these reports? 
 
 
 
The Pol/Econ section has the lead for all 84 reports.  For the 
INCSRs, a Narcotics Affairs Office subordinated to Pol/Econ has 
primary responsibility. . In Grenada, the sole American officer and 
two LES specialists prepare the reports.  These are reviewed by 
Bridgetown's Pol/Econ staff and DCM. 
 
 
 
c. How many employees are involved in preparing and submitting each 
report?  Please specify Department direct hire staff, local 
employees, eligible family members, contractors or other. 
 
 
 
For the HRR, IRF, TIP, CBTPA, Transparency, Expropriation, Sugar 
Quota, and Libertad Act reports, each of three section officers is 
responsible for preparing the reports for two countries.  They are 
assisted by the section's only LES and an RSO investigator as his 
time allows.  The Embassy's protocol LES and the section's OMS also 
support the drafting process by producing diplomatic notes that 
must accompany requests for information in keeping with local 
practice.  The section chief and Chief of Mission review the 
reports. 
 
 
 
For the INCSRs, the NAS LES has primary responsibility for data 
collection with cooperation from the Barbados DEA office, LEGATT 
and IRS Investigator; the NAS LES and a Professional Associate 
Position EFM draft the responses, and the section chief and Chief 
of Mission clear them. 
 
 
 
For the Child Labor reports (both versions) and the Labor and Child 
Labor portions of the HRR and TIP reports, the deputy section chief 
collects data and writes the reports; the section chief and Chief 
of Mission clear. 
 
 
 
d. How many person hours (by report and employee category) are 
required to prepare each of the mandated reports?  What proportion 
of the Embassy or Mission's total personnel or other resources does 
this represent? 
 
 
 
In Barbados:  difficult to pinpoint hours if we include data 
collection as part of the preparation time, as each officer and the 
sole pol/econ LES try to incorporate HRR, TIP, Labor and IRF data 
collection into every reporting trip to an off-island.  Overall, we 
estimate that about 40 percent of the total person-hours of the 
pol/econ section are dedicated to mandated annual reporting, along 
with 7-10 percent of DEA, LEGATT, IRS, and RSO's time. 
 
 
 
In Grenada,  LES staff devoted approximately 12 hours to research 
and 12 hours to draft the HRR report.  However, the LES staff also 
collects information throughout the year that facilitates 
subsequent research.  The American Officer devoted approximately 24 
hours to analyze, fact-check, revise and negotiate text with 
Washington.  The other reports generally required 3 hours of work 
by LES to research, 5 hours of work by LES to draft, and 
approximately 4 hours of work by the American Officer to revise, 
analyze, fact-check and negotiate each report. 
 
e. Does required reporting, as it is currently being produced, 
support and reinforce other mission goals or divert resources from 
them? 
 
 
 
This is a mixed bag.  The INCSR process is useful and contributes 
to our knowledge on narcotics and money laundering activities and 
government efforts - with a NAS in place, this would be even more 
useful.  The HRR can be of occasional benefit, judiciously referred 
to, to encourage better responsiveness from and professionalization 
of local law enforcement, but is otherwise unremarkable as there 
are very few human rights concerns in the Eastern Caribbean.  The 
TIP report has proven almost wholly counterproductive, threatening 
development assistance sanctions against countries that need it 
most and on the basis of non-specific allegations difficult to back 
up with facts.  The disconnect between the tier status assigned and 
credible facts to back them up has had extremely negative 
implications for our overall mission goals in the region, and has 
negatively affected broad perceptions of the United States in the 
region.  Our overall credibility and the credibility of our 
mandated reports as a whole have suffered as a result.  We have 
expended enormous energy with Washington and host governments 
trying to rationalize this report, and we have ended up devoting 
far more time and effort to this than the issue warrants for the 
region, which in turn skews our reporting profile and keeps us from 
other reporting. It also has the unintended consequence of damaging 
our access to data sources once they feel they have been unfairly 
targeted, which makes it harder to collect data for other reports. 
 
 
 
Other reports are duplicative and/or overlapping, especially Child 
Labor reporting, which we do four times for four separate but very 
similar reports.  Transparency Reports have similarly eaten up a 
disproportionate share of resources recently, with what we believe 
to be little justification and even less practical effect aside 
from delaying much-needed training opportunities for local law 
enforcement. In Grenada, manpower constraints result in the annual 
reports providing most of post reporting on a particular theme. 
 
 
 
f. What resource measures has the Embassy taken (redirecting 
personnel to this instead of other duties, hiring additional local 
staff or eligible family members, requesting additional fulltime 
positions) to fulfill requirements for mandated reporting? 
 
 
 
In the absence of a full-time NAS funded by INL, we have hired an 
EFM under the Professional Associates Program to staff the NAS 
position and we have requested a new NAS in every MSP starting in 
¶2007.  In addition, the duties of the NAS procurement assistant 
were expanded to include more data collection and drafting 
responsibilities for the INCSR.  In October, 2007, Pol/Econ hired 
an LES to assist with all six portfolios (there was not an LES 
position for Pol/Econ previously). Also in October, 2007, the 
section was reorganized along geographic vice functional grounds, 
which streamlined the reports process somewhat.  The Embassy has 
consistently requested additional funding for travel and 
representational expenses to allow us to travel to the five 
countries where we have no permanent presence, so far with very 
modest results.  We also requested an additional position in the 
IRS investigator's office, which will help speed data collection 
and clearance of the INCSR (part 2). 
 
 
 
Grenada: None when there is someone (often EFM) in the NAS 
position.  In 2006 and 2007, the LE staff spent about 10 hours 
collecting and reviewing data, while the officer spent 30-40 hours, 
drafting the questionnaires (LE staff from NAS office sent the GOG 
incomplete lists of questions to be answered) and drafting the 
reports, responding to Bridgetown queries, and finalizing the 
reports.  Should the NAS position continue to be filled, Grenada 
will do less on these reports.  However, in 2008, Bridgetown NAS 
requested assistance from Grenada LE staff in getting the response 
from the GOG; this amounted to perhaps two to three hours work. 
 
 
 
g.  Which parts of the process (information gathering, analysis, 
drafting, internal editing, negotiation of text with Washington) 
consume the most resources? 
 
Answered above.  In addition, the multiple iterations of the HRR 
and TIP report add significantly to preparation time. 
 
 
 
h. How clear and helpful are Department instructions for preparing 
each of these reports? 
 
 
 
 Directions appear confusing to staff members who do not follow a 
particular issue on a continuing basis.  Minor changes in 
directions each year, without clear guidance on the changes, itself 
requires re-reading the entire set up instructions, which 
exacerbates the confusion. The TIP report has considerable flaws in 
methodology, evidentiary standards, and burden of proof issues. 
This undermines posts' ability to explain the process and can 
confuse not only staff but also host government officials about 
what is wanted. 
 
 
 
i. What percentage of the Embassy's overall reporting on an issue 
such as human rights or trafficking in persons does the annual 
required draft represent?  Does your post submit reporting cables 
on these issues throughout the year, or gather and discuss 
information but submit it formally primarily in the required annual 
draft? 
 
 
 
Given the volume of mandated reporting, we have little time to do 
any spot or analytical reporting on these issues.  What little time 
we do have is spent on travel to our off-islands, outreach, other 
pol/econ reporting for seven countries, visitor support, 
representation, etc. In Grenada, such reports generally consist of 
80-90 percent of post reporting on particular issues. 
 
 
 
j. Do other mission agencies besides the Department make 
significant contributions to the preparation of mandated reporting 
in these areas? 
 
 
 
Answered above - DEA, IRS, LEGATT, and RSO all contribute to one or 
more of our reports.  Washington counterparts could usefully 
contribute to the process by raising issues they spot in the media 
through the course of the year for us to follow up, as there are 
many demands on our time. Grenada frequently taps Embassy 
Bridgetown and its agencies for guidance, assistance, review and 
negotiation of reports. 
 
 
 
¶7. (SBU) Responsible Officers:  The following are the Embassy 
officers responsible for mandated annual reporting: 
 
 
 
Antigua and Barbuda, St. Kitts and Nevis reports (all):  Rick 
Switzer; Barbados, Saint Vincent and the Grenadines reports (all): 
Jamal Al-Mussawi; Dominica, St. Lucia reports (all):  D.R. 
Seckinger; Grenada reports (all): Bernard Link; INCSR reports: Al 
Razick; Child Labor reports: Jake Aller 
 
 
 
¶8. (SBU) We thank the Department again for the opportunity to 
contribute to this discussion, and look forward to working with the 
OIG and others to improve the current structure. 
HARDT