TSA Publishes EXIS ICR Revision Notice

Today the DHS Transportation Security Administration (TSA) published a 60-day information collection request (ICR) notice in the Federal Register (82 FR 39900-39901) seeking to renew and update their ICR supporting the Exercise Information System (EXIS).

The TSA is estimating an 19.8% annual increase in EXIS participants. This is significantly less than the 67% increase that TSA estimated in their previous EXIS ICR. Still an increase from 364 participants at the last ICR submission to the apparent 6581 used as a base for this estimate in just three years is impressive.

There is no explanation on how TSA reached this 19.8% growth rate estimate. In fact, the 19.8% rate was not actually provided by TSA, I had to calculate it from the numbers provided by TSA in the notice. This is a common problem with the ICR submissions made by TSA (and many other federal agencies). I wish that more agencies prepared ICR submissions in the same level of detail that the DHS Infrastructure Security Compliance Division has been using in their numerous ICR submissions for the CFATS program.

The TSA is soliciting public comments on this ICR revision. Comments may be emailed to TSA (TSAPRA@dhs.gov). Comments should be received by TSA by October 23^rd, 2017.

Commentary

The TSA continues to choose not to use the Federal eRulemaking Portal to manage the comments on their EXIS ICRs. This has the perhaps unintended consequence that the public is not privy to whatever comments are made on the ICR. We have to trust that the TSA is not ignoring any serious concerns raised in the comment process.

For example, the supporting information page on the previous ICR submission shows that there were three public comments submitted. Two of those submissions were submitted years before the previous 60-day ICR was published. Both, were actually submitted for the first ICR for the program. The apparent 3^rd comment is nothing more than a copy of an email the respondent received about the 60-day ICR notice. To be fair the inclusion of the earlier comments is just as likely to be an error made by the OMB’s Office of Information and Regulatory Affairs as one made by TSA.

For all intents and purposes, it looks like there were no comments received on the previous ICR. While that is not an unusual occurrence, we have no independent method of verifying that apparent fact.

BTW: I will be emailing a copy of this post as a comment on this ICR.