1405-0129_PRA Supporting Statement

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION

Statement of Consent: U.S. Passport Issuance to a Child
OMB No. 1405-0129
Form DS-3053

A. JUSTIFICATION

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

The Statement of Consent: U.S. Passport Issuance to a Child (DS-3053) is used in conjunction with the Application for a U.S. Passport (DS-11). This form is used when both legal parents and/or legal guardian(s) of a child under age 16 cannot be present at the time the application is executed. The non-applying legal parent or legal guardian completes the form to give their statutorily required consent to the issuance of a passport to the child. For children 16 to 17 years old, the form can satisfy one legal parent/legal guardian consent for passport applicants 16 or 17 years of age.

The DS-3053 form assists the Department of State to administer the regulations in 22 C.F.R. 51.28 requiring that parents and/or any guardian consent to the issuance of a passport to a child under the age of 16, unless certain exceptions apply. This regulation was drafted to implement Section 236 of the Admiral James W. Nance and Meg Donovan Foreign Relations authorization Act, Fiscal Year 2000 and 2001 (enacted by Public Law 106-113, Div. B, Section 1000 (a)(7)), and helps to prevent international parental child abduction, as well as child trafficking and other forms of passport fraud.

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

Form DS-3053 is used by the Department to assist in determining that legal parents and/or legal guardian(s) have given consent to the issuance of a U.S. passport to a child.

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

The DS-3053 is intended to be submitted with the DS-11, which cannot be submitted electronically. If a DS-11 is submitted without the required two-parent consent, the DS-3053 can be mailed in response to an Information Request Letter (IRL). As required by 22 C.F.R. Part 51, all DS-11 applicants must appear in person for the execution of a passport.  In addition, the DS-3053 requires a notarization statement and notary signature, as well as a non-applying parent or legal guardian’s signature in the presence of the notary public. The DS-3053 is on the Department’s website, www.travel.state.gov, and can be filled out online and printed for manual signature, notarization, and submission.

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

Aside from necessary basic self-identification data, the information requested does not duplicate information otherwise available.

5. Describe any impacts on small business.

The DS-3053 does not involve small businesses or other small entities.

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

If consent is not established when required, the child may not receive a U.S. passport. The statement of consent may be submitted in other formats provided they meet statutory and regulatory requirements. Use of the DS-3053 is not mandatory.

7. Are there any special collection circumstances?

No such special circumstances exist.

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

The Department of State published a 60-day notice in the Federal Register to solicit public comments on October 20, 2022. (Public Notice: 11299; NPRM AF10). Two comments were received from the public and did not express opposition.

9. Are payments or gifts given to the respondents?

This information collection does not provide any payment or gift to respondents.

10. Describe assurances of privacy/confidentiality

This form includes a Privacy Act Statement explaining the routine uses of the information collected under the Act. No assurances of confidentiality are provided to respondents.

11. Are any questions of a sensitive nature asked?

The DS-3053 does not ask questions of a sensitive nature.

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

Hour time burden:

For FY23-25, the projected average annual number of respondents for Form DS-11 is 12,055,600. Through a Department-led time and motion study, it was determined that Form DS-3053 is attached to 3.01% of Form DS-11 receipts. The projected number of annual respondents is 362,900.

Passport Services estimates that the average time required for this information collection is 20 minutes per response. The estimated total annual respondent hour time burden is 121,000 hours.

(362,900 annual respondents x 20 minutes / 60 = 121,000 hours per year)

The sampling was completed through consultation with a small group of employees of the Department’s Bureau of Consular Affairs to validate the time.

Hour cost burden:

The estimated cost to respondents is based on the civilian hourly wage from the Bureau of Labor Statistics website multiplied by the annual hour time burden. The wage is estimated to be $28.01. The Department used the Employer Costs for Employee Compensation released by the Bureau of Labor Statistics in 2021.ⁱ The estimated total annual respondent hour cost burden is $3,389,200.

(121,000 annual hours x $28.01 civilian hourly wage = $3,389,200)

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

There is no application fee associated with this collection. Form DS-3053 is submitted in conjunction with form DS-11, Application for a U.S. Passport. However, because the form must be notarized, respondents may be required to pay a notarization fee. The national average cost to have a document notarized is $7.70.ⁱⁱ The Department of State does not track where DS-3053 forms are executed, so it is not possible to calculate the percentage of respondents who incur a notarization fee.

The estimated total annual respondent monetary burden is: $2,794,300.

(362,900 annual respondents x $7.70 notarization fee = $2,794,300)

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

Adjudication cost:

To calculate the cost to the federal government, we consider the hourly wage for an FY23 domestic Civil Service GS-11 step 10 (the highest level of a passport adjudicator) of $36.95ⁱⁱⁱ with a weighted wage rate multiplier:

$36.95 x 2 = $73.90

As suggested by the Office of Management and Budget, we use two (2) as the weighted wage rate multiplier since Department of State employees have access to many resources.

Passport Services estimates that reviewing Form DS-3053 requires 40 seconds of a passport adjudicator’s time, or 0.67 minutes. Dividing $73.90/hr. by 60 minutes yields a processing time cost of $1.23 per minute. $1.23 multiplied by 0.67 yields a cost of $0.82 to review each form. Multiplying the projected number of respondents total of 362,900 by $0.82 yields $297,600. The estimated total annual adjudication cost is $297,600.

Printing Cost:

We also take into account the cost to print the form. The DS-3053 will be produced by a contractor with cost-plus-fixed-fee line items for material and/or supply purchases. The estimate provided to the Department by the contractor includes costs for contractor labor, supplies, equipment, printing materials, delivery, overhead, support staff, etc. The current cost is $33.44 per 1000 forms^iv. Based on the projected number of 362,900 respondents per year, at a cost of $33.44 per thousand, the estimated total annual printing cost is $12,140.

Federal Register Notice Cost:

The cost to publish both a 60-day Federal Register Notice (FRN) and a 30-day Federal Register Notice is $1,590.

Time and expense to adjudicate form	362,900 x $0.82	=	$297,600
Cost to print form	362,900 x .03344	=	$12,140
Cost to publish two Federal Register Notices	2 x $795	=	$1,590
Total Cost to Federal Government			$311,330

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

In addition to general format changes, the following content changes have been made to the form:

Page 1

USE OF THIS FORM:

• Added NOTE information regarding sole authority to reduce burden to parents who do not need to fill out this form.

• HOW TO COMPLETE THIS FORM: Added – “In certain countries, this form or statement must be notarized at a U.S. embassy or consulate and cannot be notarized by a local notary public. Go to the U.S. embassy or consulate webpage for more information.”

Page 2

• Updated the consent statement to reflect relationship to child and consent validity.

• Added second affiant signature and photo ID block for cases of consent from both parents/guardians.

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

Quantitative summaries of Department of State passport activities are published periodically on the Department of State website at: http://www.travel.state.gov/. Such summaries do not involve the use of complex analytical techniques.

17. If applicable, explain the reason(s) for seeking approval to not display the OMB expiration date.

The expiration date for OMB approval will be displayed.

18. Explain any exceptions to the OMB certification statement below.

The Department is not requesting any exceptions to the certification statement.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.

i Source: Bureau of Labor Statistics, “Employer Costs for Employee Compensation – May 2021,” https://www.bls.gov/oes/current/oes_nat.htm#00-0000

ii Source: National Notary Association, “2023 Notary Fees By State” | NNA (nationalnotary.org)

iii Source: Office of Personnel Management, “Pay & Leave,” https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2023/general-schedule

iv Source: Passport forms printing contractor, Occam Solutions