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Federal Register / Vol. 86, No. 236 / Monday, December 13, 2021 / Rules and Regulations mandatory eROPs as a result of this regulation.

TABLE 2OFFICE OF THE CHIEF
IMMIGRATION JUDGE COST SAVINGS
Year
Expected cost savings
1
2
3
4
5
6
7
8
9
10

$140,304
526,622
816,841
1,115,708
1,320,399
1,500,104
1,666,355
1,816,269
1,947,925
2,060,361

Total

12,910,888

Since all paper-filed documents, per this new regulation, will be scanned and maintained in an eROP, initial case processing is estimated to become marginally more expensive as court staff must scan the paper documents into the eROP. However, this increase in cost will be outweighed by the time savings, calculated in terms of the cost of labor, for individual hearing processing and change of venue processing, as filing becomes more expeditious for court staff in each individual case. Additionally, annual shipping costs will be reduced, since changes of venue, appeals, and records retirement transfers will occur electronically instead of manually shipping the paper ROP to another court, the BIA, or the Federal Records Center.
Cost changes have been calculated with the assumption that all other processes remain the same. However, eROPs enable the possibility of further cost savings through more efficient case adjudication. For example, widely available eROPs may enable immigration judges to hear a case via video teleconference VTC almost instantly. Under the current paper ROP
system, the ROP needs to be shipped to the immigration judges location before a VTC hearing can be held. In contrast,
an eROP could enable a judge to open any eROP and hear a case immediately.
This new paradigm has the potential to improve the efficiency of workload adjudication by judges and their staff members.
EOIR may also realize savings through the reduced growth of storage requirements at court locations. EOIR
currently stores paper ROPs at immigration courts, utilizing valuable storage space in courtrooms, offices, and hallways. Conversion to an eROP
system may ease the strain on the system as new pending cases will have an eROP that will not require physical storage space. With the information currently available, storage space utilization and savings cannot be specifically calculated. However, this regulation will likely reduce costs for the immigration courts by allowing current space to be used for functional purposes, rather than storage.

70715

The impacts to the BIA largely mirror the immigration courts in that scanning paper filings into the eROP is likely to increase costs by increasing staff workload. Further, the largest cost savings are likely to come from reduced shipping. The BIAs process requires that all ROPs sent to the BIA from the immigration court must be shipped back to the court upon completion of the appeal. Shipping costs will be eliminated for future eROPs because they will be transferred electronically, reducing costs for the BIA.
c. Office of Information Technology
The Department estimates that the implementation of the rule will increase EOIRs Office of Information Technologys OIT costs by a total of approximately $51.3 million across the first 10 years of implementation. These costs are due to the additional effort required to develop, deploy, and b. Board of Immigration Appeals maintain the electronic infrastructure The Department also estimates that that serves as the backbone for implementation of the rule will reduce electronic filing.
the BIAs costs by approximately $2.7
Because OIT developed the tools and million over the first 10 years of processes necessary for the implementation. Cost changes for the implementation of mandatory electronic BIA will be realized in three main filing throughout EOIR, it is the largest process areas: Scanning pro se ROPs;
driver of quantifiable costs from receiving ROPs from the immigration mandatory electronic filing courts; and returning ROPs to the implementation. The deployment and immigration courts.
training for mandatory electronic filing will be particularly resource-intensive TABLE 3BIA COSTS SAVINGS
for OIT, as it will be responsible for the Expected cost deployment and maintenance of the Year savings hardware and software necessary to 1
$23,064 digitize and store documents along with 2
176,822 delivering training to court staff. Costs 3
201,808 related to electronic filing deployment 4
250,818 are estimated to be approximately $21.7
5
285,414 million, including $2.3 million in 6
314,243 hardware purchases, $1.7 million in 7
342,112
travel to deliver training and install 8
367,098
9
388,240 systems, and $3.4 million in external 10
407,459 services, software, and licensing for necessary cloud computing services.
Total

2,710,950

TABLE 4OIT ELECTRONIC FILING DEPLOYMENT COSTS

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Category
Year 1

External Services e.g., MS Azure Premier Access
Software
Travel
Labor/Hardware 3
Support Labor:
Program Support
Training
Service Desk/Operations
Product Labor:
eROP
Electronic Filing

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Year 2

Total
$999,429
625,988
830,295
11,316,689

$999,429
726,171
830,295
5,355,028

$1,998,858
1,352,159
1,660,590
16,671,717

1,717,020
754,782
482,417

900,298
431,820
482,417

2,617,318
1,186,602
964,834

2,699,130
3,741,362

1,322,681
1,833,416

4,021,811
5,574,778

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