01-11-24-1652-0021 FltTrngSec SS_clean May1

INFORMATION COLLECTION SUPPORTING STATEMENT

Flight Training Security Program

OMB Control Number 1652-0021

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).

In response to the terrorist attacks of September 11, 2001, and intelligence information subsequently gathered regarding the individuals who perpetrated those attacks, Congress passed legislation to prevent aviation training providers from providing flight training to individuals who may pose a threat to aviation or national security. See 49 U.S.C. 44939, as amended by sec. 612 of the Vision 100—Century of Aviation Reauthorization Act (Pub. L. 108-176; Dec. 12, 2003). Section 44939 (1) specifies various categories of identifying information required from non-U.S. citizens and non-U.S. nationals (candidates) training in the operation of aircraft; (2) authorizes assessment of a fee for the security threat assessment (STA); (3) specifies identity verification for U.S. citizens; and (4) requires flight training providers to conduct a security awareness program for employees and contract employees to increase their awareness of suspicious circumstances and activities of individuals enrolling in or attending flight training. If it is determined that the candidate presents a threat to aviation or national security, the statute requires DHS/TSA to notify the flight training provider and that person is required to immediately terminate the training.

TSA issued an interim final rule (IFR) implementing these requirements in 2004¹ and is finalizing the rule in 2024. In summary, the final rule changes the STA from an event-based STA to a time-based STA, reduces the frequency of training notifications to TSA, permits electronic storage, and requires the identification of a security coordinator. As described more fully below, this regulation requires the collection of information to implement the regulatory requirements. Accordingly, TSA is revising this information collection request (ICR).

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.

Changes to the collection as a result of the final rule:

TSA is revising this information collection request (ICR)² to reflect revisions to the FTSP program as a result of the final rule. As discussed in more detail below, TSA is making three primary types of changes to the requirements. First, TSA will change the frequency in which candidates apply for STAs from an event-based STA, each time a candidate applies for flight training, to a time-based STA, which may be valid for up to five years. These changes will result in monetary and time savings as candidates will not need to pay an STA fee for each flight training request. Furthermore, candidates will no longer need to provide notification to TSA for each flight training event. These changes will reduce the total hour burden and total costs of this ICR. Second, under the revised program, TSA will allow for records that were previously only allowed to be stored in hard copy to be stored electronically, creating further cost savings from reduced physical storage costs. Finally, the revised program adds a new collection activity that requires each provider to submit the name and contact information for each security coordinator. This new requirement for a security coordinator supports communications with TSA concerning intelligence information, security-related activities, and incident or threat response with appropriate law enforcement and emergency response agencies.

Current collection (which will remain under this ICR):

The information under the current ICR that will remain a requirement is that candidates are required to provide TSA with biographical information and fingerprints when they apply for a security threat assessment (STA).³ A “candidate,”⁴ is any individual who applies for an STA to participate in flight training who is neither a U.S citizen nor a U.S. national. Individuals endorsed by the U.S. Department of Defense to participate in commercial flight training are not considered “candidates.”⁵

TSA is revising this information collection request (ICR)⁶ to reflect revisions to the FTSP program as a result of the final rule. As discussed in more detail below, TSA is making three primary types of changes to the requirements. First, TSA will change the frequency in which candidates apply for STAs from an event-based STA, each time a candidate applies for flight training, to a time-based STA, which may be valid for up to five years. These changes will result in monetary and time savings as candidates will not need to pay an STA fee for each flight training request. Furthermore, candidates will no longer need to provide notification to TSA for each flight training event. These changes will reduce the total hour burden and total costs of this ICR. Second, under the revised program, TSA will allow for records that were previously only allowed to be stored in hard copy to be stored electronically, creating further cost savings from reduced physical storage costs. Finally, the revised program adds a new collection activity that requires each provider to submit the name and contact information for each security coordinator. This new requirement for a security coordinator supports communications with TSA concerning intelligence information, security-related activities, and incident or threat response with appropriate law enforcement and emergency response agencies.

TSA conducts an STA on all candidates requesting participation in specific training events. The candidates submit their biographic information at https://fts.tsa.dhs.gov/home. Candidates must also provide supporting documentation to enable a flight training provider to initiate training event notifications advancing a candidate’s skill or for candidates to enable benefits, such as expedited processing or a reduced fee.

The process for the STA is the same for each candidate. Under 49 CFR part 1552, candidates applying for an STA are required to provide fingerprints to TSA for a Criminal History Records Check. In general, a candidate must provide fingerprints to TSA only once as the FTSP stores those fingerprints for subsequent STA submissions to reduce the burden on the candidate. However, there may be rare occurrences when the FTSP will require a candidate to submit new fingerprints (for example, the digital fingerprint file is corrupted). Any candidate who has submitted fingerprints to the FTSP is subject to recurrent criminal history vetting.

As discussed above, to facilitate information collection, candidates submit information directly to TSA via an online portal. TSA uses this information to perform STAs to determine if the candidate poses a threat to aviation or national security. TSA also uses the portal for flight training providers to create training notifications to TSA.

Flight training providers create training notifications for a candidate and are required to:

• Estimate start and completion training dates

• Identify what rating(s) is planned for training

• Upload a photograph of the candidate upon arrival for flight training

• Submit actual start, completion, and/or abandonment training dates

Flight training providers must retain records of the initial and recurrent security awareness training provided to employees, contracted employees, and security coordinators for at least five years. Providers need only retain security awareness training records for one year after that person is no longer employed by the provider. These requirements also apply to certificated flight instructors (CFIs), who also would be required to comply with this part, regardless of whether they are providing flight instruction to non-U.S. citizens and non-U.S. nationals. See, e.g., Federal Aviation Administration Safety Team Notice dated April 20, 2020, available at https://www.faasafety.gov/spans/noticeView.aspx?nid=10089.

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.]

As required by the Government Paperwork Elimination Act (GPEA), as well as by program design, all applicant data is submitted and tracked electronically via an online portal. To the extent practicable, flight training providers may electronically store records associated with this collection.

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.

In order to ensure relevant, timely and accurate information to conduct an STA, there is no other way to collect the needed information from first-time applicants other than directly by the first-time applicant; and, to the extent possible, the information is retained so as not to duplicate the collection for subsequent STAs. After an applicant submits an initial application, that information is retained by the system for use in conducting future STAs to limit the amount of information the candidate has to re-enter. Flight training providers also retain records of the initial and recurrent security awareness training provided to staff, and for one year after that person is no longer employed by the flight training provider, so that TSA may inspect those records.

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.

The information collected is consistent with the statutory requirements and there is no significant burden to small businesses or other small entities. Furthermore, in general, the revisions to this collection reflect the revised requirements of the FTSP program which reduce the overall hour burdens for flight training candidates and flight training providers.

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 the collection of information is reduced or eliminated, TSA would not be able to fulfill its Congressional mandate to prevent non-U.S. citizens and non-U.S. nationals who pose an aviation or national security threat from obtaining flight training.

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).

No special circumstances exist.

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.

To minimize the time and cost burden without compromising security, TSA consulted with aviation community stakeholders, as well as with the Department of Justice (the agency from which program responsibility was transferred in 2004) during development of the regulation to ensure no more information than is necessary is collected from each respondent.

Additionally, the final rule addresses all public comments received on the IFR, both through the initial comment period in 2004 and a reopened comment period in 2018. TSA also addressed recommendations the agency received from regulated persons, other federal organizations, and advisory committees. Finally, TSA eliminated more than a decade of previously issued clarifications and interpretations, either by addressing them in the preamble or through changes to the regulatory text. The final rule was published May 1, 2024 (89 FR 35580).

Where possible, TSA modifiedthe program to make it more effective and less burdensome. The modifications in this ICR are consistent with multiple recommendations from industry for TSA to establish an FTSP Portal with electronic storage capabilities for provider accounts, to reduce storage costs and time burdens.

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

TSA does not provide payments or gifts to respondents.

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

TSA does not provide any assurance of confidentiality to the respondents; however, all information is handled in accordance with the Privacy Act of 1974. The applicable TSA system of records notice (SORN) is DHS/TSA-002, Transportation Security Threat Assessment System, last published in the Federal Register on August 11, 2014 (79 FR 46862). Also, a Privacy Impact Assessment (PIA), DHS/TSA/PIA-026-Alien Flight Student Program, was published on July 28, 2014, on www.dhs.gov.

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 is not posing questions of sensitive nature.

12. Provide estimates of hour and cost burden of the collection of information.

There are two categories of respondents: flight training candidates (non-U.S. citizens) and flight training providers. TSA estimates there would be a total of 82,013 respondents over the three-year period, including 58,069 flight training candidates and 23,944 flight training providers.⁷ This equates to approximately 27,338 total respondents annually; including approximately 19,356 flight training candidates and approximately 7,981 flight training providers.

Flight Training Candidates’ Burden

Each flight training candidate (non-U.S. citizens) will submit an application for a new STA, which may be valid for up to five years. For each training event, the provider will continue to submit details about their training event to TSA; however, a new STA will not be required so long that the training event takes places within the five-year validity period of the STA. Furthermore, for subsequent training event notifications, candidate will also not need to provide updated biographical and biometric information each time they apply for flight training.

TSA estimates the average annual number of STA requests for candidates with a new or renewing STA to be 19,356. TSA estimates it takes 45 minutes (0.75 hours) per application associated with a new or renewing STA. TSA calculates a $41.51 weighted compensation rate for flight training candidates using commercial pilots (SOC 532012), and the number of employees and tenth percentile of salary distribution in Nonscheduled Air Transportation (NAICS 481200), Scenic and Sightseeing Transportation, Other (NAICS 487900), and Support Activities for Air Transportation (NAICS 488100). TSA uses the tenth percentile value as candidates training to become certificated pilots are at the beginning of their careers.⁸ TSA multiplies the number of training requests by the hourly burden per training request associated with new or renewing STAs and the candidates’ compensation rate to calculate the annual hour burden cost.

Next, TSA estimates the average annual number of training event notifications for candidates with an existing STA to be 25,922. TSA estimates that applications with an existing STA will take 10 minutes less as flight training candidates will not need to resubmit biographic and biometric information, for a total of 35 minutes (0.58 hours) per training request. TSA multiplies the number of applications by the hourly time burden per training request associated with existing STAs and the candidates’ compensation rate to calculate the annual hour burden cost.

Lastly, TSA adds the annual hour burden cost for training events associated with new or renewing STAs and the annual hour burden cost for training events associated with existing STAs to calculate the total annual cost burden to flight training candidates. TSA summarizes this burden to candidates in Table 1.

Table 1. Hour Burden Cost to Flight Training Candidates
Collection Activity	Responses			Number of Annual Responses	Hour Burden Per Response	Total Hour Burden	Total Annual Hour Burden Cost
	Year 1	Year 2	Year 3	a	b	c = a × b	d = c × $41.51
Applications (with new or renewing STA)	30,847	13,611	13,611	19,356	0.75	14,517	$602,547
Training event notifications (with existing STA)	14,329	31,643	31,794	25,922	0.58	15,121	$627,611
Total				45,278		29,638	$1,230,158

Flight Training Providers’ Burden

Flight training providers must retain candidate training records, employee security awareness training records, as well as provide names and contact information for security coordinators.

All information for each candidate flight training event will be directly entered into the FTSP portal, thus eliminating the need to maintain separate candidate training event records.

For employee security awareness training records, TSA estimates it would take all flight training providers 1 minute (0.0167 hours) to electronically file their employee security awareness training records. For CFI and flying club providers, TSA uses a commercial pilot compensation rate of $61.27 for administrative tasks as TSA assumes these entities do not have dedicated staff for these tasks as larger entities would. TSA calculates the $61.27 employee compensation rate using a weighted average of three educational occupational categories related to flight training from BLS: commercial pilots (SOC 532012) in Educational Services – Privately Owned (NAICS 611005), Colleges, Universities, and Professional Schools (NAICS 611300), and Technical and Trade Schools (NAICS 611500).⁹ For large providers, TSA uses the mean wage rate for information and record clerks in Non-Scheduled Air Transportation (NAICS 481200).¹⁰ TSA leverages the $30.62 recordkeeping compensation rate to calculate the total hour burden for providers to retain security awareness records.

Next, TSA estimates that it would take 15 minutes (0.2500 hours) for providers to provide TSA with the names, titles, and contact information for all designated security coordinators. TSA uses the $61.27 compensation rate for CFI and flying club providers. For large providers, TSA uses the annual mean salary for commercial pilots (SOC 532012) in the Management of Companies and Enterprises (NAICS 551100). TSA leverages the $95.94 compensation rate for large providers to calculate the total hour burden for large providers to designate security coordinators.¹¹

Table 2 summarizes these burdens.

Table 2. Hour Burden Cost to Flight Training Providers

Collection		Responses			Number of Annual Responses	Hour Burden Per Response	Total Hour Burden	Compensation Rate	Total Annual Hour Burden Cost
		Year 1	Year 2	Year 3
					a	b		c	d = a × b × c
Security Coordinator Submission	CFI and Clubs	30,975	3,994	4,100	13,023	0.2500	3,256	$61.27	$199,463
	Large	1,122	126	125	458		115	$95.94	$10,981
Recordkeeping of Security Awareness Training	CFI and Clubs	41,378	5,435	38,742	28,518	0.0167	476	$61.27	$29,120
	Large	9,624	1,333	8,957	6,638		111	$30.62	$3,387
Total					48,637		3,958		$242,952

TSA sums the hour burdens for both flight training candidates (Table 1) and flight training providers (Table 2) to estimate a total annual hour burden of 33,594 hours (100,783 hours over three years) and annual cost of 1,473,110 ($4,419,329 over three years).

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information.

Non-U.S. citizen flight training candidates are required to pay an application fee of $140.00 to cover the cost of their STA, which may be valid up to five-years. TSA also designates a reduced fee of $125 for flight training candidates who hold a comparable STA issued by another DHS or TSA vetting program.¹² TSA estimates the annual cost burden for fees to be $2,706,212 ($8,118,637 over the three-year period). Table 3 summarizes these calculations.

Table 3. Fees and Other Annualized Costs
Activity	Annual Number of Instances	Fee	Annual Cost
	a	b	c = a x b
Standard (Regular Processing) STA Fee	19,112	$140.00	$2,675,630
Reduced STA Fee (for eligible candidates)	245	$125.00	$30,582
Total	19,356		$2,706,212

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.

The Fees associated with obtaining an STA represent the costs to TSA for providing all vetting-related services. Under 6 U.S.C. 469, TSA is required to recover the cost of vetting services rendered through the collection of user fees. The vetting fees identified fulfill this statutory obligation. TSA has published a Fee Development Report which provides an overview of the information and methodological approach TSA used to develop the fees.

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

TSA is revising this information collection request (ICR)¹³ to reflect revisions to the FTSP program as a result of the final rule. As discussed in more detail below, TSA is making three primary types of changes to the requirements. First, TSA will change the frequency in which candidates apply for STAs from an event-based STA, each time a candidate applies for flight training, to a time-based STA, which may be valid for up to five years. These changes will result in monetary and time savings as candidates will not need to pay an STA fee for each flight training request. Furthermore, candidates will no longer need to provide notification to TSA for each flight training event. These changes will reduce the total hour burden and total costs of this ICR. Second, under the revised program, TSA will allow for records that were previously only allowed to be stored in hard copy to be stored electronically, creating further cost savings from reduced physical storage costs. Finally, the revised program adds a new collection activity that requires each provider to submit the name and contact information for each security coordinator. This new requirement for a security coordinator supports communications with TSA concerning intelligence information, security-related activities, and incident or threat response with appropriate law enforcement and emergency response agencies.

First, the FTSP program change from event-based STAs to time-based STAs reduces the number of candidate STAs required, but does not reduce the number training event notifications (subsequent applications). Previously, a candidate had to undergo an STA for each flight training request. Under the new requirements, candidates undergo an STA, which may be valid for five years after submitting an initial flight training request.

Under the event-based structure, candidates participating in Category 1-3 training events would pay a $130 STA fee, per event, whereas candidates participating in Category 4 training events would pay a $70 STA fee, per event. Under the time-based structure, each candidate would undergo an STA, valid up to five years, which means even if a candidate participates in more than one training event, they would only need to pay one STA fee. Furthermore, training event notifications following applications with a new or renewal STA experience a 10-minute reduction in burden from not having to resubmit biographical information. TSA estimates a 45 minute (0.75 hours) time burden for applications with new and renewal STAs (five-years after the initial STA) and a 35 minute (0.58 hours) time burden for training event notifications.¹⁴

Second, as part of the changes to the FTSP program, flight training providers will no longer be required to retain physical records. Rather, providers will use expanded features that will be made available on the FTSP portal to retain records electronically. Subsequently, flight training providers will no longer incur costs for printer paper and toner for employee or candidate records. Employee security awareness training recordkeeping burden will also be reduced from five minutes to one (1) minute due to maintenance of the records electronically. For candidate flight training events, information for each event will be directly entered into the FTSP portal, thus eliminate the need to maintain separate candidate training event records.

Third, the revised FTSP program adds a new collection activity that requires each provider to submit the name and contact information of each security coordinator. This new requirement helps bolster communication between providers and TSA in matters of security-related activities and incident and threat responses. TSA estimates that it will take each provider 15 minutes (0.25 hours) to provide TSA with the names, titles, and contact information for all designated security coordinators.

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 does 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.

1 69 FR 56324 (Sept. 20, 2004) codified at 49 CFR part 1552.

2 OMB Control No. 1652-0021.

3 49 CFR part 1552.31(b)(1).

4 49 CFR part 1552.3.

5 49 CFR part 1552.7(a)(2).

6 OMB Control No. 1652-0021.

7 For the providers, TSA estimates there are approximately 4,206 providers who provide flight training to non-U.S. citizens, U.S. citizens, and U.S. nationals. The remaining 17,364 providers exclusively train U.S. citizens and U.S. nationals.

8 $41.51 flight training candidate compensation rate = $27.74 unloaded wage for candidates × 1.496 compensation factor. 

$57,692 annual candidate wage = $58,520 annual 10th percentile wage for non-scheduled air transportation × 19,600 non-scheduled air transportation employees) + ($42,630 annual 10th percentile wage for scenic and sightseeing transportation, other × 500 scenic and sightseeing transportation, other employees) + ($55,890 annual 10th percentile wage for support activities for air transportation × 4,820 support activities for air transportation employees) ÷ (19,600 + 500 + 4,820 employees). TSA uses the tenth percentile to reflect newer pilots and experienced for recurrent training, Bureau of Labor Statistics. Occupational Employment and Wage Statistics Query System. Last modified May 2022. (Accessed on October 25, 2023).

$27.74 unloaded wage rate for candidates = $57,692 annual candidate wage ÷ 2,080 annual working hours.

BLS. News Release, Employer Costs for Employee Compensation - Table 5. Employer costs per hour worked for employee compensation and costs as a percent of total compensation, production, transportation, and material moving. Note that this compensation factor corresponds to the average load factor for a civilian employee working in Production, Transportation and Material Moving occupational group published for March 2022, June 2022, September 2022, and December 2022 quarters. Accessed on October 25, 2023.

https://www.bls.gov/news.release/archives/ecec_06162022.pdf (March 2022),

https://www.bls.gov/news.release/archives/ecec_09202022.pdf (June 2022),

https://www.bls.gov/news.release/archives/ecec_12152022.pdf (September 2022),

https://www.bls.gov/news.release/archives/ecec_03172023.pdf (December 2022).

1.496 = (($38.70 + $37.26 + $37.68 + $36.54) ÷ 4) ÷ (($25.83 + $24.99 + $25.12 + $24.42) ÷ 4).

9 $61.27 CFI and club provider employee compensation rate = $40.94 Unloaded Hourly Wage Rate × 1.496 Compensation Factor.

$85,160 annual employee wage = ((($85,290 educational services – privately owned annual mean wage × 4,020 educational services – privately owned employees) + ($65,370 colleges, universities, and professional school annual mean wage × 630 college, universities, and professional school employees) + ($88,450 technical and trade schools annual mean wage × 3,630 technical and trade school employees) ÷ (4,020 + 630 + 3,630 employees).

$40.94 unloaded wage rate for CFI and flying club employees = $85,160 annual employee wage ÷ 2,080 annual working hours. Bureau of Labor Statistics. May 2022, Occupational Employment and Wage Statistics Query System. Retrieved Oct. 25, 2023.

10 $30.62 Large Provider Administrative Compensation Rate = $20.46 Unloaded Hourly Wage Rate × 1.496 Compensation Factor.

Bureau of Labor Statistics. May 2022. Mean wage rate for NAICS 481200 - Non-Scheduled Air Transportation. Occupation Code 43-4000, Information and Record Clerks. https://www.bls.gov/oes/2022/may/naics4_481200.htm#43-4000. Retrieved Oct. 25, 2023. See footnote 7 for how the compensation factor is calculated.

11 $95.94 large provider compensation rate = $64.11 unloaded hourly wage rate × 1.496 Compensation Factor.

$64.11 unloaded hourly wage rate = $133,350 annual wage for managers ÷ 2,080 working hours.

Bureau of Labor Statistics. May 2022. Occupational Employment and Wage Statistics Query System. To use the query system: 1) under “select a search type”, select “one occupation for multiple industries; 2) under “select one occupation”, scroll down to “commercial pilots” (SOC 532012); 3) under “select one or more industry sectors”, scroll down to “Sector 55 – Management of Companies and Enterprises”; 4) under “select one or more industries”, select “Management of Companies and Enterprises” (NAICS 551100); and 5) under “select one or more datatypes”, select “annual mean wage”. Managers are assumed to be pilots. Retrieved Oct. 25, 2023.

12 See CFR § 1552.37. TSA will post a list of acceptable comparable STAs on the FTSP portal for reduced fee eligibility.

13 OMB Control No. 1652-0021.

14 10 Minute Reduction = 45 Minutes – 35 Minutes.