Tuesday, April 7, 2015


Yesterday the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved the renewal an information collection request (ICR) from TSA for their Exercise Information System (EXIS) program. I briefly discussed the ICR last year and the EXIS program back in 2011. There is not much else publicly available on the system beyond its remarkably uninformative web site.

Earlier I commented about the change in the collection burden for this ICR renewal. I was correct that the large decrease in current responses is due to an overly energetic estimate of participants in the original ICR. As I noted earlier the current EXIS base of participants is 364 instead of the 10,000 originally estimated.

I questioned the planned increase in user numbers provided by TSA in the 60 day ICR notice since the increase was only vague explained. The OIRA web site provides a link to the supporting documentation provided by TSA which provides a fuller explanation. First TSA expects the previous year’s organic growth of 67% to continue on in future years; that’s probably not sustainable, but it is a legitimate basis for estimation.

There is also a little bit better explanation of the TSA outreach program that forms the basis for the bulk of the projected annual increase in EXIS users. It seems that TSA holds an ‘outreach event’ once every three years for each of the modes in the transportation security sector. TSA expects that 1% of the participants at each event will sign up for EXIS participation. That doesn’t seem unreasonable until you note that TSA figures assume that every transportation organization in the country will be represented in the appropriate outreach event. I really doubt that each of the 1,075,000 highway sector organizations will make it to any given event.

Oh well, I suppose it is better for TSA to over-estimate the burden associated with the ICR than to underestimate it. Unless, of course, TSA is using the numbers from this OMB approved ICR to justify funding requests. I’m not saying that that is happening, but it would certainly be a ‘good’ reason for being so generous with project growth estimates.

NOTE: If any reader has used EXIS to plan an exercise or participated in an EXIS planned exercise, I would certainly like to hear about the experience. This sounds like a useful program, but only if it actually delivers on the promises made.

No comments:

/* Use this with templates/template-twocol.html */