OMB Approves Emergency Renewal of TWIC ICR

The Office of Management and Budget (OMB) announced yesterday that it had approved a TSA emergency request for a modification of the Information Collection Request (ICR) for the Transportation Workers Identification Credential (TWIC) program. This is extremely odd, since OMB already approved this emergency request back in March. A follow-up request for a longer term approval of the revised ICR is already in the works.

A closer look at this request suggests that OMB is more than a little confused, or something out of the ordinary is occurring behind closed doors. Yesterday’s notice indicated that the requested change originated in November of last year (the same as the origination date of the earlier emergency request), but that the request wasn’t actually submitted to OMB until earlier this week (6-25-13).

To make things even more confusing the burden estimate numbers between the previous approved emergency request, this emergency request, and the follow-up request currently going through the public comment/review process do not match up. The table below shows the three sets of numbers.

	Current	Previous	New Request
Response	1,008,304	852,310	Not Available
Time Burden	807,396	741,879	829,774
Cost	52,146,260	$42,786,620	$47,633,777

There is no telling where the OMB got the data for yesterday’s action; it has not been included in any of the public TSA documents. As I noted in my earlier blog there was no data in the recent request about the number of expected responses. I do have a serious problem though with estimated cost numbers (Once again I must note that TSA is one of the few federal agencies that still includes cost estimates in their ICR submissions); with the time burden numbers on yesterday’s approved ICR being between the two other requests, it is difficult to see how the estimated cost burden can be so high.

Now realistically, this is not a big issue. This whole ICR process is an administrative exercise that has no real meaning in the practical world. The submitting agency is only accountable to OMB for the accuracy of the information and OMB’s approval is a legal technicality that has been frequently ignored. The TWIC is still in use and people are still providing a great deal of information to TSA to get their cards issued or renewed.

Still, this does cause some questions about the whole ICR process.