1652-NEW TSA_RSSP_Req SS_7.22.2019

INFORMATION COLLECTION SUPPORTING STATEMENT

TSA Reimbursable Services Program Request

OMB control number 1652-NEW

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).

The Transportation Security Administration (TSA) is collecting this information to meet the requirements of section 225, Division A, of the Consolidated Appropriations Act, 2019, Pub. L. 116-6 (Feb. 15, 2019; 133 Stat. 13). Under this provision, TSA may establish a pilot for public or private entities regulated by TSA to request reimbursable screening services outside of an existing primary passenger terminal screening area where screening services are currently provided or eligible to be provided under TSA’s annually appropriated passenger screening program. For purposes of section 225, “screening services” means “the screening of passengers, flight crews, and their carry-on baggage and personal articles, and may include checked baggage screening if that type of screening is performed at an offsite location that is not part of a passenger terminal of a commercial airport. The authority available under this section is effective for fiscal years 2019 through 2021 and currently may be used at not more than eight locations for transportation security purposes. TSA is collecting this information as part of a process for public and private entities regulated by TSA to request screening services under the Reimbursable Screening Services Program (RSSP).

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.

Public or private entities regulated by TSA interested in participating in the RSSP may submit a request to the TSA Administrator requesting that TSA provide screening services outside of an existing primary passenger terminal screening area where screening services are currently provided or eligible to be provided under TSA’s annually appropriated passenger screening program as a primary passenger terminal screening area. The request may only be submitted to TSA after consultation with the relevant local airport authority. The request is used to identify basic information to grant approval or denial.

TSA will acknowledge receipt of the request, review for completeness, and provide an official response granting approval, or denying the request. If the request is approved by TSA, TSA will enter into a contract with the entity, under which the requesting entity agrees in writing to the scope of the screening services to be provided and agrees to compensate TSA for all reasonable personnel and non-personnel costs, including overtime, of providing the screening services. The collection also allows for amendments to the RSSP by request of a regulated entity.

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.]

In compliance with GPEA, an entity wishing to submit a request to participate in the program must submit a detailed letter directed to the TSA Administrator via the email address available on TSA’s public website. 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 regulated entities submitting requests to denote their interests in the program.

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.

If this collection were not conducted TSA would be unable to consider and evaluate requests by regulated entities to participate in the RSSP, and thus be precluded from meeting the requirements of section 225, Division A, of the Consolidated Appropriations Act, 2019. The Act requires TSA to ensure that the proposed security screening services:

• Do not reduce the security or efficiency of screening services already provided in primary passenger terminals at an impacted airport,

• Do not represent any health of safety concerns,

• Demonstrate the entity’s financial ability to support the request,

• Have the support of impacted local and regional stakeholders,

• Can be implemented by TSA in a timely manner, and

• Do not pose a negative impact to other government agencies and/or state and local governments.

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 84 FR 19801 (May 6, 2019) and 84 FR 33960 (July 16, 2019). Consistent with the requirements of Executive Order (E.O.) 13771, Reducing Regulation and Controlling Regulatory Costs, and E.O. 13777, Enforcing the Regulatory Reform Agenda, the notices included a specific request for comments on the extent to which this request for information could be modified to reduce the burden on respondents. 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.

TSA will 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.

While there are no assurances of confidentiality provided, this information collection falls under the DHS Privacy Impact Assessment (PIA), DHS/ALL/PIA-006, DHS General Contacts List. (June 15, 2007).

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 burdens of the collection of information.

In this estimate, TSA describes the respondent population and then presents a summary of the information collection covered by this ICR.

The likely respondents to this proposed information collection request are public or private entities regulated by TSA requesting the screening services at an airport that is a commercial service airport (as defined by 49 U.S.C. 47107(7)).

REQUESTS

Respondents seeking to participate in the RSSP must send TSA a request for consideration. TSA estimates an average annual number of RSSP respondents to be 12. TSA estimates that each RSSP Requests requires eight (8) hours to complete, resulting in an annual hour burden of 96 hours. TSA assumes RSSP Requests are completed by an airport security coordinator with a fully-loaded¹ hourly wage rate of $97.63², for an annual hour burden cost of $9,372.48. Table 1 summarizes these estimates.

Table 1. Hour Burden and Costs for RSSP Requests
Annual Number of Requests	Hour Burden per Requests	Total Annual Hour Burden	Annual Hour Burden Cost
A	B	C = A x B	D = C x $97.63
12	8	96	$9,372.48

AMENDMENTS

TSA will process amendments to the RSSP by request of a regulated entity. TSA estimates it will receive less than one amendment (specifically, the expected probability of 0.8 amendments per year)³. TSA assumes the full-loaded hourly wage rate of $97.63 for airport operator security coordinators. TSA estimates each requested amendment will place an 8-hour burden on a regulated entity, for an average annual hour burden of 8 hours and an average annual hour burden cost of $781.04. Table 2 summarizes these estimates.

Table 2. Hour Burden and Costs for RSSP Amendments
Annual Number of Amendments Submitted	Hour Burden per Amendment	Total Annual Hour Burden	Annual Hour Burden Cost
A	B	C = A x B	D = C x $97.63
1	8	8	$781.04

Total Hour Burdens and Costs for RSSP Respondents

TSA estimates that the average annual hour burden for respondents to participate in this program is 104 hours, which corresponds to an annual hour burden cost of $10,153.52.

Table 3. Total Hour Burden and Costs for RSSP Requests and Amendments
Annual Number of Responses	Total Hour Burden per Collection	Total Annual Hour Burden	Annual Hour Burden Cost
A	B	C = A x B	D = C x $97.63
12	8	96	$9,372.48
1	8	8	$781.04
13		104	$10,153.52.

13. Provide an estimate of annualized capital and start-up costs.

There are no annualized capital and start-up costs 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.

To administer this program, TSA estimates an annual hour burden of 908 hours and a total annual hour cost of $68,527.18, to the Federal Government.

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

This is a new collection.

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 as the information gathered for the request meets the criteria for 5 CFR 1320.9.

1 A fully-loaded wage rate includes non-salary costs of employer cost of employee compensation, such as health and retirement benefits.

2 The unloaded wage rate for a General and Operations Manager is $64.16. Bureau of Labor Statistics (BLS). May 2018 National Industry-Specific Occupational Employment and Wage Estimates. NAICS 481000 - Air Transportation. OCC 11-1021 General and Operations Manager. Last modified March 30, 2018 (accessed June 11, 2019), https://www.bls.gov/oes/2017/May/naics3_481000.htm. TSA calculates a load factor for a civilian employee working in Production, Transportation and Material Moving over the March 2018, June 2018, September 2018, and December 2018 quarters to account for non-wage compensation. TSA calculates this factor by dividing the average total compensation ($28.92) by the average wage and salary component ($19.01), to get a load factor of 1.5217. BLS. Employer Costs for Employee Compensation - March 2018. 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. Production, Transportation, and Material moving Occupational Group. Last modified March 22, 2019 (accessed June 11, 2019), https://www.bls.gov/bls/news-release/ecec.htm#2018. The fully-loaded wage rate is calculated by multiplying the unloaded wage rate by the load factor. $97.63= $64.16 x 1.5217.

3 TSA estimates that 10 percent of the program’s respondents will submit an amendment, in any given year.