Cost Burden Memo EOIR 33

U.S. Department of Justice

Executive Office for Immigration Review

Office of the General Counsel

5107 Leesburg Pike, Suite 2600

Falls Church, Virginia 22041

February 4, 2021

MEMORANDUM TO: Lynn Bryant

Clearance Officer

Justice Management Division

FROM: Barbara J. Leen

Associate General Counsel

SUBJECT: Revision of a Currently Approved Form for Approval by the Office of Management and Budget: Form EOIR-33/IC and EOIR 33/BIA (Alien’s Change of Address Forms for the Immigration Court and the Board of Immigration Appeals)

Pursuant to our conversation this afternoon, please accept the following additional information regarding the information collection request (ICR) for the Alien’s Change of Address forms for the Immigration Court and the Board of Immigration Appeals, as required for certification and submission to the Office of Management and Budget.

The ROCIS system states that OMB previously approved the EOIR-33/IC and EOIR-33/BIA with an annual information collection cost burden of $0. However, our records show that OMB approved the EOIR-33/IC and EOIR-33/BIA at an annual information collection cost burden of $7,500. The agency calculated the total annual reporting burden by multiplying the number of respondents (15,000) by the frequency of response (1) by the number of hours per response (.05): 15,000 respondents x 1 response x .05 hour per respondent = 750 burden hours. Further, the agency estimated total annual public cost during the last information collection by multiplying burden hours of 750 by the individual’s estimated cost of $10/hr. to complete the form (the individual’s time and supplies): 750 burden hours x $10/hr. (individual’s estimated cost) = $7,500. The calculations for this extension of the approved EOIR-33/IC and EOIR-33/BIA reflects identical calculations and burden hours as the last IRC, despite ROCIS’s indication that the total annual information cost burden has increased from $0 to $7,500.