AFNC Supporting Statement - finalX

SUPPORTING STATEMENT – PART A

A.  JUSTIFICATION

1.  Need for the Information Collection

The American Forces Network (AFN) needs an automated way to confirm the eligibility of people seeking to acquire AFN programming using the AFN satellite decoders or via streaming AFN content. Failure to control access would jeopardize AFN programming worldwide. The information collection will enable a 99.9% solution using DEERS to validate eligibility by providing information on the geographical location of potential consumers. This will enable DMA to confirm viewer eligibility every year, and increase the Force Protection capability of local and COCOM commanders by enabling mass notification of emergency announcements to selected personnel in targeted geographical areas. Authorizing documents include 5 U.S.C. 301, Departmental regulations; 10 U.S.C. 136, DoD Directive 5400.11, DoDI 5120.20, section 3, para g, DoDI 5120.20, Enclosure 2, section 2, paragraph c, DoDD 5105.74, section 3.1 & 3.3.

2.  Use of the Information

The information will enable DMA to confirm viewer eligibility each year, and increase the Force Protection capability of local and COCOM commanders by enabling mass notification of emergency announcements to personnel in targeted geographical areas.

3.  Use of Information Technology

When an individual wants to receive AFN programming, they obtain an AFN decoder and must register it on the AFNConnect website. Minimal user data (i.e., personal email address and DoD ID number [or truncated SSN and date of birth if DoD ID number is unavailable) is collected from respondents via the AFNConnect web site. The data collected is used to uniquely identify the user in DEERS to determine their eligibility to receive AFN services, and to allow communication with the user. All other required information will be obtained from DEERS.

4.  Non-duplication

There are no systems currently available in DMA that contain the data necessary to determine a potential viewer’s initial or continued eligibility to receive AFN services.

5.  Burden on Small Business

This section does not apply. There are no large or small businesses involved.

6.  Less Frequent Collection

Less frequent collection would delay the provisioning of AFN programming to eligible individuals and families. Additionally, it would decrease the effectiveness of Force Protection, as location information would become out of date.

7.  Paperwork Reduction Act Guidelines

This section does not apply. We are following guidelines.

8.  Consultation and Public Comments

a.  On December 09, 2014, the Agency’s 60-day notice was published on Page 73053 of the Federal Register. No public comments were received.

b.  The information solicited in this collection is not available to persons outside the Department of Defense.

9.  Gifts or Payment

This section does not apply. There will be no gifts or payments to respondents.

10.  Confidentiality

A Privacy Impact Assessment has been completed. A Statement of Records Notice draft is ready for submission, pending completion of the PRA process.

The primary risk associated with the PII collected is unauthorized access and use. Access is limited to specific individuals and is limited to only the data necessary to complete required tasks. Row level encryption is used to secure data stores and user authentication/roles are used to limit access to users of the system. Truncated SSN/DOB are used for integration with DEERS (the truncated SSN is not stored) Each stage of the information life cycle is designed to limit exposure to and the release of PII. Information is collected via HTTPS (securing the transmission) and encrypted when at rest; access is limited to only authorized users. Safeguards in use include security guards, ID Badges, Key cards, Closed Circuit TV, Intrusion Detection System, Encryption, External Certificate Authority, Firewalls, Virtual Private Network (VPN), Common Access Card (CAC).

11.  Sensitive Questions

Collection of truncated SSN and date of birth, which is required only when DoD ID number is unavailable, allows integration with DEERS. (The truncated SSN is not stored.) No other sensitive information is requested.

12.  Respondent Burden, and its Labor Costs

a.  Estimation of Respondent Burden

AFN’s potential land based public audience using AFNConnect is approximately 7,000 people. About 10% of that amount enters NEW information each year; the remainder is automatically updated by the automated AFNConnect process. It takes approximately 10 minutes for an individual to enter new data into the web based interface of AFNConnect.

NUMBER OF RESPONDENTS: 700

RESPONSES PER RESPONDENT: 1

AVERAGE BURDEN PER RESPONSE: 10 minutes

ANNUAL BURDEN HOURS: 116.67 hours

b.  Labor Cost of Respondent Burden

An hourly labor rate of $30.00/hour (GS-12 Step 1 salary) for 116.67 hours per year results in an annual labor cost of $3,500.

13.  Respondent Costs Other Than Burden Hour Costs

There are no costs to respondents.

14.  Cost to the Federal Government

Estimated cost is $175,000 annually. This includes the cost of obtaining the data from the Defense Manpower Data Center, the cost of infrastructure to support secure transmission of data, and the cost of manpower at the AFN Broadcast Center to maintain their side of the infrastructure.

15.  Reasons for Change in Burden

This is a new collection, and the burden associated with it is new.

16.  Publication of Results

This section does not apply. Results will not be published.

17.  Non-Display of OMB Expiration Date

This section does not apply. We are not seeking an exemption to display the Expiration Date.

18.  Exceptions to "Certification for Paperwork Reduction Submissions"

This section does not apply. We claim no exceptions to the Certifications.

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