MBDA SuppStmt Global Commerce Survey EmergRevRequest 052810

SUPPORTING STATEMENT
U.S. Department of Commerce
Minority Business Development Agency
Survey of Minority-Owned Business Participation in Global Commerce
OMB Control No. 0640-XXXX

A.

JUSTIFICATION

This is an emergency review request to survey minority-owned businesses to identify their
participation in global commerce and to establish benchmark data. The requested
approval date is May 12, 2010.

1. Explain the circumstances that make the collection of information necessary.
On March 11, 2010, President Obama signed Executive Order 13534 entitled the National
Export Initiative. The President’s Initiative calls for “doubling exports over the next 5 years by
working to remove trade barriers abroad, by helping firms -- especially small businesses -overcome the hurdles to entering new export markets, by assisting with financing, and in general
by pursuing a Government-wide approach to export advocacy abroad.”
In support of the President’s Initiative, the Minority Business Development Agency (MBDA)
proposed to do a research study entitled, “Minority Business Contributions to the U.S. Economy
through Global Commerce,” and to release it during MBDA’s National Minority Enterprise
Development (MED) Week Conference, scheduled for August 25-27, 2010 in Washington, D.C.
This year’s conference theme is “Strategies for Growth and Competitiveness in the Global
Economy.” The MED Week conference is MBDA’s largest national event for large corporations
and minority business enterprises. The conference brings together over 1,000 attendees
including corporate executives, government and non-profit organization leaders, academicians,
and other stakeholders with the purpose of discussing strategies to promote the development and
growth of minority businesses.
On April 12, 2010 the National Oceanic and Atmospheric Administration awarded a contract to
Minimax Consulting on behalf of MBDA to develop the proposed study. The company
conducting the study proposes to survey businesses to identify the participation rates of
minority-owned businesses in global commerce. Currently there are no sources of data available
that provide this kind of information. It is necessary to conduct a survey to establish benchmarks
of minority business participation rates in export sales of goods and services, international trade
including trade with fast growing markets, and identifying barriers to global commerce. The
survey, to be completed by businesses voluntarily, will also identify minority business access to
capital markets, experiences with trade barriers and regulatory issues, their potential to enter the
export market, and their position in global supply chains.

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The survey would be administered in early May, 2010 to ensure the timely analysis of data and the
development of conclusions to finalize and deliver a completed study to MBDA by July 30, 2010.
The study will be reviewed and cleared through various offices of the U.S. Department of
Commerce, including the Office of Policy, the Office of Public Affairs, the Office of Legislative
Affairs, and the Office of General Counsel, as well as bureaus such as the Economic Statistics
Administration and the International Trade Administration. A final draft of the study must be
completed and cleared by July 30, 2010 to meet review printing and publication deadlines in
August, 2010.

The emergency review and approval for the collection of the above stated information is
necessary to comply with the Minority Business Development Agency’s global commerce
initiative in support of the President’s National Export Initiative and to meet the production
deadlines for the presentation of the findings during the MED Week Conference, our most
visible and largest national conference. Findings from the proposed survey directly support the
President’s initiative by establishing benchmarks from which to measure minority business
growth in export sales, identifying barriers to international trade and providing recommendations
on how to increase minority business participation in global commerce.

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.
MBDA will administer the survey through the Minimax, the company that has been contracted
for this purpose. The information collected through the survey will be used to conduct research
in conjunction with the above noted award. This may be a one-time collection of data and all
responses from businesses surveyed are voluntary. MBDA is considering conducting a similar
survey in the future to measure progress of MBE participation rates in global commerce. MBDA
is also considering using an alternative method in the future: correlating data from the Census’s
2007 Survey of Business Owners with the Census Shipper’s Exports database. Currently this
data is not available for correlation, but may provide a more reliable method to measure trends in
MBE global participation rates in the future.
Currently, the proposed data sampling and survey would generate the best results for MBE
participation rates in global commerce. Following the analysis of results, data in aggregate
format will be included in the research study. The findings support MBDA’s global commerce
initiative and the President’s National Export Initiative. Findings will be released to the public
through the published research paper by the end of August 2010, following clearance from all
relevant Department of Commerce’s bureaus and offices. The research complies with all
MBDA’s Information Quality Guidelines:
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Survey design and sampling procedures will be specified to ensure objectivity and utility
of the information produced.

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Appropriate statistical sampling methods will be used to yield information with sufficient
precision and accuracy.

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The contractor will provide MBDA with a dedicated and secured server space for all data
collected to ensure integrity, and security of all gathered data.

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.
The collection of information will use web-based survey tools primarily for speed and data
collection validity. Minimax has worked with both web and live survey tools, and given the time
constraints as well as the population geographic distribution, web-based survey tools are a better
fit for this research study. Telephone based surveys are also an option; however, based on time
constraints costs, they are not optimal.

4. Describe efforts to identify duplication.
The data to be collected from this survey is not supplied through any other method available nor
by any other Federal agency. In administering this survey, duplicate entries will be prevented
through coding. Each participant will be given a unique identifier and following data entry, any
duplicate identifier will be flagged for review.

5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
Some proportion of MBEs is expected to be small businesses. The survey process utilized by
Minimax Consulting will be non-intrusive (not costly in terms of time and/or effort on behalf of
the participant) and efficient to minimize time spent by all respondents, including small
businesses. Efficiency refers to obtaining accurate survey responses in the shortest amount of
time possible.

6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
The timeline for the current research study requires an expedited surveying process to begin as
soon as approval is received. Not conducting the data collection would result in missing the
timelines of data release noted in Response 1 above. The survey is a central piece of the
research paper entitled, “Minority Business Contributions to the U.S. Economy through Global
Commerce.” Findings will help in establish benchmarks from which to measure minority
business growth in exports of goods and services, international trade, and trade with fast growing

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markets. The survey will also identify minority business access to capital markets, experiences
with trade barriers and regulatory issues, their potential to enter the export market, and their
position in global supply chains.
Without the survey it would not be possible to set benchmarks of minority business participation
in global commerce to measure the progress of increasing export sales as well as the
development of recommendations to increase the participation of minority businesses in
international trade. Findings are vital to support the President’s National Export Initiative.

7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
There are no special circumstances that require the collection to be conducted in a manner
inconsistent with OMB guidelines.

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.
MBDA was granted a waiver by OMB of the Federal Register Notice announcing the submission
of the emergency review request and requesting public comment.
MBDA consulted with the U.S. Census Bureau and the International Trade Administration (ITA)
regarding availability of data. We were told no source was available which contained the data
we are seeking through this survey. In addition, MBDA consulted with ITA and the U.S. Census
Bureau in the development of the sample methodology and survey, and made modifications to
the sampling and survey based on the conversations and input from these federal agencies.

9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts will be offered to respondents. MBDA does not expect that this
methodology will be needed to attain the requisite number of responses.

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10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
Responses from all potential respondents will be kept private to the extent permitted by law.
Specific information provided by respondent firms will not be released to the public except
otherwise required by the Freedom of Information Act. Data will be collected through an online
survey hosted at Minimax Consulting's secure server, and data security will be assured by 128bit SSL encryption during data transmission, restricted access to servers, and strict firewall
settings.

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.
MBDA will collect information regarding the ethnic and racial background of the business
owners surveyed, as well as if the business owner is Hasidic Jew. This information is voluntary.
This question is essential to distinguish participation rates between minority and non-minority
business in the global economy, as well as other business characteristics. It also ensures that
MBDA is operating within the parameters of Executive Order 11625 and 15 C.F1.R. part 1400,
which specifies the ethnic and racial and religious background of business owners the Agency
must serve to meet its mission of fostering the growth of minority-owned businesses.
According to MBDA’s Executive Order 11625 and 15 C.F1.R. part 1400, and for purposes of
determining eligibility to receive MBDA services, an MBE is defined as a business concern that
is owned or controlled (greater than 50 percent) by the following persons or groups of persons
that are also U.S. citizens or resident aliens admitted for lawful admission to the United States:
African Americans, Hispanics, Asian and Pacific Islander Americans, Native Americans
(including Alaska Natives, Alaska Native Corporations and Tribal entities), Asian Indians and
Hasidic Jews.

12. Provide an estimate in hours of the burden of the collection of information.
MBDA’s contractor, Minimax, estimates a final sample size between 2,000 – 4,000 respondents,
and estimates that each survey will take 30 to 45 minutes to complete. Therefore, the amount of
burden hours is estimated between 1,500 and 3,000 hours.
The larger numbers will be used to calculate the respondent, responses, and burden hours.

13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in Question
12 above).
There is no annual cost burden to respondents resulting from the collection.

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14. Provide estimates of annualized cost to the Federal government.
There is no additional annualized cost accrued to the Federal government beyond the amount
contracted to be spent on the survey. The research study was awarded in the amount of $42,750.
That amount also includes travel and presentations on the findings in public venues.

15. Explain the reasons for any program changes or adjustments.
This is a new information collection.

16. For collections whose results will be published, outline the plans for tabulation and
publication.
Data will be analyzed and findings in aggregate format will be published in the upcoming
research study entitled, “Minority Business Contributions to the U.S. Economy through Global
Commerce,” by August 2010. An electronic copy of the research study will be posted on
MBDA’s website. Hard copies of the research study will be distributed at the MED Week
Conference and through other venues. The data collection and publication will follow MBDA
Information Quality Guidelines.

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.
Not Applicable.

18. Explain each exception to the certification statement.
There are no expected exceptions to the certification statement.

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