DS-64 Supporting Statement (final rev 8-6-2013)

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION

Statement Regarding a Lost or Stolen U.S. Passport Book and/or Card
OMB Number 1405-0014
DS-64

A. JUSTIFICATION

1. A passport applicant must submit a form DS-64, Statement Regarding a Lost or Stolen U.S. Passport Book and/or Card, with an application for a new U.S. passport when a previously issued valid or potentially valid U.S. passport cannot be presented. In order to assist in protecting against identity theft, a passport bearer must also submit a form DS-64 after a loss or theft has taken place, even if the bearer does not apply for a new U.S. passport. The statement must detail the circumstances of the loss or theft, as required in regulation 22 C.F.R. § 51.8(b), and any efforts made to recover it.

Entering a report of a loss or theft of a U.S. passport in the passport data system, as mandated by 8 U.S.C. § 1737, requires accurate verification of the reported passport. Collection of the social security number on form DS-64 is included to assist in correctly identifying the passport that needs invalidation.

The legal authorities under which the information is requested include, but are not limited to, the following:

22 U.S.C. § 211a et seq.;

Executive Order 11295;

22 C.F.R. Part 51, including 22 C.F.R. 51.8 & 51.2;

8 U.S.C. § 1737;

18 U.S.C. § 1028; and

18 U.S.C. § 1544.

2. The information on the DS-64 is used by the Department of State prior to passport issuance, and solicits information relating to the loss or theft of a valid U.S. passport book and/or passport card. This helps the Department to ensure that no person bears more than one fully valid or potentially valid U.S. passport book and/or passport card at any one time, except as authorized by the Department. The information is also used to combat passport fraud and misuse.

3. In an effort to provide customers with an electronic option to this paper-based form, the DS-64 is posted on the Department’s website at http://www.travel.state.gov, where applicants can complete the form online then print it for signature and submission.

In addition to allowing applicants to complete the form on-line and print, Passport Services is developing a pilot program to provide the public with the ability to submit the form on-line and report lost or stolen passport books and passport cards using electronic signature capability.  The online process will not replace the options to call National Passport Information Center (NPIC) or submission of a hard copy DS-64 form.  However, we expect that calls to NPIC will be greatly reduced and the ability to report from any location (domestic or international) via the web will provide substantial benefits.  This effort is consistent with the Government Paperwork Elimination Act and Executive Order 13571 – Streamlining Service Delivery and Improving Customer Service.  

Also, as required by OMB guidance, the Office of Consular Affairs has conducted a risk assessment and concludes that the proposed online process provides sufficient protections against fraud. The e-signature will be considered legally binding in the same manner as the “wet signature”.  Use of the electronic DS-64 online tool will be limited to adults with a valid U.S. passport book or card; a hard copy DS-64 form must be submitted for all minors or cases where a discrepancy is identified.  Under the existing paper process, regardless of whether the signed DS-64 form is submitted, the passport is cancelled within 24 hours to limit potential misuse.  The online process will follow the same 24-hour cancellation policy.

As the proposed electronic DS-64 is still under development, the next steps would be to conduct an analysis and in-house testing along the lines of the Online Application for the Passport Card (OAPC) conducted from January through April 2012 for the electronic DS-82 form. Once the analysis and in-house testing phases of the electronic DS-64 are complete, we will publish a 60-day and a 30-day federal register notice to solicit public comment, and seek OMB permission to conduct the proposed pilot program. . It is estimated that a Federal Register Notice, soliciting public comments about this pilot, will be published sometime between January 2014 and July 2014.

4. The DS-64 is the sole Department of State form used for the purpose outlined in item 2. The information collected does not duplicate information gathered elsewhere.

5. This collection of information does not significantly impact small businesses or other small entities.

6. If the information were not collected, the Department of State would have difficulty determining whether to issue a new U.S. passport or passport card to persons whose U.S. passports have been lost or stolen. Fraud prevention efforts would also be lessened if valuable information useful in identifying individuals were not collected. Elimination of the form would have serious or even grave consequences for national security and law enforcement.

7. No such special circumstances exist.

8. The 60-day Federal Register Notice soliciting public comment was published on November 14, 2012 (77 FR 67860) and closed January 13, 2013. The Department of State received one comment from the 60-day notice in the Federal Register. The commenter noted that “one can presume that an embassy or consulate can provide a DS-64 … but if true that fact doesn’t appear in the 60-day Federal Register notice, nor does it seem readily apparent from the Department of State website.”

The Department responded by stating that this information does appear on the Department of State website at the following link: http://www.travel.state.gov/passport/lost/lost_848.html .

At this site, it states “For passports lost or stolen overseas, please contact the nearest U.S. Embassy or Consulate.”

With regard to the comment that this information does not appear in the 60-day Federal Register Notice (FRN) for the DS-64, the Department explicitly states in the FRN that the form is available for review by the general public to assist in making comments.

Estimates on the time and cost burden associated with this form were acquired through consultations with a small group of actual respondents. Respondents gave feedback on the time required to search existing data sources, gather the necessary information, provide the information required, review the final collection, and submit the collection to Passport Services for processing.

9. This information collection does not provide any payment or gift to respondents.

10. The form includes a Privacy Act Statement explaining the routine uses of the collected information. (5 U.S.C. § 552a)

11. The DS-64 collection of information asks the respondent to provide a Social Security number to identify and confirm that the person completing the form is also the same person who held the passport that is being reported as lost or stolen. This is an anti-fraud measure. Moreover, the Department is required to collect accurate information on passports that have been reported as lost or stolen (8 U.S.C. § 1737). These passports are invalid and must be recorded as such (22 C.F. R. § 51.4(f)(2)). Because those who no longer have their passport in their possession may not know the passport number, a Social Security number allows the Department to accurately determine which passport was reported as lost or stolen.

12. Passport Services estimates a weighted average burden time of 10 minutes per response which includes both the time spent completing and reviewing the form. The number of respondents is estimated at 991,351 per year for the next three years.

The total annual burden hours for this collection is estimated to be 174,312 based on the following calculations:

All applicants will take an estimated 5 minutes to complete a standard submission. Based on this estimate, 991,351 applicants x 5 minutes per response / 60 minutes = 82,612 hours per year.

In addition, we estimate that 37% of the respondents (366,800) would need an additional 15 minutes each to obtain a photocopy of their photo identification. This results in an additional burden of 91,700 hours for this select group; 366,800 (37%) x 15 minutes (photocopy ID) / 60 minutes = 91,700 hours per year.

Therefore, the total average hour burden for this collection would be 82,612 + 91,7000 = 174,312 hours per year.

The weighted average burden time for all respondents to fill out the form is based on the following calculation:

174,312 total burden hours x 60 minutes / 991,351 total respondents = 10 minutes average per form.

To estimate the cost to respondents for this form, based on the hourly wage and weighted wage multiplier, the Department calculated the following:

$22.60 (mean hourly earnings based on estimated income per hour from the Bureau of Labor Statistics) multiplied by 1.4 (weighted wage multiplier) x 10 minutes (hour burden) x 991,351 (number of respondents) /60 minutes is approximately $ 5,227,724.

The estimated burden of five (5) minutes required per response for all respondents is based on a sampling of time required to complete this form. The sampling was completed in-house through consultation with a small group of Consular Affairs employees to validate the time.

13. The cost to the respondent includes the cost to make a photocopy of a government-issued photo identification if an applicant is submitting the DS-64 without also submitting a passport application. It is estimated that 37% of all DS-64 applicants will submit a photo copy of a government-issued photo identification at a cost of $0.44 per copy. The estimated cost of a black and white copy is based on a quote from FedEx Office.

In addition, it is estimated that approximately 19% of all DS-64 applicants will be submitted by mail. Per information received from the United States Postal Service, the cost burden for postage is approximately $1.25 per application. Therefore, the total cost to the respondents is as follows:

Photocopy	366,780 (37 % of 991,351)	X	$ 0.44	=	$ 161,392.
Postage	188,357 (19% of 991,351)	X	$ 1.25	=	$ 235,446.
Total Cost to Respondent					$ 396,838.

The estimated percentages are based off the reporting process for these applications. For instance, in the last year, the percentage of lost or stolen passport books and cards that were reported in-person at the passport agencies was 50 percent, while 31 percent was reported by phone. This number fluctuates by year and is based on the number traveling public and how well the economy is doing, since more people tend to take vacations when the economy is better. This results in more DS-11 applicants and an increase in DS-64 submissions. On the average, the number of submitted DS-64 forms correlates to 1% of all DS-11 applications.

13. Passport Services estimates 991,351 applicants will use the DS-64 form in conjunction with other Passport Applications annually during each of the next three years.

Currently, the Department has a contract in place for printing all passport forms. The estimate provided to the Department by the contractor includes costs associated with printing, equipment, overhead, and support staff. The DS-64 will be produced by a contractor under an Indefinite Delivery/Indefinite Quality type contract with Cost-plus-fixed-fee line items for materials and/or supplies purchase functions. Using the estimated projection of 991,351 respondents per year for FY’s 2013–2016 at a cost of $17.31 per thousand, the cost to the Federal Government is $17,160,286.

To calculate the passport specialist cost, the Department used the following formula:

$45,718 (mean salary of all passport specialists) x 1102 (number of all passport specialists) = 50,381,236 X 26.8% (percentage of time passport specialists spend processing the DS-64) = $13,502,171.

Therefore, the total projected annual cost to the Federal Government is:
$17,160,286 (contractor cost) + $13,502,171 (passport specialist cost) = $ 30,662,457.

13. During Passport Services’ review of production standards in 2011, the Office of Adjudication conducted a “frequency analysis” to determine, among other things, how often certain forms were submitted as current technology does not keep track of this information.  Analysts went into the field and counted approximately 20,000 applications to obtain a statistically significant sample of the workload.  This 2011 study information was just updated according to new data from the 2012 study. Therefore, the Department has recalculated using the following 2013 – 2016 projections:

The Department estimates that 14,750,000 total applications will be submitted per year during this three year period. Also, it is estimated that the completed DS-64 form will comprise 6.59% of the total applications. Therefore, using these 2012 projections, the calculations are as follows:

14,750,000 (DS-11applications) x 6.59% (DS-64’s) = 991,351 Total Number of Respondents.

The Department estimates that the change to the instructions requesting a photocopy of an identification document (listed below) will result in an increase in the average burden time to 10 minutes.

Based on the weighted calculations in item 12 for all respondents, taking into account the additional photocopy requirement listed under the changes, the burden time has increased to 174,312 hours per year.

The adjustment indicated reflects an increase in the number of respondents from the previous estimate of 122,500 to 991,351 respondents, partly because the demand for a U.S. passport has continued to increase, and is expected to continue for 2013-2016. The increase in the number of respondents may also be attributed to a more accurate projection estimate of DS-64 usage for the based on the recent 2011 “frequency analysis” and updated 2012 studies using the field sampling method, as opposed to the post-issuance audit conducted in 2009 for the previous collection.

In addition to general format changes, the following content changes have been made to the form:

• Instructions – A second section was added to page one to provide the following sentence: “If you are submitting this form without also submitting a passport application, please provide a copy of a government-issued photo identification, such as a driver’s license or state-issued identification card.”

• Form, Section 2 - was revised it its entirety breaking out the two main questions into items 2a through 2e to more efficiently organize the information we are requesting from the applicant.

• Form, Section 3 - A numbered, dark blue ribbon with instructions was added to clearly delineate the form sections and thereby assist the applicant to more efficiently review the information on the form.

• Form, Section 3 - the Department included a second signature and date line to allow for the signature of a second Parent/Guardian, if present, in keeping with the requirements of the DS-11 form.

• Form, Section 3 – at the bottom of this section, the Department added the following text below the second signature and date line:

For a child under 16, this form must be signed by both parents or the child’s legal guardian(s). In case of sole custody, include a copy of the supporting document (court order) with this form.

13. This collection of information will not be published for statistical use.

13. The expiration date for OMB approval will be displayed.

13. No exceptions to the certification statement identified in “Certification for Paperwork Reduction Act Submissions,” are being requested.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.