PRA Supporting Statement (10-2009)

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SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
AMERICAN CITIZENS SERVICES INTERNET BASED REGISTRATION SERVICE (IBRS)
OMB Number 1405-0152, DS-4024, DS-4024e

A. JUSTIFICATION

1. The information solicited on this form is requested in connection with the provisions of 22 U.S.C. § 2715, 22 U.S.C. § 4802(b), 22 C.F.R. § 71.1,22 C.F.R. § 71.6. and 22 C.F.R. 50.3.

The Department of State provides consular assistance and protection to U.S. citizens and nationals abroad. U.S. citizens and nationals may register with U.S. embassies and consulates abroad. According to 7 FAM 040, in the event of a family emergency, natural disaster or international crisis, U.S. embassies and consulates rely on the system which includes the creation of country-specific and post-specific email lists that registrants can join to receive, via email, updates to country-specific information, travel alerts, and travel warnings specific to the countries they choose to provide critical information and assistance to them.

22 U.S.C. § 2715 provides, inter alia, that in the case of a major disaster or incident abroad that affects the health and safety of nationals of the United States residing or traveling abroad, the Secretary of State shall provide prompt and thorough notification of all appropriate information concerning such disaster or incident and its effect on U.S. nationals to the next-of-kin of such individuals.

22 U.S.C. § 4802(b) provides that the Secretary of State shall develop and implement policies and programs to provide for the safe and efficient evacuation of private U.S. nationals when their lives are endangered. It also provides that the Secretary develop a mechanism whereby United States nationals can voluntarily request to be placed on a list in order to be contacted in the event of an evacuation, or which, in the event of an evacuation, can maintain information on the location of U.S. nationals in high risk areas submitted by their relatives.

22 C.F.R. § 50.3 provides that a person abroad who claims U.S. nationality, or a representative on his behalf, may apply at a consular post for registration to establish his claim to U.S. nationality or to make his residence in the particular consular area a matter of record. The applicant shall execute the registration form provided by the Department and shall submit the supporting evidence. A diplomatic or consular officer or a designated nationality examiner shall determine the period of time for which the registration will be valid.

22 C.F.R. § 71.1 provides for protection of Americans abroad. The Department of State has developed an Internet Based Registration Service (IBRS) that makes it possible for U.S. nationals to register on line from anywhere in the world. The site uses secure encryption. The IBRS system enables the Department and its embassies and consulates abroad to better assist U.S. nationals in the event of a crisis, disaster or other emergency, by providing information about which nationals are present in country.

22 C.F.R. § 71.6 Officers of the Foreign Service shall extend every possible aid and assistance within their power to distressed American citizens within their districts, but they shall not expend the funds nor pledge the credit of the Government of the United States for this purpose, except in the case of American seamen, or except as authorized by the Department of State.

2. The primary purpose for soliciting the information is to enable U.S. nationals to register their whereabouts abroad on a voluntary basis, so that they may be contacted in the event of an evacuation or other emergency, in furtherance of the Secretary's responsibility for the protection of U.S. nationals abroad.

The IBRS is intended for use by U.S. nationals residing or traveling abroad. U.S. nationals may register from their home or business in the United States prior to their overseas travel, or from anywhere in the world using the Internet. The service is available on the Department of State, Bureau of Consular Affairs web site http://travel.state.gov/ at https://travelregistration.state.gov/ibrs/. The information received is used to facilitate locating and contacting U.S. nationals in the event of a major disaster or incident abroad, an evacuation, or a family emergency.

3. This collection of information is stored and primarily collected through electronic means, but a paper version of the information collection has been developed to assist individuals who do not have access to the Internet. U.S. embassies and consulates can enter the data from the paper version received by mail or fax into the IBRS system. The paper version provides a convenient mechanism to supplement existing electronic registration services. While proof of citizenship is needed to register through the IBRS (registrants must enter their U.S. passport number), IBRS registration is not nationality adjudication and does not constitute proof of U.S. nationality.

By registering over the Internet, U.S. nationals do not have to go to a U.S. embassy or consulate, thereby reducing the burden on the public. Increased security threats against U.S. embassies abroad were also a factor in the decision to use electronic registration in lieu of requiring individuals to go to a U.S. embassy or consulate. Traditional on-site registration will still be available.

4. The information in the IBRS is not duplicative of information maintained elsewhere or otherwise available. Since U.S. adult passports are issued for a period of 10 years, the information on the passport application regarding intended places to visit and contacts in the event of an emergency are often not current. The IBRS enables the public to register this information quickly and easily for each trip abroad. 34.

5. The information collection does not involve small businesses or other small entities.

6. Protection of U.S. nationals and citizens, particularly in times of crisis or disaster, is a core function of the Department of State. It is essential that the Department have a reliable mechanism to facilitate communication in time of emergency or for country specific information. If the collection were not conducted, adverse consequences to U.S. nationals abroad during these times could be considerable.

7. Not applicable. No such circumstances exist.

8. The 60-day notice for the current OMB approval for this information collection was published in the Federal Register in Vol. 74, No. 115 / Wednesday, June 17, 2009, pages 28,752-28,753. The purpose of the FR publishing was to solicit comments from the public. No comments were received.

9. Not Applicable. No payment or gift is provided to respondents.

10. Respondents are informed that release of information obtained in this collection is subject to the restrictions on dissemination contained in the Privacy Act (5 USC § 552a). Disclosure is authorized by the Act if, for example, it is made in conjunction with a “routine use.”

The On Line Registration form includes a Privacy Act Statement that is hyperlinked to the text of the Privacy Act (http://foia.state.gov/privacy.asp); the Department of State’s Prefatory Statement of Routine Uses (http://foia.state.gov/issuances/PrefStatement.pdf).

If there are concerns about information security regarding the Internet Based Registration System please refer to the Internet Based Registration Service (IBRS) Privacy Impact Assessment.

IBRS permits registrants to provide information about other members of their traveling party. Information about U.S. nationals will not be revealed by the Department of State unless permitted by the Privacy Act. 11. Not applicable. No questions of a sensitive nature are asked.

12. The Department estimates that 676,946 respondents will file a registration request annually. The DS-4024 takes 20 minutes to complete. Therefore, the annual burden is calculated at 225,648 hrs. (676,946 respondents x 20 mins./60 mins. = 225,648 hrs.). The frequency of response is “on occasion.”

13. The cost to U.S. citizens associated with the completion of the form is de minimis. If access to the Internet is not available, the form can be completed at a public library or other location providing Internet access. The paper version of the form can be faxed or mailed to the Department of State or U.S. embassy or consulate for entry into IBRS.

14. Estimated recurring costs include annual IRM Bureau labor to operate and support servers. IRM costs are based on an average of 2 hours per week at $85/hour, the estimated contract labor rate. The weekly labor cost to operate and support servers is $170/week. 12-month IRM costs are $8,840 ($170/week x 12 months). In addition, the Bureau of Consular Affairs (CA) will incur labor costs to ensure that copies of Travel Warning and Public Announcement updates are recorded in IBRS at the same time they appear on travel.state.gov. The CA time commitment is estimated at 20 hours per week. At an average cost of $85/hour contactor rate, this translates to $1,700 per week and a 12-month total of $88,400 (52 weeks x $1,700/week). The 12-month total cost to the government for operation and maintenance of the electronic IBRS is $97,240 ($8,840 + $88,400).

The annual cost to the government has increased because contract hourly labor rates have risen. Additional labor has been dedicated to ensure that copies of Travel Warning and Public Announcement updates are recorded in IBRS at the same time they appear on travel.state.gov.

15. Burden hour figures have increased from 83,333 hrs. to 225,648 hrs. The burden change is due to the number of respondents using the IBRS increasing from 500,000 to 676,946, and, a recent re-evaluation of form completion time has indicated that the average time of burden should be increased from 10 minutes to 20 minutes.

16. Not applicable. The information collected will not be published.

17. Not applicable. The OMB approval information and expiration date for this collection will be displayed.

18. Not applicable. No exceptions are being requested.

B. STATISTICAL METHODS

This collection does not employ statistical methods.