Thursday, May 30, 2013

TSA Publishes 60-day TWIC ICR Notice

Today the Transportation Security Administration published a 60-day information collection request (ICR) notice in the Federal Register (78 FR 32417-32418). This is a follow-up to the March approval of an emergency ICR extension to reflect changes in the Transportation Workers Identification Credential (TWIC) information collection process brought about by the short-term renewal process initiated last summer.

There is little actual information in this notice beyond a brief statement of burden estimates. As shown in the table below the burden estimates in this notice are higher than those published in the approved emergency extension. Without a number for the number of expected responses it is difficult to explain the change in time burden and cost. Based upon the number of folks currently enrolled in the TWIC program (2,556,783) we would expect to see about 500,000 renewals alone each year.


Current Burden
This ICR
Responses
852,310
Not Reported
Time Burden (hours)
741,879
829,774
Cost
$42,786,620
$47,633,777

TSA does not explain the cost burden (and again I applaud TSA for including this figure; it is inexplicably absent from most ICR notices) estimation process. Based on the current published data the cost is just about $50 per response, so it does not include the actual cost of the application fee for either the extended TWIC ($60) or  the new/renewed TWIC ($129.75).

The TSA is soliciting public comments on this ICR. Comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # TSA-2006-24191). Comments should be submitted by July 29th, 2013.


NOTE: This ICR has nothing to do (directly) with the current Coast Guard TWIC Reader NPRM.

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