Saturday, November 2, 2013

Problems with DHS S&T ICR Publication

The DHS Science and Technology Directorate (S&T) published a 30-day information collection request (ICR) notice in Monday’s Federal Register (78 FR 66036; available on-line today) for a renewal of the authority to collect registration information for its First Responders Community of Practice Program (FRCoP) web site. This notice will almost certainly have to be re-done due to a number of inaccuracies included in the information.

Previous Problems

DHS S&T has a history of problems with this ICR (1640-0016). A renewal submission for the program had to be withdrawn for undisclosed reasons last year. A subsequent renewal submission was approved for only 9 months with the OMB’s Office of Information and Regulatory Affairs noting:

“If DHS submits a renewal of this collection, it should include a report with the following information: • How the First Responders Community of Practice is being used. Has the intended audience been reached? • An analysis by DHS of the practical utility of the collection. • An analysis by DHS of other similar platforms currently in use by first responders.”

Current Submission Problems

There are a number of problems with the current submission:

• Incorrect docket number;
• No reference to the 60-day Notice;
• Incorrect date of expiration of current ICR; and
• Does not include the information required by OIRA in previous approval

The middle two problems are technical issues that could probably be overlooked by OMB in the approval process. Since very few people actually read these ICR notices (and almost certainly none of the members of the FRCoP) there is no practical reason that OMB should reject this ICR based solely on those two deficiencies.

The first problem is a tad bit more problematic. The published docket number (DHS-2013-0028)
is for the renewal of the charter for the Homeland Security Science and Technology Advisory Committee. Any comments on this ICR posted to that docket would never be seen by OIRA in their consideration of this ICR renewal. That probably would not be a practical problem since there will likely be no comments posted on this ICR (other than a copy of this blog and I will post it to the correct docket, DHS-2012-0013).

The final problem listed is the most serious deficiency. Without this information OIRA would most probably fail to renew this ICR. I suspect that S&T intended to supply this information to OIRA in the documents that are actually submitted (including a copy of the registration form) that are normally not shown to the public. I think, however, that this information should be included in this public announcement for the renewal of this ICR so that there would be an opportunity for the affected community to weigh in on the utility and efficacy of this community of practice.


What is missing from this discussion is the benefit of the this program. DHS S&T notes that this congressionally mandated program {Section 313 of the Homeland Security Act of 2002 (PL 107-296); 6 USC 193}. That is a tad bit of an exaggeration since that section does not specifically mention anything about a ‘Community of Practice’. It is just a general section dealing with the S&T provision of a technology information clearing house.

Having said that it appears that the FRCoP is a beneficial program. If it is signing up 2,000 new folks per year (according to the ICR notice), it would seem to be filling some sort of need in the emergency response community. Since I am not a member I cannot make a judgement on the level of communication and information sharing within the site, but that is the sort of information that OIRA was requesting from S&T.

It would be very worthwhile if members of the FRCoP were to weigh in on this discussion, either here or in comments to OIRA on this ICR.

Public Comments

S&T is soliciting public comments on this ICR. Comments may be submitted through the Federal eRulemaking Portal (; Docket # DHS-2012-0013) or via email to DHS S&T ( Comments need to be submitted by December 4th, 2013.

I am submitting a copy of this blog post.

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