Yesterday the OMB’s Office of Information and Regulatory Affairs approved a revision to the information collection request (ICR) from the DOT’s Pipeline and Hazardous Material Safety Administration (PHMSA) for “Hazardous Materials Security Plans”. The changes were necessitated by the approval of PHMSA’s final rule on “: Liquefied Natural Gas (LNG) by Rail”. That rule added natural gas as a commodity is subject to routing requirements.
The supporting document [.docx download link] PHMSA provided to OIRA supporting the request to revise the ICR does a good of describing the need for the revision (para 1) and showing the calculations (para 12) for the revised burden estimates, but it does not specifically quantify the change in the burden. That is found in OIRA’s announcement; eight new annual reports are expected with a total additional burden of 680 hours. This will be borne by the railroads hauling the LNG performing their route security analysis and alternative route analysis reporting.
Interestingly, the LNG by rail final rule only estimated a 677 hour burden increase for this ICR. A minor difference to be sure, but not one explained in the data submitted to OIRA.
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