Application form can be completed in less than two-tenths of a second, FCC estimates

The hilariously named “Paperwork Reduction Act” (PRA) requires the FCC, like other agencies, to publish estimates every three years about the information it collects, and to invite comments on their accuracy. Needless to say this procedure vastly increases paperwork, rather than reducing it, but here in Washington we have become inured to these little inconsistencies.

A PRA notice typically estimates how many people have to fill out a form, how long it takes them, and the total cost to the economy. For example, the PRA notice for the federal income tax forms estimates that 143.4 million taxpayers spend an average of 19 hours filling out forms at a total cost of $31.5 billion dollars. (From, this, we deduce that the Government figures our weekend and evening time is worth $11.56 per hour.)

Here at the law office, we look over the PRA notices coming out of the FCC for any that might interest our clients. A recent one caught our eye.  According to the FCC, if you apply for a low-power FM construction permit, filling out the required form (that would be Form 318) will take you between 0.0025 minutes and 12 hours – anywhere from one-seventh of a second to half a day.  (Don’t believe us?  Check out the top of the middle column on page 16774.)

That’s quite a range. We are pretty good with FCC forms – we do a lot of them – but one-seventh of a second is remarkable even by our standards. Assuming this is not a typo (the Federal Government never makes mistakes), we can think of only one possible explanation. The FCC must have a secret short-cut for filling out these forms in a flash. We wish they’d let the rest of us in on it.