Supporting Statement A - Template

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Supporting Statement for Paperwork Reduction Act Submissions

Title: State, Local, Tribal and Private Sector (SLTPS) Clearance Request Form

OMB Control Number:  1670-0013


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.  

CISA collects necessary information through 1670-0013 to facilitate security clearances needed for sharing classified information with the vetted SLTPS Stakeholders. The U.S. Government is authorized to ask for this information under sections 2202 and 2212 of the Homeland Security Act (Pub. L. 107-296, 6 U.S.C. 652, 662), and Executive Orders 12968, 13526, 13549, 13636, and 13691 which authorize the collection of this information. 

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. 

Partnerships between the U.S. Government and the state, local tribal and private sector at times necessitate the sharing of classified information. The State, Local, Tribal and Private Sector (SLTPS) Clearance Request Form facilitates this sharing by sponsoring security clearances for certain members of each sector based on either their membership on a Sector Coordinating Council (SCC)/association or their infrastructure protection job-related duties and their need-to-know. The SLTPS is designed to sponsor security clearances for state, local, tribal and private sector officials involved in the infrastructure protection mission. These partners are subject matter experts within specific industries and have specialized knowledge not available within the Department of Homeland Security (DHS) and other Federal Departments or Agencies. 

This is an extension request for an existing information collection. There are no substantive changes to the collection instrument.

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. Please include a statement that usability testing was conducted and what the results from testing did for the collection.	

Once submitted to the CISA Office of the Chief Security Officer (OCSO) the SLTPS Administrator will request the Personally Identifiable Information (PII) and a record is created into the Integrated Security Management System (ISMS).  The Security Specialist will initiate an eApplication (eAPP), the Defense Counterintelligence and Security Agency secure portal for investigation processing.  Once the data is entered into e-App, the nominee is provided a password and can access the system and complete the online security questionnaire.  
This information is only available to Security Specialists within OCSO working on the program and is maintained in ISMS, which is “owned” by the OCSO. The two-part PII request process helps minimize the collection of sensitive PII for only those nominees who meet the threshold and are sponsored by CISA. Historical data and information was used to conduct the usability testing on this information collection. No significant changes have been made due to the review. 

4.  Describe efforts to identify duplication.   Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above. 

All applicants are placed in ISMS and can be identified by their full name, and or social security number. The system will not allow duplicate records to be input into the system. 

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. 

The collection of information provides Stakeholders the path to collaborate with the federal government, FBI, and other law enforcement offices to safeguard their small businesses and operations from cybersecurity threats. 

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. 

The private sector owns over 85% of the critical infrastructure. If Stakeholders are not cleared, they will not be able to crosstalk, collaborate and share classified information with federal entities. This will place critical infrastructure at risk of cyber and other threats that federal entities may only be privy to.  


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.


The federal nominator is required to complete this form once for the nominee to be approved for participation in the program. It is also used when a Periodic Reinvestigations are due, Company Changes, Reinstatements, Upgrades/Downgrades and Reciprocities.  


    (b) Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

Respondents are not required to send a written response regarding this collection.

    (c) Requiring respondents to submit more than an original and two copies of any document.

Federal nominators are not required to submit more than one copy via the tracking system.


    (d) Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years.

The form does not require individuals to retain the record for any specific length of time..


    (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.

This collection does not utilize statistical analysis.

    (f) Requiring the use of a statistical data classification that has not been reviewed and approved by OMB.

This collection does not utilize statistical analysis.


    (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.

This form does not include a pledge of confidentiality that is not supported by established authority in Section 201 of the Homeland Security Act (Pub. L 107-296, 6 U.S.C. § 121), and Executive Orders 12968, 13526, and 13549.

    (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.

No proprietary or trade information is requested from the individuals.
8.  Federal Register Notice: 
a.   Provide a copy and identify the date and page number of the 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
Volume #
Number #
Page #
Comments Addressed
60-Day Federal Register Notice:
September 10, 2026
91
174
57645-57646
0
30-Day Federal Register Notice







A 60-day notice for comments was published in the Federal Register on 9/10/2026. 0 comments were received related to the 60-day notice.

A 30-day notice for comments was published in the Federal Register on .  0 comments were received related to the 30-day notice. 

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

No gifts or payments of any kind will be provided to the respondents of this information collection.
10.  Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.  

	This form does not include a pledge of confidentiality that is not supported by established authority in statute or regulation. 


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 sensitive nature on DHS Form 9014.
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.

CISA estimates that approximately 550 stakeholders will be nominated for a clearance annually.    Since the nominee is not directly completing the form, but providing information to the Federal nominator, it is estimated that it will take an average of 10 minutes per response.   The stakeholders consisted of private sector owners, operators, and industry representatives.   

To estimate the cost of this collection, CISA uses the mean hourly wage of computer and information systems managers of $88.391.  CISA then applies a load factor of 1.4582962 to this average wage to obtain a fully loaded average hourly wage of $128.90.  For an estimated 550 respondents, the burden is 91.67 hours at a rate of $128.90 per hour. The cost burden of the total annual burden hours associated with the existing elements of this information collection equals $11,816.  The table below shows the annual hour and cost burden.



Form 
Name & Number
Number of Respondents
Number of Responses per Respondent
Average Burden per Response (in hours)
Total Annual Burden (in hours)
Loaded
Average Hourly Wage Rate
Total Annual Respondent Cost
Private Sector Clearance Request Form
( DHS Form 9014)


550
1
0.1667 (10 minutes)
91.67
$128.90
$11,816


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 is no recordkeeping, capital startup or maintenance cost burden to the respondent associated with this information collection.       

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.  

To estimate the cost to the Federal Government, CISA assumes that the equivalent of 1.5 FTE at the GS 13, Step 6 pay grade would review the submissions. The fully loaded wage for a GS 13 Step 6 is calculated by multiplying the hourly wage of $68.083 by the load factor of 1.679.4 To estimate the cost, CISA multiplies the fully loaded wage of $114.32 by a total of 3,130.5 hours (2,087 FTE hours x 1.5), for a total Federal cost of $357,879.

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. 


Program changes require a revision of the existing collection.  The changes include updates to the form itself.  The changes do not cause any additional burden to the public as the changes are for clarification and modification of choices. The burden increased from the previous collection, from $10,070 to $11,816 due to increased wages.


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. 

This information collection will not be published for statistical purposes. 

17.  If seeking approval to not display the expiration date for OMB approval of the information collection, explain reasons that display would be inappropriate.

CISA is not seeking this exemption.

18.  Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

There are no exceptions to the certification statements identified for this collection.