I’ve been looking at the Paperwork Reduction Act after learning of concerns that the law limits the government’s ability to use voluntary web surveys to gather information. What I’ve discovered is a series of good-government rules that were intended to reduce the paperwork burden the government places on each of us, but had the unanticipated consequence of limiting its ability to use common web-based feedback techniques on how to improve its services.

I’m still digging into this issue, but have put together a wiki page that gathers some useful resources. Of particular interest is an OMB request for comment on how to improve the implementation of the PRA.

[I'm also interested in the government's ability to gather data on which web pages are most visited, and then make that information available as a list of "most visited pages" or something along those lines.]

Below the fold is part of the section of the US Code that makes the government’s use of web surveys so unwieldy — 44 USC 3507. (Follow the link for a much easier to read version.)

§ 3507. Public information collection activities; submission to Director; approval and delegation

(a) An agency shall not conduct or sponsor the collection of information unless in advance of the adoption or revision of the collection of information—
(1) the agency has—
(A) conducted the review established under section 3506 (c)(1);
(B) evaluated the public comments received under section 3506 (c)(2);
(C) submitted to the Director the certification required under section 3506 (c)(3), the proposed collection of information, copies of pertinent statutory authority, regulations, and other related materials as the Director may specify; and
(D) published a notice in the Federal Register—
(i) stating that the agency has made such submission; and
(ii) setting forth—
(I) a title for the collection of information;
(II) a summary of the collection of information;
(III) a brief description of the need for the information and the proposed use of the information;
(IV) a description of the likely respondents and proposed frequency of response to the collection of information;
(V) an estimate of the burden that shall result from the collection of information; and
(VI) notice that comments may be submitted to the agency and Director;
(2) the Director has approved the proposed collection of information or approval has been inferred, under the provisions of this section; and
(3) the agency has obtained from the Director a control number to be displayed upon the collection of information.
(b) The Director shall provide at least 30 days for public comment prior to making a decision under subsection (c), (d), or (h), except as provided under subsection (j).
(c)
(1) For any proposed collection of information not contained in a proposed rule, the Director shall notify the agency involved of the decision to approve or disapprove the proposed collection of information.
(2) The Director shall provide the notification under paragraph (1), within 60 days after receipt or publication of the notice under subsection (a)(1)(D), whichever is later.
(3) If the Director does not notify the agency of a denial or approval within the 60-day period described under paragraph (2)—
(A) the approval may be inferred;
(B) a control number shall be assigned without further delay; and
(C) the agency may collect the information for not more than 1 year.