Supporting Statement
Application for Identification Card
1651-0008
Justification
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.
CBP Form 3078, Application for Identification Card, is filled out in order to obtain an Identification Card which is used to gain access to CBP security areas. This form collects biographical information and is usually completed by licensed Cartmen or Lightermen whose duties require receiving, transporting, or otherwise handling imported merchandise which has not been released from CBP custody. This form is submitted to the local CBP office at the port of entry that the respondent will be requesting access to the Federal Inspection Section (FIS). Form 3078 is authorized by 19 U.S.C. 66, 1551, 1555, 1565, 1624, 1641; and 19 CFR 112.42, 118, 122.182, and 146.6. This form is accessible at: http://www.cbp.gov/sites/default/files/documents/CBP%20Form%203078.pdf
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.
This information is needed to determine the eligibility of an employee seeking entrance to a CBP FIS area. CBP uses the information collected on Form 3078 to conduct a background investigation and thereby determine whether the applicant meets the criteria’s required for the issuance of a CBP Hologram Identification card.
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.
CBP Form 3078 is a fillable form on CBP’s website at: http://www.cbp.gov/sites/default/files/documents/CBP%20Form%203078.pdf. 19 CFR 112.42 requires that this form be submitted personally to the Port Director by the applicant, so electronic submission of this form would not be practical. CBP also requires a signed copy to certify that the information on the application is true and complete.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
This information is not duplicated in any other place or any other form.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
This information collection does not have an impact on small businesses or other small entities.
Describe consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently.
If this information was not collected, CBP would have no way of identifying those authorized to enter CBP security areas to handle merchandise in CBP Custody.
7. Explain any special circumstances.
This information is collected in a manner consistent with the guidelines of 5 CFR 1320.5(d)(2).
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.
Public comments were solicited through two Federal Register notices published on October 20, 2017 (Volume 82, Page 48840) on which no comments were received, and on January 8, 2018 (Volume 83, Page 828) on which no comments have been received.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
There is no offer of a monetary or material value for this information collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
A SORN for Persons Engaged in International Trade (Vol. 73, Page 77753), dated December 19, 2008 has been included in this ICR. No assurances of confidentiality are provided to respondents.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
There are no questions of a sensitive nature.
Provide estimates of the hour burden of the collection of information.
INFORMATION COLLECTION |
TOTAL ANNUAL BURDEN HOURS |
NO. OF RESPONDENTS |
NO. OF RESPONSES PER RESPONDENT |
TOTAL RESPONSES |
TIME PER RESPONSE |
CBP Form 3078
|
42,450 |
150,000 |
1 |
150,000 |
17 minutes (.283 hours) |
Public Cost
The estimated cost to the respondents is $1,275,198. This is based on the estimated burden hours (42,450) multiplied by (x) the average loaded hourly wage rate for importers ($30.04). CBP calculated this loaded wage rate by first multiplying the Bureau of Labor Statistics’ (BLS) 2016 median hourly wage rate for Cargo and Freight Agents ($20.15), which CBP assumes best represents the wage for importers, by the ratio of BLS’ average 2016 total compensation to wages and salaries for Office and Administrative Support occupations (1.4762), the assumed occupational group for importers, to account for non-salary employee benefits.1,2 CBP then adjusted this figure, which was in 2015 U.S. dollars, to 2017 U.S. dollars by applying a 1.0 percent annual growth rate to the figure, as recommended by the U.S. Department of Transportation’s value of travel time guidance.3
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
There are no record keeping, capital, start-up or maintenance costs associated with this information collection.
Provide estimates of annualized cost to the Federal Government. Also provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
The estimated annual cost to the Federal Government associated with the review of these records is $9,064,500. This is based on the number of responses that must be reviewed (150,000) multiplied by (x) the time burden to review and process each response (1 hour) = 150,000 hours multiplied by (x) the average hourly loaded rate for other CBP employees ($60.43)4 = $9,064,500.
15. Explain the reasons for any program changes or adjustments reported in Items 12 or 13 of this Statement.
There has been no increase or decrease in the estimated annual burden hours previously reported for this information collection. There is no change to the information collected or to CBP Form 3078.
16. For collection of information whose results will be published, outline plans for tabulation, and publication.
This information collection will not be published for statistical purposes.
17. If seeking approval to not display the expiration date, explain the reasons that displaying the expiration date would be inappropriate.
CBP will display the expiration date for OMB approval of this information collection.
18. “Certification for Paperwork Reduction Act Submissions.”
CBP does not request and exception to the certification of this information collection.
No statistical methods were employed.
1 Source: U.S. Bureau of Labor Statistics. Occupational Employment Statistics, “May 2016 National Occupational Employment and Wage Estimates, United States- Median Hourly Wage by Occupation Code.” Updated March 31, 2017. Available at http://www.bls.gov/oes/2016/may/oes_nat.htm. Accessed June 20, 2017.
2 The total compensation to wages and salaries ratio is equal to the calculated average of the 2016 quarterly estimates (shown under Mar., June, Sep., Dec.) of the total compensation cost per hour worked for Office and Administrative Support occupations ($25.3575) divided by the calculated average of the 2016 quarterly estimates (shown under Mar., June, Sep., Dec.) of wages and salaries cost per hour worked for the same occupation category ($17.1775). Source of total compensation to wages and salaries ratio data: U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation. Employer Costs for Employee Compensation Historical Listing March 2004 – March 2017, “Table 3. Civilian workers, by occupational group: employer costs per hours worked for employee compensation and costs as a percentage of total compensation, 2004-2017 by respondent type.” June 20, 2017. Available at http://www.bls.gov/ncs/ect/sp/ececqrtn.pdf. Accessed June 20, 2017.
3 Source: U.S. Department of Transportation, Office of Transportation Policy. The Value of Travel Time Savings: Departmental Guidance for Conducting Economic Evaluations Revision 2 (2015 Update), “Table 4 (Revision 2-corrected): Recommended Hourly Values of Travel Time Savings.” April 29, 2015. http://www.transportation.gov/sites/dot.gov/files/docs/Revised%20Departmental%20Guidance%20on%20Valuation%20of%20Travel%20Time%20in%20Economic%20Analysis.pdf. Accessed June 20, 2017.
4 CBP bases this wage on the FY 2017 salary and benefits of the national average of other CBP positions, which is equal to a GS-12, Step 7. Source: Email correspondence with CBP’s Office of Finance on June 14, 2017.
| File Type | application/msword |
| Author | Preferred Customer |
| Last Modified By | SYSTEM |
| File Modified | 2018-01-23 |
| File Created | 2018-01-23 |