Sunday, July 31, 2011

OMB Receives TSA TWIC ICR Renewal Request

On Friday the Office of Management and Budget announced on its website that it had received the renewal paperwork for TSA’s Transportation Workers Identification Credential (TWIC) information collection request (ICR). Readers will recall that TSA published their Federal Register notice that this was being sent to OMB over two weeks ago.

Current Approval Expired

Interestingly, the current OMB authorization expires today. As explained in the Federal Register Notice in “accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.), an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB control number”. Technically that would mean that TSA cannot require TWIC applicants to complete the necessary paperwork for that application. In the short run I expect that this will have no practical effect on the program.

Personally, I would prefer to see OMB enforce this law and notify TSA that it could not process TWIC applications until the ICR was approved in normal course at OMB. It does not seem to me that it should be that difficult for a Federal Agency to process the appropriate paperwork for this ICR renewal process in time enough to get the process completed before the current approval expires. After all, the deadline is known three years in advance.

TSA Explanation

One part of the Federal Register notice that I didn’t report on earlier was the comment that: “TSA will directly respond to the individual submitting this feedback.” (76 FR 41510) Since I was the individual submitting the referenced feedback, I can report that TSA has, as of yet, failed to make that response. I’m looking to see their explanation for the changes in processing times and costs.

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