257 



Based upon the above, clearly the NPS's methodology is statistically unreliable, due 

 to the nonrandom nature of the samples reported, the small sample numbers, and the 

 complete absence of other data essential to properly test the statistically validity of the D&B 

 Industry Norms and the RMA Statement Studies. Because of this unreliability, the validit\ 

 of an\ inferences drawn form the D&B Industry Norms and the RMA Statement Studies 

 cannot successfiilly withstand normal statistical validity testing. It is thus fatally flawed for 

 the purposes employed by the NPS. 



There is a standard and fundamental procedure in the field of quantitative statistical 

 analysis known for measuring the degree of confidence one may place in inferences about 

 an entire population, when those inferences are based upon such information contained in 

 D&B Industry Norms. The D&B Industry Norms and the RMA Statement Studies data is 

 clearh and simply be\ond the reach of such flindamental statistical evaluation because of its 

 incomplete nature and because of the unreliable statistical techniques employed. And D&B 

 itself acknowledges as much in disclaimers it publishes along with its information. The onh 

 possible conclusion is that the data has absolutely no validity for the purposes employed b> 

 the NPS. 



In my professional opinion, even if the D&B Industry Norms and RMA Statement 

 Studies were based upon data properK collected in accordance with established statistical 

 standards, the NPS clearly and fundamentally misuses such data in its NPS-48 process. It 

 is fundamentally inappropriate to use any data classified by SIC codes for the purpose of 

 setting a predetermined anticipated profitability le\el of any particular business based upon 

 SIC code classifications. Generally, four digit SIC codes, such as those employed in the 

 D&B Industry Norms and RMA Statement Studies, include too many varied businesses to be 

 properh utilized for tiiis singular purpose. In other words, rarely does a particular business 

 sufficientiv ""nt"" into anv four disit SIC code to enable anvone. includina the NPS. to 



