Wednesday, May 14, 2014

TSA Publishes Pipeline Security 60-Day ICR Notice

Today the DHS Transportation Security Administration (TSA) published a 60-day information collection request (ICR) renewal notice in the Federal Register (79 FR 27631-27632) for their Critical Facility Information of the Top 100 Most Critical Pipelines program. This ICR (1652-0050) was last renewed in February 2012 and expires February 2015.

TSA is making a revision to the number of expected responses from industry covered by this ICR and reduces the estimate time burden associated with collection of information. A summary of that change is provided in the Table below.

Time Burden (hours)
Cost Burden ($)
Table: Change in Burden Estimate

Part of the change in burden estimate is apparently driven by the fact that TSA is no longer collecting information used to establish the Pipeline System Critical Facility List. There is no indication in the ICR as to why TSA believes that this information will not require some sort of periodic updating to reflect changes in the pipeline infrastructure in this country.

Another change is that TSA is reducing the number of Critical Facility Security Reviews conducted each year from 120 to 90. These CFSRs are conducted via on-site visits and use a check list; the Pipeline Security Critical Facility Review (WORD® Download) form. According to the supporting document (WORD® Download) submitted with the last ICR renewal only 24 of the 120 visits would be conducted by TSA personnel (Q-14, pg 5) with the remainder being conducted by contractors. There was no explanation given in the earlier ICR documents why there were 120 annual visits to the ‘Top 100 100 Most Critical Pipelines’ nor is there an explanation in this ICR renewal notice as to why this is being reduced to 90.

The final change is that TSA is reducing the number of expected follow-up email questionnaires to check up on the implementation of recommended practices. The earlier ICR documentation indicates 197 annual follow up emails (for 120 visits) while this notice indicates that only 90 such email follow-ups will be conducted going forward. This may reflect TSA experience that only one follow-up is necessary as this follow-up procedure was just established as part of the last revision of this ICR.

NOTE: TSA reports that they do not estimate a cost to industry beyond their hour burden estimate. Unfortunately, this is not uncommon.

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