1652-0035 Ss

8

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).

On December 12, 2003, Congress enacted the Vision 100-Century of Aviation Reauthorization Act (Public Law 108-176; 117 Stat. 2595). Section 823 of Vision 100 requires the Secretary of Homeland Security to develop a security plan to permit general aviation (GA) aircraft to resume operations into and out of Ronald Reagan Washington National Airport (DCA).

The Transportation Security Administration (TSA) issued an interim final rule (IFR) that implemented the requirements of Vision 100 (70 FR 41586, July 19, 2005). The IFR requires GA aircraft operators to designate a security coordinator and adopt a DCA Access Standard Security Program (DASSP). As part of the DASSP, the GA aircraft operators must ensure that all flight crewmembers, armed security officers (ASOs), and security coordinators have undergone a fingerprint-based criminal history records check (CHRC).

GA aircraft operators must also apply to the Federal Aviation Administration (FAA) for a reservation, and to TSA for authorization, to operate flights into and out of DCA. To receive authorization for a flight, GA aircraft operators must ensure that name-based security threat assessments are conducted by TSA on their crewmembers and passengers, including armed security officers (ASOs),who are required to be onboard.  Each ASO must complete specialized training and receive authorization from TSA.  The last point of departure for approved flights into DCA must be from a Fixed Base Operator (FBO)¹ that holds a security program approved by TSA from an airport designated by TSA (“gateway airport”).  At each gateway airport, TSA will inspect the aircraft and will screen the passengers, their carry-on property, and property carried in the cargo hold of the aircraft, before it departs for DCA.  The aircraft operator must also comply with all applicable FAA rules.

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.

TSA requires the following individuals to submit fingerprints and other identifying information: individuals designated as security coordinators by FBOs and GA aircraft operators; flight crewmembers who operate GA aircraft into and out of DCA in accordance with the IFR and DASSP; and ASOs approved in accordance with the IFR. In addition to fingerprints, these individuals also are required to submit the following information: (1) legal name, including first, middle, and last, any applicable suffix, and any other names used; (2) current mailing address, including residential address if different than current mailing address; (3) date and place of birth; (4) social security number (submission is voluntary although recommended); (5) citizenship status and date of naturalization if the individual is a naturalized citizen of the United States; and (6) alien registration number, if applicable. In addition to providing fingerprints and identifying information, ASOs must also provide personal history information (employment, criminal, education, training, military, medical, and law enforcement experience) as well as a photograph and weapon information. For ASOs, TSA will also conduct an employment history verification check. TSA uses this information to perform a CHRC and a security threat assessment in order to assess whether the individuals pose a security threat. For flight crewmembers, TSA also uses this information to check their FAA records to determine whether they have a record of violation of specified FAA regulations. As part of the threat assessment process, TSA shares the information with the Federal Bureau of Investigation (FBI) and the FAA.

GA aircraft operators are required to provide TSA with the following identifying information for all individuals onboard each aircraft that operates into and out of DCA: (1) legal name, including first, middle, and last, any applicable suffix, and any other names used; (2) date and place of birth; (3) social security number (submission is voluntary, although recommended); (4) current mailing address, including residential address if different than current mailing address; (5) citizenship status and date of naturalization if the individual is a naturalized citizen of the United states; (6) alien registration number if applicable.

GA aircraft operators also are required to provide TSA with the flight plan and registration number of their aircraft that will operate to or from DCA. TSA shares this information with the FAA for purposes of tracking and identifying approved aircraft.

Armed security officer nomination and training

Aircraft operators and FBOs participating in this program can nominate the individuals they would like to be qualified as ASOs by submitting an ASO nomination form to TSA. Once nominated, the ASOs are required to submit information set forth above, as well as employment history information, by completing an on-line application. TSA uses the applicants’ information to conduct a fingerprint-based criminal history records check and security threat assessment. Upon successful completion of these checks, the names of all qualified applicants are provided to the Office of Law Enforcement/Federal Air Marshals Service (OLE-FAMS). All qualified applicants must then successfully complete a TSA-approved training course.

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. [Effective 03/22/01, your response must SPECIFICALLY reference the Government Paperwork Elimination Act (GPEA), which addresses electronic filing and recordkeeping, and what you are doing to adhere to it. You must explain how you will provide a fully electronic reporting option by October 2003, or an explanation of why this is not practicable.]

In compliance with the GPEA, TSA has developed an on-line application system that automatically processes all applications and reduces the burden on respondents and the Federal Government.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose(s) described in Item 2 above.

TSA is the only agency that collects information from GA pilots, crewmembers, and passengers, including ASOs, to conduct a security threat assessment for purposes of authorizing flights into and out of DCA. Because this information is collected only when GA aircraft operators apply to operate into and out of DCA, the information collected is not collected or maintained anywhere else.

TSA is responsible for maintaining the OMB control number for this ICR.  FAA does not have a control number associated with this collection.  This is similar to 1652-0033, where TSA maintains the currency of OMB control number for the FAA/TSA Airspace Access Program (AAP aka online waiver system).

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.

The impact associated with this program is the time needed for a requestor to collect the required information and complete an application, which includes information on individual crewmembers and passengers. However, the collection of information is necessary to enhance aviation and national security, while allowing GA aircraft operations at DCA. As mentioned above, TSA has implemented a program to collect all applications electronically, in an effort to reduce the burden on respondents. A hard copy application and manual application process is available for those respondents with limited access to the Internet.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If the required information is not collected, TSA will not be able to conduct security threat assessments on crewmembers and passengers onboard GA aircraft operating into or out of DCA. TSA believes that conducting security threat assessments on these individuals is essential to protect against threats to aviation security and valuable assets in the National Capital Region. Without the information needed to complete security threat assessments, TSA would be unable to process requests for airspace waivers, which would negatively impact the GA community.

Further, if TSA does not collect the required information from ASO applicants, TSA will not be able to identify qualified individuals to serve as ASOs onboard GA aircraft operating into or out of DCA. Consequently, aircraft operators would not be able to implement one of the critical security measures required under the regulation.

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 information collection is conducted in a manner consistent with the general information guidelines.

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 reporting format (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 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.

TSA has worked with a number of Federal agencies, including the FAA, during the development of the IFR and information collection, and sought public comment on the IFR (70 FR 41586; July 19, 2005).

TSA published a 60-day and a 30-day notice, as required by 5 CFR 1320.8(d), in the Federal Register soliciting comment for purposes of renewing OMB’s approval of this information collection. See 77 FR 12321, February 29, 2012 and [77 FR 25188, April 27, 2012]. TSA has not received any comments in response to notices.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

TSA does not provide any payment or gift to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

TSA does not provide any assurances of confidentiality to respondents.

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 ask any questions of a sensitive nature.

12. Provide estimates of hour burden of the collection of information.

Currently, there are 107 FBOs participating in the FBO Security Program and 73 gateway airports.  In the year preceding September 11, 2001, there were on average 660 GA flights per week into DCA.  The IFR limits the number of airports from which these operators can depart for DCA. Therefore, the total number of flights into DCA will continue to be lower than the pre-2001 numbers.  Accordingly, TSA assumes that the number of aircraft operators that will continue to apply for access to DCA will be significantly less than the number of aircraft operators that operated into and out of DCA prior to September 11, 2001.

      Based on participation in the past three years, TSA estimates that approximately 663 aircraft operators will apply for access to DCA annually and thus be required to respond to the information collection requirements.  For security coordinators, ASOs, and flight crewmembers, the respondents are required to provide the required information only once for a CHRC.  For passengers and crewmembers onboard aircraft operating into or out of DCA, the respondents are required to provide the required information for a name-based threat assessment for each flight into or out of DCA.  Based on participation historically and in the past three years, TSA estimates the total number of annual responses to be 4887 per year (663 ASO responses + 1326 flight crewmember responses +246 security coordinators + 2652 passengers).

Burden Table

Respondents	Annual Hour Burden
4,887	.75
Total	3665.25

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

Based on participation in the last three years, TSA estimates the total costs to respondents associated with this information collection to be $46,395.24 annually ($50,490 for security threat assessment fee + $56,391.72 for processing the information + $32,304 for fingerprints and the criminal history records check divided by 3 to reach an annual estimate). Note that the costs for fingerprints and the criminal history records check are a one-time estimate.

Name Check Population and Cost
Round-Trip Flights based on participation in the last three years	Number of Checks = (4 Passengers + 2 Crew Per Flight)	Name Based Check Unit Cost	Total Annual Name Based Check Cost
663	3,978	$15	$59,670

Security Coordinators and Paperwork:

 

Item	Loaded Hourly Rate	Hours	Quantity	Total
Passenger and Crew Manifest and Security Program work based on participation in the last three years	$50.26	Average 1 hour/Roundtrip Flight	663	$33,322.38

Fingerprints and criminal history records check (one-time cost) = $48

6,315 Crewmembers and 107 FBOs X $48 = $308,256

Out of the total costs outlined above, the aggregate cost burden to ASOs for their initial application is currently estimated at $19,215 ($48 to conduct a CHRC + $15 to conduct a security threat assessment = $63; $63 X 305 ASOs = $19,215) based on participation in the last three years. There continue to be additional costs for processing background checks that could add up to an additional $250 per ASO for a possible total cost burden of $469,500 ($63 + $250 = $313; $313 X 305 = $95,465). These costs do not include the recurring costs for the security threat assessment that will be required when an ASO flies into or out of DCA. These recurring costs are included in the passenger costs.

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.

Any initial outlays TSA incurs in the first year will be recovered over five years through the security threat assessment fee ($15 per person, see question 13 above). Costs over five years are outlined as follows: (also see “Fee Summary” section of the interim final rule (70 FR 41586; July 19, 2005).)

5-Year Lifecycle Costs
	Program Operating Year
	Year 6	Year 7		Year 8		Year 9	Year 10		Total
	2010	2011		2012		2013	2014
Fixed Costs
Automated Flight Authorization System	$106,961	$106,961		$106,961		$106,961	$106,961		$534,805
TSA Interface	$0	$0		$0		$0	$0		$0
Payment Interface	$0	$0		$0		$0	$0		$0
System Hosting Set-Up Costs	$0	$0		$0		$0	$0		$0
Scheduling Staff	$400,000	$400,000		$400,000		$400,000	$400,000		$2,000,000
Total Fixed Costs	$506,961	$506,961		$506,961		$506,961	$506,961		$2,534,805

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

There has been a significant increase in program participation. Specifically, the number of aircraft operators in the program has risen over 60%, the number of FBOs has increased by 138%, and the number of actual flight operations has grown 66%. Several of the newer corporate aircraft operators have a very large number of flight crewmembers (e.g., one operator has over 2,000 flight crew members). This increased agency estimate resulted in an annual increase of 4,339 responses and 2,295 burden hours. The decrease in government cost is a direct result of no longer having intial start up costs and current maintenance of only the online system. The new numbers represent data collected based on the actual number of operators and number of operations conducted under the DASSP program.

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 the results of this information collection.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

TSA will display the expiration date as required.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

TSA is not seeking any exception to the certification statement in Item 19.

1 An FBO is an airport-based commercial enterprise that provides support services to aircraft operators, such as maintenance, overnight parking, fueling, and deicing.