Advocacy supporting statement

5

Supporting Statement for Paperwork Reduction Act Submissions

A1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

1. This collection of information is being sponsored by the SBA’s Office of Advocacy. As the federal office responsible for examining the contributions and challenges of small businesses in the U.S. economy, one of Advocacy’s goals is to initiate internal and external research projects that examine these issues. See, 15 U.S.C. 634b, a copy of which is attached. This data collected from the proposed survey will provide Advocacy with a better understanding of the role of small business and entrepreneurship in the U.S. economy. As noted below in our response to B4, we seek approval to conduct a pre-test with 25 respondents.

A2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

2. This survey is intended to improve understanding of the relative roles of immigrants and native-born citizens in founding rapidly growing U.S.-based high-technology companies.

A3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

3. The information will be collected through a telephone survey. The telephone survey is automated through the use of Computer Assisted Telephone Interviewing (CATI) software and equipment. A web-base survey was considered. Prior experience with such surveys shows that a web-based survey would not be as effective as a telephone survey, given the difficulty of collecting accurate e-mail addresses for this population and the very low response rates in such surveys.

A4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

4. There are no available data that would enable us to assess the population of firms (rapidly growing high-technology firms) that is the target of this survey. The contractor for this survey has reviewed similar research efforts and found that none focused on the same population of firms that is the focus of this survey.

A5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

5. The collection will not have a significant impact on small entities. The survey will be short (estimated time of completion of ten minutes) in order to minimize the burden and raise the response rate.

A6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles

to reducing burden.

6. The research program of the SBA Office of Advocacy will be diminished if the survey is not conducted, which in turn would adversely impact Advocacy’s ability to carry out its functions.

A7. Explain any special circumstances that would cause an information collection to be conducted in a manner…:

7. There are no special circumstances.

A8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments.

8. Advocacy published the 60-day comment notice in the Federal Register on January 14, 2008, at 73 FR 2299. We received a total of 1 comment. This comment expressed support for the objectives of the survey, but also suggested that the contractor may face challenges in securing a valid sample and an acceptable response rate. Procedures described in Section B of this supporting statement, including pretesting, are intended to address these challenges.

A9. Explain any decision to provide any payment or gift to respondents, other than re-enumeration of contractors or grantees.

9. No payments or gifts are to be provided.

A10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

10. Respondents are informed prior to the survey that their responses will be kept confidential. The contractor will retain all information collected and provide a report based on aggregated data to the Agency.

A11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly

considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

11. The survey will ask about the country of birth and, for foreign-born respondents, citizenship status and length of residence in the U.S. The survey will also ask U.S.-born respondents about their race and ethnicity. Knowledge of the nativity and ethnicity of high-technology entrepreneurs is important for researchers and for policy-makers at the national and state levels. High-technology entrepreneurship is one of the most important elements of economic growth for states and the nation as a whole in an era of global economic competition. The supply of entrepreneurs may be a constraint on the entrepreneurial process. A better understanding of the characteristics of high-technology entrepreneurs, especially those who are born outside the U.S., who comprise a growing and particularly poorly-understood group, may provide insights into means to increase the supply. These data may also provide insights into whether the barriers to high-technology entrepreneurship faced by immigrants are similar to or different from those that face U.S. born high-technology entrepreneurs as a whole and those that face U.S. born high-technology entrepreneurs from racial and ethnic minority groups.

A12. Provide estimates of the hour burden of the collection of information. The statement should:

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden

hours for customary and usual business practices.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.

12. We expect to have 1000 complete responses to a survey of approximately 10 minutes in length. The total burden is therefore approximately 167 hours. Using the national GS-14, step 5 hourly rate ($44.04) from OPM Salary Table 2008-GS, the estimated total cost to respondents will be $7354.68.

A13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

13. Other than the time devoted to responding to the survey, there are no costs to the business.

A14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

14. The survey and data analysis are the main tasks of the above-referenced contract, which totals $92,700. This cost is included in the annual research budget of the SBA, which would have been devoted to a different research project if it had not been spent on this one.

A15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

15. There are no changes or adjustments.

A16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

16. The results of the project will be submitted to the SBA Office of Advocacy as a report and may be published by the Office as a working paper. Academic researchers associated with the project may use the results in further publishable academic work. The survey will be conducted over an approximately two-week period in the late spring of 2008. The final report is scheduled to be delivered to SBA by September 1, 2008. No personal or individualized data will be reported or published.

A17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

17. We are not seeking such approval.

A18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

18. No exceptions are sought.