1. 1670-NEW_Critical Infrastructure Workers Denied Movement Reporting Form_SS-A_v2

Supporting Statement for Paperwork Reduction Act Submissions
Title: Critical Infrastructure Workers Denied Movement Reporting Form
OMB Control Number: 1670-NEW
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.
The Cybersecurity and Infrastructure Security Act of 2018 created the Cybersecurity and
Infrastructure Security Agency (CISA) within the Department of Homeland Security. The act
directs CISA to “integrate relevant information, analysis, and vulnerability assessments,
regardless of whether the information, analysis, or assessments are provided or produced by the
Department, in order to make recommendations, including prioritization, for protective and
support measures by the Department, other Federal Government agencies, State, local, tribal, and
territorial government agencies and authorities, the private sector, and other entities regarding
terrorist and other threats to homeland security.” With the advent of the global pandemic referred
to as COVID 19, the agency has extended our operating environment to include this biologic
threat to the homeland.
As part of the National Pandemic Action Plan for responding to this threat, social distancing and
local “Stay at Home” or similar orders have become the normal across the county. The President
has left the establishment of these orders to the State, Local, Territorial, and Tribal (SLTT)
governments. This had the potential to create a patchwork of exceptions to who was exempted
based on the essentiality of their work. To help provide order to this issue, CISA worked with
the Sector Specific Agencies described in PPD 41, the White House, the Department, and the
SLTT governments to provide guidance on what is considered Essential Critical Infrastructure
Workers. Many SLTT governments have adopted our guidance in full and other have adopted it
in part. All 50 states, the District of Columbia, and all Territories and Tribal lands have limited
movement of non-essential workers to some extent, making this issue truly national.
As part of our routine monitoring or our programs, we have heard anecdotal evidence that even
though our non-mandatory guidance has been adopted, local Law Enforcement are not fully
following this guidance and have restricted entities that are excepted by local rules. CISA has a
duty to evaluate the risk of this behavior. The proposed collection will not attempt to rigorously
validate or measure the prevalence of these incidents, but represents an important first step in
better understanding the issue.
This collection is designed to allow affected parties to voluntarily submit relevant evidence of
denied Essential Critical Worker movement to CISA. The information will allow the agency to

document alleged instances where someone has been denied movement as an Essential Critical
Infrastructure Worker.
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.
The Critical Infrastructure Workers Denied Movement Report is a voluntary form that CISA will
post to its public facing website and advertise through our Regional Offices and during our
frequent engagements with our stakeholders. Respondents can fill out the form for each instance
where they believe they have been denied movement as an Essential Critical Infrastructure
Worker.
CISA will utilize this information as evidence of a need to seek additional information to assess
the need to develop a National Standard for Essential Critical Infrastructure Workers, expand our
existing voluntary programs for reentry into previously denied areas, or take other appropriate
action with our interagency partners. Without this information the Agency is unable to make an
informed decision. The Agency will not use information collected through this voluntary
feedback collection as the justification for new regulations or policies.
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.
This information will be collected from a form hosted on the CISA Website. Respondents will
need to fill out the form and submit via the website. Respondents that phone CISA’s service desk
will be able to convey the information to our service agents, who will submit the information on
the respondent’s behalf.
4. Describe efforts to identify duplication. In Show specifically why any similar information
already available cannot be used or modified for use for the purposes described in Item 2 above.
A search of reginfo.gov revealed that this information is not collected in any form, and therefore
is not duplicated elsewhere.
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.
This information collection will only affect those small businesses or other small entities that are
considered Essential Critical Infrastructure.

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6. Describe the consequence to Federal/DHS program or policy activities if the collection of
information is not conducted, or is conducted less frequently, as well as any technical or legal
obstacles to reducing burden.
CISA is charged with coordinating a national effort to secure and protect against critical
infrastructure risks and to provide analyses, expertise, and recommend measures necessary to
protect key resources and critical infrastructure of the United States. Without this information,
the agency will be unable to make an informed decision to seek additional evidence on the need
to create additional guidance regarding critical infrastructure employee access vis-à-vis State and
local stay-at-home orders.
7. Explain any special circumstances that would cause an information collection to be conducted
in a manner:
(a) Requiring respondents to report information to the agency more often than quarterly.
(b) Requiring respondents to prepare a written response to a collection of information in
fewer than 30 days after receipt of it.
(c) Requiring respondents to submit more than an original and two copies of any document.
(d) Requiring respondents to retain records, other than health, medical, government contract,
grant-in-aid, or tax records for more than three years.
(e) 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.
(f) Requiring the use of a statistical data classification that has not been reviewed and
approved by OMB.
(g) 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.
(h) 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.
The special circumstances contained in item 7 of the Supporting Statement are not applicable to
this information collection.
8. Federal Register Notice:

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a. Provide a copy and identify the date and page number of publication in the Federal Register
of the agency’s notice 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.
b. 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.
c. Describe consultations with representatives of those from whom information is to be obtained
or those who must compile records. Consultation should occur at least once every three years,
even if the collection of information activities is the same as in prior periods. There may be
circumstances that may preclude consultation in a specific situation. These circumstances should
be explained.
Date of Publication
60Day Federal
Register Notice:
30-Day Federal
Register Notice

Volume
#

Number
Page #
#

Comments
Addressed

CISA is seeking an approval of this information collection through the Emergency Approval
Process. Upon approval, CISA will follow the normal clearance process and seek public
comment through the publication of a 60- and 30-Day Federal Register Notice.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration
of contractors or grantees.
There is no offer of 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.
There are no assurances of confidentiality.
This collection is not affected by the Privacy Act and is not impacted by a PIA or SORN.
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.

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12. Provide estimates of the hour burden of the collection of information. The statement should:
a. 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
desired. 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.
To estimate the burden associated with reporting a denied movement incident, CISA multiplies
the number of responses and the estimated time needed to respond. Based on subject matter expert elicitation, CISA estimates that there are 150 to 200 critical infrastructure workers denied
movement per day, and approximately 10% will report the incident. The burden estimate is based
on the form being used for 60 days from approval of this collection, for a total of 12,000 incidents and 1,200 responses (200 incidents x 60 days x 10%). Completing the form to report a denial of movement will take approximately 5 minutes. The respondent’s average hourly compensation rate of $37.46 is based on an average hourly wage rate of $25.72 1 with a benefits multiplier of 1.4566. 2 To estimate the cost, we apply a fully loaded hourly compensation rate of $37.46
to the time required to file an incident report.
As shown in Table 2, the estimated cost associated with reporting is $3,746.

Instrument

Respondents

Responses per
Respondent

Burden per
Response
(hours)

Total Burden
(hours)

Hourly
Compensation
Rate

Cost

Critical Infrastructure Workers Denied
Movement Report

1,200

1

0.083
(5 min.)

100

$37.46

$3,746.42

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.)
There are no recordkeeping, capital, start-up, or maintenance costs associated with this
information collection.
1
Bureau of Labor Statistics (BLS). Occupational Employment Statistics. May 2019. All Occupations (SOC 000000). https://www.bls.gov/oes/2019/may/oes_nat.htm#00-0000.
2
BLS. Employer Costs for Employee Compensation – December 2019. 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, December 2019. https://www.bls.gov/news.release/pdf/ecec.pdf The compensation factor (1.4566) is estimated by dividing total compensation ($37.10) by wages and salaries ($24.57).

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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 have been incurred without this collection of information. You may also
aggregate cost estimates for Items 12, 13, and 14 in a single table.
CISA estimates the burden on the government of this collection by estimating the time required
for CISA personnel to review the submitted denial of movement reports. All reports will initially
be reviewed by a GS-14, with 10% of reports requiring a secondary review by a GS-15. All
1,200 forms submitted by critical infrastructure workers will be reviewed by a GS-14, with 120
(10%) of those also being reviewed by a GS-15. The burden of the GS labor is estimated by
multiplying the fully loaded hourly compensation rate of the employee by the number of hours to
review. As with the burden to complete the report, we estimate it will take 5 minutes for each
review. The hourly rate for a GS-14, Step 3 is $62.21 3, which is multiplied by the load factor of
1.4566 for a loaded compensation rate of $90.62. The hourly rate for a GS-15, Step 3 is $73.18 4,
which is multiplied by the load factor of 1.4566 for a loaded compensation rate of $106.60. As
shown in Table 3 the estimated cost to the Federal Government is $10,128.

Respondents

Responses per
Respondent

GS-14

1,200

1

GS-15

120

1

Total

Average
Burden per
Response
(hours)
0.083
(5 min.)
0.083
(5 min.)

Total
Burden
(hours)

Hourly
Compensation
Rate

Cost

100

$90.62

$9,062.11

10

$106.60

$1,065.96
$10,128.07

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of
the OMB Form 83-I. Changes in hour burden, i.e., program changes or adjustments made to
annual reporting and recordkeeping hour and cost burden. A program change is the result of
deliberate Federal government action. All new collections and any subsequent revisions of
existing collections (e.g., the addition or deletion of questions) are recorded as program changes.
An adjustment is a change that is not the result of a deliberate Federal government action. These
changes that result from new estimates or actions not controllable by the Federal government are
recorded as adjustments.
3
GS pay rates are from The annual salary for a GS-14 Step 3 is $129,404, which is divided by 2080 to obtain the
hourly rate. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salarytables/20Tables/html/DCB.aspx
4
GS pay rates are from The annual salary for a GS-15 Step 3 is $152,215, which is divided by 2080 to obtain the
hourly rate. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salarytables/20Tables/html/DCB.aspx

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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.
NPPD does not intend to employ the use of statistics or the publication thereof for this
information collection.
17. If seeking approval to not display the expiration date for OMB approval of the information
collection, explain reasons that display would be inappropriate.
NPPD 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 Submissions,” of OMB Form 83-I.
NPPD does not request an exception to the certification of this information collection.

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