Admin Review of QHSR Dialogue

Earlier this year I looked at the initial report by DHS on their Quadrennial Homeland Security Review. While we are waiting for the results of the Department’s ‘bottom-up’ review of the QHSR we can now read a review of the process used in the National Dialogue that formed a part of that review. The National Academy of Public Administration (the group that actually ran that ‘National Dialogue’) had a panel take a detailed look at the process and they published their report last week. Rather than looking at the QHSR Dialogue results, this report focuses more on the lessons learned in how to conduct this type of public interaction in the policy development realm. As such I think that this report will be beneficial to DHS and other government organizations at all levels in developing future interactive tools of this sort. Of particular interest to me was the 5th section of the report that dealt with the legal issues surrounding the conduct of this type of review. It includes a discussion of how the Paperwork Reduction Act of 1980 impedes the formation of this type of information exchange. The bureaucratic rules governing the ‘collection of information’ with its 60-day and 30-day notice requirements for information collection requests was never intended to deal with this type of electronic communications. This report recommends that OMB and the White House Counsel’s Office issue a “issue a legal opinion on the circumstances under which the PRA and similar statutes apply to publicly available collaborative engagement opportunities and such platforms as the National Dialogue on the QHSR” (page 60). I think that it might be more appropriate for Congress to look at updating the 30 year old legislation to bring it into line with the electronic age and Web 2.0 technologies. DISCLOSURE NOTE: One of my blog postings was quoted in this report (page 27, footnote 22), so the report drafters were astute and well read. Unfortunately they got the link wrong; the quote comes from the following blog post: http://chemical-facility-security-news.blogspot.com/2009/09/qhsr-bloggers-round-table-8-31-09.html In any case, this report provides some interesting discussions about the mechanics of last year’s National Dialogue and how to use that technique in the future. Of course, I’m more interested in the DHS report on the bottom-up review…