DHS to Revise Current CSAT ICR

Earlier this week DHS NPPD filed a notice in the Federal Register announcing their intent to file a revision of the currently approved ICR for the CSAT system. Comments should be submitted to www.Regulations.gov (Docket No. DHS-2009-0033) by August 31st, 2009. OMB has already approved (OMB 1670-0007) the basic data collection requirements for CFATS (though DHS is separately requesting approval of some new CFATS data collection) and that approval does not expire until 05-31-11. DHS does not provide a reason for this 60-day advance notice for a revised information collection request. More information should be available when DHS provides the Notice of their actual submission of this ICR to OMB. What is interesting about this notice is that DHS does provide some information about how often they expect each data collection activity to occur each year. Here is the DHS data from the Notice:

CFATS Helpdesk 25,000 @ 0.25 hrs/request CVI Authorization 8,073 @ 1.00 hr/request CSAT User Registration 4,167 @ 1.00 hr/request CSAT Top Screen 4,167 @ 30.3 hrs/request SVA and Alternative SVA 825 @ 250 hrs/request SSP 825 @200 hrs/request

Looking at the numbers it appears that DHS is assuming that they will have about 4,000 new facilities registering in the CFATS system and submitting Top Screens. The number of SVA/SSP submissions look to be calculated from the high-risk facility rate from the initial Top Screen submissions. This appears to mean that DHS is planning on executing some sort of enforcement program to bring facilities into the program that some how missed participating in the initial go-round. I think that these numbers ignore (whether deliberately or because of over sight remains to be seen) the significant number of Top Screens that current high-risk facilities will submit as their inventory levels and product mixed change over time. It also overlooks facilities that had previously registered and were not classed as high-risk facilities, but are required to re-submit Top Screens because of new COI or increased inventory levels. All of these facilities would be expected to have a higher rate of being identified as requiring submission of a new SVA. Similarly the CVI Authorization number appear to be too low. It would reflect about one new employee per year from the current crop of high-risk facilities. The number of State and local government employees that will be requiring CVI authorization as facilities begin coordinating their emergency response and law enforcement response will be substantially higher than the cited figure. It will be interesting to see the additional information that accompanies the actual submission of this ICR to OMB.