SUPPORTING STATEMENT
(Form I-92)
A. Justification
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 statue and regulation mandating or authorizing the collection of information.
Form I-92 is part of the manifest requirements of Sections 231 and 251 of the Immigration and Nationality Act (INA). This Form is used to collect passenger and crew information from commercial and military airlines and vessels upon arrival in the U.S. at CBP ports of entry. It lists the name of the airline or vessel, flight number, points of origin, and information about the passengers and crew. This form is provided for in 8 CFR 231.
2. Indicate how, by whom, and for what purpose 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.
The Form I-92 is used by CBP to verify passenger and crew counts against those provided through the Advanced Passenger Information System (APIS). In addition, the Bureau of Economic Analysis and the Office of Travel and Tourism Industries, both of the Department of Commerce, have stated a continuing need for the data collected on this form. This data from the I-92 provides necessary information for these agencies to develop statistics and trends in international travel, trade, and tourism.
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 decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
Form I-92 is filled out on the plane or vessel and submitted to CBP upon arrival, so electronic submission is not appropriate. In addition, CBP plans to eliminate this Form in the next one to two years, so it would not be appropriate for CBP to devote resources to automate this form.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
The data collected on the I-92 is duplicative of several other information collections such as the Advance Passenger Information System. Because of this duplication, CBP plans to eliminate the I-92 in the next one to two years. See Item #8 of this Statement for further discussion.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
This information collection does not have an impact on small businesses or other small entities.
6. Describe consequences to Federal program or policy activities the collection is not conducted or is conducted less frequently.
The Bureau of Economic Analysis and Office of Travel and Tourism of the Department of Commerce have stated a continuing need for the data collected on this form. These agencies currently obtain their data from the Department of Transportation’s analysis of the I-92 forms. Also if this information was not collected, it would hinder CBP’s ability to verify passenger counts on arriving commercial and military flights and vessels.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
This information is collected in a manner consistent with the guidelines of 5 CFR 1320.5(d)(2).
If applicable, provide a copy and identify the date and page number of publication in the Federal Register 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.
Public comments were solicited through two Federal Register notices published on October 23, 2009 (Volume 74, Page 54839) and on January 20, 2010 (Volume 75, Page 3245).
Three comments were received. Two commenters from Department of Commerce, including the Bureau of Economic Analysis and the International Trade Administration, Office of Travel and Tourism Industries were in support of CBP continuing the I-92 because they use the data from this form to compile statistics on travelers.
The Air Transport Association requested that CBP eliminate this form because they say it is unnecessary and duplicative of similar information collections such as Advance Passenger Information System (APIS) and of US-VISIT’s system Passenger Name Records (PNR).
CBP agrees with the Air Transport Association in that the data collected on the I-92 is similar to some the data collections that they cite in their letter. CBP has continued to collect the I-92 primarily for the data requirements of the Department of Commerce. CBP is working with the Department of Commerce so that they will eventually be able to obtain the data they need from alternate sources including the I-94 and APIS. Once the Department of Commerce is no longer dependent on the I-92, CBP will eliminate this form. We plan to eliminate the I-92 in the next one to two years.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
There is no offer of a monetary or material value for this information collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
There are no assurances of confidentiality provided to the respondents of this information collection.
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. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
There are no questions of a sensitive nature.
Provide estimates of the hour burden of the collection of information.
INFORMATION COLLECTION |
TOTAL ANNUAL BURDEN HOURS |
NO. OF RESPONDENTS |
NO. OF RESPONSES PER RESPONDENT |
TOTAL RESPONSES |
TIME PER RESPONSE |
Form I-92
|
129,600 |
720,000 |
1 |
720,000 |
11 minutes (.18 hours) |
Public Cost
The estimated annual public cost is $3,628,800. This is based on the annual burden hours (129,600) x the average hourly rate ($28.00) = 3,628,800.
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
There are no record keeping, capital, start-up or maintenance costs associated with this information collection.
14. Provide estimates of annualized cost to the Federal Government. Also provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
The estimated annual cost to the Federal Government associated with the review of these records is $2,509,920. This is based on the number of annual responses (720,000) that must be reviewed (x) the time to review and process each response (.083 hours) = 59,760 hours (x) the average hourly rate ($42.00) = $2,509,920.
15. Explain the reasons for any program changes or adjustments reported in items 12 or 13 of this Statement.
There has been no increase or decrease in the estimated annual burden hours previously reported for this information collection
16. For collection of information whose results will be published, outline plans for tabulation, and publication.
This information collection will not be published for statistical purposes by CBP.
17. If seeking approval to not display the expiration date, explain the reasons that displaying the expiration date would be inappropriate.
CBP will display the expiration date for OMB approval of this information collection.
18. “Certification for Paperwork Reduction Act Submissions.”
CBP does not request an exception to the certification of this information collection.
No statistical methods were employed by CBP.
File Type | application/msword |
File Title | SUPPORTING STATEMENT |
Author | ANDREA FLEET |
Last Modified By | Authorized User |
File Modified | 2010-01-25 |
File Created | 2010-01-25 |