OMB Approves CI Security Clearance ICR

Yesterday the OMB’s Office of Information and Regulatory Affair (OIRA) announced that it had approved an information collection request (ICR) from DHS National Programs and Protection Directorate (NPPD) for information collected to support the Critical Infrastructure/Key Private Sector Clearance Program (CI PSCP). This is the security clearance program for members of the Sector Coordinating Council (SCC) and selected representatives of various private sector critical infrastructure organizations.

This is a revision of an existing ICR (1670-0013). There were significant changes made to the collection burden estimates for this revision. The estimated number of annual information collection requests was increased from 450 to 500 to reflect the increase in submissions to this program in 2013 and 2014. According to the ICR approval notice OMB is reporting that the hours burden for this collection has increased from 75 hours to 833 hours. That is almost certainly a misprint because the supporting information provided by NPPD to OIRA (pg 6) indicates that the total hour burden for this ICR is only 83.33 hour (500 x 10 minutes/submission). This reflects no change in the per request burden estimate.

Commentary

As various threat information sharing programs start to come on-line or expand, this program at DHS will also likely see and expansion of the number of security clearance requests. Depending on how those programs are structured, DHS will expand this collection effort or initiate new ones. One would like to think that they would use the same form as the current program which would lead to an expansion of the expected burden numbers for this ICR.