1652-0064 Spp Ss 4.17.2018

INFORMATION COLLECTION SUPPORTING STATEMENT

Screening Partnership Program Application

OMB control number 1652-0064

Exp. 8/31/2018

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).

Under 49 U.S.C. 44920, an airport may submit an application to TSA to have the screening of passengers and property required by 49 U.S.C. 44901 conducted by non-Federal personnel. TSA must approve the application if the approval "would not compromise security or detrimentally affect the cost-efficiency or the effectiveness of the screening of passengers or property at the airport." TSA implements this requirement through the Screening Partnership Program (SPP). Currently, 22 airports participate in the program. Participation in the SPP is initiated with the application covered by this information collection.

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.

As stated in 49 U.S.C. 44920, an operator of an airport may submit to the TSA Administrator an application requesting to have the screening of passengers and property at the airport under 49 U.S.C. 44901 carried out by the screening personnel of a qualified private screening company under a contract entered into with the Administrator for TSA. The airport operator application is used to identify basic information from the authorized requestor. This application is reviewed by TSA’s SPP and granted approval or denial within 120 calendar days of receipt. If the SPP application is approved by TSA, TSA will enter into a contract with a qualified private screening company (SPP Contractors) for the airport. Under 44920(b)(3)(B), TSA is also required to submit information to Congress regarding the approval or denial of applications.

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 SPP application that will be submitted to the airport’s Federal Security Director is two (2) pages, and is stored electronically via TSA’s internal iShare site. This process directly supports the Government Paperwork Elimination Act (GPEA).

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 already held by TSA that could be used for the purpose of airport operators submitting applications to denote their interests in converting from a federally-supported airport to a contract-supported airport.

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.

This collection does not have a significant impact on a substantial number of small businesses.

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.

Before allowing an airport to opt-out of the Federal screening requirements in 44901, TSA must first receive an application from the airport and then determine that approving the application "would not compromise security or detrimentally affect the cost-efficiency or the effectiveness of the screening of passengers or property at the airport." See 49 U.S.C. 44920(a) and (b)(2). Without receiving the information collected through the application, TSA would not be able to meet the requirements of 49 U.S.C. 44920.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5(d) (2).

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

8. Describe efforts to consult persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d) soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

TSA published two Federal Register notices with a 60-day and a 30-day comment period, soliciting comments on the information collection. See 82 FR 58650 (December 13, 2017) and 83 FR 11236 (March 14, 2018). The agency received no comments in response to either of the notices.

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

No payment or gift will be provided to respondents.

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

This information collection is covered under DHS/ALL/PIA-006, DHS General Contacts List. (June 15, 2007). As the SPP application does not request either personally identifiable information (PII) or classified information, no special handling or protection is required.

11. Provide additional justification for any questions of sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

TSA does not ask any questions of a sensitive nature.

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

TSA estimates the annual hour burden associated with completing and submitting the application for the SPP, covered by this information collection, to be one-quarter hour (0.25 hours) per respondent. TSA estimates that two airports will respond annually, though it would be possible that 10 or more airports could respond to the application request.¹ TSA assumes that respondent would be an Airport Director,² with a fully-loaded wage rate³ of $91.92⁴.

TSA estimates a total hour burden cost to the public of $137.88 for the three-year approval window, with an average annual estimated cost of $45.96. Table 1 summarizes the annual hour burden cost calculations.

Table 1: Hour Burden and Hour Burden Cost for Respondents
Year	Number Of Respondents	Hour Burden to Respondents	Hour Burden Cost to Respondents
	A	B = A x 0.25	C = B x $91.92
2018	2	0.5	$ 45.96
2019	2	0.5	$ 45.96
2020	2	0.5	$ 45.96
Total	6	1.5	$ 137.88
Annualized	2	0.5	$ 45.96

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

Beyond the hourly burden, there are no respondent or recordkeeper costs estimated for this collection.

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 estimates that it will take one-half hour (0.50 hours) for one Federal Security Director (FSD) to process one application. TSA estimates a total annual hour burden of one hour by multiplying the number of applications TSA receives and the time to process each application (1 = 2 x 0.5). The estimated fully-loaded annual salary of a TSA FSD is $208,999.⁵ TSA estimates an hourly wage rate of $100.14.⁶ TSA calculates the annual costs to the Federal Government by multiplying the total annual hour burden of processing those application by the wage rate of a TSA FSD.

TSA estimates a total hour burden cost to the Federal Government of $300.43 for the three-year approval window, with an average annual estimated cost of $100.14. Table 2 summarizes the federal government cost calculations.

Table 2: TSA Hour Burden and Hour Burden Costs
Year	Number of Applications	Hour Burden of Applications	Hour Burden Cost of Applications
	A	B = A x 0.5	C = B x $100.14
2018	2	1.0	$ 100.14
2019	2	1.0	$ 100.14
2020	2	1.0	$ 100.14
Total	6	3.0	$ 300.43
Annualized	2	1.0	$ 100.14

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

TSA is requiring that the SPP application be submitted to the Federal Security Director for the airport that is requesting to opt-out rather than to an SPP program-office email address. This requirement increases efficiency of the program by ensuring early awareness for those most affected by the potential change in their operations and by providing a familiar, direct point of contact for the airport director. This change affects the cost estimate as the TSA recipient of the application changes from one H/I program analyst to a Federal Security Director. There is no change to the time necessary to receive and/or process the application; this time remains at one-half hour for one application.

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 SPP 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 SPP is not seeking any exceptions to the certification statement as the information gathered for the application meets the criteria for 5 CFR 1320.9.

1 TSA Program Office Estimate, Office of Security Operations, Security Screening Program. In accordance with the Paperwork Reduction Act (PRA), OMB approval must be obtained prior to collecting federally-sponsored data in any situation where there could be 10 or more respondents. A respondent includes individuals; partnerships; associations; corporations; organized groups of individuals; and State, territory, tribal or local governments. Agencies must publish Federal Register notices describing the information collection, respondents and burden estimates for public comment. See, Paperwork Reduction Act of 1995 (Pub. L. 104-13, 109 Stat. 163, Oct. 1, 1995), 44 USC. 3501-3520.

2 TSA Program Office Estimate, Office of Security Operations, Security Screening Program.

3 A fully loaded wage rate accounts for the non-wage compensation costs borne by an employer, such as retirement contributions and health benefits, among other things.

4 TSA approximates the wage rate of an Airport Director, by using the wage rate for General and Operations Managers in the Air Transportation Industry ($60.62). BLS. May 2016 Occupational Employment and Wages. NAISC 481000 - Air Transportation, 11-1021 General and Operations Managers. Last Modified Date: 3/31/17. Retrieved 10/2/17. https://www.bls.gov/oes/2016/May/naics3_481000.htm.

TSA calculates a compensation of 1.5164 by dividing the total compensation of civil workers in the Production, Transportation, and Material Moving Occupation group ($28.25) by the wages and salaries of the same group ($18.63). The compensation factor is therefore: (1.5164 = $28.25/$18.63). BLS, News Release, Employer Costs for Employee Compensation - June 2017. Table 1. Employer costs per hour worked for employee compensation and costs as a percent of total compensation: civilian workers, by major occupational and industry group: transportation, and material moving occupational group, June 2017. Release date September 8, 2017. https://www.bls.gov/news.release/archives/ecec_09082017.pdf. Retrieved 10/2/2017.

TSA calculates the fully loaded wage rate by multiplying the wage rate for General and Operations Managers in the Transportation Sector by the compensation factor. The fully-loaded wage rate is therefore: ($91.92 = $60.62 x 1.5164).

5 This wage rate is estimated using data provided by the TSA Office of Finance and Administration.

6 TSA calculates this by dividing the annual salary by 2,087 work hours in a year.