I-131a Ss (4-15-2018)

SUPPORTING STATEMENT FOR

Application for Travel Document (Carrier Documentation)

OMB Control No.: 1615-0135

COLLECTION INSTRUMENT(S): I-131A

A. Justification

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.

U.S. Citizenship and Immigration Services (USCIS) Form I-131A, Application for Travel Document (Carrier Documentation), is utilized to allow LPRs to request a Travel Permit (transportation letter or boarding foil) at a U.S. Embassy or U.S. Consulate. An approved I-131A will allow a commercial carrier to board the LPR on a vessel or aircraft destined for the United States without transportation carrier liability.

Applicants may be required to submit biometric information if the regulations or form instructions require such information or if requested in accordance with 8 CFR 103.2(b)(9). DHS may collect and store for present or future use, by electronic or other means, the biometric information submitted by an individual. DHS may use this biometric information to conduct background and security checks, adjudicate immigration and naturalization benefits, and perform other functions related to administering and enforcing the immigration and naturalization laws. See 8 CFR 103.16.

The Department of State (DOS) and/or DHS will conduct background, security and identity checks on all applicants that request a Travel Document (Transportation Letter or Boarding Foil). Applicants may be required to appear for an interview and submit biometrics information at a U.S. Embassy, U.S. Consulate or DHS office overseas.

Authorities: 8 U.S.C. §§ 1103, 1158, 1182, 1203 and 1204

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.

Form I-131A has a single use. A lawful permanent resident, who is traveling overseas and is not in possession of a valid, unexpired Permanent Resident Card or other evidence of lawful permanent resident status, may use this form to apply for a Travel Document within one year of his or her last departure from the United States. The lawful permanent resident must submit the application in person at a U.S. Embassy or U.S. Consulate. The decision on Form I-131A is entirely discretionary and may not be appealed. Furthermore, DHS may revoke or terminate a Travel Document at any time.

If the Form I-131A is approved, DOS or DHS will issue a Travel Document, generally valid for 30 days, which will allow the lawful permanent resident to board a vessel or aircraft, travel to the United States, and present him or herself at a U.S. port-of-entry for inspection as a returning lawful permanent resident. A Travel Document is not a guarantee of admission or other form of entry into the United States, and U.S. Customs and Border Protection (CBP) will carry out all required inspection procedures upon the alien’s arrival at a U.S. port of entry.

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.

The use of this information collection provides the most efficient means for collecting and processing the required data. Form I-131A must file Form I-131A in person at a USCIS international field office or with a Consular Section at a U.S. Embassy or Consulate.  Prior to appearing at a U.S. Embassy or U.S. Consulate to file Form I-131A, the filing fee must be submitted through the USCIS online filing system on the USCIS Website. Respondents will be directed to make their fee payment via the collection approved at 1615-0131 (USCIS Electronic Payment Processing). When you appear in person to file Form I-131A, you must bring evidence that you paid the fee, such as a copy of the payment confirmation page or a copy of the email payment receipt notice.

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.

A review of the USCIS automated forms tracking system was accomplished and revealed no duplication. There is no similar data collected.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

This collection of information does not have an impact on small businesses or other small entities.

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.

The collection of this information is required to verify the status of permanent or conditional residents, and determine whether the applicant is eligible for the requested Travel Document. The lack of such documentation will result in LPRs who travel abroad not being able to apply for readmission into the United States. Use of this form will enable U.S. Embassies and U.S. Consulates to provide more efficient service to qualified lawful permanent residents who, without other evidence of lawful permanent resident status, are unable to board a vessel or aircraft destined for the United States.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• Requiring respondents to report information to the agency more often than quarterly;

• Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• Requiring respondents to submit more than an original and two copies of any document;

• Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• In connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• That includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• Requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

This information collection is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2).

8. If applicable, provide a copy and identify the data 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.

Describe efforts to consult with 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.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

On March 13, 2018, USCIS published a 60-day notice in the Federal Register at 83 FR 10868. USCIS did not receive comments after publishing that notice. On May 25, 2018, USCIS published a 30-day notice in the Federal Register at 83 FR 24329. USCIS did not receive comments.

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

USCIS does not provide any payment for benefit sought.

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

There is no assurance of confidentiality. The system of record notice associated with this information collection are: DHS/USCIS/ICE/CBP-001 Alien File, Index, and National File Tracking System of Records, September 18, 2017, 82 FR 43556 and DHS/USCIS-007 Benefits Information System, October 19, 2016 81 FR 72069.

The associated Privacy Impact Assessment are: DHS/USCIS/PIA-016(a) Computer Linked Application Information Management System (CLAIMS 3) and Associated Systems and DHS/USCIS/PIA-051 Case and Activity Management for International Operations (CAMINO).

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.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

Type of Respondent	Form Name / Form Number	# of Respondents	#. of Responses per Respondent	# of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate*	Total Annual Respondent Cost
Individuals or Households	Application for Travel Document (Carrier Evidence)Form I-131A	4,110	1	4,110	.92 hours	3,781	$34.84	$131,730
Individuals or Households	Biometric processing**	4,110	1	4,110	1.17 hours	4,809	$34.84	$167,545
Total						8,590		$299,275

* The above Average Hourly Wage Rate is the May 2016 Bureau of Labor Statistics average wage for All Occupations of $23.86 times the wage rate benefit multiplier of 1.46 (to account for benefits provided) equaling $34.84.  The selection of “All Occupations” was chosen as the expected respondents for this collection could be expected to be from any occupation.

**Biometrics may be required at the time of any interview or other appearance at a U.S. Embassy or U.S. Consulate, to verify identity and/or update background and security checks.

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

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995; (2) to achieve regulatory compliance with requirements not associated with the information collection; (3) for reasons other than to provide information or keep records for the government; or, (4) as part of customary and usual business or private practices.

In addition to the time burden for the form’s preparation an estimated 35% of respondents may incur expenses for third party assistance to prepare the responses, legal services, translators, and document search and generation. USCIS estimates that the average cost for these activities is $490 and that an average of 35% of the total respondent population may incur this cost. The total cost to respondents would generate as follows: 4,110 respondents x 35% of the population = 1,438 multiplied by the average cost per response of $490 = $ 704,620. This averages to $171.40 per respondent ($704,620/4,110).

There is a fee of $575 required with the filing of Form I-131A.

14. 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. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Annualized Cost Analysis:

1. Collection and Processing Cost $ 2,712,600

2. Total Cost to Government $ 2,712,600

The collection and processing cost to the Federal Government is calculated by multiplying the total number of respondents filing Form I-131A (4,110) times the $575 fee required, equaling $ 2,363,250 and adding in the total number of filers that are required to pay the biometric fee, (4,110) of the filers times the $85 biometric fee, equaling $ 349,350. The cost to the government is $ 2,712,600.

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

Data collection Activity/Instru-ment	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
I-131A				13,800	3,781	(10,019)
Biometrics processing				17,550	4,809	(22,359)
Total(s)				31,350	8,590	(32,378)

There is a 32,378 decrease in the time burden last reported for this information collection. This decrease is due to a decrease in the estimated number of respondents for Form I-131A.

Data collection Activity/Instru-ment	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New) [new minus current]	Difference
I-131A				$0	$704,620	$704,620
Total				$0	$704,620	($704,620)

The cost burden for this information collection is $704,620. This is due to the calculation of a cost burden for this submission of Form I-131A.

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.

This information collection will not be published for statistical purposes.

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.

USCIS will display the expiration date for OMB approval of this information collection.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submission,” of OMB 83-I.

USCIS does not request an exception to the certification of this information collection.

B. Collections of Information Employing Statistical Methods.

There is no statistical methodology involved with this collection.

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