ARCS form - Supporting Statement (10-28-2021)

ARCS form - Supporting Statement (10-28-2021).docx

Afghanistan Request for Consular Services Form

OMB: 1405-0249

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SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION

Afghanistan Request for Consular Services Form
OMB Number 1405-XXXX



A. JUSTIFICATION

  1. Why is this collection necessary and what are the legal statutes that allow this?

The information on this form is requested pursuant to Executive Order 12656 (Assignment of emergency preparedness responsibilities), the Vienna Convention on Consular Relations, 8 U.S.C. § 1101 et seq. (Immigration and Nationality Act), and U.S. Department of State authorities providing for consular and emergency assistance and visa functions, including 22 U.S.C. § 4802(b) (Overseas evacuations), 22 U.S.C. § 3904 (Functions of Service), 22 U.S.C. § 2671 (Emergency Expenditures), and 22 U.S.C. § 2656 (Management of Foreign Affairs).

  1. What business purpose is the information gathered going to be used for?

The Department of State has as its highest priority protecting the lives and serving the interests of U.S. citizens overseas. The purpose of collecting this information is to assist the Department of State in planning and coordinating the evacuation or relocation from Afghanistan of private U.S. citizens, Lawful Permanent Residents (LPRs), Special Immigrant Visa (“SIV”) holders and applicants, and other individuals at risk due to the security situation in the country, and where applicable in facilitating assistance in Afghanistan and onward transportation and assistance, to or in intermediate locations and/or the United States. The need for this collection arose out of immediate and unforeseen exigent circumstances in the last month after the end of U.S. military involvement in Afghanistan and the suspension of operations of the U.S. Embassy in Kabul, a clear and specific emergency; a crisis response that requires Department action to assist U.S. citizens and others who are in dire circumstances. The collection will also support the commitments made by the President to assist those U.S. citizens, LPRs and at-risk Afghans (including SIV applicants) to depart Afghanistan.

As requested by the applicant, the information may also be used to provide additional information related to consular services. The information may be used by the U.S. Departments of State, Defense and Homeland Security and may be shared with other U.S. or foreign government agencies, international organizations, airlines and other transportation providers, non-governmental organizations and relevant family or other private individuals or entities, consistent with the purposes here described.

Absent the collection, the Department would be severely constrained from obtaining this information, which would severely impact its ability to evacuate U.S. citizens, LPRs and individuals at risk from Afghanistan, and to process visa applications and inquiries from individuals in Afghanistan or others acting on their behalf. First, were the agency not to utilize the online form to collect and manage this significant amount of information in a structured manner (such as by trying to collect and collate from emails), the agency would be significantly hindered in assisting these individuals efficiently, delaying or even preventing such assistance. Considering the circumstances on the ground in Afghanistan, including an agreement for all U.S. military forces to have withdrawn from the country by August 31, requiring compliance with normal clearance procedures would result in public harm. Second, while the end of the military mission in Afghanistan was anticipated, the rapid fall of the country to the Taliban was not. The agency expected to continue to provide services through normal processes (passport and CRBA and visa issuance) at the Embassy in Kabul. The current circumstances, and their rapid appearance, was unanticipated by the U.S. government. Finally, use of normal clearance procedures would prevent collection of the information in a fashion that is sufficiently structured as to be manageable and actionable in order to support the underlying agency mission to assist the public.

Due to the emergency situation surrounding the evacuation and relocation of individuals from Afghanistan, and the disruption to and subsequent suspension of U.S. Embassy operations in Kabul, a web-based form to collect this information was put in use August 14. The original form and a subsequent iteration have been used extensively already and a third version is pending; all solicit largely the same basic identity and contact information from individuals. Collection is intended to continue until eligible individuals are no longer seeking and requesting assistance.

  1. Is this collection able to be completed electronically (e.g. through a website or application)?

The collection will be completed 100% electronically. The respondent accesses the form at the following link: https://seirmprod.servicenowservices.com/arcs. The Department of State acknowledges that under M-17-06 “Policies for Federal Agency Public Websites and Digital Services,” official public-facing websites are expected to be hosted on a .gov or .mil domain. Due to the urgency with which the Department needed to launch this form, it was unable to ensure it was located on a .gov. To ensure the public can trust that the form is an official government information collection, the Department will provide instructions on www.travel.state.gov that describes the form and its purpose, and directs respondents to the form’s URL. The Department’s seal is also included. The Department may also choose as appropriate to distribute the form’s URL through emails from @state.gov email addresses, or in messaging sent as consular information products (such as mascot messages).

  1. Does this collection duplicate any other collection of information?

This collection will not duplicate any other collection of information.

  1. Describe any impacts on small business.

There is no impact on small business.

  1. What are consequences if this collection is not done?

With the suspension of U.S. Embassy operations in Kabul as of August 31, 2021, the Department lacks direct visibility into populations still in the country with need for consular services or related assistance.  The Department requires an online collection tool that can be readily used by individuals in need specifically in Afghanistan – and those in the United States or elsewhere who are acting on their behalf – to submit requests for assistance that include identity documentation data for individuals and/or family members or others, and that enables the Department to easily sort, direct, respond, track, and measure requests.

There is an ongoing need for this collection in Afghanistan. In addition, the Department thinks it likely that the collection might be used in future operations, in versions adapted to those circumstances.

  1. Are there any special collection circumstances?

No.

  1. Document publication (or intent to publish) a request for public comments in the Federal Register

The Department is requesting emergency approval of this collection. Concurrent to approval, the Department will publish a Federal Register Notice and seek public comment on the collection which may inform future enhancements or modifications to the collection.

  1. Are payments or gifts given to the respondents?

No.

  1. Describe assurances of privacy/confidentiality

All information will be handled in accordance with the Privacy Act (5 U.S.C. § 552a) and the confidentiality provisions of the INA (8 U.S.C. § 1202(f)), as applicable. The form includes a Privacy Act Statement & Consent to Sharing notice for U.S. citizen and LPR respondents, and a Privacy/Confidentiality Notice geared to other respondents.

  1. Are any questions of a sensitive nature asked?

No questions of a sensitive nature are asked.

  1. Describe the hour time burden and the hour cost burden on the respondent needed to complete this collection

The Department anticipates approximately 260,000 respondents will respond to this collection using the version of the form set to be launched on or around October 22, 2021, and reports that approximately 220,000 respondents submitted data on two prior, similar temporary versions of the form (“Repatriation Assistance Request Form”) that became available online via the U.S. Embassy Kabul web site and the travel.state.gov web site as of August 14, 2021.

The form in its latest version takes approximately 15 minutes to complete, resulting in a time burden of 65,000 hours (260,000 x 15 minutes). The prior form versions, which solicited less family member data, took approximately 10 minutes to complete.

For U.S. citizen respondents, the estimated hourly cost burden to respondents is based on $27.07 (mean hourly earnings) based on estimated income per hour from the Bureau of Labor statistics1 x 1.4 (weighted wage OMB multiplier) = $37.90 (weighted hourly wage) x 65,000 (annual hours) = $2,463,370 (hour cost burden). For Afghan respondents, there is no hourly earnings data.


Of the 260,000 estimated respondents to all versions of the form, it is expected that roughly 15% will be U.S. citizens or Lawful Permanent Residents and 85% will be Afghan nationals. Many may hold dual citizenship or be Afghan nationals with LPR status. Respondents include individuals in the United States or elsewhere who are not in need of assistance themselves but are completing the form on behalf of family members or other Afghan individuals they consider at risk.

  1. Describe the monetary burden to respondents (out of pocket costs) needed to complete this collection.

There are no out-of-pocket costs to the respondents.


  1. Describe the cost incurred by the Federal Government to complete this collection.

There will be no new cost to the federal government to set up this collection. The collection instrument is made available through an existing Department platform. The responses will be reviewed by Department employees in the normal course of their duties, including on dedicated task forces pertaining to operations in Afghanistan.

  1. Explain any changes/adjustments to this collection since the previous submission

This is a new information collection.

  1. Specify if the data gathered by this collection will be published.

The information collected pursuant to this collection will not be published.

  1. If applicable, explain the reason(s) for seeking approval to not display the OMB expiration date. Otherwise, write “The Department will display the OMB expiration date.”

The Department will display the OMB expiration date.

  1. Explain any exceptions to the OMB certification statement below. If there are no exceptions, write “The Department is not seeking exceptions to the certification statement”.

The Department is not seeking exceptions to the certification statement.



B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.



1 Source: Bureau of Labor Statistics, “Employer Costs for Employee Compensation May 2020,” https://www.bls.gov/oes/current/oes_nat.htm#00-0000.

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
AuthorCanfield, Danielle P
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File Created2021-10-29

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