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to be withdrawn for undisclosed reasons last year.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.
The FRCoP
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 (www.Regulations.gov; Docket # DHS-2012-0013)
or via email to DHS S&T (Kathy.Higgins@hq.dhs.gov).
Comments need to be submitted by December 4th, 2013.
I am submitting a copy of this blog post.
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