Manufacturing	Technology	Acceleration	Center	

Pilot	Projects

Request	for	Information

Prepared	By:	 Carrie	Hines

Organization: American	Small	Manufacturers	Coalition

Date: July,	2013
M-TAC	RFI	Comments

2

The	American	Small	Manufacturers	Coalition	(ASMC)	appreciates	the	opportunity	to	provide	

comments	in	response	to	the	RFI	on	the	M-TAC	proposal	in	the	FY14.	As	the	trade	association	

of	the	nation’s	manufacturing	extension	agents	(e.g.	MEP	Centers),	it	is	critical	that	we	have	the	

opportunity	to	comment	on	a	program	in	which	MEP	Centers	are	integrally	involved.

In	2011,	ASMC	released	its	Next	Generation	Manufacturing	Study1 based	on	a	survey	of	826	

manufacturers.	 That	study	showed that	72	percent	of	manufacturers	surveyed	believe	that	

supply	chain	management	is	important	or	highly	important,	but	only	29	percent	of	

manufacturers	are	near	or	at	world-class	status	in	supply	chain	management.	This	gap	presents	

a	barrier	for	long-term	success	for	US	manufacturing.	Small	manufacturers	face	an	even	wider	

gap	than	their	large	manufacturer	counterparts.	Only	25%	of	small	manufacturers	(less	than	

$10	million	in	revenues)	are	near	or	at	world	class	supply	chain	management	vs.	41	percent	of	

large	manufacturers	(more	than	$100	million	in	revenues).2		The	NGM	Study	reported	that	62.7	

percent	of	manufacturers	surveyed	never	or	rarely	get	support	from	outside	resources	for	

supply	chain	development.3		For	this	reason,	ASMC	understands	the	need	for	such	a	supply	

chain	or	industry	cluster	focused	program	like	M-TAC.	Ultimately	however,	it	is	the	structure	

and	execution	of	the	M-TAC	program	which	will	affect	its	impact	on	the	US	manufacturing	

supply	chain	as	a	whole.

ASMC	will	address	the	questions	posed in	the	RFI	in	a	slightly	different	order	to	address	

structural	considerations	first.

Question	5:	Are	there	any other	critical	issues	that	NIST	MEP	should	consider	in	its	strategic	

planning	for	future	M_TAC	investments	that	are	not	covered	by	the	first	four	questions?		Is	so,	

please	address	those	issues	here	and	explain	your	response.

M-TAC	Recipient.	Recipients	of	an	M-TAC	award	should	be	a	MEP	Center	or	a	collaboration	of	

Centers	with	a	proven	expertise	in	an	industry	cluster	or	supply	chain.	M-TAC	recipients	should	

collaborate	with	research	consortia,	institutions	and/or	organizations	with	a	technical	expertise	

in	the	industry	cluster	or	supply	chain.	The	success	of	the	M-TAC	program	should	be	locally	

driven	as	the	needs	of	small	manufacturers	are	individualized	and	cannot	be	broadly	

implemented.	

Overall	structure.	M-TACs	should	have	employ	or	have	access	to	staff	with	an	expertise	in	an	

industry	cluster	or	supply	chain.	M-TACs	would	operate	with	a	three	pronged	approach.

																																																												 1 Manufacturing	Performance	Institute	(MPI). Next	Generation	Manufacturing Study. 2011,	 p.	4 2 MPI, p.	5 3 MPI,	p.	26
M-TAC	RFI	Comments

3

1. Coordinator	of	industry	specific	or	supply	chain	needs.	M-TACs	would	convene a	group	

of	OEMs,	associations	and	others	to	identify	the	challenges	facing	a	specific	supply	

chain.	The	group	would	develop	the	desired	supplier	standard	for	each	challenge	

identified	by	a	set	of	metrics.	 These	standards	would	be	shared	with	all	MEP	Centers	

who	could	assist	local	suppliers	to	achieve	the	supplier	standard.	Center	assistance	

would	not	be	prescribed	about	how	to	achieve	the	standard	(input),	but	the	success	of	

the	service	would	be	evident	in	supplier	achievement	of	the	standard	(output).	As	the	

supplier	standard	is	made	public,	manufacturers	will	want	to	contact	their	local	Center	

to	help	them	achieve	the	standard	and	therefore	make	them	a	more	competitive	

supplier.	This	approach	could	eventually lead	to	the	M-TACs	being	the	supplier	

certification	hub	for	the	industry	or	supply	chain.

2. Gateway	of	small	manufacturers	to	supply	chains.	The	M-TAC	would	also	be	used	as	a	

third	party	provider	of	industry	specific	services	to	local	manufacturers.	Much	like	a	

“Tiger	Team”	of	technical	experts,	staff	of	the	M-TAC	would	provide	third	party	

assistance	to	MEP	Centers	needing	expertise	in	a	certain	industry	or	supply	chain.	For	

example,	when	a	MEP	Center	enters	into	an	engagement	with	a	local	manufacturer	it	

may	call	on	the	M-TAC	to	help	the	manufacturer	improve	its	position	or	gain	access	to	a	

certain	supply	chain.	The	M-TAC	would	be	able	to	draw	on	services	and	technologies	to	

assist	the	manufacturer	to	better	position	itself	in	the	supply	chain,	thereby	improving	

its	performance	and	competitiveness.	This	is	a	bottom-up	approach	which	would	force	

the	M-TAC	to	stay	on	the	leading	edge	of	technology	scouting	and	commercialization.	

This	strategy	also	ensures	that	M-TAC	services	are	market	driven	and	not	pushed.

3. Facilitator	of	OEM	supply	chain	improvements.	M-TACs	could	serve	as	a	third	party	

facilitator	of	OEM	supply	chain	improvements.	Many	OEMs	spend	a	great	deal	of	time	

focused	on	the	stability	and	performance	of	their	supply	chain	by	pushing	down	

requirements	or	metrics	for	their	suppliers	to	achieve.	M-TACs	could	serve	as	the	

national	facilitator	for	the	local	implementation	of	the	national	product	and	process	

technology	the	OEM	requires.	The	MEP	Centers	would	help	implement	the	OEM	

requirements	while	making	the	necessary	improvements	necessary	to	achieve	the	

standard.

Authority	and	Precedence.	Without	specific	authorization	for	the	establishment	and	creation	of	

the	M-TAC	program,	NIST	is	forced	to	use	existing	authority	and	precedence	to	execute	the	

awards.	15 U.S.C.	272	(b)(1,	4,	5)	and	(c)(3,7).4		Precedence	for	this	authority	is	exemplified	in	

																																																												 4 http://www.gpo.gov/fdsys/pkg/USCODE-2011-title15/html/USCODE-2011-title15-chap7-sec272.htm
M-TAC	RFI	Comments

4

the	State	Relations	Rapid	Response	Team	Grants	Program	established	in	2001	which	used	the	

authority of 15 U.S.C. 272 (b)(1) and (c)(17).5

M-TAC	could	also	use	the	authority	of	the	Competitive	Grant	Program	indentified	in	the	

America	COMPETES	Act	(PL	110-69).	The	purpose	of	the	Competitive	Grant	Program	is	aligned	

with	the	goal	of	the	M-TAC	proposal	as	stated	in	the	RFI.	The	Competitive	Grant	Program’s	

purpose	is:

The	purpose	of	the	program	under	this	subsection	is	to	develop	projects	to	solve	new	or	

emerging	manufacturing	problems	as	determined	by	the	Director,	in	consultation	with	

the	Director	of	the	Centers	program,	the	Manufacturing	Extension	Partnership	Advisory	

Board,	and	small	and	medium-sized	manufacturers.	One	or	more	themes	for	the	

competition	may	be	identified,	which	may	vary	from	year	to	year,	depending	on	the	

needs	of	manufacturers	and	the	success	of	previous	competitions.	These	themes	shall	

be	related	to	projects	associated	with	manufacturing	extension	activities,	including	

supply	chain	integration	and	quality	management,	and	including	the	transfer	of	

technology	based	on	the	technological	needs	of	manufacturers	and	available	

technologies	from institutions	of	higher	education,	laboratories,	and	other	technology	

producing	entities,	or	extend	beyond	these	traditional	areas.6

Required	MEP	Center	Involvement.	In	order	to	achieve	the	goal	of	“fostering	connections	

between	the	existing	MEP	system	and	its	network	of	Centers...”7 the	involvement	of	the	MEP	

Centers	within	a	proposed	region	should	be	a	requirement.	As	the	only	national	public/private	

conduit	to	the	nation’s	small	manufacturing	community,	local	MEP	Center	involvement	is	

critical	to	the	success	of	this	program.	The	involvement	however,	should	be	defined	as	a	key	

coordinator	of	partners	and	expertise	as	well	as	financial	recipient/sub-recipient	of	the	FFO	to	

cover	the	expenses	of	the	expanded	services.	

Role	of	the	MEP	Center.	The	role	of	the	MEP	Center	is	simple.	The	local	MEP	Center	will	serve	as	

the	interface	between	the	M-TAC	and	the	local	manufacturer	being	served.	The	very	nature	of	

MEP’s	original	authorizing	legislation	calls	for:	

1.	the	transfer	of	manufacturing	technology	and	techniques	developed	at	the	Institute	

to	Centers	and,	through	them,	to	manufacturing	companies	throughout	the	United	

States;

2.	the	participation	of	individuals	from	industry,	universities,	State	governments,	other	

Federal	agencies,	and,	when	appropriate,	the	Institute	in	cooperative	technology	

transfer	activities;

3.	efforts	to	make	new	manufacturing	technology	and	processes	usable	by United	

																																																												 5 https://www.federalregister.gov/articles/2001/10/04/01-24928/state-relations-rapid-response-team-sr3-teamgrants-program 6 http://www.nist.gov/mep/upload/PL110-69_8907.pdf 7 https://www.federalregister.gov/articles/2013/06/21/2013-14895/request-for-information-on-pilots-to-informthe-creation-of-potential-new-manufacturing-technology
M-TAC	RFI	Comments

5

States- based	small- and	medium-sized	companies;

4.	the	active	dissemination	of	scientific,	engineering,	technical,	and	management	

information	about	manufacturing	to	industrial	firms,	including	small- and	medium-sized	

manufacturing	companies;	and

5.	the	utilization,	when	appropriate,	of	the	expertise	and	capability	that	exists	in	Federal	

laboratories	other	than	the	Institute.8

These	functions	are	consistent	with	the	purpose	of	the	M-TAC	with	the	nuance	that	the	M-TAC	

would	provide	a	more	broad	regional	or	national	coordination	and	service	offering	aligned	by	

industry	cluster	or	supply	chain.	The	participating	MEP	Centers	would	be	the	conduit	to	the	

local	manufacturer	who	will	draw	up	on	the	specialized	capacity	of	the	M-TAC	to	deliver	supply	

chain	or	industry	cluster	services	as	needed.

Questions	1:	What	are	the	specific	types	of	technology	transition	and	commercialization	tools	

and	services	that	should	be	provided	by	M-TACs?	Emphasis	is	on	the	alignment	of	these	tools	

and	services	with	the	most	pressing	needs	of	small	and	mid-sized	U.S.	manufacturers.

Without	knowledge	of	the	needs	of	the	specific	supply	chains	or	industries,	it	is	impossible	to	

specify	what	technology	commercialization	tools	and	services	could	be	provided.	As	mentioned	

in	question	5	above,	M-TACs	should	first	identify	the	most	pressing	needs	and	develop	supplier	

standards	in	each	area.	M-TACs	should	then	call	upon	industry	experts	and	research	institutions	

to	develop	tools	and	services	to	meet	these	needs	and	offer	them	as	a	suite	of	services	to	

Centers	to	implement.	M-TACs	should	focus	on	the	improving	small	manufacturers	

performance	and	integration	within	a	supply	chain,	without	prescribing	(or	requiring)	a	way	in	

which	to	achieve	it.	

Throughout	the	history	of	the	program,	MEP	Centers	have	learned	that	the	needs	of	its	small	

manufacturing	clients	are	as	unique	as	their	product.	Tools	and	services	must	be	tailored	to	the	

needs	of	each	unique	client.	Unless	prescribed	by	an	OEM,	technology	transition	and	

commercialization	tools	would need	maximum	flexibly	for	small	manufacturer	implementation.	

Question	1a:	How	would	M-TAC	services	complement	the	services	currently	offered	by	MEP	

Centers?

MEP	Centers	currently	offer	an	array	of	services	to	small	manufacturers	including	(but	not	

limited	to):	process	improvements;	quality	systems;	business	systems;	product	development	

and	testing;	innovation;	and	technology	implementation.	The	M-TAC	would	be	yet	another	

access	point	to	manufacturers	which	would	provide	a	specialized	expertise	around	one	industry	

cluster	or	supply	chain.	M-TACs	could	also	coordinate	the	supplier	development	needs	of	OEMS	

and	serve	as	an	intermediary	between	the	OEM	and	MEP	Centers	for	implementation	to	

																																																												 8 http://www.gpo.gov/fdsys/pkg/USCODE-2011-title15/pdf/USCODE-2011-title15-chap7-sec278k.pdf
M-TAC	RFI	Comments

6

suppliers.	MEP	Centers	would	continue	to	be	the	local	contact	to	all	small	and	medium-sized	

suppliers	but	draw	upon	regional	or	national	resources	as	necessary.

Question	2:	What	role	should	future	M-TACs	play	with	respect	to	supply	chain	needs?		How	

should	OEMs	participate?		How	can	industry	associations,	professional	societies,	and	other	

appropriate	national	organizations	participate?

M-TACs	should	have	a	significant	role	in	identifying	the	needs	and	challenges	of	supply	chains	

as	noted	above.	By	first	identifying	the	needs	of	the	supply	chain	and	developing	a	supplier	

standard	in	each	area,	the	M-TACs	can	then	identify	appropriate	tools	and	services	that	can	

meet	those	needs.	Doing	so	would	identify	market	demand	for	supplier	development	services	

which	would	drive	local	manufacturers	to	pay	for	those	services	through	their	local	MEP	Center.	

Market	demand	for	supplier	development	services	is	a	critical	component	to	the	M-TAC	

program	as	cost	share	for	the	MEP	Center	is	a	significant	driver	of	service	delivery.

Industry	associations,	professional	societies	and	other	appropriate	national	organizations	could	

participate	in	three	ways.	First,	these	organizations	can	serve	a	key	role	in	identifying	the	needs	

of	various	supply	chains	and	assisting	in	the	supplier	standard	in	each	of	those	areas.	Second,	

industry	associations	and	professional	societies	could	be	a	service	provider	of	the	M-TAC	to	

local	MEP	Center	clients.	For	example,	with	significant	knowledge	of	the	supply	chain	M-TAC	

experts	could	provide	an	individual	market	analysis	of	the	supply	chain	for	perspective	

suppliers.	Third,	these	organizations	can	market	the	M-TAC	services	specific	to	the	supply	chain.

Question	3:	Is	there	a	particular	long-term	scalable	and	financially	sustainable	business	model	

that	should	be	implemented	by	future	M-TACs	that	will	enable	small	and	mid-sized	U.S.	

manufacturers	to	effectively	access	and	benefit	from	the	technology	transition	and	

commercialization	assistance	and	other	resources	they	need?

Without	authorization	as	proposed,	the	current	M-TAC	program	does	not	have	long-term	

scalable	and	financially	sustainable	business	model	without	using	the	existing	MEP	network.	By	

using	the	existing	MEP	Center	network	for	cost	share	and	reporting,	start-up	costs	are	

minimized	and	the	probability	for	success	for	the	M-TAC	program	are	increased.	 If	the	M-TAC	

program	is	structured	like	a	specialized	coordination	or	service	model	for	industry	clusters	and	

supply	chains,	it	could	be	an	addition	to	a	Centers	base	offering	and	therefore	use	the	financial	

and	reporting	mechanisms	in	place	to	be	scalable	in	the	future.	This	structure	(exempt	from	

cost	share)	could	be	immediately	effective	and	targeted	as	M-TACs	are	intended.

If	the	

Questions	3a:	Because	of	the	programmatic	connection	to	the	NIST	MEP	Program,	M-TACs	

may	require	cost	share.	Are	there	cost	share	models	for	future	M-TACs	that	promote	scale	up	
M-TAC	RFI	Comments

7

to	reach	nationally	dispersed	clusters	of	small	and	med-sized	manufacturers?		If	so,	what	are	

those	models,	and	why	might	they	be	successful?

The	M-TAC	program	should	not	require	cost	share.	If	the	Centers	are	to	be	the	conduit	to	the	

manufacturer	and	the	deliverer	of	services	using	the	M-TAC	specialist	as	third	party	providers,	

the	program	should	not	require	cost	share.	Placing	a	matching	requirement	on	M-TACs	would	

be	duplicative	to	Center	matching	requirements	and	could	be	detrimental	to	base	operations	of	

an	MEP	Center.	Currently,	Centers	are	strategically	partnered	with	local	research	institutions,	

federal	labs	and	others.	If	M-TACs	require	cost	share	separately,	Center	partners	would	be	

more	inclined	to	partner	with	the	M-TAC	assuming	that	the	cost	requirement	is	less	than	the	

Center.	In	addition,	these	research	institutions	would	be	more	inclined	to	partner	with	a	

regional	based	M-TAC	than	their	local	Center	for	the	prospects	of	a	broader	manufacturing	

base.	These	two	factors	alone	would	cause	Centers	to	possibly	lose	match	necessary	to	access	

federal	funds	for	the	base	MEP	Center	award	as	well	as	client	impact	needed	to	maintain	it.	

There	are	several	programmatic	connections	to	the	NIST	MEP	Program	that	do	not	require	cost	

share.	An	example	of	which	is	the	State	Relations	Rapid	Response	Team	Grant	referenced	

above.	Although	this	program	used	NIST	authority,	it	was	directly	related	to	MEP	and	was	

similar	in	its	approach.	The	Rapid	Response	Team	was	funded	as	group of	specialist	that	would	

be	deployed	to	Centers	to	improve	upon	or	establish	state	relations.	M-TACs	would	operate	in	

an	identical	manner	and	therefore	should	not	require	cost	share.

Another	example	is	the	“T-CAR”	grant	program	authorized	in	the	America	COMEPETES	Act

(PL110-69).	Funding	was	subsequently	provided	for	this	authorized	program	via	MEP’s	annual	

appropriation	without	a	special	designation	in	the	appropriations	law.	“Unless	the	underlying	

law	prohibits	it,	the	Congress	may	also	extend	the	program,	simply	by	providing	new	

appropriations.”9		Since	appropriations	for	the	T-CAR	program	was	not	specifically	included	in	

the	FY10-13	Appropriations	bills,	yet	was	funded,	existing	precedent	exists	to	use	part	of	MEP’s	

overall	appropriation	for	the	M-TAC	program	using	T-CAR	authority	as	a	basis.	Through	the	TCAR	authorization,	Centers	(or	collaboration	of	Centers)	can	apply	to	expand	existing	

operations	to	provide	such	services	using	the	existing	infrastructure,	metric	system	and	

partners	in	place.	

Question	4:	How	should	an	M-TAC’s	performance	and	impact	be	evaluated?		What	are	

appropriate	measures	of	success	for	future	M-TACs?		Please	explain	your	response	including	

the	value	of	performance	measure	to	business	growth.

																																																												 9 http://www.appropriations.senate.gov/about-budget-process.cfm
M-TAC	RFI	Comments

8

M-TAC	performance	and	impact	should	be	evaluated	through	the	existing	MEP	client	survey.	

This	would	prevent	increased	administrative	burden	and	cost	to	both	NIST	and	MEP	Centers.	MTAC	success	is	based	a	small	manufacturers	improved	access	and	integration into	the	supply	

chain.	Additional	client	survey	questions	should	include	should	include	new	and	retained	access	

to	supply	chains	which	would	measure	the	success	of	a	client	served	by	the	M-TAC	and	

therefore	the	M-TAC	itself.