Tuesday, June 17, 2014

First Responders Community of Practice ICR Notice – Again

Today the DHS Science and Technology Directorate (S&T) published a 60-day ICR renewal notice in the Federal Register (79 FR 34545) for their First Responders Community of Practice Program (FRCoP). I wrote about the previous submission of this ICR to OMB last year; that submission has not yet been acted upon by OMB. This ICR notice completely ignores that previous submission.

I noted in my earlier blog that the previous approval of this ICR (which expired last October) was a short term approval because OMB wanted additional information about the program and its efficacy. I noted that S&T had not included that information in its published ICR notices. Looking back now at the actual ICR submission supporting documents there is an attempt [Word® download link] by S&T to fulfill that requirement. There is no indication on the OMB site if that was considered to be an adequate response.

One interesting item of information from that S&T document is the report that there are 5,000 active members of the FRCoP. Since this ICR only covers the submission of registration information that is supplied on a one time basis, it would seem that there is a pretty good retention of site members. The site has been active since somewhere in 2010 and S&T indicates that there have been an average of 2000 registrations per year. That means that between 6,000 and 8,000 registrations have taken place. Retaining 5,000 members from that number would seem to be a pretty high success rate.

One other interesting administrative note; this ICR notice uses the same docket number as the ICR submission that was withdrawn last year. It seems that everyone, both at DHS and OMB, is ignoring the ICR that was submitted last year. That seems to be more than a little strange.

Anyway, S&T is soliciting public comments on this ICR submission. Public comments may be made via the Federal eRulemaking Portal (www.Regulations.gov; Docket # DHS-2012-0013). Comments need to be submitted by August 18th, 2014.

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