RT Supp Stmt (2-27-07)

INFORMATION COLLECTION SUPPORTING STATEMENT
Registered Traveler Program

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any
legal or administrative requirements that necessitate the collection. Attach a copy of the
appropriate section of each statute and regulation mandating or authorizing the collection
of information. (Annotate the CFR parts/sections affected).
Section 109 of the Aviation and Transportation Security Act (ATSA) provides the
Transportation Security Administration (TSA) with the authority to "establish requirements
to implement trusted passenger programs and use available technologies to expedite security
screening of passengers who participate in such programs, thereby allowing security
screening personnel to focus on those passengers who should be subject to more extensive
screening." TSA's Registered Traveler (RT) program is being piloted under the authority of
this section. TSA will facilitate a partnership with the private sector to establish an
interoperable, vendor-neutral RT program in the United States. RT potentially offers
advantages for the TSA, industry, and the traveling public primarily through enhanced
security and customer service.
TSA has been conducting a RT Pilot Program to test this concept with OMB's approval since
late June 2004. TSA is seeking a revision of this collection so it may expand the RT Pilot
Program and add additional locations. This expansion, called the Registered Traveler
Interoperability Pilot (RTIP), will evaluate technologies and business processes related to the
RT concept including interoperability and a privatelpublic partnership model of RT. Based
on the RTIP, TSA will incorporate lessons learned and best practices followed by a Notice of
Proposed Rulemaking (NPRM) for the national program.

2. Indicate how, by whom, and for whatpurpose the information is to be used. Except for a
new collection, indicate the actual use the agency has made of the information received
from the current collection.
TSA will be gathering information in relation to the RTIP through three mechanisms. For all
three mechanisms, TSA received approval for the substance of the information tools through
previous Information Collection Requests (ICR). First, TSA requested a Statement of
Interest (SOI) from all airportslair carriers interested in participating in the RT program. The
SO1 is a collection of basic information TSA is using to determine the level of interest and
intent to participate in the RT program.
Second, as part of the pre-qualification process for companies that wish to participate in RT
SPs, TSA will collect certain personally identifying information on company officers and key
personnel and basic financial information about the company in order to verify the
company's identity and assess whether a security risk exists should that vendor participate in
RT. TSA will use the identifying information, such as name, contact information, and date
of birth, to conduct a security threat assessment (STA) and collect fingerprint images to

conduct fingerprint-based Criminal History Records Check (CHRC) on the company officers
and key personnel. TSA has uploaded the Service Provider application in ROCIS.
Third, an application form will solicit biographic information from RT applicants before they
join the program. RT applicants provide express written authorization to collect this
information and provision of the information is voluntary. This information will be collected
by SPs, which must be sponsored by an airport or air carrier participating in the RT program.
The SPs create their own application forms, which TSA does not design or control. SPs may
collect additional information from applicants for their own business purposes, beyond that
which TSA requires to conduct a name-based STA. Each SP web site includes a statement
that additional information beyond biographic collected by SPs is not endorsed by TSA.
During this enrollment process, SPs will collect biographic and biometric information from
RT applicants, transmit it to the TSA contractor which operates the Central Information
Management System (CIMS), where it will be formatted and transmitted to TSA in order to
perform a name-based STA. Based on the results of the STA, applicants will receive an
approved or not approved STA and those results (approvedlnot approved) will then be
transmitted back to the CIMS and retrieved by the SP. The SP will then issue RT cards to
approved applicants that contain the individual's biometric template. TSA requires the use of
biometric data to verify the identity of Registered Travelers at the airport security checkpoint.
TSA will use the applicants' information for the following purposes: to pre-screen travelers
by conducting STAs; to accept applicants who receive an approved STA finding; to expedite
security screening at airport checkpoints for approved Registered Travelers by using
advanced identification technologies, including biometrics; to assist in the management and
tracking STA results for RT applicants and RT participants; to permit the retrieval of STA
results; and to refer to the appropriate intelligence and law enforcement entities the identity
of RT applicants or RT participants who pose or are suspected of posing a threat to
transportation or national security.

3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological collection techniques or other
forms of information technology, e.g., permitting electronic submission of responses, and
the basis for the decisionfor adopting this means of collection. Also describe any
consideration of using information technology to reduce burden.
In compliance with the Government Paperwork Elimination Act (GPEA), all collection
elements of the RT program may be submitted to TSA electronically. For example, RT
applicants will be required to enroll in person at a designated RT enrollment center where an
SP sponsored by an airport or air carrier participating in the program will enter their
information electronically. This not only fulfills the requirements of the GPEA, but it also
facilitates the collection and processing of the data and provides an efficient means of
retrieving information.

4. Describe efforts to identify duplication. Show specifically why any similar information
already available cannot be used or modified for usefor the purpose(s) described in Item 2
above.
Since 911 1, key aviation stakeholders have asked TSA to provide leadership and direction in
assessing the feasibility of the RT concept.
Prior to establishing the RT Program Management Office (PMO), TSA directed a contractor
to determine whether any other programs or organizations were collecting similar
information and data that could be leveraged by the RT Pilot Program. It was determined that
no programs or organizations were collecting information and data that met the security and
procedural requirements of the RT Pilot Program.

5. If the collection of information has a significant impact on a substantial number of small
businesses or other small entities (Item 5 of the Paperwork Reduction Act submission
form), describe the methods used to minimize burden.
There is no significant burden to small businesses.

6. Describe the consequence to Federal program or policy activities if the collection is not
conducted or is conducted lessfrequently, as well as any technical or legal obstacles to
reducing burden.
Without collecting the information from airports, air carriers, and companies that seek to
participate in the RTIP, TSA will be unable to select qualified Sponsoring Entities and
Service Providers that meet TSA-mandated standards. Without gathering the information
and data needed to enroll individuals in the RTIP, TSA cannot verify an individual's identity,
conduct an STA or permit the SP to issue an RT card
7. Explain any special circumstances that require the collection to be conducted in a manner
inconsistent with the general information collection guidelines in 5 CFR 1320.5(d)(2).
This collection is consistent with 5 CFR 1320.5(d)(2).

8. Describe efforts to consult persons outside the agency to obtain their views on the
availability of data,frequency of collection, the clarity of instructions and recordkeeping,
disclosure, or reportingformat (if any), and on the data elements to be recorded, disclosed,
or reported. If applicable, provide a copy and identify the date and page number of
publication in the Federal Renister of the agency's notice, required by 5 CFR 1320.8(d)
soliciting comments on the information collection prior to submission to OMB.
Summarize public comments received in response to that notice and describe actions taken
by the agency in response to these comments. Specifically address comments received on
cost and hour burden.
TSA provided notice of its intent to seek approval of a new information collection to expand
the RT Pilot Program beyond the pilot phase in the Federal Register on December 16, 2005

(70 FR 74837). Although there has been much interest in the RT concept, TSA did not
receive any comments addressing the burden estimates provided in the Federal Register.
TSA ultimately decided to seek approval for a revision of this control number in order to
extend the pilot further, rather than seek an entirely new control number at this point, hence
the reason for the emergency submission. After receiving emergency approval, TSA
provided notice of its intent to seek renewal of this collection of information on July 18, 2006
(7 1 FR 4073 1). To TSA's knowledge, no comments were received on the information
collection aspect of this collection.
In addition, TSA has been working with and will continue to work closely with many public
and private stakeholders to develop and implement the most efficient and secure system
possible.
9. Explain any decision to provide any payment or gifi to respondents, other than
remuneration of contractors or grantees.

TSA will not provide payment or gifts to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.

TSA has not provided assurances of confidentiality to respondents. However, the surveys
will be conducted on an anonymous basis.

11. Provide additional justification for any questions of sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private.
TSA does not seek sensitive information from RT applicants.

12. Provide estimates of hour burden of the collection of information.
TSA will be gathering information in relation to the RTIP through three mechanisms. First,
TSA is suggesting airportslair carriers interested in participating in the RT program submit
an SOI. Second, as part of the pre-qualification process for companies who wish to
participate in RT as SPs an application form will solicit personally identifying information on
company officers and key personnel and basic financial information about the company.
Third, an application form will solicit biographic information from potential participants
before they join the program. For all three mechanisms, TSA received approval the
substance of the information tools through previous ICRs.
AirportIAir Carrier Statement of Interest

In our previous ICR submission, TSA estimated that 10-20 airportslair carriers would
participate in the RTIP. Based on increased airportlair carrier interest, TSA currently
estimates that up to 30 airportslair carriers will apply to participate and that it will take each

airport approximately 1 hour to prepare and submit their SOI, for a total hour burden of 30
hours. TSA also will require airports or air carriers seeking to participate in the RTIP to
submit other documents as necessary describing how the program will operate, which will
include preparing and submitting a Validation and Verification Report demonstrating how its
operations comport with TSA-issued RT guidelines. TSA estimates that a maximum of 30
airports will submit this documentation, with an hour burden of approximately 40 hours per
airport, for a total of approximately 1,200 hours. Thus, TSA estimates the total hour burden
for the airport participation approval process to be approximately 1,230 hours (30 hours +
1,200 hours).

Number of AirportsIAir Carriers Submitting Statement of Interest
1 Number of AirportsIAir Carriers Submitting other supporting
documentation
Total Burden Hours

Minimum Maximum
15
30
15

30

61 5

1230

Service Provider Applications

TSA will require that all SPs complete an application form prior to participation in the RT
program. TSA will use this information to assess qualifications of the SP and determine
whether a security risk exists should that vendor participate in RT. TSA will use the
identifying information, such as name, contact information, and date of birth, to conduct an
STA and fingerprint-based CHRC on the company officers and key personnel. TSA
estimates that it will collect the information necessary to conduct the STAs from up to 12
companies, with approximately 25 persons per company affected and with an hour burden of
approximately 3 hours per person. Thus, TSA estimates the hour burden for the collection of
STA information to be 900 hours. TSA also will require participating companies to submit
general information (organizational, legal, and ownership) about themselves so that TSA can
ensure the company does not present a known security risk in relationship to RT. TSA
estimates the hour burden per company for this aspect of the collection to be approximately
12 hours for a total of 144 burden hours. Thus, TSA estimates the total hour burden for the
company pre-qualification process to be approximately 1,044 hours (900 hours + 144 hours).

1

/
Number of Companies
Number of Employees per Company
Estimated Total Processing Time in Hours

Minimum
6
25
522

I

Maximum 1
12
25
1044

Participant Applications for Expansion of Pilot

There are currently 28,000 participants in the RT Pilot. Based on the current RT Fee Model,
the potential population size during the expansion of the pilot will range from 180,000
(12,000 participants x 15 participating airportslair carriers) to 900,000 (30,000 participants x
30 participating airportslair carriers). For the RT Pilot Program participants, we expect a

maximum of 900,000 respondents and based on an estimate of a 20-minute burden per
respondent, a maximum total burden of 300,000 burden hours for participant applications.
Minimum

Maximum

15
12,000
180,000
60,000

Number of Locations
Participants per Location
Population Size
Total Burden Hours

30
30,000
900,000
300,000

The RT program will require that all applicants complete an application providing biographic
information that TSA will use to conduct STAs. Biometric data (fingerprints and iris data)
will also be collected. It is expected that the entire population (up to 900,000 participants-less the 28,000 current participants) will complete these forms and provide biometric data.
Listed below is the breakdown for the methods TSA will use for collection of information.

Estimated Respondents

Airport/Air Carrier
Statements of Interest
AirportIAir Carrier
other supporting
documentation
Service Provider
~~~lications'
Service Provider
Employee Applications
Participant Applications
Total Burden Hours

Min

Max

15

30

15

Time per
Response
(Hrs)

Estimated Burden
Hours

Min

Max

1.O

15

30

30

40.0

600

1200

6

12

12.0

72

144

150

300

3.O

450

900

180,000

900,000

0.33

60,000

300,000

61,137

302,274

Total Annual Burden: TSA estimates the maximum total burden for all collection pieces of
this ICR is 302,274 hours.
Total Annual Number of Respondents: The maximum number of respondents for all
aspects of this program is 900,3 12 respondents.

I

The Service Provider and Service Provider Employee Applications are in one document, titled "Service Provider
Application."

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers
resulting from the collection of information.

Only a portion of the fee charged to voluntary RT applicants, which covers the cost for TSA
to fulfill its responsibilities under the RT program, will be forwarded to TSA. TSA estimates
this to be approximately $28 per participant. This includes the cost to convert participants of
the existing Orlando pilot program to the new phase. Thus, TSA estimates the total annual
cost burden to respondents or record keepers resulting from the collection of information is
$25,200,000 [$28 X 900,000]
TSA estimates that the Service Provider applicant companies will be charged $43 per
employee for the STAs and CHRCs, for a total annual cost of $12,900 [$43 X 300
employees].
TSA estimates the costs the airports will incur as a result of preparing and submitting the
other supporting documentation to TSA if they wish to participate in the RT program will be
approximately $2,400,000. This cost is attributed to the likelihood that airports will require
the services of a Certified Public Accountant to complete the Validation and Verification
Report for their vendors. TSA estimates that between 6 and 12 vendors will participate in
Registered Traveler at a cost of approximately $200,000 per company, with the cost burden
ranging between $1,200,000 (for 6 companies) and $2,400,000 (for 12 companies).
Thus, the total annual cost burden for all aspects of this collection will be $27,612,900.
14. Provide estimates of annualized cost to the Federal Government. Also, provide a
description of the method used to estimate cost, and other expenses that would not have
been incurred without this collection of information.

The estimated cost to the Government for STAs will be recovered in the fee charged to the
RT participants. TSA will not assume the costs for enrollment in this pilot program, rather,
the private partner will perform these business processes (or hire a contractor to do so) and
TSA will provide standards and guidelines.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of
the OMB Form 83-1.

As discussed above, due to positive responses to the current pilot, the need to evaluate
systems interoperability, and the need to conduct a robust metrics analysis, TSA has
extended the current pilot program. The program changes reflected in items 13 and 14 are
the result of this extension. Specifically, the burden increased due to the expansion of the
potential number of respondent airportslair carriers and the setting of a fee for program
participants. TSA anticipates that as the program expands, the number of potential
respondents will increase (for example, participant airportslair carriers, Service Providers
(SPs), and the number of individual program participants); thus, TSA has built this change
potential into its burden estimates.

Additionally, TSA has decided not to administer two instruments (customer satisfaction
surveys and stakeholder interviews) described in previous submissions of this ICR. The
intent of these instruments was to measure satisfaction of RT Pilot Program participants and
key stakeholders. However, after further evaluation, TSA has determined that the SPs, which
market the program and are the point of contact for program participants, are in the best
position to measure customer satisfaction if they so choose. TSA has removed these
instruments from our ICR.
Breakdown of burden increasetdecrease for each collection:
Collection
AirporttAir Carrier Statement
of Interest
Service Provider PreQualification
Participant Enrollment

Previous ICR burden estimate
850 hours (for 20 airportslair
carriers)
$2,400,000 cost
1,044 hours

Current ICR burden estimate
1230 hours (for 30 airportslair
carriers)
$2,400,000 cost
1,044 hours

300,000 hours
$25,200,000 cost (assuming
900,000 respondents X $28
fee)
0*
72,000 hours
Surveys
0*
120
Stakeholder Interviews
*These collections have been removed from TSA's Information Collection Request.
396,000 hours
$8,000,000 cost (assuming
1,200,000 participants)

16. For collections of information whose results will be published, outline plans for tabulation
and publication. Address any complex analytical techniques that will be used. Provide the
time schedule for the entire project, including beginning and ending dates of the collection
of information, completion of report, publication dates, and other actions.
TSA will not publish results from this information collection.

17. If seeking approval to not display the expiration datefor OMB approval of the information
collection, explain the reasons that display would be inappropriate.
TSA is not seeking such approval.

18. Explain each exception to the certification statement identified in Item 19, "Certij?cation
for Paperwork Reduction Act Submissions," of OMB Form 83-1.
TSA does not seek any exception to the certification statement.