Comment on DOS-2011-0134-0001

Form DS 7007 is deeply flawed in many respects. Most of these have been submitted by the Alliance. I would like to focus on one issue only - with respect to this Form: According to the Dept. of State's Public Notice 7695, the "Average Hours per Response: 1 hour" is vastly understated. Circulating this paper Form from the U.S. sponsor to the overseas SWT applicant and back to the U.S.-based employer will take many hours of tracking, following up, FedExing, logging in and out, etc. There will be significant additional costs - not only of postage, telephoning, e-mailing, driving, etc., but as this Form would be piggybacking on the already existing job verification forms each SWT organization already uses, organizations will have to hire additional help... This at a time of already reduced number of DS forms - and income. Let's support the administration's green efforts by at least saving the trees and make this form electronic. I believe that the "Average Hours per Response is 3 hours at the least, plus large expense in postage, labor and processing costs - in the times of diminishing returns.