Supporting Statement

OMB Control No. 0694-0119

SUPPORTING STATEMENT
U.S. Department of Commerce
Bureau of Industry and Security

Defense Industrial Base Assessment:
The U.S. Microelectronics Industry
OMB Control No. 0694-0119

A. Justification
1. Explain the circumstances that make the collection of information necessary.
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS), Office of Technology
Evaluation (OTE) is conducting a comprehensive assessment of the U.S. microelectronics
industrial base (MEIB). This assessment is being performed pursuant to Section 9904 of Title
XCIX of the National Defense Authorization Act (NDAA) of Fiscal Year 2021. Title XCIX,
Creating Helpful Incentives to Produce Semiconductors for America (CHIPS), contains multiple
provisions related to promoting U.S. leadership in microelectronics and ensuring secure
microelectronics supply chains. Section 9904 of the legislation, under which this data collection is
mandated, requires the Secretary of Commerce to assess the capabilities of the U.S.
microelectronics industrial base to support the national defense and includes a mandatory survey
on the manufacture, design, and end use of microelectronics.
The principal goal of this assessment is to better understand the domestic microelectronics network
to support the national defense. The data collected will help identify the structure and
interdependencies of organizations that participate in the MEIB. This effort will enable the U.S.
government (USG) to understand and respond to supply chain deficiencies and disruptions related
to diminishing manufacturing sources and material shortages (DMSMS), foreign sourcing and
dependencies, critical minerals and materials, and other challenges. The resulting data and
subsequent analysis will allow industry representatives and government policy officials to better
monitor trends, benchmark industry performance, and raise awareness of potential issues of
concern.
The data collected from the survey will assist in determining the overall health and
competitiveness of the microelectronics industry in the United States and raise awareness of
diminishing domestic manufacturing and technological capabilities, among other issue areas. The
resulting data will support a report to Congress (which may be classified) detailing vulnerabilities
and challenges in the microelectronics supply chain and impacts on critical technology areas to
better inform risk management planning and the development of targeted strategies to ensure the
availability and security of the supply chain network that supports the U.S. microelectronics
industry.
The collection of this information is necessary because BIS research, data collection, and analysis
provide needed information to benchmark industry performance. The OTE survey is designed to
provide detailed information on several categories related to microelectronics industrial base health
and competitiveness including mergers and acquisitions, capabilities, critical inputs, research and
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development, financial information, employment statistics, and industry challenges. This data is
needed to assess the status of both direct and indirect suppliers and identify issues and challenges
for consideration in the microelectronics industrial base supply chain risk management planning.
The resulting aggregate data is otherwise not available and is needed to effectively conduct this
assessment.
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 1,000 organizations representing multiple facets of the
microelectronics industrial base. This information will be used to afford visibility into
the current and prospective microelectronics industry, specifically, trends in mergers and
acquisitions (M&A), advances in emerging technology (e.g., artificial intelligence, quantum
computing, additive manufacturing, etc.), foreign sourcing and dependencies, workforce/STEM
practices, trends in research and development (R&D) and capital expenditures (CapEx)
investments, U.S. federal acquisition constraints and reforms, supply chain disruptions, impacts of
export controls, and more.
The survey is a one-time only request. Both quantitative and qualitative information obtained
from the survey will be compiled into a relational database for analysis by OTE. The qualitative
questions, specifically, are used to complement the statistical data. By anonymizing the data and
sharing insights with the broader distribution, manufacturing, research and development, and
sustainment communities, OTE intends to improve the monitoring of industry’s overall
performance, while raising awareness of shared risks to mission implementation, any of which
could adversely affect the U.S. microelectronics industrial base and, more broadly, U.S. national
security.
BIS utilizes the Defense Production Act of 1950 (DPA), as amended, to both collect and protect
the business proprietary information submitted by survey respondents. Additionally,
Executive Order 13603 delegates to the Department of Commerce the authority to assess the
capabilities of the U.S. industrial base to support the national security and critical program needs,
and develop policy recommendations to improve the international competitiveness of specific
domestic industries.
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 assessment responsibilities. OTE has
conducted nearly 100 surveys and assessments of this kind in the past 30 years. These studies
review in detail industries with challenges relating to employment/STEM, international
competition and trade, financial performance, production, supply chain, investment, foreign
sourcing and dependencies, and other factors influencing industry’s ability to support end-users
across commercial, defense, and other national security programs. This survey is designed to
collect information that facilitates such in-depth analysis.

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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 firms to provide electronic responses in
Excel format. Each respondent will receive a personalized distribution letter signed by BIS
management and a project overview fact sheet which outlines the scope of information required.
The letter will contain directions to the BIS survey landing page, where the respondent will be
redirected to a BIS website where both Excel and PDF versions of the survey are housed. This
approach was used successfully for the 2017 U.S. Integrated Circuit Design and Manufacturing,
2019 DHS ICT Software, 2020 U.S. Air Force Sustainment Center (Supply Chain), and 2022 U.S.
Civil Space surveys. All four surveys were approved by OMB.
The statistical data requested in the survey adheres closely to categories of questions and survey
nomenclature common to the microelectronics sector. The relevance of these fields also has been
verified through remote field-testing with stakeholders from academia, the U.S. government, and
U.S. industry. Nearly all respondents will have the requested data stored on computer systems or
within internal resources, allowing retrieval of the information to populate the survey response.
BIS has conducted numerous industry and technology surveys in the past 30 years and actively
pursues the refinement and updates of its survey techniques and information technology 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 a particular industry or technology, BIS will avoid duplication of information
being gathered. Most information that BIS collects is not obtainable elsewhere. Some of the basic
corporate data, such as address location, stock symbol and leadership profiles, is submitted by
companies 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.
Participants in this collection are primarily designers, distributors, and producers of
microelectronics. The survey is designed to minimize burden on all respondents. For small
firms, BIS has developed and implemented estimate 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 financial data in aggregated figures, while the remaining survey
respondents provide full balance sheets and income statements.
Moreover, prior to submission to OMB, BIS makes every effort to minimize the information
collection burden that a survey imposes on the public. For example, BIS circulates a draft
survey to academic and government experts, as well as representatives of companies within the
target industry or sector as a “field test.” Comments received are factored into the survey.
Additional inputs obtained from facility site visits and outside research are also added to the
survey. The survey, typically in Excel format, is constructed for clarity and ease of
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completion. Drop down and check-the-box answers are used throughout the survey, thus
reducing the overall burden on industry, especially small businesses.
Additionally, to minimize the time needed to complete the survey, questions are clearly labeled
and grouped by subject. Most of the data requested is common organization 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) that allow
respondents to better explain their views on topics of concern.
If, for any reason, the respondent cannot complete the survey in Excel format, OTE will work
closely with the respondent to ensure a response is successfully submitted. Based on previous
survey data collections, OTE expects most 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 evaluation of the US. Microelectronics industrial base, a survey is the only method
available to define the ecosystem of capabilities and relationships. Furthermore, this
assessment is required by Section 9904 of the FY 2021 National Defense Authorization
Act, which details the specific authorities to be used, including to conduct a mandatory
industry survey pursuant authority delegated to BIS under Section 705 of the Defense
Production Act and E.O. 13603. Without the information collected in the survey, OTE
could not obtain company specific data necessary to perform a robust, accurate evaluation
of the health and competitiveness of the U.S. microelectronics industrial base. Examples of
such information include company and financial information, capabilities, suppliers and
customers, the role of U.S. export controls, critical inputs, obsolescence and supply chain
disruptions, industry challenges, workforce challenges, and more.
The resulting data will allow OTE to benchmark industry performance, categorize risks and
vulnerabilities, identify issues influencing domestic manufacturing readiness and key sole source
dependencies within the supply chain, as well as raise awareness of various risk factors influencing
overall supply chain resilience and the resulting impact on the national security.
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 BIS 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.
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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 was renewed
in September 2022 and is renewed every three years to support BIS industrial base assessment
needs.
OTE staff developed the U.S. microelectronics industry survey in consultation with government
and industry experts over a period of several months. The following is a list of individuals who
participated in the process:
U.S. Government
Department of Defense
Kevin Geoghegan, Defense Microelectronics Cross Functional Team (DMCFT)/ME Knowledge
Centralization Working Group, [email protected], (916) 231-1675
Craig Herndon, Naval Surface Warfare Center Crane Division, [email protected],
(812) 296-8266
Jennifer Schmitt, U.S. Air Force Tinker 448 Air Force, [email protected],
(801) 710-3269
Brian Gabriel, DASD, Industrial Policy and OUSD(A&S), [email protected],
(571) 255-9754
Department of Energy
Paul Syers, Advanced Manufacturing Office (AMO), [email protected], (202) 713-6427
Tina Marie Kaarsberg, Advanced Manufacturing Office (AMO), [email protected],
(202) 586-5112
John VerWey, Pacific Northwest National Laboratory, [email protected], (206) 528-3130
Justin Rizzi, National Nuclear Security Administration (NNSA), [email protected],
(240) 306-7848
Executive Office of the President
Sahar Hafeez, National Security Council (NSC), [email protected], (202) 482-0119
Department of Homeland Security
Laura Hershon, DHS CISA, [email protected], (202) 809-7312
Department of Labor
Frugoli Pam, DOL National Programs, Tools, and Technical Assistance, [email protected],
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(202) 693-3643

National Aeronautics and Space Administration
Patrick Besha, Office of Technology, Policy & Strategy, [email protected], (202) 358-2636
Industry
Joe Pasetti, SEMI, [email protected], (202) 701-6716
Robert Casanova, Semiconductor Industry Association (SIA), [email protected],
(202) 431-4869
Tom Quillin, Intel Corporation, [email protected], (503) 712-8017
Rob Beard, Micron Technology, Inc., [email protected], (443) 257-6480
Karmi Leiman, GlobalFoundries, [email protected], (202) 845-4860
Michael O'Sullivan, Vishay Intertechnology, Inc., [email protected], (610) 251-5260
Doug Hackler, American Semiconductor, Inc., [email protected], (208) 336-2773
David Henshall, Semiconductor Research Corporation, [email protected],
(919) 941-9400
Roy Bishop, The Charles Stark Draper Laboratory, Inc., [email protected], (617) 418-0826
Thomas Lopez , Boston Consulting Group, [email protected], (301) 395-3298
Brandon Kulik, Deloitte, [email protected], (714) 436-7530
Jay Chittooran, Samsung, [email protected], (202) 913-5670
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.
Both the survey and the accompanying 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 USC §
4555). This section prohibits the publication or disclosure of such information unless the
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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 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.
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 participating in the mandatory survey
will be approximately 16,000 hours. This estimate is based on a sample of 1,000 respondents
with an average completion time of 16 hours per survey. This burden estimate is subject to
variations among respondents due to discrepancies in product/service participation, record
keeping, company size, and other variables.
The estimate is based on OTE’s overall past experience, as well as specific feedback from
industry participants, including the U.S. defense industrial base, healthcare products, information
and communications technology (ICT), microelectronics, rocket propulsion, strategic materials,
underwater acoustic transducers, and others. The projected burden estimate of future surveys
includes feedback obtained from these respondents.
The estimated total cost to respondents of this particular data collection is $664,000. This
estimate was calculated by assuming the average hourly payrate of a microelectronics industry
employee is $41.50 per hour multiplied by the total burden hours of 16,000.

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 annual cost to the Federal government for the survey is $1,259,311.30. A
significant portion of the cost relates to the survey questionnaire which includes preparing,
collecting, verifying, tabulating, and analyzing the data. Other costs are incurred in field testing
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the survey, developing findings and recommendations, preparing reports, and report printing and
distribution.
The direct employee costs are estimated by assuming one GS-13 Step 1 ($51.18/hour + 35%
benefits) and two GS-12 Step 1 ($43.04/hour + 35% benefits) (based on the January 2022 OPM
schedule) federal employees were assigned full-time to the assessment. The annual costs are
calculated as follows: ((51.18/hour + $17.91) x 40 hours/week x 52 weeks = $143,707.20) +
((43.04/hour + $15.06) x 40 hours/week x 52 weeks x 2 persons = $241,696.00) = $385,403.20
Indirect or overhead costs associated with the project are calculated as 20 percent of the direct
employee costs, or $57,100.16. 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.
The total estimated annual costs to the federal government is as follows:
Federal Employee Salaries
$385,403.20
Federal Government Overhead @ 20%
$ 77,080.64
Compliance Support
$796,800.00
Total:
$1,259,283.84
15. Explain the reasons for any program changes or adjustments.
Because the scope of this collection of information falls within BIS’s generic authority “DOC/BIS
National Security and Critical Technology Assessments of the U.S. Industrial Base,” (Control
Number 0694-0119), there is no increase in burden hours being requested.
BIS renewed this authority in September 2022 and has an unused balance of 28,000 responses
and 308,000 burden hours. After the expected 1,000 responses and 16,000 burden hours attributed
to the microelectronics assessment, BIS will have a remainder of 27,000 responses and 292,000
burden hours.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
The data collected by OTE will be aggregated to protect the confidentiality of the respondent
information. Any public report will only contain aggregated data.
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. OTE will display the expiration date of this information collection authority
Control Number 0694-0119 on all surveys and instructional information the public receives.
18. Explain each exception to the certification statement.
Not applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
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Not applicable.

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