Review - TSA Published 60-day ICR Revision for Surface Security Training – 1-10-23

Today the TSA published a 60-day information collection extension notice in the Federal Register (88 FR 1397-1398) supporting their Security Training for Surface Transportation Employees regulations. While this is listed as an ICR extension, the TSA is making a major change to the burden estimate, reporting a reduction in the overall annual burden from 12,318 hours to 4,623 hours, reportedly due to a reduction in the number of reporting entities from 289 to 218.

Commentary

This is the first update of this information collection request. The data provided in the initial ICR notice was an estimate that was broadly based on TSA’s expectations of industry’s response. It is not unexpected that those expectations would be found to be incomplete, thus changes in the burden estimate are to be expected. Having said that, this ICR is much too complicated in the response and burden estimate for TSA to be able to glibly state that a reduction in the estimated burden from a smaller than originally estimated number of responses provides an adequate explanation of the change in burden estimate for this ICR, especially where there is a 62.5% reduction in burden estimate from a 24.6% reduction in the number of expected responses.

 

For more details about this complex ICR, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/tsa-published-60-day-icr-revision - subscription required.