Thursday, March 14, 2013

OMB Approves ‘Emergency’ TWIC ICR Revision

Yesterday the Office of Management and Budget (OMB) approved an ‘Emergency’ information collection request (ICR) revision submitted by TSA last October. TSA had been directed by the Office of Information and Regulatory Affairs (the OMB office that processes and approves ICRs) to submit an emergency ICR revision request when they approved the TWIC ICR just weeks after TSA published their TWIC renewal Exemption notice last June.

The Revised ICR

The emergency ICR was necessary because the short-term change in policy regarding the renewal of most TWIC pending the establishment of the final TWIC Reader Rule would reduce the number of people that would be filling out the TWIC application form for some time into the future. This reduces the estimated number of annual responses, burden hours and burden cost associated with the TWIC ICR.

The projected reduction in collections (applications) was 69,744. This translated into a burden hours decrease of 65,200 hours and a cost savings of $10,389,606.

The Emergency ICR process only allows for a 6-month approval, leaving this approval to expire on September 30th, 2013. It also allow for filing of the Emergency ICR without the standard publication of pre-filing notices in the Federal Register by the agency involved, in this case TSA.

Approved With Change

It is not too unusual for OIRA to request some minor revisions when the approve the ICR. Typically, however, the do not publicly list what that ‘change’ is. In this case they did; the ICR approval notes:

“For the survey portion of this collection, TSA should consider offering the instrument in Spanish, since this has been identified as a potential reason for low response rates. In the next submission, the survey response scales should be modified as discussed. Also, TSA should consider the sample size/number of respondents, since only a small fraction of the responses are used to calculate customer service satisfaction.”

They are of course talking about a customer satisfaction survey that TSA asks TWIC applicants to complete voluntarily and anonymously. While I have no personal problem with providing survey’s in Spanish (being raised in California in the 60’s I’m used to bilingual governments) I’m kind of surprised that OIRA thinks that this would make a significant difference in the response rate.

TWIC Reader Rule Impact

With the TWIC Reader NPRM being issued in the near future we are just a little closer to the final rule, but it will still be sometime in 2014 before we can possibly expect to see the final rule published. This means that TSA will have to re-submit the renewal of the data in the Emergency ICR sometime before September. Then they will have to include a new ICR submission as part of their publication of the final rule.

Cost Burden

It was interesting to see that TSA included a cost burden in this ICR. That has been an almost obsolete part of the ICR. TSA did not include a cost burden, for example, in their Certified Cargo Screening Program ICR that was recently approved by OMB. Kudos to TSA for at least attempting to quantify the cost of compliance in this instance.

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