0694.0119.SuppStmt.122909

SUPPORTING STATEMENT
U.S. Department of Commerce
Bureau of Industry and Security
National Security and Critical Technology
Assessments of the U.S. Industrial Base
OMB Control No. 0694- 0119

A. Justification
This is a request to extend the Office of Management and Budget’s approval of this generic
clearance information collection.
1. Explain the circumstances that make the collection of information necessary.
Under authority of Section 705 of the Defense Production Act of 1950, as amended and related
Executive Order 12656, the Bureau of Industry and Security (BIS) conducts surveys and
assessments of critical U.S. industrial sectors and technologies. Undertaken at the request of
various research and development (R&D), and planning agencies within the Department of
Defense and the Armed Services, BIS research and analysis provide needed information to
benchmark industry performance and raise awareness of diminishing manufacturing capabilities.
Many Defense agencies can no longer afford to conduct such comprehensive surveys and
assessments themselves, nor do they possess the legal authority to require industry responses.
This has made BIS=s survey authority and experience a cost-effective tool for monitoring the
U.S. defense industrial base. BIS has a long history of assisting government agencies and
industries to better understand economic trends and trade issues that impact vital sectors and
technologies.
Typically, such assessments are conducted under individual information collection
authorizations obtained by BIS from the Office of Management and Budget (OMB), a process
that can require a considerable amount of time to obtain. In all cases, the reason for OMB
authorization is to obtain permission (under the Paperwork Reduction Act) to collect sensitive
business information, generally through the use of a mandatory survey of an industry sector or
technology deemed critical to the nation=s security. It is not unusual for BIS to submit similar
survey instruments in support of each unique assessment, the primary difference is what
particular industry/technology is being targeted. The use of a generic clearance process (fasttrack) allows BIS to conduct the assessments in a shorter timeframe.
Most surveys, under this generic clearance, include questions to obtain essential employment,
financial, production, R&D, investment, export control and other needed data. Some surveys
include a few non-standard questions, depending on the industry and the needs of the client.

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BIS will invoke the Defense Production Act of 1950 (DPA), as amended, to collect and protect
the business confidential information submitted by the survey respondents. Executive Order
12656 delegates to the Department of Commerce the authority to assess the capabilities of the
U.S. industrial base to support the national defense; to develop policy alternatives to improve the
international competitiveness of specific domestic industries; and the capabilities of these
industries to meet U.S. defense program needs.
By conducting these studies in cooperation with experts from the private sector, academia and
other government agencies, BIS ensures that the final assessments provide useful findings and
recommendations for government policy-makers and industry leaders.

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.
Based on historical data, BIS=s Office of Technology Evaluation (OTE) anticipates the need to
annually conduct 3,000 surveys, averaging 8 hours each to complete, of domestic facilities
engaged in activity that is deemed critical to national security. This may include both prime
contractor and subcontractor entities, and limited public entities. A greater number of shorter
surveys, or a reduced number of longer surveys may be required. .
The data obtained from the surveys, which is not available from other sources, will be used to
prepare an assessment of the economic status and competitiveness of the targeted industry
sector or technology. Factors including employment, financial, production, R&D, investment,
export control, competitive outlook, and foreign sourcing are reviewed.
BIS typically conducts a survey and furnishes a final report within 12 to 18 months of the
formal request.
The Section 515 Information Quality Guidelines apply to this information collection and
comply with all applicable information quality guidelines, i.e., OMB, Department of
Commerce, and specific operating unit guidelines.

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.
Distribution of surveys and the obligation to respond will be accomplished and conveyed
electronically through the Internet. However, respondents will be offered the option of

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receiving the survey in manual form in instances where the respondent=s access to the Internet
is limited.
All reasonable information technology will be incorporated into the execution of the survey in
order to reduce the overall burden on industry respondents.
BIS has conducted a number of industry and technology surveys in recent years and actively
pursues the constant refinement and updates of its survey techniques to minimize the burden
on the respondents.

4. Describe efforts to identify duplication.
In partnering with other agencies including the Census Bureau and private organizations
involved with the targeted industry, BIS will avoid duplication of information being gathered.
The vast majority of information that BIS will collect from each targeted industry is not
obtainable elsewhere.

5. If the collection of information involves small businesses or other small entities,
describe the methods used to minimize burden.
Most technology and industry sectors have a spectrum of large, medium and small (less than
500 employees) businesses. For small firms, BIS has developed and implemented exemption
thresholds to relieve these entities from the obligation of responding to portions of the survey
instrument. For example, small businesses may only have to provide one year of financial data
while the remaining survey respondents provide four years.
Moreover, BIS makes every effort to minimize the information collection burden that a survey
will impose on the public prior to submission to OMB. BIS circulates a draft survey in a
“field test” to government experts and representatives of companies within the target industry.
Comments received are factored into the survey form. The survey form, usually in Excel
format is constructed for clarity and ease of completion, thus reducing the overall burden on
industry, especially small businesses.
In addition, to minimize the time needed to complete the survey form, questions are clearly
labeled and grouped by subject. Most of the data requested is common business management
information, requiring a minimal amount of time to gather and insert. There are a minimal
number of open-ended questions (typically the most time-consuming and low-yield format).
BIS surveys typically ask for three years of actual historic data, and estimated data for 1 year
into the future.

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6. Describe the consequences to the Federal program or policy activities if the collection
is not conducted or is conducted less frequently.
The data obtained from industry surveys is essential for BIS to adequately assess the health
and competitiveness of the key U.S. industry sectors. Questions addressing fundamental
business activities such as production, technological development, financial performance, and
foreign sourcing all contribute to the robustness of the final report. Limited or total shutdown
of data collection would seriously impact the ability of BIS to complete what have been
unique, comprehensive assessments for the Defense Department and the related industrial
community. This could have serious programmatic and in some cases, national security
consequences.
An industry survey and assessment represents the beginning of a positive relationship between
BIS, the subject industry, and key defense-related agencies. The data, and the findings and
recommendations generated from the data, are essential elements to fully understanding the
challenges facing U.S. industry. BIS final reports allow industry and government leaders to
develop informed strategies to address the many problems facing sectors and technologies.

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 will result in the collection of information in a manner
inconsistent with the guidelines of 5 CFR 1320.6.

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 notice requesting public comment was published in the Federal Register on September 10,
2009 pp. 46564-46565. While no comments were received, BIS will continue to seek input
and guidance from the subject industry. Those comments will be reflected in each submission
to OMB under this information collection authorization.

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9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
This survey will not involve any payment or gifts to respondents, however final copies of the
assessment will be provided to the respondents upon request.

10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
Both the survey, and the accompanying cover letter, will provide assurances to the respondents
that the information collected through the survey will be deemed business confidential and
will be treated in accordance with Section 705 of the Defense Production Act of 1950, as
amended (50 U.S.C.A. app. Section 2061 et. seq. (1993)). This section prohibits the
publication or disclosure of such information unless the President determines that its
withholding is contrary to the national defense.
Information submitted will not be shared with any non-government entity, other than in
aggregate form, and the Department will protect the confidentiality of such information
pursuant to the appropriate exemptions from disclosure under the Freedom of Information Act
(FOIA) if it is the subject of a FOIA request. BIS, Office of Technology Evaluation (OTE)
has a long and successful track record in protecting confidential business information collected
pursuant to the Defense Production Act.

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.
Not applicable.

12. Provide an estimate in hours of the burden of the collection of information.
BIS estimates that the total annual public burden placed on industry by this survey authority
will be approximately 24,000 hours. This is based on past surveys and the data collected
annually in support of several assessments conducted in a typical year. BIS estimates it will
receive surveys from approximately 3,000 companies annually, and that each survey will
require an average completion time of 8 hours, with a range of 4 to 12 hours. As noted in
question 5, BIS has taken actions to minimize the burden of the information collection,
especially on small businesses.

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This estimate is subject to variations among individual organizations because of differences in
record keeping, organization size, and other variables. The estimate is based on past
experience of BIS in conducting surveys. BIS has recently conducted surveys of multiple
industries, including machine tools, integrated circuits, imaging and sensors, space, counterfeit
electronics and small explosives, and the burden estimate of this survey is based on feedback
obtained from respondents.
The estimated total cost to respondents of this information collection is $999,600. In
calculating this cost, we estimated that respondents would take an average of 8 hours to
complete the survey form and that the average hourly cost to each respondent would be
approximately equal to that of a Federal employee working on the assessment. The cost was
calculated by determining the total number of burden hours the respondents would require to
complete the survey form, assuming a reply rate of 100 percent (3,000 responses out of 3,000
survey forms distributed), and multiplying those hours (estimated at 24,000 hours) by the
hourly cost in salary of a Federal employee at the GS-13 level:
($86,927/2,087 hours) = $41.65 per hour x 24,000 hours = $999,600.

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).
Not applicable.

14. Provide estimates of annualized cost to the Federal government.
The estimated cost to the Federal government for the survey is $239,904. A major portion of
this cost is related to the survey questionnaire, which includes survey preparation, collecting
and verifying the information, and storing the information for analytical purposes. Other costs
will be incurred in preparing the final report summarizing our findings. The direct costs were
estimated by determining the total Federal employee hours allocated to each assessment and
multiplying the total hours of the employees assigned to the assessment by the gross average
hourly pay of a GS-13, step 1 or $41.65. Since it is estimated that a maximum of 3 such
assessments are being conducted by BIS at any one time, the annual costs are calculated as
follows: [$86,927/2,087 hours x 40 hours x 40 weeks x 3 persons) = $199,920].
Overhead costs associated with the assigned employee costs were derived by increasing the
direct costs by 20 percent. A review of the Office of Technology Evaluation=s budgets from
previous years indicates overhead costs for building maintenance, telephone, and space rental
charges generally ran about 20 percent of direct costs.

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Assuming three GS-13 employees working an average of 40 hours per week for 40 weeks, the
estimated time to complete the study, the costs to the federal government are outlined below:
Employee Salaries (40 weeks x 40 hours x 3 employees) $199,920
Federal Government Overhead @20%
$39,984
Total: $239,904

15. Explain the reasons for any program changes or adjustments.
The number of respondents, and burden hours per response have been adjusted, based upon
recent experience. The total burden hours are unchanged.

16. For collections whose results will be published, outline the plans for tabulation and
publication.
All data collected will be aggregated before publishing to protect company confidentiality.

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.
This item is not applicable. BIS is not seeking authorization to not display the expiration date
for OMB approval. All manual and Internet-based surveys will display the authority=s
expiration date.

18. Explain each exception to the certification statement.
Not applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable. This collection will not employ statistical methods.

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