Supporting Statement

SUPPORTING STATEMENT
U.S. Department of Commerce Bureau of Industry and Security
The Effect of Imports of Titanium Sponge on the National Security
OMB Control No. 0694-0120
A. Justification
1. Explain the circumstances that make the collection of information necessary.
On March 4, 2019, the Secretary of Commerce initiated an investigation to determine the effect of
imports of titanium sponge on U.S. national security requirements. In support of the investigation,
the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), Office of Technology
Evaluation (OTE), is conducting a survey and assessment focused on the domestic producers and
melters of titanium sponge and select end users of melted titanium products.
The resulting data will be used to support this investigation conducted under Section 232 of the
Trade Expansion Act of 1962, as amended. The Section 232 investigation was initiated by the U.S.
Department of Commerce, based on a petition filed by a single producer of titanium sponge.
The investigation must be completed by November 29, 2019.
The principal goal of this survey effort is to assist BIS in determining whether titanium sponge is
being imported into the U.S. in such quantities or under such circumstances as to threaten to
impair the national security of the U.S. The surveys will also assist in determining the overall
health and competitiveness of the titanium sponge affiliated companies to assess their capabilities
to support the national defense.
Information collected will include organizational data, information on mergers and acquisitions,
production and inventories, imports and exports, sales, employment, capital expenditures, R&D,
investment, financial performance, customers, suppliers, demand trends and other topic areas. The
resulting aggregate data will provide BIS detailed information that is otherwise not available and
is needed to effectively conduct its analysis.
During the design and development of the survey instrument, BIS gathered input primarily from
the interagency but also from industry, their corresponding associations, and experts in academia.
BIS has authority under Section 705 of the Defense Production Act of 1950, as amended, and
Section 232 of the Trade Expansion Act of 1962, as amended, to conduct assessments and collect
information on the capabilities and capacity of the U.S. industrial base and domestic industries to
meet national defense requirements. These industrial base assessments are normally undertaken
in partnership with the U.S. Department of Defense and other agencies and typically focus on
manufacturing capability, workforce, financial performance, foreign sourcing and dependencies,
inventories, R&D, and economic issues affecting key industrial sectors or critical technologies.
The attached survey questionnaire, which covers a five-year period, is the key source of
information needed for a national security analysis of this type.
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Pursuant to the abovementioned statutes and relevant delegations thereunder, BIS is the focal
point for national security investigations and assessments among civilian federal agencies. This
includes mandatory data collection authority to carry out these responsibilities.
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.
BIS intends to survey 35 organizations with facilities in the United States.
This survey is a one-time only request. Quantitative data obtained from the responses will be
held into a database for analysis, with public publication consisting only of aggregate,
nonproprietary results with no business confidential information.
This survey-based data is needed to assess the status of the organizations involved in the
production, melting and end use of titanium sponge product, and learn how U.S. national security,
including the national defense, may be threatened by imports of titanium sponge. Qualitative
response data are also used in limited cases to complement the statistical data.
Through analysis of the tabulated survey results BIS will be better able to determine whether or
not to recommend further actions be taken by the President to adjust imports of titanium sponge
if they are found to threaten to impair the national security.
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, BIS is asking organizations to provide electronic, Excelbased survey submissions. Each respondent will receive a personalized letter and overview fact
sheet which outline the requirements of the survey and scope of information required. The letter
will contain directions to the dedicated BIS website where the respondent can gain access to the
Excel survey instrument and corresponding PDF materials. This approach was used successfully
for the 2019 Uranium, 2018 Automotive, 2017 NASA Propulsion, and 2016 Textiles, Apparel,
and Footwear surveys. All four survey instruments were reviewed and approved by OMB.
The statistical information requested in the survey tracks closely with categories adopted in the
industry. Almost all responding organizations 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. Only basic organization data requested by BIS is submitted to the U.S. Census
Bureau. However, by law, the Census Bureau may only use such data for Census purposes and
may not disclose the individual organization data for any other purpose.
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5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
Target companies for this survey are titanium sponge producers, melters and end users of
melted titanium sponge. The survey instrument was designed to minimize the burden on all
respondents. If for any reason the respondent cannot complete the survey in Excel, the
preferred format, BIS will work closely with the respondent to facilitate an alternate form of
response submittal. Based on previous surveys, BIS expects nearly all participant organizations
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 U.S. titanium sponge producers, melters, and end users of melted titanium
sponge, a mandatory survey is the only method available for BIS to carry out its responsibilities
under the Defense Production Act of 1950, as amended. Without the survey instrument, BIS
could not obtain company specific information on: organization profile, mergers and
acquisitions, facility capability, production and inventory, financials, capital expenditures, R&D,
imports and exports, customers, suppliers, contracts, employment, permits, supply chain,
competition, and demand trends. The resulting database will allow BIS to benchmark industry
performance, identify impacts of imports on the titanium sponge supply chain, as well as
determine the resulting impact on the national security. Furthermore, if not surveyed in such
detail, the Section 232 investigation process would not be thorough enough to determine the
effect of titanium sponge imports on the national security.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
Not applicable.
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 requirement is not applicable to this collection because this
collection falls within the scope of the BIS generic authority entitled, “Request for Investigation
Under Section 232 of the Trade Expansion Act,” as approved under OMB Control No. 06940120. This authority is renewed by OMB every three years (and was renewed by OMB on June
29, 2018, expiring on June 30, 2021) to support ongoing BIS national security investigation
needs.
BIS personnel developed the surveys in consultation with industry and government experts over
a period of several months. The following is a partial list of those individuals who provided
input and advice:
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U. S. Government
Matthew Zolnowski, OSD-Industrial Policy - (571) 372- 5006
Andrew Green, DLA-Strategic Materials - (571) 767-5515
Nathan Her, OSD-Industrial Policy – (571) 372-6245
Anne Flatness, DOC-International Trade Administration - (202) 482-2551
Tom Rasmussen, DLA-Strategic Materials – (571) 767-5476
Joseph Gambogi, USGS Mineral Information Center – (703) 648-7718
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 Sec.
4555). This section prohibits the publication or disclosure of such information unless the
President determines that withholding it is contrary to the interest of 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. BIS 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.
BIS estimates that the total burden placed on respondents by this survey on titanium sponge
producer, melters and end users of titanium sponge will be approximately 385 hours. This
estimate is based on distributing surveys to 35 respondents with an average time of 11 hours
needed to complete each survey.
This burden estimate is subject to variations among respondents due to discrepancies in the level
of participation in the titanium sponge industry, record keeping, company size, and other
variables.
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The estimate is based on BIS’s overall past experience, as well as specific feedback from
industry participants in information collections such as bare printed circuit boards, textiles and
apparel, footwear, strategic materials, microelectronics, the U.S. space sector, magnesium, and
others.
The estimated total cost to respondents of this information collection is calculated as $13,475.
This estimate was made by assuming an average hourly respondent work rate of $35 multiplied
by 385 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 $244,375 over a 6-month 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 by summarizing the analysis and findings. The direct employee costs were estimated by
assuming the hours spent on the project, about 6-month equivalent, or 26 weeks and taking the
annual pay of one GS-15 step 10, one GS-13 step 2, one GS-12 step 1, and one GS-9 step 2. The
direct employee costs are $203,646.
Indirect or overhead costs associated with the project are calculated as 20 percent of the direct
employee costs, or $40,729. A review of BIS 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,
“Request for Investigation Under Section 232 of the Trade Expansion Act,” (OMB Control No.
0694-0120), there is no increase in burden hours. BIS used this authority in FY2019 for one
other Section 232 Investigation: Uranium (a total of 910 hours out of the 12,260 hours
authorized in 2019). An unused balance of 10,965 annual burden hours (11,350 less 385 hours)
will remain if the titanium sponge survey instrument 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 companies in August 2019. The analysis will be
started in September 2019 and a draft Section 232 report on the effects on the national security
of titanium sponge imports, which will incorporate aggregate data from the analysis, will be
prepared in October 2019. The final Section 232 report is planned to go to the President in
November 2019. The public version of the report will be available soon after completion of the
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President’s review and final determination of the Section 232 investigation’s findings and
conclusions.
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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