Persistence Analytics Group LLC - Comments

To the Transportation Security Administration / Office of Management and Budget — Re: TSA-2013-0001 — TSA PreCheck Application Program / OMB Control No. 1652-0059 Persistence Analytics Group LLC respectfully submits this comment regarding TSA’s proposed revision of the TSA PreCheck Application Program 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 filing should not be viewed only as a Paperwork Reduction Act burden estimate. It is a national identity-verification infrastructure issue. TSA’s proposal involves biographic and biometric information, identity verification, Security Threat Assessment, recurrent vetting, FBI NGI / Rap Back, DHS IDENT / HART, MyTSA PreCheck ID, the TSA Customer Service Portal, and expanded 1:n touchless identity verification through Seamless Identity Automation. The core question is: What must be verified before biometric and digital identity systems become relied-upon infrastructure for aviation security, trusted traveler benefits, airport access, and public identity assurance? PAG respectfully recommends that TSA and OMB evaluate the collection through an implementation-verification framework addressing: 1. Identity Accuracy What evidence proves that biometric and biographic matching reduces identity risk without creating unacceptable false positives, false negatives, or misidentification burdens? 2. Data Integrity What controls verify that name, date of birth, KTN, citizenship or immigration-status evidence, identity documents, fingerprints, facial images, and mobile ID information remain accurate and auditable across systems? 3. Recurrent Vetting Accountability What standards govern FBI NGI / Rap Back and DHS IDENT / HART recurrent vetting, and how are applicants protected from inaccurate or outdated data? 4. Error Correction and Due Process What practical burden falls on individuals who are wrongly flagged, misidentified, or deemed ineligible? How does TSA verify that the correction process is accessible, timely, and effective? 5. Biometric Governance What evidence proves that facial-image, fingerprint, and 1:n touchless identity systems are accurate, secure, opt-in, auditable, and not subject to unauthorized use or mission creep? 6. Cybersecurity and Vendor Risk What cybersecurity, cloud, vendor, mobile-wallet, and data-sharing assumptions must hold for MyTSA PreCheck ID, the Customer Service Portal, and Seamless Identity Automation? 7. Public Trust and National-Security Confidence What evidence demonstrates that the system improves security while preserving public confidence, privacy, lawful access, and operational reliability? 8. Burden Verification Given TSA’s estimated annual burden hours and cost burden, what evidence supports the assumptions underlying the burden calculation, including correction burden, opt-in friction, digital access, customer-support needs, and identity-resolution delays? PAG is not opposing TSA PreCheck modernization. The issue is that identity systems become national-security infrastructure when they are used to determine access, risk status, eligibility, screening treatment, and trust. That means the implementation assumptions must be verified before scale. A trusted traveler system is only as strong as the integrity of the verification layer underneath it. Trust the identity system. Verify the assumptions. 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