Length or Size of FAR over time?

You'd have to decide what versions of the FAR to check. You'd probably have to check the official CFR version published by the GPO. Should be easy to do, though tedious.

It would be easier just to check the 1984 version against the 2020 or 2021 version.

But page counts won't tell the whole story.

BrettK said:

We know that amendments are added and the number of pages increases but has anyone ever seen an historical account, by year, of the increased length of the FAR since its inception? Even better would be a chart showing the change in volume.

Any page count comparison would have to be in a uniform format, using the same font and size lettering, etc.

In 1984, in the GPO pamphlet format, FAR Vol. I, Parts 1 - 51 was 1,276 pages; Vol II, Parts 52 - 99 was 552 pages, for a total of 1,828 pages.

In 2020, in the GPO pamphlet format, FAR Vol 1 was 1,148 pages; Vol II was 525 pages, for a total of 1,683 pages.

Those page counts include covers and all front and back matter. So in that format the FAR shrank.

I did not investigate further.

The pamphlet edition for 2021 is not yet available.

The current edition will grow some when they add the new Part 40.

Yes, this is my exact problem. I know the FAR has grown and not shrunk over time. I also know the electronic versions counting pages are not exactly comparable to the paper versions of yesteryear. What might be a good way to illustrate visually the increase in complexity over time? I would have thought someone would have already created a nifty infographic for this but it might me up to me to do.

Instead of counting pages, do a word count. But that takes a special effort.

BrettK said:

Yes, this is my exact problem. I know the FAR has grown and not shrunk over time. I also know the electronic versions counting pages are not exactly comparable to the paper versions of yesteryear. What might be a good way to illustrate visually the increase in complexity over time? I would have thought someone would have already created a nifty infographic for this but it might me up to me to do.

Try this.  It only goes back to 1999.  It doesn't answer your question but if you want to illustrate an increase in complexity, this might help.  On the left is the FACs since 1999.  On the right are the  FAR Cases.  Federal Acquisition Regulation Research.

bob7947 said:

Try this.

Interesting approach, Bob. Not sure I could effectively paint the complete picture using this but it is a different way to consider the problem for sure.

On 9/20/2022 at 11:05 AM, Vern Edwards said:

Instead of counting pages, do a word count. But that takes a special effort.

I don't think I have that kind of special effort in me, Vern.

BrettK said:

Interesting approach, Bob. Not sure I could effectively paint the complete picture using this but it is a different way to consider the problem for sure.

I don't think I have that kind of special effort in me, Vern.

Well, not manually. There is software that can do it. There are several such programs

Is there a reliable repository for all prior versions of the FAR that you would recommend as the source of truth? It's easy to get the most current, or sporadic yearly versions, but I cannot seem to locate all of them in one place in a standard format.

BrettK said:

s there a reliable repository for all prior versions of the FAR that you would recommend as the source of truth?

Acquisition.gov has archives going back to 1996. There may be archives going back further on the internet. Heinonline has archives going back to the beginning in the CFR pamphlet/pdf format.

For some reason, I was missing the archive section on Acquisition.gov. Got it now. Many thanks. If I get this made, I will share here.

If you're still looking, this old AT&L interview with Gansler has an infographic for the number of pages in the FAR from 1975 to 2011:

https://asc.army.mil/web/access-the-new-gansler-report/

The infographic cannot show the number of pages in the FAR from 1975 to 2011, because the FAR was not published until 1983. It took effect in 1984.

It's number of pages in the CFR.

That makes sense.

On 10/18/2022 at 9:41 AM, It_Depends said:

If you're still looking, this old AT&L interview with Gansler has an infographic for the number of pages in the FAR from 1975 to 2011:

Thank you for this! I still did word count but this is useful as well.

BrettK said:

Thank you for this! I still did word count but this is useful as well.

The information that it_depends referenced did not identify the number of pages in the FAR.

On 10/19/2022 at 4:01 PM, joel hoffman said:

The information that it_depends referenced did not identify the number of pages in the FAR.

I understand and I did not end up using it_depends' info. I have good word counts for the 1995 FAR and the 2022 FAR and compared them to the number of words in Harry Potter series for impact. I thought it came out nicely. If you're interested, the graphic is on this page and also embedded in the white paper that can be downloaded from the same page.

https://www.bidscale.com/whitepaper

@BrettKDid you write the white paper?

Just the growth in the 52.212-5 required "commercial" clauses is enough to make you want to give up on any hope of better days to come.

Vern Edwards said:

@BrettKDid you write the white paper?

It was a group effort. Thoughts?

BTW, the most interesting thing I learned about the FAR in terms of word count, having counted all years that were electronically available to me, was that it was not a linear expansion as I expected. There were some years parts were replaced or removed casuing a decrease from the prior year. It was much more of a jagged trend that eventually made its way upwards from 1995 - present.

@BrettKYes, some, but not for public disclosure.

Just now, Vern Edwards said:

@BrettKYes, some, but not for public disclosure.

Feel free to DM or email me. I'll put on a bulletproof vest just in case it gets ugly.

BrettK said:

BTW, the most interesting thing I learned about the FAR in terms of word count, having counted all years that were electronically available to me, was that it was not a linear expansion as I expected. There were some years parts were replaced or removed casuing a decrease from the prior year. It was much more of a jagged trend that eventually made its way upwards from 1995 - present.

Word count, in and of itself, is not a very important problem. Complication, complexity, and lack of clarity are much more important problems. If I had a choice between fewer pages and clearer text, I'd take clearer text.

BrettK said:

Feel free to DM or email me. I'll put on a bulletproof vest just in case it gets ugly.

I'll send a message to you at Wifcon mail. It won't be ugly. The paper isn't bad. It's just more of what we've heard a hundred times, with slightly different emphases.

I swear, I think I'll puke on my keyboard if I read innovate, innovation, or innovative in one more white paper. And I don't think technology will solve our problems. It has already made our old problems worse. But if technology is what you're selling...

Vern Edwards said:

Word count, in and of itself, is not a very important problem. Complication, complexity, and lack of clarity are much more important problems. If I had a choice between fewer pages and clearer text, I'd take clearer text.

Really interesting idea. So I ran an older version of the FAR through Gunning Fog readability index. According to that non-scientific reading, the old FAR was written at the 16.55 level (college senior to college graduate).

The most recent FAR is written at 14.32 (college sophomore to junior).

From a reading index level, it is less complex now. I'm sure that doesn't track with your findings.

Did you run the entire FAR or just a part? If you ran the entire FAR, you probably got a lower number than if you ran particular parts. Try running Part 13, Part 25, and Part 31 and tell us what you get for each.

I just ran 15.306, 31.205-6, 52.212-4, and 52.215-10 through Gunning Fog and got the following results:

15.306 --- 17.3 difficult to read

31.205-6. --- 12.6 hard to read

52.212-4 --- 12.6 hard to read

52.215-10 --- 20.9 very difficult to read; the highest level of difficulty

Vern Edwards said:

Did you run the entire FAR or just a part? If you ran the entire FAR, you probably got a lower number than if you ran particular parts. Try running Part 13, Part 25, and Part 31 and tell us what you get for each.

Here is the data I got for the parts you mentioned. Still looks like a decrease in Gunning Fog for each:

Part 13

1995: 13.98

2022: 13.69

Part 25

1995: 13.51

2022: 13.25

Part 31

1995: 16.55

2022: 15.41

Vern Edwards said:

52.215-10 --- 20.9 very difficult to read; the highest level of difficulty

So in order to understand Price Reduction for Defective Certified Cost or Pricing Data the reader is expected to have, what, two PhDs?

I tried getting a score for this, but it came back as undefined:

Quote

If an emergency or unanticipated event interrupts normal Government processes so that proposals cannot be received at the office designated for receipt of proposals by the exact time specified in the solicitation, and urgent Government requirements preclude amendment of the solicitation, the time specified for receipt of proposals will be deemed to be extended to the same time of day specified in the solicitation on the first work day on which normal Government processes resume.

This was the excerpt from FAR 52.215-1 that I used for The Plain Language Writing contest a few years ago.

I just checked FAR 52.215-1 as a whole, and the Gunning Fog result was 18.1, difficult to read, college graduate level.

For more on computerized readability tests see https://www.researchgate.net/profile/Dennis-Fisher-3/publication/15614441_How_reliable_is_computerized_assessment_of_readability/links/0046352e889c94bea9000000/How-reliable-is-computerized-assessment-of-readability.pdf

BrettK said:

So in order to understand Price Reduction for Defective Certified Cost or Pricing Data the reader is expected to have, what, two PhDs?

I have used that contract clause, 52.215-10, as the basis for a reading test in classes for more than 15 years. In a typical class of 25, in which one-third to one-half of the students have graduate degrees, mostly MBAs, but also some law degrees, maybe one or two students get the right answer for the right reason. I have put experts to the test, and most have answered incorrectly.

Professional reading is a professional skill.

On 10/21/2022 at 7:43 PM, Vern Edwards said:

I have used that contract clause, 52.215-10, as the basis for a reading test in classes for more than 15 years. In a typical class of 25, in which one-third to one-half of the students have graduate degrees, mostly MBAs, but also some law degrees, maybe one or two students get the right answer for the right reason. I have put experts to the test, and most have answered incorrectly.

Professional reading is a professional skill.

I believe I ran into this via one of the classes often advertised at the top of this page.  As I recall, it was in the form of a scenario - and I was called upon to present my opinion of that scenario in front of the class.  As I presented, a number of classmates poked at my logic, suggested alternatives, just said I was wrong, etc.  In the end, my fellow students did not agree with my assessment of the scenario.   And where I feared I was being fed into the buzz saw of failure, it was instead a proud moment for me when the teacher (not you) told me I got it exactly right - the reasoning, the math, and the resulting opinion.  

I don't have fancy degrees and don't really do this stuff for a living, but...I can diagram a sentence.  They told me that someday it would come in handy!

And to add to the original (interesting) conversation:

While the growth of pages and words are one measure of complexity, I find that the number and degree of edits are what really drives challenges in maintaining compliance against a changing FAR.  Simply put, next year's FAR could have the same number of pages and words but be wildly different via re-writes, deletions/additions, etc.  

Measuring that is difficult and would depend on exactly how such changes are reported/captured.   But it might look like:

• # of words, sentences, pages, clauses or sections that have changes, or
• % of words that have been replaced or added vs. what stayed from the year before.

If the last one could be pretty revealing - how long does it take the FAR to be 'turned over' (where the cumulative number of changed words > the total words in the FAR) - 30 years?  More? Less?   Is the rate of change increasing/decreasing/steady?   Is there any trend in the nature of the changes, say from wholesale re-writes to minor tinkering (like to update thresholds or references)?   My gut tells me there's a steady-to-rising increase in the changes YoY, and that the changes are more of the 'tinkering' type over time.    But I really have no idea.

jayandstacey said:

I believe I ran into this via one of the classes often advertised at the top of this page.  As I recall, it was in the form of a scenario - and I was called upon to present my opinion of that scenario in front of the class.  As I presented, a number of classmates poked at my logic, suggested alternatives, just said I was wrong, etc.  In the end, my fellow students did not agree with my assessment of the scenario.   And where I feared I was being fed into the buzz saw of failure, it was instead a proud moment for me when the teacher (not you) told me I got it exactly right - the reasoning, the math, and the resulting opinion.  

I don't have fancy degrees and don't really do this stuff for a living, but...I can diagram a sentence.  They told me that someday it would come in handy!

Ah, the defective subcontractor cost or pricing data case! Out of a class of 25 it is unusual for even one person to get the answer right for the right reason. I have given that scenario to defective pricing experts, and most of them get it wrong on the first try. And lawyers don't do better than others.

Well done!

jayandstacey said:

how long does it take the FAR to be 'turned over' (where the cumulative number of changed words > the total words in the FAR) - 30 years?  More? Less?   Is the rate of change increasing/decreasing/steady?

To get an idea of what is coming, see https://www.acq.osd.mil/dpap/dars/opencases/farcasenum/far.pdf