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Federal Register / Vol. 86, No. 236 / Monday, December 13, 2021 / Rules and Regulations TABLE 4OIT ELECTRONIC FILING DEPLOYMENT COSTSContinued Category
Year 1

Year 2

Total
Hardware

1,921,978

384,396

2,306,374

Total

13,772,401

7,910,923

21,683,324

Costs are estimated to be highest in the first year of the deployment, as hardware is purchased, software systems are finalized and implemented, and training is delivered to court staff.
Costs are estimated to decrease by over 40 percent in the second deployment year as OIT completes training court staff and transitions to a steady state of software and hardware maintenance.
The cost reductions in the second year of deployment will be driven by a 47

percent reduction in labor costs and an 80 percent reduction in hardware costs.
Once training and deployment are complete, OITs costs will stabilize.
While OIT will no longer incur costs related to training court staff, OIT will be using more labor than before mandatory electronic filing. This is due to the additional staff necessary to provide help desk support to the courts and IT services related to the electronic filing system. OIT will also continually accrue expenses for cloud computing
platform licensing and hardware repairs, upgrades, and replacements required to support electronic filing.
OIT estimates that overall costs will increase by approximately 1 percent each year, primarily driven by increases in labor costs. These ongoing expenses will represent the new steady state for OIT. The eight years following completion of the deployment phase are estimated to cost an additional $29.6
million due to mandatory electronic filing.

TABLE 5OIT ELECTRONIC FILING STEADY STATE COSTS
Category
Year 3

Year 10

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

$999,429
366,521
0 2,227,541

$999,429
366,521
0 2,255,993

$999,429
366,521
0 2,445,561

$7,995,432
2,932,168
0 18,666,644

239,564
172,728
482,417

239,564
172,728
482,417

239,564
172,728
482,417

1,916,512
1,381,824
3,859,336

466,808
481,628
384,396

480,812
496,076
384,396

574,115
592,341
384,396

4,151,015
4,282,793
3,075,168

Total

3,593,491

3,621,943

3,811,510

29,594,242

caseload will have mandatory eROPs as a result of this regulation, which will cause the ratio of eROPs to paper ROPs, and thus expected cost savings, to increase over time, as detailed in Table 6.

The Department estimates that the implementation of the rule will increase efficiencies for the EOIR Office of the
General Counsel OGC programs. For example, digitization of files will allow for more expeditious compliance with Freedom of Information Act FOIA
and other requests for information, reducing the time burden of such activities on EOIR staff. Specifically, the Department estimates that costs associated with FOIA compliance will decrease by approximately $2.8 million across the first 10 years of implementation. These savings will be realized through reduced shipping costs in the FOIA response process as more ROPs are accessible electronically instead of requiring storage retrieval and shipping.
As electronic filing becomes more widespread, the proportion of FOIA
requests that can be satisfied through electronic records searches will proportionally increase. A higher percentage of the future pending
3 Labor/Hardware represents a total of the individual categories of support labor, product labor, and hardware.

4 Years 5 through 9 are not included in this visual, but are factored into the totals calculations.
OIT estimates that labor costs will increase by 3

percent per year. Non-labor costs, such as hardware, software, and external services, remain constant through each year.

As mandatory filing is implemented and electronic filing progresses, the Department anticipates that this will lead to significant additional efficiencies in case processing. This may include more expeditious case scheduling and adjudication, improved data quality, increased performance monitoring and tracking, augmented data analytics capabilities, and better alignment with information storage best practices. There may also be further impacts to EOIRs internal datainformed decision-making process, as the digitization of the data may allow for increased analysis of the relationship between various practices, procedures, and outcomes.
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TABLE 6OGC COST SAVINGS
Year 5
1 2
3 4
5 6
7 8
9

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Expected cost savings $0
0 60,052
203,084
295,661
360,279
404,478
443,370
479,318