Comment Submitted by Persistence Analytics Group LLC

To the Department of Homeland Security / U.S. Immigration and Customs Enforcement — Re: ICEB-2026-0001 — Departure Notification Record Persistence Analytics Group LLC respectfully submits this comment regarding ICE’s Departure Notification Record information collection. PAG is a national security and infrastructure risk analytics firm focused on implementation-assumption verification, decision assurance, identity-system integrity, critical-infrastructure risk, and public-trust exposure. This information collection should not be viewed only as a Paperwork Reduction Act burden issue. It is part of the nation’s immigration, border, identity-verification, and voluntary-departure infrastructure. DHS, including ICE and CBP, proposes to use biographic data, biometric data, intended-departure information, and a mobile application to identify individuals geographically located in the United States who want to voluntarily depart. That creates a practical implementation question: What must be verified before DHS relies on a mobile identity and departure-notification system for immigration processing, voluntary departure, border integrity, and public accountability? PAG respectfully recommends that DHS, ICE, CBP, and OMB evaluate the collection through an implementation-verification framework addressing: 1. Identity Accuracy What evidence confirms that the individual submitting the record is the correct person and that biometric and biographic matching does not create unacceptable false positives, false negatives, duplicate records, or misidentification? 2. Departure Verification What evidence proves that intended departure becomes actual departure, and how is the departure event confirmed, reconciled, and audited across DHS systems? 3. Data Integrity What controls verify the accuracy of names, locations, biometrics, travel information, intended destination, immigration status, and supporting records submitted through the mobile application? 4. Mobile Application Risk What cybersecurity, authentication, fraud-prevention, device-integrity, data-retention, and vendor assumptions must hold for CBP Home or any successor mobile platform? 5. Interagency Data Sharing How will ICE, CBP, DHS components, and any relevant federal partners ensure that data is shared only for authorized purposes, remains accurate, and does not create conflicting records? 6. Burden and Access Given the estimated response volume and annual burden hours, what evidence supports the burden assumptions, including access to mobile devices, language access, digital literacy, connectivity, identity-document availability, and support needs? 7. Error Correction and Due Process What practical process exists for individuals whose records are incorrect, incomplete, duplicated, fraudulently submitted, or linked to the wrong person? 8. Public-Trust and National-Security Confidence What evidence demonstrates that the system improves immigration administration and national-security awareness without creating unverified exclusion, inaccurate records, privacy risk, or public-confidence failure? PAG is not opposing the use of modernized departure-notification tools. The issue is that systems of this type become sovereign identity infrastructure when they are used to determine presence, departure intent, identity, immigration records, and government reliance. That means the implementation assumptions must be verified before scale. A departure-notification system is only as strong as the identity, data, audit, and verification layer underneath it. Trust the process. Verify the identity and departure record. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC | United Grid National Security & Infrastructure Risk Analytics Demand Durability | Grid Stress | Load Integrity neil@persistenceanalyticsgroup.com 609-464-9055 https://persistenceanalyticsgroup.com/ SAM.gov Registered Vendor UEI: D3VYU39H6DX9 | CAGE: 19T34 D-U-N-S: 142849930