National Export Initiative
June 30, 2010 Federal Register - Requested Comments
By James R. Meenan

Experience Related to Comments Being Provided
For the past twenty years, I have been closely involved with assisting small and minority businesses to expand their trade operations through gaining better access to related Federal trade support programs. During that period, I have also served:
Summary Comments
President Obama’s issuance of an Executive Order creating the National Trade Initiative (NEI) was long overdue. As documented in a U.S. House Small Business Committee Hearing on April 26, 2006 and follow-on reviews by seven Inspectors General (see my Internet site for details at, the then functioning Trade Promotion Coordinating Committee (TPCC) and its legislative required National Export Strategy where sorely lacking in performance, clarity and results. In fact, the review of the Federal Department receiving the largest amount of trade promotion funding found that while that organization knew which private institutions received those promotion funds, it did not know how the funds were used or if any real trade expansion resulted from those expenditures.

In now moving forward, it is vital that a comprehensive NEI Plan be developed that establishes real measurable goals that are to be achieved over its five year period. These goals, along with their companion semi-annual and annual benchmarks of performance, must be documented in advance in terms of the qualitative and quantitative factors that will be measured so not only progress can be measured but a true determination made that the goals have been achieved and/or what shortfalls hindered their progress and achievement.

While, the TPCC needs to work on establishing these performance goals for the overall NEI, it must also insure that each member Federal organization's own NEI plans fit well together and will in fact achieve the overall goals. Thus, each member's submission must be put to a thorough test to determine if it adequately augments the overall NEI and likewise has good clarity and sound performance benchmarks. In past efforts, TPCC members would simply outline events they undertook during the year and attempt to link them to some broad objective without much clarity or being able to confirm what real trade improvements resulted. NOTE: I recently had the pleasure to review the NEI Plan for a critical TPCC member. While the organizations goals appeared sound and on target, they lacked clarity in regards to spelling out what qualitative and quantitative factors would signal achievement of those goals. More concerning, under its performance section, I found it failed to establish any periodic benchmarks that would indicate if they were on track to achieve the goals or not.

Most important to a successful NEI, the Executive Office of the President must, this time, take an active role in providing the leadership and oversight measures, including budgetary reallocations were needed, to insure the Initiative goals are achieved in a timely and fully documented manner. That Office will need to remain active in promoting semi-annual and annual performance reviews of each TPCC member's NEI Plans and be prepared to take all necessary corrective actions where needed. It's this senior level oversight that in the past further impeded real trade improvements.

Over the years, I have found many Federal trade promotion efforts that yielded good results. In many cases they were the direct result of "INNOVATIONS" introduced by the employees running the programs whether they be at Commerce, State, USAID, OPIC, Ex-Im Bank or SBA. It would be good if the NEI could help foster new program innovations by encouraging enhance public/private sector coordination to better insure the trade promotion efforts being offered truly meet the exporters’ needs, particularly those of small, medium, and minority businesses.

(Based on U.S. House Small Business Committee Hearing & Inspectors General Reviews) With the U.S. trade deficit in goods and services running approximately $65 billion or more per month, so far in 2006, the U.S. is well on its way to break the 2005 record annual trade deficit of $724 billion. So far this year, through the end of February, the accumulated U.S. trade deficit with China, alone, is somewhat worse, totaling $31.75 billion, up $2.63 billion from the same period in 2005.

Equally threatening is the U.S. dependence on the inflow of foreign capital to finance these deficits through the purchase of Federal debt instruments, which in turn lend support for a strong dollar that continues this deficit to debt cycle.

Congress, in the Export Enhancement Act of 1992, established the Trade Promotion Coordinating Committee (TPCC) with two main purposes: Two of the key duties assigned the TPCC were to: Over the past 14 years, TPCC has had mixed results in fulfilling its Congressional mandates. Without clear budgetary influence or a strong will to exert oversight authority of the numerous federal entities that make up its members, currently totaling 21, the TPCC’s impact on unifying the diverse U.S. trade promotion and finance operations has been negligible.

Our trading partners are well organized and effectively market their small businesses in the expanding global markets, particularly in China. With small businesses offering the best prospect to boost export growth, we need to redouble our efforts to help them achieve this goal.

It is time the U.S. put some order into its federal trade promotion and financing operations through strengthening the TPCC by: Building on the adverse findings from the April 2006 Hearing, some seven Inspectors General were engaged to undertake specific federal department reviews of the identified shortcomings.

National Export Strategy
In September 2007, a Consolidated Inspectors General Report was issued covering the Congressionally Mandated National Export Strategy and the operations of the U.S. Trade Promotion Coordinating Committee.

In summary, the report concluded that the National Export Strategy which had been submitted to Congress did not clearly articulate a strategy, establish consistent goals for promoting exports, align agency-specific strategic objectives with government-wide export promotion strategic goals, or measure progress toward meeting those goals. To correct these shortcomings, greater effort was needed by the Trade Promotion Coordinating Committee to outreach to and engage all federal departments to better prepare and implement a comprehensive strategy.

Trade Facilitation
In March 2007, a Commerce Department Inspector General's Report was issued covering the trade facilitation operations of the Department including its officers assigned overseas, within the states, and at the multi-lateral development banks.

In summary, the report highlighted the urgent need to manage the identified trade leads so that U.S. businesses could better take advantage of the business opportunities. It identified various disconnects within the federal government that impeded the efficient and effective implementation of a sound export strategy.

In February 2007, an Agriculture Department Inspector General's Report was issued covering the use of the large trade promotion funding that has been made available on a yearly basis.

In summary, the report documented the fact, that while the Department knew which private organizations received the funding provided for trade promotion, it was unable to document how the funds were used or if any real results were achieved.

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