Today the Transportation Security Administration published a
60-day information collection request (ICR) notice in the Federal Register (78 FR
32417-32418). This is a follow-up to the March approval of an emergency
ICR extension to reflect changes in the Transportation Workers
Identification Credential (TWIC) information collection process brought about
by the short-term renewal process initiated last summer.
There is little actual information in this notice beyond a
brief statement of burden estimates. As shown in the table below the burden
estimates in this notice are higher than those published in the approved
emergency extension. Without a number for the number of expected responses
it is difficult to explain the change in time burden and cost. Based upon the number
of folks currently
enrolled in the TWIC program (2,556,783) we would expect to see about 500,000
renewals alone each year.
|
Current Burden
|
This ICR
|
Responses
|
852,310
|
Not Reported
|
Time Burden (hours)
|
741,879
|
829,774
|
Cost
|
$42,786,620
|
$47,633,777
|
TSA does not explain the cost burden (and again I applaud
TSA for including this figure; it is inexplicably absent from most ICR notices)
estimation process. Based on the current published data the cost is just about
$50 per response, so it does not include the actual cost of the application fee
for either the extended TWIC ($60) or the new/renewed TWIC ($129.75).
The TSA is soliciting public comments on this ICR. Comments
may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # TSA-2006-24191).
Comments should be submitted by July 29th, 2013.
NOTE: This ICR has nothing to do (directly) with the current
Coast Guard TWIC Reader NPRM.
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