0128

SUPPORTING STATEMENT

U.S. Department of Commerce

Bureau of Industry and Security

Application for NATO International Competitive Bidding

15 U.S.C. ' 1512

OMB No. 0694‑0128

A. Justification

1. Explain the circumstances that make the collection of information necessary.

All U.S. firms desiring to participate in the NATO International Competitive Bidding (ICB) process under the NATO Security Investment Program (NSIP) must be certified as technically, financially and professionally competent. The U.S. Department of Commerce is the agency that provides the Statement of Eligibility that certifies these firms. Any such firm seeking certification is required to submit a completed Form ITA-4023P (or Form BIS-4023P) along with a current annual financial report and a resume of past projects in order to become certified and placed on the Consolidated List of Eligible Bidders.

Pursuant to Section 401 (10) of Executive Order 12656 (November 18, 1988), the Department of Commerce is the lead agency representing the United States in industry-related international (NATO and allied) civil emergency preparedness planning and related activities. In addition, the Department=s organic authority, 15 U.S.C. ' 1512, provides the Department with broad authority to Afoster, promote, and develop the foreign and domestic commerce...,@ and the Reorganization Plan No. 3 of 1979 provides the Department with Ageneral operation responsibility for major nonagricultural international trade functions of the United States government, including export development. These authorities authorize a broad range of trade related activities, and the activity transferred from the International Trade Administration to the Bureau of Industry and Security, is consistent with these authorities.

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.

Applications are submitted to the U.S. Department of Commerce=s Office of Strategic Industries and Economic Security, Defense Programs Division where the contents are reviewed for completeness and accuracy by the NATO Procurement Officer. The application is a one-time effort. The information provided on the ITA-4023P (or BIS-4023P) form is used to certify the U.S. firm and place it on the bidder=s list database.

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.

BIS has developed an electronic form-fillable .PDF version of the BIS-4023P. This form was developed using Adobe Acrobat Professional and includes a button to submit the form via e-mail directly to BIS. Currently all submissions are received on paper.

4. Describe efforts to identify duplication.

There is no other information collecting effort that duplicates the filing of an application for NATO certification.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

The collection of information does not impose a significant burden on small businesses. All firms, large and small, are required to provide the same information.

6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.

Only companies from NATO member nations can compete for NATO projects and all companies must be certified by their respective governments. If the collection of information was not conducted, the NATO Procurement Officer would not be able to certify a U.S. firm=s eligibility. This would hinder American companies= ability to compete for NATO infrastructure projects.

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 require the information collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.

8. Provide a copy 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 February 7, 2007. Vol. 72 No. 25, pp. 5675-5676. No comments were received.

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

There are no plans to provide any payment or gift to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.

None. No firm has ever requested confidentiality.

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.

There are no questions of a sensitive nature.

12. Provide an estimate in hours of the burden of the collection of information.

It is estimated that 40 applications will be submitted each year. The average amount of time needed to complete and process the application is estimated to be 60 minutes. The estimated average annual respondent cost for this collection of information is $55 per form.

This includes $40 per hour average salary for the persons responding, plus $15 for the total capital, start-up and operational costs per form.

13. Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in #12 above).

The cost to the respondents is approximately $2,200 annually. This is based on an average time of 60 minutes at $40 per hour, and an additional $15 for each respondent=s Capital, Start-up and Operational costs associated with this information collection.

There are no annualized costs associated with this collection of information.

14. Provide estimates of annualized cost to the Federal government.

It is estimated that the annual cost to the Federal Government is approximately $1,950. This cost is based on an average processing time of 60 minutes per application at an hourly rate of $35 per hour. Printing and postage for this collection of information is estimated to cost $550 annually.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB 83-I.

The increase in burden hours is a result of adjustments due to increased public awareness of the program and outreach activities.

16. For collections whose results will be published, outline the plans for tabulation and publication.

There are no plans to publish this information.

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.

Since application for export licenses can be submitted using downloaded electronic forms as well as paper forms, separate consideration for expiration dates are necessary depending on the method used.

BIS requests exemption from displaying an expiration date on pre-printed versions of form ITA-4023P and form BIS-4023P. Downloaded electronic forms will display the current expiration date of the collection.

18. Explain each exception to the certification statement identified in Item 19 of the

OMB 83-I.

Not applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

Not applicable. Statistical methods will not be used.