Supporting Statement

SUPPORTING STATEMENT
U.S. Department of Commerce
Bureau of Industry and Security
National Security Assessment: U.S. Information Network Infrastructure
OMB Control No. 0694-0119

A. Justification
1. Explain the circumstances that make the collection of information necessary.
The Bureau of Industry and Security (BIS), Office of Technology Evaluation (OTE), is
undertaking a national security assessment of the U.S. Information Network Infrastructure in
coordination with the U.S. Department of Defense (DOD), Office of the Assistant Secretary for
Defense Networks and Information Integration (DNII). This project was initiated by DNII to
manage risk to its information and weapons systems stemming from globalization of the
commercial information and communication technology market. The results of this assessment
will assist DOD in safeguarding U.S. Government systems and the commercial infrastructure on
which they depend (see attached letter).
The U.S. Information Network Infrastructure consists of three main segments: Terrestrial,
Undersea Cable and Satellite Ground Stations. The principal goal of this proposed data
collection is to quantify replacement cycles for information network equipment, document
network maintenance and procurement practices, and understand issues affecting network
reliability and integrity for all three segments. The effort will also identify best practices to help
ensure the operational reliability of the overall national information network infrastructure.
Through the successful collection and analysis of this data, DOD will have a better
understanding of the potential challenges to the critical network infrastructure.
Assisting OTE in this survey and assessment are representatives from a variety of agencies and
organizations including the Department of Energy National Laboratories (Sandia, Los Alamos,
and Livermore), Federal Agencies (Department of Homeland Security, National Security
Agency, Defense Information Systems Agency, Office of the Director of National Intelligence,
and Federal Communications Commission), and Universities (Carnegie Mellon and MIT-Lincoln
Labs). A number of private companies are also providing insight regarding the current status and
future of the information network infrastructure (Verizon, AT&T, Hughes Satellite, Senena and
Tecor).

1

The proposed survey and assessment will assist OTE and DOD analysts in better understanding
the current supply chains being utilized and the future challenges facing this important sector as
non-U.S. sourcing network information equipment and related software begins to increase.
The final report will also assist U.S. industry and government policy officials monitor trends,
benchmark performance and raise awareness of potential foreign sourcing and dependencies that
could jeopardize network reliability and integrity for the entire telecommunications
infrastructure.
OTE has authority under Section 705 of the Defense Production Act of 1950, as amended and
Executive Order 12656, to conduct assessments and collect information from industry in support
of the U.S. industrial base. These assessments are normally undertaken at the request of the
Department of Defense, with one or more of the Armed Services participating, or with other
federal agencies. They usually focus on industrial, financial and economic issues affecting
specific key industrial sectors or critical technologies. The enclosed survey questionnaire, which
covers the period 2008-2010 with an out year projection, is the primary source of information
needed for an industrial base assessment of this type.
The information gained from the survey will be used to: 1- quantify and assess replacement
cycles for information network equipment; document network maintenance and procurement
practices; and understand issues affecting network reliability and integrity; 2- identify best
practices to help ensure the operational reliability of the U.S. national information network
infrastructure; and 3- provide government and industry representatives with a comprehensive
picture of this critical sector to better prepare and plan for potential challenges which could
negatively affect the U.S. telecommunications sector.
OTE is the focal point for industrial base and critical technology analyses among civilian Federal
agencies by virtue of the above mentioned statute and executive order, which includes mandatory
data collection authority to carry out these responsibilities. OTE has conducted approximately
42 assessments of this nature in the past 20 years under various related defense industrial base
programs. Assessments generally review in detail those industries experiencing employment,
international competition, financial, production, investment, foreign sourcing and dependencies
and other factors which may affect their ability to support the industrial base, including defense
and national security programs. The survey document is designed to collect information that
facilitates this kind of in-depth analysis.

2

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.
OTE intends to survey approximately 900 companies representing various segments of the U.S.
Information Network Infrastructure – Terrestrial, Undersea Cable and Satellite Ground Stations.
The survey is a one-time only request. Quantitative data obtained from the survey will be
compiled into an aggregate database for analysis and eventual publication. This data is needed to
assess trends in replacement cycles, network maintenance and procurement practices, market
share, international competition, and foreign sourcing and dependencies. Qualitative questions
are used in some cases to complement the statistical data. Using the aggregated survey data, the
overall goal is to enable the private sector and government agencies to monitor trends,
benchmark industry and government performance, and raise awareness of the implications
regarding potential challenges to the overall U.S. information network infrastructure which could
inhibit network reliability and integrity.

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.
To lessen the burden on respondents, OTE is encouraging the firms to provide electronic
responses. Each respondent will receive a personalized letter which outlines the requirements of
the study and the scope of information required. The letter will also contain directions to the BIS
website where the respondent can gain access to the Excel survey application. This approach
was used successfully for the 2010 Encryption Products, 2010 NASA Supply Chain and 2010
Healthcare Infrastructure surveys. All three surveys were reviewed and approved by OMB.
The statistical information requested in the survey tracks closely with categories and groups
commonly used in the industry and verified by field-testing the OTE survey. Most firms and
organizations will have the information computerized and will be able to retrieve it in the form
requested on the survey. Other questions will require thought and perhaps discussion among
several individuals for proper responses. These questions do not lend themselves to standardized
computer automation. However, the questions only require brief responses in the text boxes
provided.

3

4. Describe efforts to identify duplication.
The information sought in the survey is unique and not available from any other source, either
public or private. Some of the basic corporate background data requested is submitted by firms
in a statistical sample to the U.S. Census Bureau. However, the Census Bureau is precluded by
law from releasing information on specific companies.

5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
While the majority of telecommunications companies are medium and large size firms, this
survey will be distributed to a number of small businesses. The electronic survey instrument was
designed to minimize the burden on all respondents. If for any reason the respondent cannot
complete the survey in Excel, OTE will work with the respondent on an alternate form of
submission. However, due to the world class status of the U.S. telecommunications sector, we
are expecting almost all firms to respond electronically.

6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
In the case of this industrial base assessment of the U.S. Information Network Infrastructure, a
survey is the only method available for OTE to carry out its responsibilities under the Defense
Production Act of 1950, as amended, and Executive Order 12656. Without the information
gathered from the survey, OTE could not: 1- quantify and assess replacement cycles for
information network equipment; document network maintenance and procurement practices; and
understand issues affecting network reliability and integrity; 2- identify best practices to help
ensure the operational reliability of the U.S. national information network infrastructure; and
3- provide government and industry representatives with a comprehensive picture of this critical
sector to better prepare and plan for potential challenges which could negatively affect the U.S.
telecommunications sector.

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. Survey responses will contain business

4

confidential information, which will be protected by the U.S. Department of Commerce, Bureau
of Industry and Security.

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 is not applicable to this collection because it falls within the scope of
the BIS generic authority entitled, “National Security and Critical Technology Assessments of
the U.S. Industrial Base,” approved under OMB Control No. 0694-0119. This authority is
renewed every three years (last renewed in 2010) to support on-going BIS defense industrial base
assessment needs.
OTE staff developed the survey in consultation with industry and government experts over a
period of several months. The following is a list of those individuals who provided input and
advice:
Government
Doug Gardner, Defense Information Security Administration – 703-882-2404
Raymond Berg, Defense Information Security Administration – 703-882-1615
Robert Runser, National Security Agency – 240-373-5085
Bill Semancik, National Security Agency – 240-373-4036
Frank Gac, Office of the Director for National Intelligence – 571-204-4377
Kevin Briggs, Department of Homeland Security – 703-235-5265
Kathleen Blasco, Department of Homeland Security – 703-235-5260
Companies
Kent Bowen, AT&T Services – 703-235-5634
Kathryn Condello, Qwest – 703-363-3990
Organizations
Celeste Matarazzo, Lawrence Livermore National Laboratory – 925-423-9838
Jim Smith, Los Alamos National Laboratory – 505-665-0921
D.V. Rao, Los Alamos National Laboratory – 505-667-4567
Fred Sexton, Sandia National Laboratory – 505-844-3927
Chuck Villamarin, Sandia National Laboratory – 505-284-8332

5

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, copies of the
completed public version of the National Security Assessment: U.S. Information Network
Infrastructure 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.
The survey and its cover letter 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.). This section prohibits the publication or disclosure of such
information unless the President determines that its withholding is contrary to the national
defense. The survey will be administered and the data collected via a secure U.S. Department of
Commerce server. Information submitted will not be shared with any non-government entity,
other than in aggregate form, and the U.S. Department of Commerce will protect the
confidentiality of such information pursuant to the appropriate exemptions from disclosure under
the Freedom of Information Act (FOIA), should it be the subject of a FOIA request. OTE has a
long and successful track record of protecting business confidential information collected under
the above statute.

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.
This survey will not collect information that could be construed as being of a sensitive nature,
such as information concerning sexual behavior and attitudes, religious beliefs, and other matters
that are commonly considered sensitive or private.

12. Provide an estimate in hours of the burden of the collection of information.
OTE estimates that the total burden placed on the respondents by this U.S. Information Network
Infrastructure survey effort will be approximately 12,600 hours. This is based on distributing
surveys to approximately 900 respondents with an average time of 14 hours needed to complete
the survey.

6

This burden estimate is subject to variations among individual respondents because of
differences in record keeping, organization size, and other variables. The estimate is based on
the past experience of OTE, as well as feedback from companies and organizations that have
completed our surveys. OTE has conducted surveys of various industries, including imaging and
sensors, biotechnology, NASA supply chain network, U.S. space industry, counterfeit
electronics, 5-axis machine tools, microelectronics, encryption products and others.
The estimated total labor cost to respondents of this information collection is $441,000. This
estimate was calculated by assuming a respondent's average work rate of $35 per hour multiplied
by the total burden hours of 12,600.

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).
This item is not applicable because the survey questionnaire will not impose any annual costs on
respondents involving capital and start-up costs or affect the costs of operation, maintenance, or
purchased services.

14. Provide estimates of annualized cost to the Federal government.
The estimated cost to the Federal government for the survey is $123,039. A major portion of this
cost is related to the survey questionnaire, which includes preparation, collecting and verifying
the information, and analyzing the data. Other costs will be incurred in summarizing the analysis
and findings, preparing the final report, and report printing and distribution. The direct
employee costs were estimated by assuming the hours spent on the project as about threequarters year equivalent, or 39 weeks and taking three-quarters the annual pay of one GS-14,
step 10. The direct employee cost is $102,533.
Indirect or overhead costs associated with the project are calculated as 20 percent of the direct
employee cost, or $20,506. A review of OTE budgets from previous years indicates costs for
building maintenance, telephone, computers, and space rental charges generally run about 20
percent of total employee costs.

7

15. Explain the reasons for any program changes or adjustments.
Because the nature of this collection of information falls within BIS’s generic authority entitled,
“DOC/BIS National Security and Critical Technology Assessments of the U.S. Industrial Base,”
(OMB Control No. 0694-0119), there is no increase in burden hours. This is the first time BIS
has used this authority in FY2011 (a total of 74,000 authorized annually). An unused balance to
the authority of 61,400 annual burden hours (74,000 minus 12,600) will remain if the assessment
is approved under this authority.

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. The
surveys will be provided electronically to the 900 companies in January 2011. The analysis and
report writing will be started in April 2011, a draft report prepared by the end of June 2011. The
final report is planned for publication in August 2011.

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. BIS will display the expiration date of this information collection authority on
all survey and instructional instruments the public receives.

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

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.

8