Friday, January 7, 2011

TSA Publishes 60-day ICR for New Exercise Program

Yesterday the Transportation Security Administration published a 60-day notice of their intent to file with the Office of Management and Budget (OMB) an information collection request (ICR) to support a new exercise program. Not an ab-reduction exercise program, the Exercise Information System (EXIS) described in this ICR is a component of TSA’s new Intermodal Security Training Exercise Program (I-STEP).

TSA estimates that up to 380,000 users may take about 8 hours each to submit information into EXIS over the next three years to support their voluntary participation in I-STEP. TSA is seeking public comments on this ICR notice. Comments need to be submitted by March 7, 2011 and may be emailed to


TSA describes EXIS as “an Internet-accessible knowledge-management system developed by TSA serving stakeholders-industry, port authorities, Federal agencies, and State and local governments--and integrating other security-related training and exercise components at the sensitive security information level [emphasis added]” (76 FR 792). EXIS will provide data management throughout the exercise development, execution and review process. The new system can allow users to:

• Customize exercise design;
• Conduct robust analyses;
• Create analytical reports; and
• Collaborate and share information
Information Collection

As part of the voluntary exercise development, execution and review process EXIS will collect five types of information:

• User registration data
• Desired nature and scope of the exercise
• Post-exercise security evaluations
• EXIS evaluation
• After-Action reports
Based upon the participation projected and one exercise per year per participant, TSA expects a total annual hour burden for this ICR to be 3 million hours. Since there is no charge for participation in I-STEP, TSA projects no cost annual cost burden for participants. This of course totally ignores the time cost of participation.

Information Uses

Within the EXIS process the information submitted will be used to aid in the development of the user’s training exercise. Additionally, TSA notes that the information will be used to “automatically populate the [exercise] database with lessons learned from past exercises conducted in similar environments” (76 FR 793) both by the immediate user and other EXIS participants.

TSA also expects to analyze and use this information to internally to inform their efforts “to assess and improve the capabilities of all surface transportation modes to prevent, prepare for, mitigate against, respond to, and recover from transportation security incidents”.

Personal Observations

Anyone that has worked on emergency planning, and make no mistake security planning is at heart emergency planning, knows that, as we used to say in the Army, no plan survives contact with the enemy. No matter how hard one works on developing a plan, something will go unnoticed. Short of having to implement the plan in an emergency situation, conducting exercises are the best way to identify and correct shortcomings in such plans.

TSA is to be commended on providing a modern, internet based, exercise development program. Allowing exercise developers to learn lessons not only from their own exercises but from the exercises of others is perhaps one of the best ideas to come out of TSA. Now all we need to do is to see how well this is executed.

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