Then the agency has to make sure another one doesn't want [the building]. Then state and local governments get a crack at it, then nonprofits — and finally, a 25-year-old law requires the government to see if it could be used as a homeless shelter.
Every one of those regulations is perfectly reasonable. Yet when put together they lead to empty buildings staying empty, expensive and useless. This is a very uderappreciated consequence of regulation in general.
The purpose of a sale is to find out who wants something. That's the economic system we use.
Aimlessly asking around works when you want to know if your cousin wants your old sofa before you craigslist it; but is just ridiculous in any larger context.
I'm not saying there's not a better way but why is this ridiculous in a larger context? If the government didn't have these rules in place, we'd be seeing another article about how the government keeps buying and selling buildings, costing taxpayers billions, when they could have transferred buildings at a relatively minimal cost. I suspect that this is why these regulations were enacted in the first place.
First of all, it can take some effort to find a buyer. This effort needs to be expended regardless, and I don't see how it's better to in-source the work to the selling government agency. They are not professional brokers, have little incentive to act quickly or efficiently, and we've already established that they don't have any magical database that makes the buyer obvious. Just let a commercial RE broker handle it like a business would.
Second, you need to settle-up the accounting so it's no longer on the seller's books, and is now on the buyer's books. That means you need to agree to a price. You can skip this because "it's all part of the federal government", but that leaves us with the mess we have now: nobody knows what buildings are being used by whom at what cost. Accounting costs are not waste; otherwise large private (not publicly-traded) companies would fire their accountants. So it seems like the best course of action is to do the same negotiation and accounting work that happens as a part of the sale.
So the buying/selling costs are not a waste, they are money well-spent. It's possible to make them more efficient in special circumstances -- maybe the costs of due diligence, fraud prevention, title insurance, etc. are little or nothing when buying from the federal government. But those special cases can be handled as special cases and there could be a cheaper, quicker path to sell if those circumstances are met.
It should be made a law that Congress (or for that matter, any law-passing authority, this problem exists not just in the US), should before passing any law evaluate its impact and interference with already existing law.
Such thorough checks would also quite likely regularly turn up the "bit rot" equivalent of laws...
"It should be made a law that Congress (or for that
matter, any law-passing authority, this problem exists
not just in the US), should before passing any law
evaluate its impact and interference with already
existing law."
Ironically, that law would have so many impacts on so many other laws, it would be impossible to evaluate them all.
It's already the law...Congress already has several agencies that deal with these sorts of analyses. The most famous are the Congressional Budget Office and the Congressional Research Service. They deal with this silliness all the time, so they're actually quite good at it.
It's a great idea but mandating it won't make it happen. You have to get people in office who actually care about not making bit rot in the law. Most of the folks making laws right now at a Federal level like the bit rot because it gives their donors loopholes to drive their armored cars through.
For example a large chunk of what the Federal government is doing right now isn't specifically authorized by the Constitution, but the Congress doesn't care. "Necessary and proper clause" they say, nevermind that running well over half the Federal government on the necessary and proper clause defeats the whole idea of limited enumerated powers.
I don't have any good suggestions on how to fix the problem with the officials not really caring to do their jobs, though.
I don't know if the irony was intended, but this sounds like another level of regulation (likely requiring additional levels of auditing, etc)... potentially yielding the exact opposite what it intends.
I briefly worked for the Federal Government, and I recall an immense amount of paperwork being generated by the regulations of the "Paperwork Reduction Act."
I call bull on this one, fella; I think you're a bit ignorant on this matter.
I'm federally funded, and have been for the better part of my career. The paperwork reduction act has nothing to do with physically reducing paperwork, and more in reducing the work burden to the public.
It states that every form has to have a justification tied to your guiding principle, and that the public should know how difficult the form will be to fill out. In other words, if the OMB says that form 1014a(1) should only take 15 minutes to complete, it's up to your office to ensure that is the case, if you created that form. As far as physical paperwork - it only adds a couple of lines to document headers, and in the case of enormous institutions, it's listed on their main website or main document to avoid adding it to the rest of the documents.
The paperwork reduction act is usually the brunt of office jokes when it pops up on paperwork, because most people have no idea what it is and it sounds funny, and because it may add a line or two. I'm guessing you've seen that disclaimer and went from there.
It's not a personal attack? Being called ignorant just means that you don't know something. Stupid, that's an insult, but ignorant simply means that you don't know.
Your comment stated that the paperwork reduction act added paperwork, which you used as an example to the statement "potentially yielding the exact opposite [of] what it intends."
The intention of the federal paperwork reduction act isn't to reduce the physical amount of paperwork to you. It is to ensure that all paperwork has a purpose, and a timeframe for completion that isn't overly burdensome.
Therefore, your premise that its main goal was to reduce the physical number of pages for federal programs is incorrect, I assumed you were ignorant of what the federal paperwork reduction act was, and I explained it.
I have gone through the process of having federal forms cleared with the OMB at the federal level, large scale and small scale data collection, and have worked with them in several capacities. I don't like that I have to have everything relate to my goals and purpose or that I have to conduct studies on the front end for forms, but I see the purpose for it.
your premise that its main goal was to reduce the physical number of pages for federal programs is incorrect
That isn't my premise. I mean 'paperwork' in the 'burden' sense, not as in physical pieces of paper. However, the extra layer of bureaucracy added paperwork in the 'burden' sense.
Looking at the crap we Europeans see happening in the US, I seriously doubt the efficiency of this agency.
A good example is that story about the old lady on HN who had rented an illegal building. One agency demanded that she be evicted, yet another law forbid the eviction, or such.
The stuff I see here in the US is nothing compared to what happens in Europe -- people incite revolution, no one seems to know who's in charge, and governments attack their own people in broad daylight!
Your generalization is as meaningless as mine is. The USA is roughly the size of your continent and its land can be governed by any number of rules and regulations, depending on where you are.
For every Texas, there's a California. For every Germany, there's a [Ukraine|Greece|Spain|...].
Neither Turkey nor the Ukraine is in the EU, that point of yours is a bit off. And for our treatment of the African refugee seekers, well I compare that to the US-Mexican border. No side is better in any way than the other.
But agreed, how we Germans treat Greece is disgusting. Basically, everyone claims "how bad the Greeks are", but the bailout money does not go to the Greeks but to our own banks. This has never been to "rescue Greece", but to rescue our fucking banks.
A lot of this isn't actually the CBO's fault... because they're totally non-political, or need to appear to be, they score things according to the letter of the law. The thing is, the letter of the law is never followed, as whenever the painful (cost reduction) parts start to apply, Congress votes to nullify the pain, which makes them more expensive.
I'm not that interested in fault. I'm interested in its reliability as a source of information. I'm interested in the trust that their information is given when they're wrong so often - for whatever political or non-political reason.
CBO numbers are used as a shield by politicians to push their agendas. I wish that they didn't have that shield because voters were more aware of its inaccuracy.
Not sure what an old lady renting a building has to do with the CBO, but I suspect that cmelbye is pointing out not that the CBO is efficient at its job, but that institutionalizing impact measurement (CBO) is insufficient in the face of powerful political incentives. That's how I read it, anyhow.
If every law had to be re-passed every six years or so, that would tend to limit the number of laws that could be in existence at any given time. I don't recall which, but some culture had a tradition whereby the entire body of law had to be read aloud in public before any new business could be conducted. It feels in my memory like it might have been Medieval Iceland.
That is an excellent tradition. But I also get the feeling that all we'd get from Washington DC is an act every 6 years to reauthorize the entire US Code in its entirety, which would pass without debate in about 30 seconds.
I had a similar thought regarding omnibus renewal of regulations, but it's a technical problem that could be addressed.
Perhaps by introducing another reform I would like to see: make it trivial (maybe through a petition?) for U.S. citizens to sue the government to get laws repealed. I'm not a lawyer, but my understanding is that, which some exceptions, you need to be actually harmed to have standing to challenge laws on constitutional grounds.
That just allows for new earmarks and stipulations with an increased possibility of corruption and more influence from vocal special interest groups on a regular basis.
It's counter-intuitive, but sometimes inefficiency is the safest course of action. Not necessarily the best, but the safest. And not always, I need to stress that again.
If you read this article and you were surprised (dismayed, I hope), then you should examine your news sources. This problem has been floating around for years.
Worse, this is just the tip of the iceberg. A building that has been empty for decades is an obvious waste, but there are many wastes that far outstrip this one. There are hundreds of billions of dollars out there that could be put toward paying down our debt and securing programs that are going bankrupt like Medicare and Social Security.
That's why when I hear Pelosi and others say that they can't cut a dime out of the budget. She said, "The cupboard is bare." I feel disgusted.
It's easy to denigrate obvious waste like empty buildings. But context matters: even waving a wand and disposing of all of these buildings would improve the federal budget by ~0.0119%. Put another way, we'd get roughly the same impact by reducing our order of Littoral Combat Ships by 1 boat.
If you profile your code, you don't go after the line item that's < .1% until everything else is fixed; I'd argue that our representatives have more substantive budget fixes they can target.
Congressional budgets are really complex and can't be evaluated like code. That $3 billion subsidy for farmers in Nebraska? The people of Nebraska really, really want that. So much so that if their senators can't push it through, they'll likely vote them out of office. So those senators trade every favor they have to get it through, which usually means voting for keeping a military base open in Colorado, funding road work and pipelines in Texas, building a new airport in Oklahoma, etc.
That's how we get such a bloated federal budget. It's why Congress wants to build a whole bunch of tanks for the Army that they have said they don't need. It's really more of a tragedy of the commons situation than inefficiency.
IMO the question shouldn't be "how can we lower our tax burden", it should be "how do we get more value out of our tax dollars." That may mean increasing the tax burden. There's a sweet spot between socialism and capitalism, and IMO we're swinging a bit far towards capitalism right now. I'm not saying we should go full-on welfare state, but our infrastructure is crumbling and people are losing faith in the American dream, yet companies are more profitable than ever.
It's also important to recognize that government accounting is substantially different from normal corporate accounting. Governments can literally print money if they need to do so to cover debts (and thus shift the burden of debt repayment onto all holders of their currency). The flip side of that is that governments have such a massive scale, they tend to absorb a lot of economy-scale losses (such as building vacancies) that businesses wouldn't have to, so their balance sheets look awful.
That's the problem with central planning. When you look from the top down, every gain seems tiny.
But small businesses would know if a chair was underutilized, and it would be sold in 10 minutes; let alone a whole building. Taken over the whole economy, these efficiencies are a big deal, and arguably account for the success of market economy over centrally-planned economies.
>> small businesses would know if a chair was underutilized, and it would be sold in 10 minutes
Right-O, no waste in small businesses. The smaller the business, the more efficient. Hence ever-smaller businesses are gaining a growing share of the economy. (In fact, the opposite is true.)
"Right-O, no waste in small businesses. The smaller the business, the more efficient."
I didn't say that; no need for the sarcasm.
The answer is somewhat complicated. Small businesses have an advantage because the information flow between directly involved parties and decision makers is very short; possibly the same person. They can notice an inefficiency and correct it immediately, rather than needing some kind of permission or authorization (which is inherently a slow way for information to travel because it involves other people). They can also seize opportunities quickly for the same reason (which may involve changing prices or making a non-traditional deal).
Large businesses can get economies of scale, although I think these are dramatically over-emphasized. Producing one marginal unit may be cheaper up to a point, but eventually the next marginal unit becomes more costly than the last (because there becomes so much demand for the inputs that it increases the price). That's the nature of the supply curve. Often, businesses that deal in huge volumes and have great economies of scale are medium-sized or even small. Of course, there are some industries where economies of scale are crucial and only large businesses or governments can really operate efficiently.
Large businesses have greater political influence and more ability to work in a regulated/political/government environment. This is perhaps their greatest advantage.
I'd be interested to see the numbers you have about the share of the economy powered by small/medium businesses. Is it a long, consistent decline, or more of a local minimum?
Fair enough. To be fair, you did overstate the point a bit; I'm sure we will all walk into a small business today that could do with one less chair. :-)
>> I'd be interested to see the numbers you have about the share of the economy powered by small/medium businesses. Is it a long, consistent decline, or more of a local minimum?
There's a lot of research out there on this. I don't have the time to dig up much more than this:
Note that in 12 years, small businesses lost ~6% of their GDP contribution to larger businesses (table 5). In 2010, small business share of the economy fell below 50% for the first time ever (http://www.businessweek.com/articles/2012-02-16/small-busine...).
Interesting, thank you. I wonder what is causing that decline?
A more libertarian type might say that the increasing power of government is driving small business out through various types of intervention. Evidence would include the ever-increasing share of GDP made up by government spending. This would be countered by the fact that you can still start most kinds of businesses with remarkably little federal involvement aside from taxation.
Someone more inclined toward central planning might say that the information age is making central planning more effective. Evidence would include companies like amazon that have amazing reach. That would be countered by the observation that there are still a lot of small businesses that sell through amazon and set their own prices; and amazon has many robust competitors for each product they sell.
If business success were all about efficiency then you might have a point. It has a lot more to do with critical mass, especially as we make it more and more difficult to start and run small businesses through excessive regulation while favoring large campaign donors that can have legal barriers-to-entry constructed by their paid-for representatives.
So, you would rather cut a feature from your application than multiple lines of code that simply allocates memory, waits a long time, and then frees it for no reason?
In other words, at least the boat is actually potentially useful. The empty building is completely wasteful.
Whew, missing the point. s/Littoral Combat Ship/any of the 1000s of wasteful or inefficient programs larger than $1.7B annually/ and reread my comment.
My point is that available effort to resolve any problem is roughly finite. Fixing the regulations to solve this problem would involve Congressional time and attention, and that applying that attention to a larger problem could lead to much larger gains.
I'm not saying this is good waste, I'm saying that all things being equal it makes sense to rank problems by potential impact and then start near the top.
An empty building, used by nobody but costing the government money, is not useful to anyone except the people receiving the money. So I guess in that respect, if the money is going into the local economy, it's a really poor form of stimulus.
A ship designed for war, not being used for war, but costing the government money, is not useful to anyone except the people receiving the money. So, I guess in that respect, if the money is going into something other than the local economy, it's really a poor form of stimulus.
Most of the reason money is spent on defense is deterrent. Some people gain more value out of that than others. Hopefully it never gets used, although if you need it eventually, it's much harder to build a warship and train a crew to use it than it is to find an empty building somewhere (or just build it).
Yeah, difference of values is fairly spot on. I don't know anybody who values an empty building, though. Or didn't, until now?
It's not that I value the empty building, I value the potential for an empty building a heck of a lot more than I value the potential for large weapons.
I understand where you're argument is - at least we get some use out of the big boat. I just don't like it, and would prefer to see the buildings be paid for overtop of weapons.
Man, that makes me sound like a giant hippy now that I've written it out.
A bit, but I was just quoting Jim Morrison to a friend, so there's that. :-D
At the risk of pushing this thread well past the point of usefulness and too far into the abstract, you know the building could be used to quarter troops, store weapons, etc, so long as it is owned by the government, even not in time of war? Personally, I value the government owning large weapons more than I value them owning millions of small weapons. The large weapons are more likely to be used under the correct circumstances. I think that's part of why we overuse (IMHO) drones - it made it cheap to wage asymmetric warfare.
I'm aware that the could use it for storing troops and weapons, etc. But, these buildings are not expressly designed for warfare, and therefore could have other uses. In fact, it seems that we have this issue because there are steps in place to make sure these buildings get used for something else.
It's a matter of design versus function. The buildings could be re-purposed for war, but they weren't expressly designed for it.
The funny thing is, a lot of these costs are so high because of previous attempts to save money.
For example, contractors are used heavily at just about every level of government. We're hellishly expensive. You know why this happens? In no small part it's because the government general schedule pay scale is a vow of poverty for any skilled and educated professional.
So those people go to contractors to get paid reasonably and the contractor happily applies a markup and sells their services back to the government.
Where I'm at, the ratio's currently at ~3:1, with about 90% of the actual dollars going towards contracts. Admittedly, we're also one of the higher agency ratio's in the gov.
Frankly, a lot of this isn't driven by cost cutting though. In the case I can speak to, and IMO, budget has trended more and more towards contract vs civil due to the irregularity of the budget process, and to some degree, due to the perceived inflexibility & cost (real or not) of a civil job vs a contract.
At a basic level, its easier to swap a contractor if you suddenly find that you need a widget maker rather than a sprocket aligner.
At some level, there is also the feeder and lobbying ecosystem that is most obvious within the military industrial complex, but is present through all agencies, pushing for more and bigger contracts.
Are there actually "hundreds of billions of dollars" out there? Or is this another red herring like earmarks that amounts to a few billion here and there?
Yes. That's my point about news sources. If you're surprised at this building waste and unaware of many others, then you might want to branch out in your reading.
Or is this another red herring like earmarks that amounts to a few billion here and there?
I'm not sure if you're just trolling me here, but I'll bite. The problem with earmarks isn't the total that they add as a broken-out line item. It's the corruption of a system that creates you-scratch-my-back incentives for passing unnecessary legislation.
The cost of earmarks isn't the line item. It's the cost of the entire boondoggle law that wouldn't have been passed without the back room incentives.
> Yes. That's my point about news sources. If you're surprised at this building waste and unaware of many others, then you might want to branch out in your reading.
I'd love to see a source that shows "hundreds of billions" in actual waste, in an itemized fashion.
> The cost of earmarks isn't the line item. It's the cost of the entire boondoggle law that wouldn't have been passed without the back room incentives.
The idea of earmarks is to attach them to a law that was going to pass anyway.
> I'd love to see a source that shows "hundreds of billions" in actual waste, in an itemized fashion.
This is again my point. You're waiting for me to show up with links at your front doorstep showing you a perfectly digested and itemized list for information that you should be seeing all the time if you have a healthy list of news sources.
Even though it references Eric Holder's mentioning that fraud and abuse in Medicare and Medicaid is probably between $120 - $180 billion, that's not an itemized list. In your mind, I'm sure you think that crusso provided no evidence whatsoever that there's plenty of waste in the budget.
My guess is that your world view just doesn't include the possibility that the government could be tragically wasteful of money. I'm sure that if you looked around at the Heritage Foundation, they probably have itemized lists, but you'd disregard that because of the source, I'd suspect. Really, the only groups you trust to tell you that there was hundreds of billions of dollars in waste wouldn't dare do that kind of research in the first place.
The idea of earmarks is to attach them to a law that was going to pass anyway.
That makes absolutely no sense. Why would they include earmarks in a bill if they were superfluous. They're there to grease the wheels. They're incentives to get congressional votes. They're bribes, but legal.
The article you linked to does almost nothing to make the case for poor management of Medicare / Medicaid. In fact, it does a pretty good job of saying that a program which provides health services for 1/6th of our population is waging a pretty darn good fight against an army of people who want to defraud it. Probably the only thing in the article that could be called "waste" is the policy of "pay and chase", which they then immediately note is improving.
Sure, there are an army of medical professionals that want to scam the Fed, but its not like Medicare / Medicaid's just sitting there and letting them be scammed. I mean really, if you're going to pick on a gov. program, you probably shouldn't go for one of the better run ones in the Fed, maybe try the DoD. Now them,... they've got some waste. How many times has the DoD said it doesn't want more tanks? "Oh, what's that, you say you want more tanks? Here's 50 billion. Make it happen. In my district."
Yet another example showing that no profitable company could ever be run like the Federal government and continue to exist. Aren't you glad you paid your taxes on time this year?
You should study companies and their real estate portfolios. There are a number of companies sitting on vacant properties that are intentionally unused. As an example, most pharmaceutical and chemical companies have large unused facilities that sit empty while the company is churning out billions of profits a year. The main reason is that these sites are contaminated and the companies are afraid of liabilities from selling the properties. Funnily enough, this is exactly the first hurdle the article says the federal government faces in selling their properties. Guess the corporate world ain't that different.
The difference is that one isn't forced to unwillingly pay those unaccountable companies (the scourge of a government's corporate subsidies notwithstanding).
Creating good governance(whether it's government, charities, corporations, and so on) is one of the biggest unsolved problem for humanity.
Yes, we function quite well on some level. We wouldn't have a civilization otherwise. It does seems that the government is so inefficient in many way that reducing many of them would probably lead to an order of magnitude of improvement in the lives of human beings, economically and socially.
A bunch of salespeople (legislators), chosen mostly for the feature changes they say they want to make (or prevent) sit down in a room and negotiate. Developers (staffers), chosen by those salespeople, turn it into code - which, after some audit (but no testing) is pushed straight into production. It is then patched in the field by QA & tech support (judges and lawyers) - those patches never make it back into the source.
Also, revolution isn't refactoring - it's starting a complete rewrite after you turn off your production system, and is usually every bit as bad an idea as you'd expect.
I love the software analogy, because it puts people who think we need revolution in the same camp as people who think Microsoft should rewrite Windows.
Amazing. It would be great to have some sort of open-sourced effort to catalog government owned buildings. Kind of like an OpenStreetMap. I don't see why most govt buildings shouldn't be publicly listed on a database; they can obviously classify the ones they don't want everyone knowing about.
$1.7B is a lot. I'd be curious how much they'd (we'd) get if the government sold used buildings that are now in expensive areas. For example, the Department of Transportation has a huge gigantic building in the middle of Kendall Square in Cambridge, MA, which is the most expensive office space in New England. I have to imagine the land alone is worth a ton.
Nothing stops us from doing this. We issue Freedom Of Information Act requests to agencies via https://www.muckrock.com, and then we integrate it into OpenStreetMap.
It's just a matter of someone taking the time to do it.
> It's just a matter of someone taking the time to do it.
And there's the crux of the matter; it takes a ton of time, and few people care enough to invest that time. And even if there is someone that cares - like the people / organization listed in the article - their efforts will only make a dent in this issue, which is exacerbated by the heaps of paperwork and whatnot they have to go through.
The General Services Administration (more specifically the Public Building Service) is responsible for maintaining the federal building portfolio and leases for itself and other agencies. You can see all GSA-owned buildings from here: http://www.gsa.gov/portal/content/104797
However, many agencies manage some or most of their buildings (VA, IRS, and others). DoD is completely separate.
Property disposal (or renovation) is further complicated by historic preservation requirements as well.
While talking to someone in NYC government a while ago, they were lamenting the fact that there wasn't a unified system to view all of the city properties, who was occupying them, and how much vacant space there was within the buildings. Fully vacant buildings are one problem, but if you have 100 10,000 sq. ft. office buildings and only 5,000 sq. ft. each is being used, that is a completely different problem -- but equally important in terms of eliminating waste or saving money.
That's a tricky problem to solve. I work with the NYC government on some projects, and they actually do seem to keep pretty decent track of all of the city's properties (at least, my experience with this is with the tax and finance people who assess every property in the city annually).
Empty space is generally not fungible. A vacant upstairs floor of a police department couldn't be turned into elementary school classrooms, for example. But the NYC government owns a lot of properties, and rents space from private owners, and there are definitely inefficiencies that could be eliminated. Tracking all of this would be a fun project to work on.
What is the incentive to say you're not using the space? It could force you to move to a more cramped location and extend your commute. And your agency's budget is now permanently lower, with no benefit you can see.
Better to just fill up the space somehow; even it it means hiring do-nothing people.
Financial incentives could be set up between agencies. Say for example DOT has extra office space in one building and they can rent it out to DSNY for cheap. Then DOT gets money they wouldn't otherwise, and DSNY can pay less than they might pay to rent office space in a private building (This is just an example and I don't know if DSNY actually rents, but I know some agencies do).
This works if you can relocate teams of people together (along with their stuff). Also advances in technology help here, as you can scan paperwork into a document management system and virtualize peoples machines so that it matters less where they are actually sitting. The city is doing some of this, but they move slowly.
What you just described sounds like a lease, to me. I'm sure that's fairly common.
The problem you run into here is: who gets the lease money? Why should the DOT get extra money just because they bought a building that is too big?
The root of the problem is that budgets are based on perceived need with no downward pressure. The DOT has every incentive to make the perceived need higher, and leasing out half of their office space is not a good way to do that.
To be honest, I don't know much about how this works in NYC government.
I think DCAS is the agency that manages all of the city properties. So individual agencies might not have much control over their own space. DCAS might need to be the ones to establish the incentives.
I was under the impression a great many of the buildings counted are on military bases. that in itself is an issue because as with post offices Congressmen step and dictate what is open and what isn't
Clearly a business opportunity. GAO/GSA are likely to fund an improvement to their database (http://www.gao.gov/products/GAO-12-645). If any other small-outfit contractors out there want to form a coalition and put together a preemptive proposal, shoot me an email. I have some contacts who work in procurement who may be able to advise on the best approach.
This is pretty insane. It seems like such a simple problem to solve (eg, send auditor with an app on his phone, input building condition, occupancy, etc. sync back to database that has other information, value etc.) But the regulatory hoops and the bureaucracy involved just break everything. It blows my mind that we don't try to approach these problems more rationally.
It's hard because there isn't a reliable source of data to begin with. How do you solve a "simple problem" with an auditor and an app if you don't know where to send them?
Every one of those regulations is perfectly reasonable. Yet when put together they lead to empty buildings staying empty, expensive and useless. This is a very uderappreciated consequence of regulation in general.