**SUPPORTING STATEMENT**

**Freedom of Information/Privacy Act Request**

**(Form G-639)**

**OMB No. 1615-0102**

**A. JUSTIFICATION:**

1.  Title 5 U.S.C. 552 allows requestors to have access to U.S.
    Citizenship and Immigration Service (USCIS) records under the
    Freedom of Information Act, except those that have been exempted by
    the Act. Title 5 U.S.C. 552a, with certain exceptions allows
    individuals to gain access to information pertaining to themselves
    in USCIS records. 8 CFR 103.10 provides procedures for accessing
    USCIS records.

2.  Form G-639 is provided as a convenient means for persons to provide
    data necessary for identification of a particular record desired
    under FOIA/PA. However, requests may be submitted in any written
    form. Form G-639 provides rapid identification of such requests and
    ensures expeditious handling.

3.  The use of this form provides the most efficient means for
    collecting and processing the required data. In this case the USCIS
    does not employ the use of information technology in collecting and
    processing information. However, this form has been designated for
    e-filing under the Business Transformation Project.

4.  A review of the USCIS Forms Inventory Report revealed no duplication
    of efforts. There is no similar information currently available that
    can be used for this purpose.

5.  This collection of information does not have an impact on small
    businesses or other small entities.

6.  This form was created to facilitate an accurate and timely response
    to an information request. If the information is not collected, a
    response to an information request may be unduly delayed.

7.  There are no special circumstances applicable to this information
    collection.

8.  USCIS will address any comments in it's second submission.

9.  USCIS does not provide payments or gifts to respondents in exchange
    for a benefit sought.

10. There is no assurance of confidentiality.

11. There are no questions of a sensitive nature.

12. [Annual Reporting Burden]{.underline}:

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a.  Number of Respondents 100,000

b.  Number of Responses per Respondent 1

c.  Total Annual Responses 100,000

d.  Hours per Response .25

e.  Total Annual Reporting Burden 25,000

##### Annual Reporting Burden

The total annual reporting burden hours are **25,000.** This figure was
derived by multiplying the number of respondents (100,000) x frequency
of response (1) x 15 minutes per response (.25).

13. There are no capital or start-up costs associated with this
    information collection. Any cost burdens to respondents as a result
    of this information collection are identified in Item 14. There are
    no fee charges associated with the collection of this information.

14. **[Annualized Federal Cost Analysis]{.underline}**:

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a.  Printing Cost \$ 18,000

b.  Collection and Processing Cost 4,000,000

c.  Total Cost to Program 4,018,000

d.  Fee Charge 0

e.  Total Cost to Government \$ 4,018,000

## Government Cost

> The estimated cost to the Government is **\$4,018,000**. This figure
> is calculated by using the estimated number of respondents 100,000 x 1
> hour (Time required to collect and process information) x \$40
> (suggested average hourly rate for clerical, officer, and supervisory
> time with benefits). In addition, this figure includes the estimated
> overhead cost for printing, stocking, and distributing the form, which
> is \$18,000.

## Public Cost

> The estimated annual public cost is **\$250,000**. This is based on
> the number of respondents 100,000 x 15 minutes (.25) per response x
> \$10 (Average hourly rate).

15. There has been no increase or decrease in the number of burden hours
    previously reported for this information collection.

16. USCIS does not intend to employ the use of statistics, or the
    publication thereof for this information collection.

17. USCIS will display the expiration date of OMB approval of this
    information collection.

18. USCIS does not request an exception to the certification of this
    information collection.

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B.  **Collection of Information Employing Statistical Methods.**

> Not Applicable.

### Certification and Signature.

#### PAPERWORK CERTIFICATION

> In submitting this request for OMB approval, I certify that the
> requirements of the Privacy Act and OMB directives have been complied
> with including paperwork
>
> regulations, statistical standards or directives, and any other
> information policy directives promulgated under 5 CFR 1320.
>
> \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
> \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Stephen Tarragon Date

Acting Chief,

Regulatory Management Division

U.S. Citizenship and Immigration Services.