Thursday, June 16, 2011

TSA Publishes Pipeline Security ICR Renewal Notice

Today the Transportation Security Administration (TSA) published a 60-day notice in the Federal Register (76 FR 35229-35230) of their intention to request OMB approval for the renewal and expansion of their information collection request (ICR) for continued authority to collect ‘critical facility’ information on the top 100 ‘most critical’ pipelines.

That ‘top 100’ description is a misnomer. It comes from the requirement in the Implementing the Recommendations of the 9/11 Commission Act of 2007 {§1557(b)} for TSA to “develop and implement a plan for inspecting critical facilities of the 100 most critical pipeline systems”. What TSA has actually done is to identify the top 125 critical pipeline systems and have them identify their ‘critical facilities’. This has resulted in about 600 facilities that TSA is including in their pipeline inspection program.

According to the discussion in this notice, TSA expects to conduct follow-up visits to up to 125 critical pipeline facilities per year after reviewing the updated information collected under this ICR renewal. During these visits TSA will collect additional information under this ICR using the Critical Facility Security Review form. This new form will be different than the Corporate Security Review (which will remain in use) that is described in the current ICR in that it looks at facility specific information rather than corporate policy data.

This new form, and the intended follow-up data on implementing recommended security measures, have resulted in a change in the burden hours associated with the renewal of this ICR. TSA expects pipeline operators to spend 4 hours providing updated critical facility information. The new Critical Facility Security Review will take 4 hours at each facility and TSA expects facilities to spend five hours responding to TSA follow-up requests about the status of their security recommendations implementation. This results in an expected industry burden of 2,730 hours in the first year and 1,080 hours in each of the following years.

Public comments on this notice are solicited by TSA. Comments may be submitted by email to (TSA does not appear to be using the Federal eRulemaking Portal for these comments). Comments must be submitted by August 15, 2011.

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