Review - Changes in TSA Rail Security Burden Estimation

On Tuesday, I reported that the TSA had published a 30-day ICR extension notice in the Federal Register. I noted that there was a minor discrepancy in the reported burden number. Since then, the OMB’s Office of Information and Regulatory Affairs (OIRA) has published the supporting document submitted by TSA in their extension request for this ICR. While this information explains the burden discrepancy, the total data submission to OIRA makes it clear that this is an ICR revision, not a simple extension.

The table below shows the data abstracted from Section 12 of both the submitted supporting data document and the supporting document for the currently approved ICR.

	Proposed Estimate		Current Estimate
	# Responses	Burden	# Responses	Burden
Security Coordinator	475	475	475	475
Location Reporting	327	164	655	328
Security Concerns	4,961	4,961	4,961	4,961
Chain of Custody	214,000	107,000	214,000	107,000
Total	219,763	112,600	220,091	112,764

While there is nothing nefarious about the discrepancies in the changes made in the supporting information for this information collection revision, the TSA continues to have substantial problems with their ICR documentations. While the recent Federal Register notice classified this as an extension of a currently approved collection, this is clearly a revision of the ICR. TSA has provided OIRA with an adequate explanation for the revision, but TSA continues to be sloppy and vague about their public reporting about their ICRs. Unfortunately, OIRA will undoubtedly approve the changes to this ICR, as they have so often in the past.

For more details about the change in burden estimate, as well as other changes in the information collection request, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/changes-in-tsa-rail-security-burden - subscription required.