We are almost a full week into the month of December and I would normally be looking for the monthly report from ISCD about the number of authorized and approved CFATS site security plans. This month, however, I’m not so sure when it is going to be coming out for a couple of reasons.
Last month, of course the report came out towards the end of the month with a data close date of November 19th. DHS wanted to report a full month of data after restarting the CFATS program after the end of the federal funding fiasco. The numbers for that “month” were disappointing because you can’t just snap your fingers and restart a regulatory program as complicated as CFATS.
Now ISCD has an interesting conundrum. The can publish a ‘December’ report for data closing on November 29th (the last working day of the month), but those numbers would be absolutely horrible since they would only cover 10 calendar days and 6 working days (two days off for Thanksgiving). It will be even worse since the inspection schedule still wasn’t completely filled back up at the start of the period. All of this would be legitimate reasons for bad numbers, but politicians are notoriously inattentive to reasons, legitimate or otherwise, and there are a number of congrescritters who are hunting for ISCD’s collective head anyway.
ISCD could also just go with a new 30 day period and issue the ‘December’ report with a data close of December 19th. The numbers will certainly be better than the November report, but not as good as the October report. If ISCD would include a little bit of an explanatory note in their program update, this should give them some breathing room with Congress. Of course, the ‘next’ report would include the holiday period at the end of December which I would expect to drastically cut into the number of inspections, authorizations and approvals. So the weak ‘January’ report would be handed to Congress as it comes back into town and put ISCD squarely in the target zone of a couple of committees early in the new year.
What I think would probably make a lot more sense would be for ISCD to hold off on any reporting on CFATS status until the end of December. They could use a data cut-off date of December 30th (nothing serious is going to get done on the 31st anyway) and have a set of numbers that would almost certainly be more in-line with the October report. This would also allow them to correct one of the ‘discrepancies’ that has been bothering my anal-retentive nature and the ‘December’ report would actually reflect December activities not the previous month.
Whichever of the three options (or maybe something completely different, I don’t own this program) that ISCD uses for their next report, they need to shakedown some of the boilerplate copy on the report and add an explanatory note of what they are doing with the data until they get things back down to some nice bureaucratic data report that no one pays any attention to since it is always the same.