1652-0027 STA HME SS Pt.A 1.25.2017(1)

INFORMATION COLLECTION SUPPORTING STATEMENT

Security Threat Assessment for Individuals Applying for a Hazardous Materials Endorsement (HME) for a Commercial Driver’s License (CDL)

OMB control number 1652-0027

Exp. 01/31/2017

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).

This collection supports the implementation of section 1012 of the USA PATRIOT Act (Pub. L. 107-56, 115 Stat. 272, 396, Oct. 26, 2001, the “Act”; codified at 49 USC § 5103a), which mandates that no State or the District of Columbia may issue a hazardous materials endorsement (HME) on a commercial driver’s license (CDL) unless TSA has first determined the driver is not a threat to transportation security. The currently published rule found at 49 CFR 1572 (“the rule”) and section 1012 of the Act are attached to this application.

The rule describes the procedures, standards, and eligibility criteria for security threat assessments of individuals seeking to obtain, renew, or transfer an HME on a CDL. In order to conduct the security threat assessment, States (or a TSA designated agent in States that elect to have TSA perform the collection of information) must collect information in addition to that already collected for the purpose of HME applications, which will occur once approximately every five years. The driver is required to submit an application that includes personal biographic information (for instance, height, weight, eye and hair color, date of birth); information concerning legal status, mental health defects history, and criminal history; as well as biometrics such as fingerprints, iris scans, and/or photographs. In addition, 49 CFR part 1572 requires States to maintain a copy of the driver application for a period of one year.

TSA also invites all HME applicants to complete an optional survey to gather information on the applicants’ overall customer satisfaction with the service received at the enrollment center. The optional survey will be administered at the end of the in-person enrollment service (see Supporting Statement Part B for more information). Please note that the optional survey is only provided for applicants that enroll with a state serviced by TSA’s designated enrollment contractor. These states are referred to as TSA agent states.

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.

Commercial drivers seeking an HME are required to provide biometrics and an application for the purpose of conducting a security threat assessment. State Motor Vehicle Agencies, or a TSA designated contractor in TSA agent states, collect this information as part of the procedure to obtain, renew or transfer an HME on a CDL, which will occur once approximately every five years. Individuals applying through a TSA agent state have the option to provide biographic information online before enrollment (also known as pre-enrollment), in-person, online after enrollment (post-enrollment), or via mail or fax. Applicants who choose to pre-enroll online must still go to an enrollment center to complete the enrollment process by submitting biometric data (e.g., fingerprints) and identity and citizenship or immigration documents/data to TSA’s contracted vendor if they did not provide this information online. Alternatively, applicants can choose to enroll entirely in-person at an enrollment center without pre-enrolling. Lastly, if applicants are not able to provide identity and citizenship or immigration documents/data during in-person enrollment, they may provide this information post-enrollment either online or via mail/fax.

Since calendar year 2015, TSA’s enrollment provider has offered an additional service to applicants that allows for the real-time electronic certification of birth certificates from most States for applicants who did not bring US citizenship-proving documents to in-person enrollment. To use the birth certificate certification service, the applicant must pay a supplemental fee to TSA’s enrollment provider and provide an additional data element (mother’s maiden name) that is not required as part of the actual HME threat assessment application. The supplemental fee for birth certificate certification is provided directly to TSA’s contractor and is not remitted to TSA.

The optional customer satisfaction survey offered to those who enroll through TSA agent states is designed to gauge the experience and customer satisfaction of applicants at enrollment centers. TSA will use the information to determine whether any trends exist regarding customer service at a particular enrollment center or particular application enrollment activity and to take steps to improve service.

TSA is revising the collection of information so that it may also use additional biometric information (e.g., iris and/or photo) to determine a HME holder’s eligibility to facilitate the security threat assessment and participate in other TSA vetting programs, such as TSA’s expedited screening program for air travel, the TSA Pre^® Application Program, or the Transportation Worker Identification Credential (TWIC).

In addition, TSA is revising the collection of information to allow for recurrent biometric and criminal history vetting. Applicants’ fingerprints and associated information will be provided to the Federal Bureau of Investigation (FBI) for the purpose of comparing their fingerprints to other fingerprints in the FBI’s Next Generation Identification (NGI) system or its successor systems including civil, criminal, and latent fingerprint repositories to identify additional activity that may occur after the initial application. The FBI may retain applicants’ fingerprints and associated information in NGI after the completion of their application and, while retained, their fingerprints may continue to be compared against other fingerprints submitted to or retained by NGI. TSA will also transmit applicants’ fingerprints for enrollment into the Department of Homeland Security Automated Biometrics Identification System (IDENT) as part of the security threat assessment.

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.]

The process is fully electronic for submission to TSA. If applicants choose to pre-enroll, an enrollment record is created for them that will be retrieved when they complete the in-person enrollment process. The in-person enrollment process validates the applicant identity with documents and information presented, and collects the biometric information from the applicant.

Based on current data, TSA estimates that about 9 percent of applicants will submit their biographic portions online before going in-person to an enrollment center to complete the application process, while about 91 percent will submit their biographic portions in-person without providing pre-enrollment information before arriving at the enrollment center.

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.

There is no similar information held by TSA that could be used to initiate the required background checks and accurately establish that a person’s claimed identity is a true identity. For cases in which an applicant has already received a comparable threat assessment from DHS, including those for a TWIC holder and Free and Secure Trade (FAST) card holder, the biographic and biometric information is collected in order for the HME system to ensure that applicants do not apply for multiple HMEs under the same or a different claimed identity. In such cases, the previous DHS threat assessment is leveraged and the fee to the applicant is reduced since a full assessment does not have to be performed. TSA intends to reduce the burden to applicants by combining collection and/or using previously collected information (when available), should the applicant desire to enroll in additional programs or multiple programs at the same time.

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.

While respondents may be associated with or employed by small businesses, TSA has determined that the collection will not have a significant impact on a substantial number of small businesses because the collection, as well as TSA’s regulations, are directed at respondents individually.

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 this information is not collected, TSA cannot fulfill its statutory mandate. Without collection of the information, it would be impossible to conduct STAs on individuals who require hazardous material endorsements on their CDL.

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).

There are no special circumstances requiring the collection of information to be inconsistent with 5 CFR 1320.5(d)(2).

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 published a 60-day notice to seek approval of a revised information collection for the Hazardous Material Endorsement Program in the Federal Register on August 16, 2016 (81 FR 54585), and a 30-day notice on January 9, 2017 (82 FR 2389).

TSA received a comment on the 60-day notice from the Land Line - The Business Magazine for the Professional Trucker, inquiring as to whether the offer of TSA Pre^® Application Program eligibility to HME applicants was a move in a “one-card-fits-all” direction for ports, facilities, airports, etc. TSA responded to the commenter that this change, i.e., offering TSA Pre^® Application Program eligibility to HME applicants, is not a move to a “one-card-fits-all” but is rather in furtherance of increasing the number of individuals eligible to receive expedited screening, which is a stated goal of TSA. The decision is based on most approved HME applicants being considered low-risk via their approved HME STA.

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.

Although there is no assurance of confidentiality to any respondent, TSA will handle all records concerning HME Threat Assessment Application Program applicants in accordance with the Privacy Act of 1974, and maintain the security of the information technology systems that transmit, process, and/or store the personal information in accordance with Federal Information Security Management Act (FISMA) requirements. In addition, this information collection is covered by a Privacy Impact Assessments (PIA). See, DHS/TSA/PIA-002 Hazardous Materials Endorsement (September 16, 2005). TSA also published a system of records notice in the Federal Register on May 19, 2010, DHS/TSA-002 (70 FR 33383).

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.

Collection of this information may raise questions of a sensitive nature for the individual undergoing the security threat assessment, but only to the extent necessary for TSA to determine the risk of the individual to transportation security. The security threat assessment could reveal, for example, mental health defects or convictions of certain crimes that would bar the individual from transporting explosives or other hazardous materials.

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

The USA PATRIOT Act (Pub. L. 107-56, 115 Stat. 272, 396, Oct. 26, 2001, the “Act”; codified at 49 USC § 5103a) mandates that no State or the District of Columbia may issue a hazardous materials endorsement (HME) on a commercial driver’s license (CDL) unless TSA has first determined the driver is not a threat to transportation security. Hence:

1. To conduct security threat assessment, States (or TSA agent States) must collect information in addition to that already collected for the purpose of HME applications. The driver is required to submit an application that includes personal biographic information (such as height, weight, eye and hair color and date of birth), information concerning legal status, mental health defects history, and criminal history, as well as fingerprints.

2. Applicants that enroll through TSA agent States are also invited to complete an optional survey to gather information on the applicants’ overall customer satisfaction with the service received at the enrollment center. The optional survey is administered at the end of the in-person enrollment service.

3. In addition, 49 CFR part 1572 requires States to maintain a copy of the driver application for a period of one year.

TSA provides estimates of the average number respondents, responses, and hour and cost burdens due to these information collection activities for the period 2017 through 2019. Accordingly, based on the data provided by TSA Office of Intelligence & Analysis (OIA), Program Management Division, TSA estimates that the average number of respondents to this information collection process is 804,885 over three years (268,295 annually), out of which 18,110 applicants over three years (or 6037 responses per year) would be engaged in an appeal/waiver process. In addition, of those completing the HTAP application, 192,211 over three years (or 64,070 responses per year). These result in an average of 1,015,206 responses over three years (or 338,402 responses per year). TSA also estimates that the estimated hour burden is 1,571,459 hours for the period 2017 through 2019 (or 523,820 hours per year). The total annual hour burden cost of this information collection is estimated to be $48.18 million for the period 2017 through 2019 (or $16.06 per year).

Calculations: ¹

A. Applicants for New or Renewal of HME

(1) Number of HME Threat Assessment Program respondents/applicants

The average number of individual respondents is determined based on the number of drivers that are required to obtain a security threat assessment before applying for new endorsement and HME renewal, which occurs about every five years. Table 1 shows the actual number of individuals applying for a new endorsement and HME renewal each year from 2014 to 2016. Since the number of individuals applying for HME shows a small variation over time, TSA assumes approximately 1 percent annual growth rate to determine the number of individual respondents for the period 2017 through 2019.²

Table 1: Number of New Applicants and HME Renewals

Year	TSA agent State Enrollments (a)	Non-TSA agent State Enrollments (b)	Total HME Enrollments (c = a+b)
2014	182,111	85,847	267,958
2015	182,231	84,865	267,096
20163	179,445	83,555	263,000
Projection (using 1% growth rate)
2017	181,239	84,391	265,630
2018	183,052	85,234	268,286
2019	184,882	86,087	270,969
Total (2017-2019)	549,174	255,712	804,885
Average (2017-2019)	183,058	85,237	268,295

Average number of individual respondents (2017-2019)

= 265,630 + 268,286 + 270,969

= 804,885 over three years

= 268,295 per year

(2) Individual applicants’ hour burden during enrollment

Applicants enroll either through (i) TSA agent States or (ii) non-TSA agent States. Those who enroll through TSA agent States can submit their applications either during an online pre-applicant followed by in-person application, or in-person application.

1. Applicants who enroll through a TSA agent State may provide biographic, biometric, and payment information to TSA through any of the methods listed below:

• Online pre-application (or pre-enrollment) before appearing at an enrollment center to complete the process;

• Online pre-application with TSA telephone customer service support before appearing at an enrollment center;

• In-person at an enrollment center without online pre-enrollment to provide biographic data;

• In-person with or without online pre-enrollment at an enrollment center to provide biometric data; or

• Post-enrollment mail, e-mail, or fax of valid identity and citizenship or immigration documents

2. Applicants who enroll through non-TSA agent State may submit their applications only in-person.

As stated above, biographic data may be provided through pre-enrollment or in-person at the enrollment center. However, all applicants must visit an enrollment center in person to submit biometric information. Valid identity and citizenship or immigration data or documents may be provided during pre-enrollment, in-person enrollment, or post-enrollment. At the end of the in-person enrollment application process, applicants are also given the option to respond to a customer satisfaction survey. Biographic, payment, biometric and survey information are submitted electronically to TSA.

The proportion of applicants through each of the above options and the associated time burdens are summarized in Table 2. These estimates are made based on historical data from the HME Threat Assessment Program. Table 2 also includes the time that an applicant may wait on average at an enrollment center before beginning the in-person portion of the application process. It should be noted that the estimates for wait time at the enrollment facility may vary depending on the location, as TSA operates over 300 enrollment locations to complete in-person enrollment across the U.S. The current national wait time average is 10 minutes.

For travel time, TSA reviewed a sample of data for HME applicants from the following locations to represent a range of enrollment centers spanning rural, suburban and urban locations:

• Boise, ID

• Denver, CO

• Hendersonville, NC

• Pocasset, MA

• Kenner, LA

• San Jose, CA

TSA calculates the distance and travel time between applicants’ residential address zip codes to their respective enrollment center zip codes. Based on this information, TSA estimates 86 minutes for a roundtrip commute time to enrollment centers.

Table 2: Summary of Percentage of Applicants and Estimated Time Burden for Providing Enrollment Data

(i) Applicants through TSA agent States

Type of Enrollment Data Submission	Estimated % of Applicants	Estimated Time Burden per Applicant
Online pre-application/pre-enrollment followed by in-person visit to an enrollment center	9%	29 minutes total based on: 10 min online pre-application 9 min in person application completion at enrollment center 10 min wait time at enrollment center 86 minutes roundtrip travel time to enrollment center
In-person at an enrollment center with no pre-enrollment	91%	22 minutes total based on: 12 min in person application completion at enrollment center 10 min wait time at enrollment center 86 minutes roundtrip travel time to enrollment center
Provide Enrollment Feedback via Customer Satisfaction Survey (only in-person applicants)	35%	Minutes

(ii) Applicants through non-TSA agent States

Type of Enrollment Data Submission	Estimated % of Applicants	Estimated Time Burden per Applicant
In-person at an enrollment center with no pre-enrollment	100%	22 minutes total based on: 12 min in person application completion at enrollment center 10 min wait time at enrollment center 86 minutes roundtrip travel time to enrollment center

Using the information given in Tables 1 and 2, TSA estimates the hour burden costs for all applicants who enroll through TSA agent States and non-TSA agent States. Table 3 summarizes the enrollment options and hour burden.

Table 3: Summary of Enrollment Methods and Hour Burden

	Two Enrollment Methods
	Through TSA agent State		Through Non-TSA agent State
	On-line pre-application, then in person	In person application	On-line pre-application, then in person	In person application
Proportion of applicants	9%	91%	0	100%
Enrollment time burden (hours)	0.48	0.37	N/A	0.37
Roundtrip travel time (hours)	1.43	1.43	N/A	1.43
Participate in customer satisfaction survey	N/A	35%	N/A	N/A
Survey burden time (hours)	N/A	0.042	N/A	N/A

Note: N/A denotes not applicable

For enrollments through TSA agent States

(a) Pre-enrollment applicants:

TSA calculates the number of individuals who would choose to enroll on-line under TSA agent States by multiplying the number of TSA agent State enrollments in Table 1 by 9% (from Table 3). This calculation is shown in columns (a) and (b) of Table 4(a).

TSA estimates the total hour burden by multiplying the total number of pre-enrollment applicants by the hour burden per applicant, 1.92 hours (0.48 + 1.43). This calculation is shown in columns (d) of Table 4(a). TSA also estimates the hour burden cost by multiplying the total hour burden obtained by the fully loaded average hourly wage of $30.67 per applicant,⁴ as shown in column (e) of Table 4(a).

Total pre-enrollment applicants (9% of respondents) = 49,426 over three years (or 16,475 per year).

Hour burden per applicant = Enrollment time + Roundtrip travel time

= 0.48 hours (29 minutes) + 1.43 hours (86 minutes)

= 1.92 hours per applicant

Hour burden (pre-enrollment applicants) = 49,426 applicants x 1.92 hours

= 94,898 hours per three years

= 31,633 hours per year (16,475 x 1.92 hours)

Hour burden cost (pre-enrollment applicants) = 94,898 hours x $30.67

= $2,910,522 over three years

= $970,174 per year

(b) In-person applicants:

TSA calculates the number of individuals who would choose to enroll in-person under TSA agent States by multiplying the number of TSA agent State enrollments in Table 1 by 91% (from Table 3). This calculation is shown in column (g) of Table 4(b).

TSA estimates the total hour burden by multiplying the total number of in-person applicants by the hour burden per applicant, 1.80 hours (0.37 + 1.43). This calculation is shown in columns (i) of Table 4(b). TSA also estimates the hour burden cost by multiplying the total hour burden obtained by the fully loaded average hourly wage of $30.67 per applicant, as shown in column (j) of Table 4(b).

Total in person applicants (91% of respondents) = 499,748 over three years (or 166,583 per year).

Hour burden per applicant = Enrollment time + Roundtrip travel time

= 0.37 hours (22 minutes) + 1.43 hours (86 minutes)

= 1.80 hours per applicant

Hour burden (in-person applicants) = 499,748 applicants x 1.80 hours

= 899,546 hours per three years

= 299,849 hours per year (or 166,583 x 1.80 hours)

Hour burden cost (in-person applicants) = 899,546 hours x $30.67

= $27,589,076 over three years

= $9,196,369 per year

(c) All applicants through TSA agent States:

TSA calculates the total hour burden by adding the hour burdens for pre-enrollment and in-person applicants shown above. Similarly, the total hour cost is calculated by adding the hour burden costs for pre-enrollment and in-person applicants shown above. These calculations are summarized in Table 4(c).

Total hour burden (enrollment through TSA agent State)

= 94,898 hours + 899,546 hours

= 994,444 hours over three years

= 331,481 hours per year

Total hour burden cost (enrollment through TSA agent State)

= 994,444 hours x $30.67 per applicant

= $30,499,598 over three years

= $10,166,533 per year

Table 4: Summary of Information Collection Applicants' Hour Burden Cost for Enrollment Through TSA agent States

(a) Pre-Enrollment Applicants (9% of Respondents)
Year	Average annual Respondents	Average Annual Responses	Hour Burden per Response	Annual Hour Burden	Annual Hour Burden Cost
	a	b = a x 9%	c	d = b x c	e = d x $30.67
2017	181,239	16,312	1.92	31,319	$960,554
2018	183,052	16,475	1.92	31,632	$970,153
2019	184,882	16,639	1.92	31,947	$979,815
Total	549,174	49,426		94,898	$2,910,522
Average	183,058	16,475		31,633	$970,174

(b) In-Person Applicants with no Pre-Enrollment (91% of Respondents)
Year	Average annual Respondents	Average Annual Responses	Hour Burden per Response	Annual Hour Burden	Annual Hour Burden Cost
	f	g = f x 91%	h	i = g x h	j = i x $30.67
2017	181,239	164,928	1.80	296,870	$9,105,003
2018	183,052	166,577	1.80	299,839	$9,196,062
2019	184,882	168,243	1.80	302,837	$9,288,011
Total	549,174	499,748		899,546	$27,589,076
Average	183,058	166,583		299,849	$9,196,359

(c) All Applicants Through TSA Agent States
Year	Total Average Annual Responses	Total Annual Hour Burden	Total Annual Hour Burden Cost
	k = b + g	l = d + i	m = e + j
2017	181,239	328,189	$10,065,557
2018	183,052	331,471	$10,166,215
2019	184,882	334,784	$10,267,826
Total	549,174	994,444	$30,499,598
Average	183,058	331,481	$10,166,533

For enrollments through non-TSA agent States

All applicants who enroll through non-TSA agent State (with no pre-enrollment option) can submit their applications only in-person. Hence, the average number of annual responses is equal to the average number of annual respondents, as shown in columns (a) and (b) of Table 5.

TSA estimates the total hour burden by multiplying the total number of in-person applicants by the hour burden per applicant, 1.80 hours (0.37 + 1.43). This calculation is shown in columns (d) of Table 5. TSA also estimates the hour burden cost by multiplying the total hour burden obtained by the fully loaded average hourly wage of $30.67 per applicant, as shown in column (e) of Table 5.

Total in person applicants (100% of respondents) = 255,712 over three years (or 85,237 per year).

Hour burden per applicant = Enrollment time + Roundtrip travel time

= 0.37 hours (22 minutes) + 1.43 hours (86 minutes)

= 1.80 hours per applicant

Total hour burden (enrollment through non-TSA agent State)

= 255,712 applicants x 1.80 hours

= 460,282 hours per three years

= 153,427 hours per year (85,237 x 1.80).

Total hour burden cost (enrollment through non-TSA agent State)

= 460,282 hours x $30.67 per applicant

= $14,116,849 over three years

= $4,705,606 per year (153,427 x $30.67).

Table 5: Summary of Information Collection Applicants' Hour Burden Cost for Enrollment Through Non-TSA agent States

Year	Average annual Respondents	In Person Applicants with no Pre-Enrollment (100% of Respondents)		Total Annual Hour Burden	Total Annual Hour Burden Cost
		Average Annual Responses	Hour Burden per Response
	a	b	c	d = b x c	e = d x $30.67
2017	84,391	84,391	1.80	151,904	$4,658,896
2018	85,234	85,234	1.80	153,421	$4,705,422
2019	86,087	86,087	1.80	154,957	$4,752,531
Total	255,712	255,712		460,282	$14,116,849
Average	85,237	85,237		153,427	$4,705,616

Summary: Enrollments through TSA agent States and non-TSA agent States

Total individual applicants’ hour burden during enrollment (Table 4(c) and Table 5)

= 994,444 hours + 460,282 hours

= 1,454,726 hours over three years

= 484,909 hours per year

Total individual applicants’ hour burden cost during enrollment (Table 4(c) and Table 5)

= 1,454,726 hours x $30.67 per applicant

= $44,616,446 over three years

= $14,872,149 per year

Table 5(b): Summary of Information Collection Total Enrollments of Applicants.

Total Enrollments
IC	Responses		Hour Burden		Annual Hour Burden Cost ($30.67)
	3 years	Annual	3 years	Annual		3 years	Annual
Pre-Enrollment	49,426	16,475	94,898	31,633		2,910,522	970,174
In-Person	499,798	166,583	899,546	299,849		27,589,076	9,196,359
Non-TSA Agent State	255,712	85,237	460,282	153,427		14,116,849	4,705,616
Total	804,885	268,295	1,454,726	484,909		44,616,446	14,872,149

(3) Optional customer satisfaction survey participants

After completing enrollment at the enrollment center, in person applicants are provided the option to respond to a customer satisfaction survey. Based on historical survey response rates, approximately 35 percent of applicants will choose to respond to the survey questions. TSA estimates that the survey takes an average of 2.5 minutes (0.042 hours) to complete. The number of survey participants is determined by adding the number of applicants who choose to enroll through TSA agent States and multiplying the total by 35 percent (no customer satisfaction surveys are offered for non-TSA agent state enrollments, as surveys are a feature of the TSA agent enrollment center software). Table 6 presents the detailed calculation.

From Table 1, enrollments through TSA agent States = 549,174 over three years.

Total applicants = 549,174 over three years = 183,058 per year.

Total participating in customer satisfaction survey = 549,174 applicants x 35%

= 192,211 over three years

= 64,070 per year.

Total hour burden = 192,211 applicants x 0.042 hours = 8,073 hours over three years

= 2,691 hours per year.

TSA estimates the hour burden cost due to participation in the customer satisfaction survey by multiplying the total hour burden by the fully loaded average hourly wage rate of $30.67 per survey participant. This gives the time value (or opportunity cost) of applicants participating in the survey.

Total hour burden cost = 8,073 hours x $30.67 per applicant

= $247,599

over three years

= $82,533 per year

Table 6: Summary of Information Collection Survey Participants’ Hour Burden Cost

Year	TSA agent States applicants (applicants from non-TSA agent States do not have a survey option)	Customer Survey Participants (35% of in-person applicants)	Hours to Complete Survey per Applicant	Total Annual Hour Burden	Total Annual Hour Burden Cost
	a	b = a x 35%	c	d = b x c	e = d x $30.67
2017	181,239	63,434	0.042	2,664	$81,705
2018	183,052	64,068	0.042	2,691	$82,533
2019	184,882	64,709	0.042	2,718	$83,361
Total	549,173	192,211		8,073	$247,599
Average	183,058	64,070		2,691	$82,533

(4) Summary of applicants for new or renewal of HME

TSA estimates the total hour burden cost for all HME Threat Assessment Program applicants by adding the total hour burden and the associated costs shown in (1) through (3) above. Table 7 shows the detailed calculation of all applicants’ total hour burden cost for new and renewal of HME.

Total hour burden (HME Threat Assessment Program applicants) = 994,444 + 460,282 + 8,073= 1,462,799 hours over three years

= 487,600 hours per year.

Total hour burden cost (HME Threat Assessment Program applicants) = $30,499,598+ $14,116,849 + $247,599

= $44,864,046 over three years

= $14,954,682 per year.

Table 7: Summary of Information Collection HME Threat Assessment Program Applicants' Hour Burden Cost

Year	Total HME Enrollments	TSA Agent State Enrollments		Non-TSA Agent State Enrollments		Customer Survey Participants		Grand Total
		Total Annual Hour Burden	Total Annual Hour Burden Cost	Total Annual Hour Burden	Total Annual Hour Burden Cost	Total Annual Hour Burden	Total Annual Hour Burden Cost	Annual Hour Burden	Annual Hour Burden Cost
	a	b	c	d	e	f	g	h =b + d+ f	i = c + e + g
2017	265,630	328,189	$10,065,557	151,904	$4,658,896	2,664	$81,705	482,757	$14,806,158
2018	268,286	331,471	$10,166,215	153,421	$4,705,422	2,691	$82,533	487,583	$14,954,170
2019	270,969	334,784	$10,267,826	154,957	$4,752,531	2,718	$83,361	492,459	$15,103,718
Total	804,885	994,444	$30,499,598	460,282	$14,116,849	8,073	$247,599	1,462,799	$44,864,046
Average	268,295	331,482	$10,166,533	153,427	$4,705,616	2,691	$82,533	487,600	$14,954,682

B. Applicants for Appeal and Waiver

After individuals provide biographic and biometric information and payment to TSA, TSA conducts a security threat assessment (STA) to determine the applicant’s eligibility for the HME Threat Assessment Program. Applicants who were initially deemed ineligible would have an opportunity to correct cases of misidentification or inaccurate criminal or immigration records.

Based on historical data, approximately 3 percent of HME applicants are deemed initially ineligible. TSA will send a letter to the applicant with information regarding their potential disqualification along with instructions for applying for an appeal or waiver. Of this 3 percent, approximately 75 percent of them contact TSA in writing and request a correction of record before TSA makes a final determination.

Individuals who request an appeal or waiver must do a variety of activities depending on his or her application. At the very least, individuals need to write a letter to TSA, and they also may need to collect information about their conviction from their local jurisdiction for criminal history-related disqualifying factors. In other cases, applicants may need to only provide additional citizenship or eligible immigration-related documentation. TSA estimates the average time individuals require to gather relevant documentation and request a correction of record as 6 hours. TSA does not have full information on the time individuals spend to request corrections for existing TSA security threat assessment programs. As a result, TSA extrapolated data based on customer service inquiries and TSA support provided to applicants who have had questions or request assistance/guidance for submitting requests to TSA. The times will vary depending on each individual’s specific circumstances. For example, some individuals may only need to respond to an inquiry for valid citizenship/immigration eligibility while others may need to request additional documents from multiple jurisdictions and entities if there are multiple items (such as criminal history events) to address and the individual does not have historical records on hand. Table 8 shows the detailed calculation of the total hour burden cost for appeal and waiver applicants.

Total appeal/waiver applicants = 804,885 HME applicants x 3% x 75%

= 18,110 appeal/waiver applicants over three years

= 6,037 appeal/waiver applicants per year

Total hour burden (appeal/waiver applicants) = 18,110 applicants x 6 hours per applicant (6,037 x 6 hours).

= 108,660 hours over three years

= 36,220 hours per year

Total hour burden cost (appeal/waiver applicants) = 108,660 hours x $30.67 per applicant

= $3,332,602 over three years

= $1,110,867 per year

Table 8: Summary of Information Collection Appeal/Waiver Applicants' Hour Burden Cost

Year	Total HME Enrollments	Percent of Applicants Initially Deemed Ineligible	Percent of Applicants that request Appeal or Waiver	Total Applicants that Request Appeal or Waiver	Hour Burden per Applicant for Appeal or Waiver	Total Annual Hour Burden	Total Annual Hour Burden Cost
	a	b	c	d = a x b x c	e	f = d x e	g = f x $30.67
2017	265,630	3%	75%	5,977	6	35,862	$1,099,888
2018	268,286	3%	75%	6,036	6	36,216	$1,110,745
2019	270,969	3%	75%	6,097	6	36,582	$1,121,970
Total	804,885			18,110		108,660	$3,332,603
Average	268,295			6,037		36,220	$1,110,867

Table 8(b): Total Information Collection

Information Collection
IC	Responses		Hour Burden
	3 years	Annual Resp.	3 years	Annual Burden
Pre-Enrollment	49,426	16,475	94,898	31,633
In-Person	499,798	166,583	899,546	299,849
Non-TSA Agent State	255,712	85,237	460,282	153,427
Survey	192,211	64,070	8,073	2,691
Waiver/Appeals	18,110	6,037	108,660	36,220
Total	1,015,257	338,402	1,571,459	523,820

C. Total Hour Burden and Cost

TSA estimates the total hour burden and the associated costs for the HME Threat Assessment Program by adding the hour burdens and costs calculated under sections (A) and (B) above. Table 7 and Table 8, respectively, present the summaries of the hour burden costs under these sections. While Table 7 summarizes the total hour burden costs of applicants for new or renewal of HME, Table 8 gives the total hour burden costs of applicants for appeal/waiver. Table 9 shows the detailed calculation of the total hour burden costs for the HME Threat Assessment Program.

Total number of responses = 804,885 HME enrollments + 18,110 applicants for appeal or waiver

= 822,995 over three years

= 274,332 per year.

Total hour burden (applicants for new or renewal of HME and for appeal/waiver)

= 1,462,799 + 108,660

= 1,571,459 over three years

= 523,820 per year.

Total hour burden costs (applicants for new or renewal of HME and for appeal/waiver)

= $44.86 million + $3.33 million

= $48.19 million over three years

= $16.06 million per year.

Table 9: Summary of Information Collection HME Applicants and Appeal/Waiver Applicants' Total Hour Burden Cost

Year	A. Applicants for New or Renewal of HME & Survey			B. Applicants for Appeal and Waiver			Grand Total
	Total HME Enrollments	Total Annual Hour Burden	Total Annual Hour Burden Cost (million $)	Total Applicants that Request Appeal or Waiver	Total Annual Hour Burden	Total Annual Hour Burden Cost (million $)	Number of Responses	Annual Hour Burden	Annual Hour Burden Cost (million $)
	a	b	c	d	e	f	g = a + d	h = b + e	I = c + f
2017	265,630	482,757	$14.80	5,977	35,862	$1.10	271,607	518,619	$15.90
2018	268,286	487,583	$14.95	6,036	36,216	$1.11	274,322	523,799	$16.06
2019	270,969	492,459	$15.10	6,097	36,582	$1.12	277,066	529,041	$16.22
Total	804,885	1,462,799	$44.85	18,110	108,660	$3.33	822,995	1,571,459	$48.18
Average	268,295	487,600	$14.95	6,037	36,220	$1.11	274,332	523,820	$16.06

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

Individuals applying for new or renewal of HME are required to pay for their STA. Based on the data provided by the TSA Office of Intelligence & Analysis (OIA), Program Management Division, TSA estimates that the total STA and appeal/waiver costs incurred by HME applicants is $70,187,586 over three years (or $23,395,862 per year).

TSA is currently revising its fee for the HME Threat Assessment Program as well as the fee for comparable security threat assessments in light of changes to the FBI’s criminal history processing fee and TSA’s costs related to conducting the security threat assessment (STA). The FBI’s fee and STA fee are two out of three segments of the HME Threat Assessment Program’s overall fee. The HME fee contains segments for enrollment, the STA, and FBI fees, most recently $38.00 for vendor enrollments (amount varies by state for state enrollment), $34.00 for all enrollments, and $14.50 for all enrollments, respectively.

On February 1, 2015, the FBI reduced its fingerprint-based criminal history record check fee by $1.75 based on recommendations from a required user fee study (75 FR 18751). Effective October 1, 2016, the FBI again reduced its fingerprint-based criminal history record check fee, this time by $2.75 based on recommendations from a required user fee study (81 FR 45535). Section 1572.501(b)(3) states that if the FBI amends its fee for criminal history records checks, TSA will collect the amended FBI fee of $10.00 per applicant.

By contrast, TSA will increase the STA segment of the standard HME fee in the amount of $3.00. TSA has identified, in accordance with the methodologies described in the 2013 final fee rule, threat assessment service costs related to the STA segment of the standard HME fee that exceed the expected STA segment revenue. The majority of these costs relate to technology infrastructure. In addition to increased technology costs, the number of HME applicants has been in decline, leaving fewer applicants from which costs may be recovered. These two factors necessitate an increase in cost recovery in the ongoing operation of the HME program. The enrollment segment of the HME Threat Assessment Program’s overall fee will remain at $38.00 for enrollments conducted by TSA’s vendor. As a result of the FBI’s fee decreases ($4.50 over the FBI’s past two fee changes) and the increase in the STA segment of the standard HME fee ($3.00), the overall HME standard enrollment fee ($86.50) for applicants enrolled by TSA’s vendor will be reduced by $1.50 to the new fee of $85.00 ($10.00 + $37.00 + $38.00), effective upon publication of TSA’s Notice of Fee Adjustment. For applicants who enroll through the State in States that opted not to use TSA’s enrollment vendor, the revised fees for the FBI and STA segments of the overall fee for state enrollments will be the same as those for enrollments conducted by the TSA vendor ($10.00 and $37.00, respectively); however, because each State that conducts enrollments charges a its own fee (over which TSA has no control) for its enrollment segment, TSA cannot provide a revised overall enrollment fee for enrollment conducted by the States.

TSA will also decrease the amount of the STA segment of the reduced HME fee by $1.00 from $29.00 to $28.00, which applies to both TSA vendor and State enrollment methods. TSA is decreasing this segment of the reduced HME fee because TSA has identified, in accordance with the methodologies described in the 2013 final fee rule, threat assessment service revenue related to the STA segment of the reduced fee that exceeds the expected STA segment costs. Thus, the HME reduced enrollment fee ($67.00) will be reduced to the new fee of $66.00 for TSA vendor enrollments, effective upon publication of TSA’s Notice of Fee Adjustment. The STA segment of the reduced fee will change from $29 per enrollment to $28 for non-agent states as well. Again, because each State that conducts its own enrollments charges its own fee for the enrollment segment, it is not possible to give a revised overall reduced HME fee for state enrollments. The following tables summarize the current and revised HME fees:

Table 10: HME Fees (via State Enrollment)

Standard
	Current Published Fee	Revised Fee
Enrollment Segment	N/A*	N/A*
STA Segment	$34.00	$37.00
FBI Segment	$14.50	$10.00
Total	$48.50	$47.00

.

Reduced
	Current Published Fee	Revised Fee
Enrollment Segment	N/A*	N/A*
STA Segment	$29.00	$28.00
Total	$29.00	$28.00

* Enrollment charges are set individually by each respective state.

Table 11: HME Fees (via Vendor Enrollment)

Standard
	Current Published Fee	Revised Fee
Enrollment Segment	$38.00	$38.00
STA Segment	$ 34.00	$37.00
FBI Segment	$14.50	$10.00
Total	$86.50	$85.00

Reduced
	Current Published Fee	Revised Fee
Enrollment Segment	$38.00	$38.00
STA Segment	$29.00	$28.00
Total	$67.00	$66.00

Calculations: ⁵

The HME Threat Assessment Program is a fee-based program where HME Threat Assessment Program applicants pay a fee that represents the total cost of the program, prorated over the expected number of applicants. HAZMAT endorsements are valid for a period of up to five years. The five-year renewal of an HME costs the same as the initial enrollment. The HME cost for each applicant includes initial processing fee, fee for FBI criminal history records check, and administrative fees. Processing costs vary depending on whether applicants are enrolled by a TSA agent State or non-TSA agent State. For individuals applying through a TSA agent State, the enrollment fee is $85.00. For individuals applying through a non-TSA agent State, the enrollment fee averages $91.86.⁶ TSA estimates the costs of STA for HME Threat Assessment Program by multiplying the number of applicants enrolled through the TSA agent States and non-TSA agent States by their corresponding enrollment fees. Table 12 shows the detailed calculation of the total STA costs for HME Threat Assessment Program.

STA costs (TSA Agent State) = 549,174 enrollments x $85.00

= $46,679,790 over three years

= $15,559,930 per year.

STA costs (non-TSA Agent State) = 255,712 enrollments x $91.86

= 23,489,704 over three years

= $7,829,871 per year.

Total STA costs for HME Threat Assessment Program = $46,679,790 + $23,489,704

= $70,169,494 over three years

= $23,389,801 per year.

Table 12: Summary of the total STA costs for HME Threat Assessment Program

Year	TSA Agent State		Non-TSA Agent State		Total STA Annual Cost for HME Threat Assessment Program
	Total Annual Enrollments	STA Costs (Fee: $85.00 per applicant)	Total Annual Enrollments	STA Costs (Fee: $91.86 per applicant)
	a	b = a x $85.00	c	d = c x $91.86	e = b + d
2017	181,239	$15,405,315	84,391	7,752,157	23,157,472
2018	183,052	$15,559,420	85,234	7,829,595	23,389,015
2019	184,882	$15,714,970	86,087	7,907,952	23,622,922
Total	549,174	$46,679,790	255,712	23,489,704	70,169,494
Average	183,058	$15,559,930	85,237	7,829,871	23,389,801

For individuals that choose to request an appeal or waiver after TSA notifies them of its preliminary determination of ineligibility, TSA estimates the cost for the appeal/waiver process to be $1.00 per applicant. This cost includes the cost for mailing in an appeal/waiver request to TSA and any cost that involves printing, photocopying or requesting additional supporting documentation, if necessary.

TSA assumes that approximately 3 percent of HME applicants would be deemed initially ineligible and approximately 75 percent of them would submit a request for an appeal/waiver. Based on these proportions, TSA estimates the number of appeal/waiver applicants (as shown in Table 8) and multiplies it by the cost of the appeal/waiver ($1.00) to estimate the total cost of the appeal/waiver process. Table 13 shows the detailed calculation of the total cost of the appeal/waiver process.

Total appeal/waiver applicants = 18,110 applicants over three years (Table 8)

= 6,037 applicants per year.

Total appeal/waiver costs = 18,110 applicants x $1.00 per applicant

= $18,110 over three years

= $6,037 per year.

Table 13: Summary of the Total Appeal/Waiver Costs

Year	Total Applicants that Request an Appeal or Waiver	Average Appeal or Waiver Cost (per Applicant)	Total Annual Appeal or Waiver Cost
	a	b	c = a x b
2017	5,977	$1.00	$5,977
2018	6,036	$1.00	$6,036
2019	6,097	$1.00	$6,097
Total	18,110		$18,110
Average	6,037		$6,037

TSA adds the total STA costs and the total appeal/waiver costs to estimate the total applicants’ costs of the HME Threat Assessment Program under this section. Table 14 shows the detailed calculation.

Total applicants’ cost of HME Threat Assessment Program = Total STA costs + Total appeal/waiver costs

= $70,169,494 + $18,110

= $70,187,604 over three years

= $23,395,868 per year.

Table 14: Summary of Total Applicants' Costs of the HME Threat Assessment Program

Year	Total STA Annual Cost for HME Threat Assessment Program	Total Annual Appeal or Waiver Cost	Total Annual HME Threat Assessment Program Cost
	a	b	c = a + b
2017	23,157,472	$5,977	$23,163,449
2018	23,389,015	$6,036	$23,395,051
2019	23,622,922	$6,097	$23,629,019
Total	70,169,494	$18,110	$70,187,604
Average	23,389,801	$6,037	$23,395,838

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.

TSA charges a user fee, which covers threat assessment and other operational costs associated with the program. TSA’s annualized cost is estimated at $9,926,915. As a fee-based program, costs are estimated based on the TSA portion of the applicant fee that are established to recover the TSA cost of the program, prorated over the expected number of applicants. See Section 13 on fee structure and costs.

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

All tables have been updated to start with Calendar Year (CY) 2014 and CY 2015 actuals as Years 1 and 2 then CY 2016-2019 for Years 3-6. As mentioned in response to Item 13, TSA is currently revising its fee for the HME Threat Assessment Program as well as the fee for comparable security threat assessments in light of changes to the FBI’s fingerprint processing fee and TSA’s costs related to conducting the security threat assessment (STA).

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 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 is not seeking such approval.

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 exceptions to the certification statement.

1 In all calculations, totals may not add due to rounding.

2 The growth rate is provided by TSA Office of Intelligence & Analysis (OIA), Program Management Division.

3 The 2016 estimate is based on historical enrollments and the PMO’s projection for 2016.

4 Fully loaded hourly average wage rate $30.67 = hourly average wage $19.91 x compensation factor 1.541.

Source-hourly average wage: BLS, May 2015 National Industry-Specific Occupational Employment and Wage Estimates (Heavy and Tractor-Trailer Truck Drivers NAICS 533032 and Light Truck or Delivery Services Drivers NAICS 533033 working for various hazardous material shippers). Released on March 30, 2016. http://www.bls.gov/oes/tables.htm (Accessed on 08/10/2016)

Source-compensation factor: BLS Economic News Release March 2016 Employer Costs for Employee Compensation Summary Table 11 for All Full Time Workers Transportation and material moving. 1.541 = $30.98 in total compensation ÷ $20.11 in wages and salaries. http://www.bls.gov/news.release/pdf/ecec.pdf. (Accessed on 08/10/2016)

5 In all calculations, totals may not add due to rounding.

6 These fees are provided by the TSA Office of Intelligence & Analysis (OIA), Program Management Division.