DS-82 Supporting Statement revised (12-3-13)

DS-82 Supporting Statement revised (12-3-13).docx

U.S. Passport Renewal Application for Eligible Individuals

OMB: 1405-0020

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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

U.S. Passport Renewal Application for Eligible Individuals

OMB #1405-0020 (Form DS-82)


A. JUSTIFICATION


  1. The Application for a U.S. Passport by Mail (Form DS-82) is used by eligible citizens and non-citizen nationals (hereinafter, collectively referred to as “nationals”) of the United States who need to renew their current or recently expired U.S. passport (a travel document attesting to one’s identity and U.S. nationality).


The DS-82 solicits data necessary for Passport Services to issue a United States passport (book and/or card format) in the exercise of authorities granted to the Secretary of State in 22 United States Code (U.S.C.) Section 211a et seq. and Executive Order (E.O.) 11295 (August 5, 1966) for the issuance of passports to U.S. nationals.


The issuance of U.S. passports requires the determination of identity, nationality, and entitlement, with reference to the provisions of Title III of the Immigration and Nationality Act (INA) (8 U.S.C. sections 1401-1504), the 14th Amendment to the Constitution of the United States, other applicable treaties and laws and implementing regulations at 22 C.F.R. Part 50 and 51. The specific regulations pertaining to the Application for a U.S. Passport by Mail are at 22 C.F.R. 51.20 and 51.21.


  1. The information collected on the DS-82 is used primarily to facilitate the issuance of U.S. passports to U.S. nationals. The primary purpose for soliciting the information is to establish nationality, identity, and entitlement to the issuance of a U.S. passport, and to properly administer and enforce the laws pertaining to the issuance thereof.


The DS-82 is retained in the files of the Department of State, along with other documentation related to passport applications, adjudication, and issuance. Among other uses within the Department of State, these records are consulted when a U.S. passport has been lost, and the bearer has no evidence of nationality available or in support of any derivative claims to nationality made by an applicant’s children. The records may also be consulted by consular personnel in the event of an emergency abroad involving Americans: the application has a block for the name, address, and telephone number of a person to notify in the event of an emergency. Information from the DS-82 may also be shared with certain parties outside of the Department of State, as permitted by the Privacy Act of 1974, as amended, including as set forth in the Department of State’s Prefatory Statement of Routine Uses and the Department’s System of Records Notice (SORN) for Passport Records (STATE-26) and Overseas Citizens Records Services (STATE-05).


The DS-82 becomes part of the applicant’s passport file, which is covered by the Privacy Act. The information contained in this file cannot be released except as provided by the Privacy and Freedom of Information Acts.


Intentionally making a false statement on the DS-82 may constitute a violation of 18 U.S.C. sections 1001, 1542, and/or 1621.


  1. In an effort to provide customers with an electronic option to this paper-based form, the DS-82 is currently posted on the Department’s website at http://www.travel.state.gov where applicants can fill out forms on-line and print them for submission. With the completed application, a 2-D Barcode will print on each application. This barcode will be scanned by Passport Services and automatically record the applicant’s information in our system. This process will save time for both Passport Services and the applicant and may also reduce errors.


In addition to allowing applicants to fill out the form on-line and print it for submission, Passport Services conducted the Online Application for a Passport Card (OAPC) pilot January 24, 2012 through April 30, 2012.  Participation was limited to holders of 10 year validity passport books who were also first time passport card applicants.   A total of 2,563 applications were received, of which 2,226 were approved for the issuance of a passport card.  The average processing time for these electronic applications was eight days.  The pilot was deemed a success as Passport Services demonstrated the ability to accept and process electronic applications in addition to accepting electronic payments.


Although the OAPC was successful, it also exposed a number of issues that must be addressed before continuing or expanding the acceptance and processing of electronic DS-82 applications.  Three of the issues were identified as vital.  One is the mechanism by which data (the electronic application) is pulled from the public facing webpage (Travel.state.gov, in this instance) into the Travel Document Issuance System TDIS.  For reasons yet to be determined, approximately 275 applications “failed” and had to be reconstituted (a very time consuming manual process) on the back end to complete processing.  A second issue involves the Photo Wizard used by applicants to upload and submit images.  The standard photo reject rate for paper applications is approximately 2%, but the photo reject rate for the pilot was 15.3%.  Requesting and waiting to receive acceptable images added days to the normal processing time.  The third issue pertains to the security questions used for initial identification verification of the applicant (part of the e-Signature).  A number of valid applicants responded incorrectly, but were able to be verified against Passport Services’ electronic records and a commercial database for identity verification provided by the LexisNexis Company.


Passport Services is currently working with the stakeholders (the Office of Consular Systems and Technology, Pay.gov, the Office of Fraud Prevention Programs, the Bureau of Diplomatic Security (DS), and others) to devise solutions to the identified issues in preparation for continuing and expanding the use of electronic DS-82 applications.  Once these issues have been resolved, Passport Services intends to conduct another pilot to test the solutions by 2015.  Pending the post pilot analysis, a permanent online application offering will be pursued with OMB clearance.  


The Department’s goal is to have a completely functional electronic application available to the public by 2017. 


  1. Aside from necessary basic self-identification data, the information requested does not duplicate information otherwise available. The DS-82 is the Department of State form used by those U.S. nationals who meet the qualifications to apply for a U.S. passport book and/or passport card by using a mail-in application.


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


  1. The information collected on the DS-82 is crucial for documenting a U.S. citizen’s request for a replacement passport and for establishing the applicant’s entitlement to a replacement U.S. passport.


  1. No such special circumstances exist.


  1. The 60-day Federal Register Notice soliciting public comment was published on April 26, 2013 (78 FR 24781) and closed June 27, 2013.


The Department of State received one public comment on the 60-day notice in the Federal Register for the proposed DS-82, “U.S. Passport Renewal Application for Eligible Individuals” form regarding the Electronic Passport Statement. The commenter stated that he was confused about which type of passport to select when completing the form because the instructions refer to “a type of electronic passport book containing an embedded electronic chip and called an “Electronic Passport.”  The Department replied with the following:

All passport books issued by the U.S. Department of State at this point in time are Electronic Passports Books that contain an embedded electronic chip.  The Electronic Passport Statements in the Instructions sections in all public-use passport forms do not currently state this fact clearly.

As the result of this suggestion, the Department has revised the first sentence of the Electronic Passport Statement in the DS-82 as well as all other Public-Use Passport Forms from:

The U.S. Department of State now issues a type of passport book containing an embedded electronic chip called an “Electronic Passport”

to read:

The U.S. Department of State now issues an “Electronic Passport” book, which contains an embedded electronic chip.”

Therefore, this change has been made to the Electronic Passport Statement on page 4 of the DS-82 form instructions.


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


  1. This form includes a Privacy Act Statement explaining the routine uses of the information collected under the Act. There are no promises of confidentiality to the respondents other than those contained in federal statutes and regulations.


  1. The DS-82 does not ask questions of a sensitive nature. The DS-82 collection of information asks the respondent to provide a Social Security number in order to help confirm the applicant’s identity. The applicant’s identity must be established before a passport can be issued. Moreover, passport applicants are requested to submit their Social Security numbers with the passport application (26 U.S.C. 6039E).


  1. Passport Services estimates that the average time required for this information collection is 40 minutes per response. Therefore, the total estimated annual burden for the collection is:


4,215,761 (number of respondents) x 40 (minutes) / 60 = 2,810,507 hours per year.


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) x 1.4 (weighted wage multiplier) = $31.64 (weighted wage)


2,810,507 (annual hours) x $31.64 (weighted wage) = $88,924,441.48.


Estimates on the time and cost burden were completed through consultation with a group of Consular Affairs employees to validate the time required. 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.


  1. To properly complete and submit a DS-82 passport application, an applicant must provide:


  • A photograph that meets criteria specified in the instruction pages, with a national average cost of $10.

  • A certified copy of a marriage certificate or court order for applicants whose current name differs from the one used on their most recent passport. It is estimated that 10% of all DS-82 submissions will be accompanied by these certified documents, based on previous actual receipts (10% x 4,215,761 applicants = 421,576). Based on internet search of various states, the average cost of obtained certified documents is $10.00.


The estimated cost of a photograph is based on a sampling through consultation with a small group of actual respondents.) DS-82 applications are primarily 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:


Passport Photo 4,215,761

X

$10.00

=

$42,157,610.

Postage 4,215,761

X

$ 1.25

=

$ 5,269,701.

Certified Copy 421,576 (10%)

(marriage certificate or court order)

X

$10.00

=

$ 4,215,761.






Total Cost to Respondents




$51,643,072.


The current DS-82 application fee is $110.00. This is a non-refundable processing fee retained by the U.S. Department of State for cost recovery, and is not considered a cost to the respondent.


  1. The Department pays a contractor for materials and/or supplies purchase functions to produce the DS-82. The estimate provided to the Department by the contractor includes cost for contractor labor, supplies, equipment, printing, materials, delivery, overhead, support staff, etc. Using the estimated projection of 4,215,761 respondents per year for FYs 2013– 2016 at a cost of $35.00 per thousand, the contractor cost to the Federal Government is $147,560.


The Department charges a $110.00 non-refundable processing fee to recoup the cost of processing the application. This includes all associated costs to various Passport personnel at all Passport Agencies and Centers, and Acceptance Facilities nationwide. The total costs recovered by the Department to process the form paid by the applicant is $463,733,710. per year (4,215,761 responses x $110.00 fee).


Therefore, the total cost to the Federal Government per year is $147,560. + $463,733,710. = $463,881,270.


  1. The projected adjustments indicated reflect a slight increase in the number of projected

respondents from 4,200,000 (previous 2010 - 2013) to 4,215,761 (FYs 2013 – 2016). The previous number of respondents was estimated based on a 2009 projection for those three years. However, using actual receipts for 2010 – 2012, the average total amounted to 3,695,439. While demand decreased slightly in 2011, it began to rise again in 2012. The annual number of respondents projected to use the DS-82 for the next three years was adjusted to reflect the actual demand while taking into account a steady increase for FYs 2013 through 2016.

Demand forecast projections, by their nature, will have some uncertainty in their accuracy, which can explain differences between actual and forecast.


The change in respondent costs is due to the elimination of the fees that were incorrectly attributed as a Cost to Respondent in the last submission. The only costs attributed to the respondent in this submission are the costs of providing passport photographs, certified copies of marriage certificate or court order, and postage.


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


  • Page 1, Instructions: Under the heading, “Can I Use This Form?”, the following new statement and “yes and no” checkboxes were added:

“My U.S. passport has not been limited from the normal ten year validity period due to passport damage/mutilation, multiple passport thefts/losses, or non-compliance with 22 C.F.R. 51.41. (Please refer to the back pages of your U.S. passport book for endorsement information.)”



  • Page 1, Instructions: In the third section that begins “U.S. PASSPORTS, EITHER IN BOOK OR CARD FORMAT, ARE ISSUED…”, the following statement was added at the end of this section:

PLEASE NOTE: YOUR NEW PASSPORT WILL HAVE A DIFFERENT PASSPORT NUMBER THAN YOUR PREVIOUS PASSPORT.”


  • Page 2, Instructions: In sentence 2, “A Marriage Certificate…” the word “certified” has been added before “Marriage”. Also, parentheses and the words “(Photocopies are not accepted)” have been added at the end of the sentence.



  • Page 2, Instructions: Under “Where Do I Mail This Application?”, the following change has occurred:

“Note Regarding Mailing Addresses:” in the third sentence, the telephone number and words “at 1-877-487-2778 or visit travel.state.gov” have been added at the end of the sentence.



  • Page 3, Instructions: At the bottom of the page, a new section was added with the heading:

“Special Notice to U.S. Passport Card Applicants Only”.

The section text follows:

“The maximum number of letters provided for your given name (first and middle) on the U.S. passport card is 24 characters. The 24 characters may be shortened due to printing restrictions. If both your given names are more than 24 characters, you must shorten one of your given names you list on item 1 of this form”.


  • Page 4, Instructions: Under the heading “Electronic Passport Statement”, the first sentence, “The U.S. Department of State now issues a type of passport book containing an embedded electronic chip called an “Electronic Passport.” has been revised to read “The U.S. Department of State now issues an “Electronic Passport” book, which contains an embedded electronic chip.”


  • Page 1, Form: In the photograph box, the words “Submit a recent color photograph” have been replaced with “Attach a color photograph taken within the last six months”.



  • Page 1, Form: Under Line Item 11, “Please submit a certified copy of your marriage…”, the language has been revised to now read “Please submit a certified copy. (Photocopies are not accepted!)”.


  • Page 1, Form: In the signature block, the word “Legal” was added between “Applicant’s” and “Signature”.


  • Page 1, Form: In the section at the bottom of the page “For Issuing Office Only”, the letters “BK” were added between “PPT C/R” and “PPT S/R” to now read “PPT BK C/R” and “PPT BK S/R”.


  • Page 1, Form: In the section at the bottom of the page “For Issuing Office Only”, two additional “checkboxes” and the words “PPT CD C/R” and “PPT CD S/R” were added after “PPT BK S/R”.


  • Page 2, Form: For Line Item 20, the following changes have occurred:

  • The words “Date of Trip” have been replaced with “Departure Date”.

  • The words “Duration of Trip” have been replaced with “Return Date”.


The Department estimates that these changes will not result in an increase in the current burden time of 40 minutes.


  1. Quantitative summaries of Department of State passport activities are published periodically on the Department of State website at www.travel.state.gov. Such summaries do not involve the use of complex analytical techniques.


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


  1. The Department is not requesting any exceptions to the certification statement.


B. Collection of Information Employing Statistical Methods


This collection does not employ statistical methods.

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleSUPPORTING STATEMENT
AuthorDicksonMA
File Modified0000-00-00
File Created2021-01-11

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