Justification for OMB 1140-0019 (ATF Form 8_ 5310.11) 2023.07_508

Department of Justice
Bureau of Alcohol, Tobacco, Firearms and Explosives
Supporting Statement
Information Collection Request
OMB 1140-0019
Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
A. Justification:
1. Title 18 of the United States Code, Chapter 44 (18 U.S.C. Chapter 44) provides that no
person may engage in the business of importing, manufacturing, or dealing in either
firearms, or ammunition, without first obtaining a license to do so. These activities are
licensed for a specific period. The benefit of a collector’s license is also provided for in
the statute. In order to continue to engage in the afore mentioned firearms activities
without interruption, licensees must renew their Federal Firearms License (FFL) by filing
Federal Firearms License (FFL) RENEWAL Application -ATF Form 8 (5310.11) Part II,
prior to its expiration.
2. The information collected on the Federal Firearms License (FFL) RENEWAL

Application -ATF Form 8 (5310.11) Part II, is used to identify the applicant and
determine their eligibility to retain the license. The renewal form is filed by the licensee,
so they can continue to engage in firearms activities. As long as 18 U.S.C. 923 requires
that a person wishing to engage in the firearms business or the collection of curios and
relics firearms pays a fee and file an application, this form or one like it will be
necessary. Without the information provided by applicant on the renewal form, ATF
might renew the FFL for a person who is prohibited by law from engaging in firearms
business activity or collection.

3. The Federal Firearms License (FFL) Renewal Application -ATF Form 8 (5310.11) Part II
is issued by the ATF’s Federal Firearms Licensing Center (FFLC) in Martinsburg, West
Virginia. The form is unavailable on the ATF website because it is electronically
generated from ATF’s FFL database, approximately 90 days prior to the expiration of an
existing FFL license. The form is pre-populated with data related to the expiring license,
including the appropriate renewal fee. The pre-populated data reduces the respondent
burden and processing delays, while increasing the accuracy of form completion. Once
generated, the partially pre-filled form is distributed to respondents for completion of the
remaining applicable fields, signature, and submission of payment for processing. All
completed forms must be accompanied by payment via check, money order, or
credit/debit card for processing. Electronic or online payment options to renew an FFL is
currently unavailable.
4. ATF uses a uniform subject classification system to identify duplication and to ensure
that any similar information already available cannot be used or modified for use for the

purpose of this information collection.
5. This collection of information has no significant impact on small businesses or other
small entities.
6. Less frequent use of this information collection would pose a threat to public safety, since
the collected information helps ATF to ensure that the applicant remains eligible for an
FFL Renewal.
7. This information collection is conducted in a manner consistent with 5 C.F.R. § 1320.6.
8. Both a 60-day and 30-day notice will be published in the Federal Register to solicit
public comments.
9. No decision of payment or gift is associated with this collection.
10. In accordance with the System of Records Notice (SORN) Justice/ATF-008 Regulatory
Enforcement Record System FR Vol. 68 No. 16 3558, dated January 24, 2003, physical
records for this IC are filed and stored in cabinets located in rooms that are locked during
non-duty hours. Records are also stored in electronic form and are password protected.
Direct access to these records is limited to specific Department of Justice personnel during
the performance of official duties. Records may also be transmitted to routine users and
others on a need-to-know basis and upon validation of the nature of their request. Disclosure
of ATF Form 8(5310.11) Part II is governed by 26 U.S.C. § 6103, as well as the Privacy Act
of 1974, 5 U.S.C. 552a, and the Freedom of Information Act, 5 U.S.C.§552. Any personally
identifiable information (PII) collected in conjunction with this IC will not be disclosed,
except as provided by the Privacy and Freedom of Information Acts.
11. Questions of a sensitive nature are asked on the application to determine the continued
eligibility of the applicant to renew an FFL.
12. There are approximately 33,500 respondents for this application collection. Each
respondent will complete this form once every three (3) years. The average number of
annual responses to this IC is 33,500. The total time to complete the form is 30 minutes.
Therefore, the total annual burden hours are 16,750.
13. There is no annualized capital/startup cost associated with this collection. However, the
annual cost has increased due to a change in the postal rate from $0.55 during the last
renewal in 2019, to $0.63 in 2023. Consequently, the new public cost burden will be
reported as $21,105.00, which is equal to $0.63 (mailing cost per respondent) * 33,500 (#
of respondents).

14. Estimates of annual costs to the Federal Government are as follows:
Direct Labor $ 1,742.88 (GS9-6 hourly rate x 48 hours)
Printing
$ 2,190.90 ($.0094 per imprint x 134,000 imprints {33,500 x 4 imprints}
+ $.0139 per sheet of paper x 67,000 {33,500 x 2 pages})
Postal Costs $ 20,100.00 ($0.60 metered postage x 33,500 envelopes)
Total
$ 24,033.78
15. The adjustments associated with this information collection include a slight decrease in
the average total respondents and responses from 34,000 per year to 33,500 per year,
since the last renewal in 2019. Therefore, the total annual burden hours decreased by 250
hours.
16. The results of this collection will not be published.
17. ATF requests authorization to exclude the IC expiration date from the printed ATF Form
5310.11. This is because printing the expiration date on the form will incur higher
printing costs to replace inventories that become obsolete when this IC is issued a new
expiration date. All FFLs must utilize this form annually, so ATF must maintain a
substantial inventory of this IC instrument. Therefore, omitting the expiration date will
ensure that inventories can be quickly replenished, and forms can be made available for
public use, as often as needed.
18. There are no exceptions to the certification statement.
B. Collections of Information Employing Statistical Methods
This collection does not involve statistical methods.