0625.0241.SuppStmnt.042710

SUPPORTING STATEMENT

U.S. DEPARTMENT OF COMMERCE

International Trade Administration

ITA Environmental Technologies Non-Tariff Barriers Survey

OMB CONTROL NO. 0625-0241

A. JUSTIFICATION

This request is to extend the Office of Management and Budget approval.

1. Explain the circumstances that make the collection of information necessary.

The Office of Energy and Environmental Industries (OEEI) is the principal resource and key contact point within the U.S. Department of Commerce (DOC) for U.S. energy and environmental technology companies. OEEI’s goal is to facilitate and increase exports of environmental technologies, goods and services by providing support and guidance to U.S. exporters.

The environmental technologies industry has consistently cited the proliferation of non-tariff barriers as a factor that is making increased U.S. exports in this sector more difficult. This factor has been cited across all subsectors of environmental technologies products and all global geographic regions. The collection of information related to the experience of U.S. exporters with regard to these non-tariff measures is essential to the mission of OEEI. It allows accurate market analysis as well as support to industry in its export efforts and to the U.S. government in its trade negotiation efforts. This capability is especially important in light of U.S. efforts to negotiate a number of regional and multilateral agreements on trade and other policies with major trade implications that will incorporate the goal of liberalized trade in environmental technologies. OEEI has played a significant advisory role in these types of U.S. trade agreements and expects to continue to fulfill this role. In particular, this capability will be of critical importance to the DOC’s efforts to analyze and otherwise provide support to U.S. participation in emerging international global climate change and greenhouse gas emissions control initiatives. Collection of this information will allow OEEI to retain its ability to provide the most accurate and effective support to these and other environmental industries trade efforts in the future. The ITA Environmental Technologies Non-Tariff Barriers Survey (Form No. ITA-4150P) is used to collect this vital information.

The information will not be presented as a definitive representation of the experiences of U.S. industry in export markets, but will rather be used to help OEEI identify potential non-tariff trade barriers for further U.S. government investigation.

2. Explain how, by whom, how frequently, and for what purpose the information will be used. If the information collected will be disseminated to the public or used to support information that will be disseminated to the public, then explain how the collection complies with all applicable Information Quality Guidelines.

Information collected via this survey will inform the DOC’s efforts to analyze the competitive affects of trade policies and proposals for the U.S. environmental technologies industry.

OEEI’s goal is to facilitate and increase exports of energy and environmental technologies, goods and services by providing support and guidance to U.S. exporters. One aspect of this is to help reduce tariff and non-tariff trade barriers. OEEI works closely with other agencies including the Department of State and the Office of the U.S. Trade Representative on trade negotiations and trade liberalization initiatives. The information collected by this survey will be used to support initiatives by these and other U.S. government agencies to maintain a current, relevant snapshot of non-tariff measures that create trade barriers for U.S. exports of environmental goods and services.

OEEI staff, on occasion, will advise clients in speeches and presentations that the form exists, but most respondents are aware of the survey while visiting the website.

The results of the survey will not be reported to the public in any tabular form.  However, information from the survey becomes a part of OEEI’s analysis of the industry and may be included as a part of that analysis in various presentations to industry and interagency audiences.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological techniques or other forms of information technology.

This information will primarily be collected via the environmental industry’s home page on the ITA web site www.trade.gov. Based on previous history, the vast majority (approximately 90%) of the responses will be submitted electronically.

Using Internet technology allows us to drastically reduce the paperwork that would otherwise be required. Collecting the information via the web site allows users to complete the form easily, increasing the probability that concerned U.S. exporters will reply. This method of collection will be augmented by hard copy forms that will be distributed periodically at major environmental technologies trade events. Respondents will be invited to complete these forms and send them back via fax.

4. Describe efforts to identify duplication.

The survey form was developed and is mainly distributed, aggregated, analyzed, and reported by OEEI. No other agency collects identical information. In fact, the information collected via this survey informs OEEI’s input into the initiatives of other agencies and interagency processes.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

The use of a standardized form, criteria, and instructions are utilized to help ensure that the burden on small businesses is minimized. In addition, the amount of information requested has been reduced to the minimum necessary to evaluate viable applications. This was ensured, in part, by consulting with a number of small businesses in developing the information and format of the survey form.

6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.

Non-tariff measures can include technical standards, product design requirements, licensing regulations, and more. It is an area as dynamic as the development of the international economies that might use them. The regular collection of this information is necessary to keep OEEI’s understanding of this critical international trade issue relevant and accurate. If this information is not collected or collected less frequently, it would leave OEEI and the agencies that seek its input operating without a knowledge base while trying to negotiate environmental agreements, trade agreements featuring environmental liberalization, greenhouse gas agreements, more.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

N/A.

8. Provide information of the PRA Federal Register Notice that solicited public comments on the information collection prior to this submission. Summarize the public comments received in response to that notice and describe the actions taken by the agency in response to those comments. Describe the efforts to consult with persons outside the agency to

obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

The Federal Register Notice soliciting public comment was published on February 24, 2010 (Vol. 73, pg. 8300). No public comments were received.

A number of environmental firms of various sizes and specialties assisted with the crafting of the content and design of this form. This form was developed through consultation with other agencies and offices of the U.S. government and private industry.

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

N/A.

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

The information collected will remain business confidential and will be used only by ITA staff in assessing the applicant’s experience as a part of the broader environmental industry or one of that industry’s specific subsectors.

The following information is stated on the survey –

‘Freedom of Information Act: Information submitted to the government may be subject to disclosure pursuant to the Freedom of Information Act. However, all confidential commercial information will be protected from disclosure to the extent permitted by law. You will be notified in advance if any such information submitted by you becomes subject to release pursuant to a Freedom of Information Act request.’

11. 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.

The survey does not contain questions of a sensitive nature.

12. Provide an estimate in hours of the burden of the collection of information.

Time to No. of No. of Total

Complete Respondents Responses Hours

10 minutes 200 200 (1 each) 33

TOTAL ANNUAL BURDEN HOURS: 33

The estimated average private sector salary for persons responding is $35 per hour.

Estimated Annual Labor Cost to Respondents: $3,500 (Total Hours (100) x Average Salary ($35).

13. Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in

Question 12 above).

N/A.

14. Provide estimates of annualized cost to the Federal government.

The average public sector salary for persons processing the application is $25 hour.

Estimated Annual Cost to the Federal government: Total Hours (100) x Average Salary ($25) = $2,500.

15. Explain the reasons for any program changes or adjustments.

None.

16. For collections whose results will be published, outline the plans for tabulation and publication.

The results will not be reported to the public as a collective set of data, though results may be analyzed and cited, as one source of information supporting OEEI recommendations to the U.S. environmental industry and other U.S. government agencies, as a part of policy processes.

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

The OMB number and expiration date will be displayed on the form.

18. Explain each exception to the certification statement.

None.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection of information does not employ statistical methodologies.