Defense Industrial Base Assessment: U.S. Air Force/Boing C-17 Aircraft Program

SUPPORTING STATEMENT
U.S. Department of Commerce
Bureau of Industry and Security
Defense Industrial Base Assessment:
U.S. Air Force/Boeing C-17 Aircraft Program Industrial Base
OMB Control No. 0694-0119

A. Justification
1. Explain the circumstances that make the collection of information necessary.
The Bureau of Industry and Security’s Office of Technology Evaluation (OTE) is conducting an
industrial base survey and assessment of the supply chain impacts resulting from cancellation of
the U.S. Air Force/Boeing C-17 aircraft program. This study is being conducted at the request of
the Defense Department’s Office of Economic Adjustment (OEA) and in close coordination with
the City of Long Beach, California.
The principal goal of this effort is to characterize the industrial base impacts resulting from the
recent cancellation of the C-17 aircraft program. This information will help ongoing and future
initiatives by OEA and the City of Long Beach, among other municipal organizations impacted
by C-17 aircraft production losses, to implement economic transition and assistance programs.
These assistance programs are intended to (A) minimize the impacts of lost C-17 business on
participating subcontractors and suppliers that support the C-17 aircraft program while also (B)
helping affected companies take the necessary steps to remain healthy and competitive.
The mission of the Defense Department’s OEA is to support economic adjustment strategies
involving technical and grant assistance for companies in the defense industrial base that are
impacted by cuts in U.S. defense spending. These adjustment strategies generally focus on
regional job creation and community economic diversification.
In addition to learning of the current and pending impacts resulting from the C-17 aircraft
program’s cancellation, the resulting survey-based database will allow OEA to benchmark
industry performance, identify key interdependencies within the supply chain network, as well as
raise awareness of part obsolescence and diminishing domestic manufacturing capabilities.
During its design and development of the survey instrument, OTE conducted site visits, gathered
inputs from industry, academia, and the U.S. Government, and later field tested the draft
instrument with both companies and government experts. Among them were Honeywell
International, The Boeing Company, the City of Long Beach, and regional offices of the U.S.
Department of Commerce’s International Trade Administration (ITA).
BIS’ OTE has authority under Section 705 of the Defense Production Act of 1950 (DPA) and
Executive Order 13603 to conduct assessments and collect information in support of the U.S.
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industrial base. These assessments are normally undertaken in partnership with the U.S.
Department of Defense or with other U.S. federal agencies and typically focus on defense
manufacturing capability, supply chain resiliency, workforce, investment and financial
performance, and economic issues affecting key industrial sectors or critical technologies.
The enclosed survey questionnaire, which covers a five-year period, is the primary source of
information needed for a defense industrial base assessment of this type.
By virtue of the above mentioned statute and executive order, OTE is the focal point for
industrial base and critical technology analyses among civilian federal agencies, which includes
mandatory data collection authority to carry out these responsibilities. OTE has conducted
nearly 60 surveys and assessments of this kind in the past 29 years under various defense
industrial base programs.
These studies typically review in detail those industries with challenges relating to workforce/
STEM, international competition and trade, investment, sales, and financial performance,
manufacturing capability, supply chain resilience, foreign sourcing and dependencies, USG
program participation, cyber security, and other factors affecting the support of defense and
national security programs. This survey instrument is designed to collect information necessary
to conduct such in-depth analysis.

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 650 industry organizations affiliated with the C-17 aircraft
program.
The survey is a one-time only request. Quantitative data obtained from the survey responses will
be compiled into a database for analysis, with publication consisting only of aggregate,
nonproprietary results with no business confidential information. This data is needed to assess
the impacts of C-17 program cancellation on the industrial base and for the development and
implementation of adequate economic transition and assistance programs.
Additionally, qualitative questions are used in limited cases to complement the statistical
information.
Through analysis of the aggregated survey results, the overall goal is to first characterize the
industrial base impacts resulting from the cancellation of the C-17 aircraft program and then
implement appropriate economic adjustment strategies to address said impacts.
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.

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To lessen the burden on respondents, OTE is asking firms to provide electronic submissions.
Each respondent will receive a personalized letter and overview fact sheet which outline the
requirements of the study and scope of information required. The letter will contain directions to
the dedicated U.S. Department of Commerce portal where the respondent can gain access to the
Excel survey instrument and corresponding PDF materials. This approach was successfully
implemented for the 2016 Textiles, Apparel, and Footwear, 2017 Integrated Circuit Design and
Manufacturing, and 2017 Rocket Propulsion surveys. All three survey instruments were
reviewed and approved by OMB.
The statistical information requested in the survey tracks closely with categories adopted in the
industry and verified by field tests. Almost all responding companies will have the necessary
information stored electronically and will be able to retrieve it in the form requested. Other
limited questions will require thought and perhaps discussion among several individuals for
proper responses. These particular questions do not lend themselves to computer automation.
However, such questions only require brief responses in the text boxes provided.

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 data requested by OTE is submitted by companies
to the U.S. Census Bureau. However, the Census Bureau is precluded by law from releasing
information on specific companies and organizations.

5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
The C-17 aircraft program supply chain network is comprised of medium and large companies,
primarily; however, the survey will be distributed to some small businesses. The survey
instrument was designed to minimize the burden on all respondents. If for any reason the
respondent cannot complete the survey in Excel format, OTE will work closely with the
respondent to facilitate an alternate form of survey submission. Based on previous survey
instruments, OTE expects almost all companies 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.
For the assessment of the U.S. Air Force/Boeing C-17 aircraft program, a survey is the only
method available for OTE to carry out its responsibilities under the Defense Production Act and
Executive Order 13603. Without the survey instrument, OTE could not obtain company specific
information on workforce/STEM, investment, sales, and financial performance, domestic
manufacturing capability, supply chain resilience, foreign sourcing and dependencies, USG
program participation, cyber security, and other factors affecting C-17 aircraft program supplier
health and competiveness. This information will help ongoing and future initiatives by OEA and
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the City of Long Beach, among other municipal organizations participating in C-17 aircraft
production, to implement adequate economic transition and assistance programs.
This method of data collection will allow OEA and other stakeholders to more accurately
monitor industry trends and benchmark performance related to the cancellation of the C-17
program. Absent the insights generated from this information, such as reduced U.S.
manufacturing capability, sole source non-U.S. supplier relationships, or USG program
interdependencies, U.S. defense and civil capabilities could be jeopardized.

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 response information will contain
business confidential information which will be protected by the U.S. Department of Commerce,
Bureau of Industry and Security, consistent with OMB guidelines and 15 CFR Part 702.

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,” as approved under OMB Control No. 0694-0119. This authority is
renewed by OMB every three years (last in 2016) to support ongoing BIS industrial base
assessment needs.
OTE developed the survey in consultation with U.S. Government and industry experts over a
period of several months. The following is a list of select individuals who provided input:
Government
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Daniel Glasson, Office of Economic Adjustment, 703-901-7670
John Thornquist, Washington State Department of Commerce, 206-256-6109

Industry:


Art Sauls, Composite Solutions Corporation, 253-245-5119
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Don Adkins, Precision Coil Spring Company, 626-444-0561
James Fullaway, The Boeing Company, 714-896-4512
Michael Tate, Honeywell International, 602-738-1357
Thomas Innocenti, Teledyne Controls, 310-765-3682
Tracy Knuff, Eaton Industrial Corporation, 616-831-8384

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.

10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
The survey, cover letter and fact sheet provide assurance 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 portal. Information submitted will not be shared with any non-government entity,
other than in aggregate form. 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 respondents by this survey and assessment of the
U.S. Air Force/Boeing C-17 aircraft program industrial base will be approximately 6,500 hours.
This is based on distributing surveys to approximately 650 respondents with an average time of
10 hours needed to complete each survey.

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This burden estimate is subject to variations due to discrepancies in the levels of participation in
the C-17 supply chain network, record keeping, company size, and other areas. The 10 hour
projection is based on OTE’s overall past experience, as well as specific feedback from industry
participants in information collections such as bare printed circuit boards, cartridge and
propellant actuated devices, underwater acoustic transducers, strategic materials,
microelectronics, the U.S. space sector, healthcare products, and others.
The estimated total cost to respondents of this information collection is calculated as $227,500.
This estimate was made by assuming an average hourly respondent work rate of $35 multiplied
by 6,500 total 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).
Not applicable.

14. Provide estimates of annualized cost to the Federal government.
The estimated cost to the Federal Government for the survey is $318,647 over a one-year period.
A major portion of this cost is related to the survey questionnaire, which includes preparing,
collecting, verifying and tabulating the information, and analyzing the data. Other costs will be
incurred in field testing the survey, 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, about one-year equivalent, or 52 weeks and taking the
one-year annual pay of one GS-15, step 10 and one GS-12, step 10. The direct employee costs
are $265,539.
Indirect or overhead costs associated with the project are calculated as 20 percent of the direct
employee costs, or $53,108. 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.

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 third time BIS
has used this authority in FY2017 (a total of 201,000 hours authorized in 2017). An unused
balance of 183,300 annual burden hours (189,800 less 6,500 hours) will remain if the survey
instrument is approved under this authority.

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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 distributed to the 650 companies in September 2017. The analysis will begin in
November 2017 and a compendium of results will be prepared by January 2018. The final
results presentation is planned for February 2018.

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 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.

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