Justification for DTAG survey

Request for Approval Under Generic Survey of Routine Customer Feedback (OMB Control Number: 1405-0193)

TITLE OF INFORMATION COLLECTION:

Online Survey – Directorate of Defense Trade Controls IT Modernization Initiative.

PURPOSE:

The Directorate of Defense Trade Controls (DDTC) of the Department of State has both statutory and delegated authority to regulate the export and temporary import of defense-related goods and defense services under the Arms Export Control Act (AECA) (22 U.S.C. 2751 et seq.) and its implementing regulations, the International Traffic in Arms Regulations (ITAR) (22 CFR 120-130).

Because of the unique needs of DDTC to collect very specific data from exporters in the defense industry, and the need to share that data with Federal interagency partners, a multitude of information technology systems have historically been used, each performing a discrete function. As new programmatic requirements have been promulgated, whether in response to new legislation, changing geopolitical events, or interagency requirements, the IT systems which DDTC uses have become outmoded and obsolete. Moreover, as the information security posture of the United States Government has transformed and improved, DDTC’s legacy systems have been unable to keep pace with the changes that are required of Executive agencies. In response to these changing circumstances, in 2015 DDTC began a modernization initiative that will replace its legacy IT systems with a single portal case management system (CMS) which will allow both industry users and DDTC staff to smoothly and securely navigate the registration, licensing, and compliance functions of the Directorate.

In addition to replacing the DDTC-specific systems that industry users interact with, DDTC is redesigning its IT systems to collate with the International Trade Data System (ITDS). ITDS is a government-wide initiative among agencies that have oversight of imports and exports to consolidate licensing and shipping information into a single portal with uniform data fields and a high degree of interoperability. ITDS is designed to eliminate traders having to submit duplicative information to separate agencies, thus vastly reducing the total burden associated with exporting and importing commodities from the United States.

This information collection will be conducted by the Department of State’s Defense Trade Advisory Group (DTAG) via an electronic survey disseminated to a select group of industry stakeholders. DTAG will use the results of the survey to compile an analysis/recommendation to DDTC concerning the topics of query. Topics in the survey cover general company information (No PII), a proposed Interagency One Form and DDTC DS-7788 form, Electronic Batch Filing, and Security/Authentication. Continuous industry feedback and input is vital to the success and efficiency of DDTC’s IT Modernization. Because the focus of the CMS will be on user experience, information security, and usability, it is very important for DDTC staff to receive accurate and timely feedback so that the system can achieve the greatest possible buy-in and be reflexive to the needs of industry.

The DTAG survey consists of the aforementioned four sections covering various topics of concern to DDTC and industry. The survey totals 29 questions and DDTC anticipates approximately 80 respondents with a maximum burden of 1 hour per respondent. The burden to industry is anticipated to be 80 hours (80 respondents x 1 hour per response). Participation in completing the survey is voluntary. Given DTAG is conducting the survey, they will handle the correspondence with industry and there is no anticipated cost or burden to the Federal Government.

The DTAG survey is attached for reference.