TSA Publishes 30-day Pipeline Security ICR – 03-09-19

The Transportation Security Administration is publishing a 30-day information collection request (ICR) notice in Monday’s Federal Register (on-line today; 84 FR 8738-8739) for their Pipeline System Operator Security Information ICR. The 60-day ICR notice was published on October 29^th, 2018. It does not appear that there were any comments submitted in response to the 60-day ICR notice.

The notice is billed as an extension of the current ICR, but it also contains an unremarked revision of the burden estimate. The table below compares the burden estimate in this notice and the previously approved ICR.

	Current ICR	This Notice
Responses	60	32
Burden Hours	30	16
Burden Cost	Not Provided	Not Provided

Comment

Neither the 60-day notice nor the current notice provides any justification for the change in burden estimate. The lack of justification for the change in burden estimate makes it impossible for the public to accurately comment on the accuracy of the burden estimate. More importantly, the failure to provide the public specific notice that there has been a change in the burden estimate makes it unlikely that people would take the time to prepare a comment on the ICR. In effect this makes it appear that the ICR notice is deliberately misleading and incomplete.

I urge the Office of Information and Regulatory Affairs to return this ICR extension to TSA for new public notices providing the missing information and properly identifying this as an ICR revision, not a simple extension.

NOTE: This blog post is being submitted to OIRA as a comment on this ICR notice.