OMB Approves CISA’s ICAR ICR

Yesterday, the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved an information collection request from CISA’s Emergency Communications Division (ECD) for their Incident Communications Activity Report (ICAR). This approval allows ECD to send incident commanders a form requesting information about the communications processes used in responding to the incident. Completion of the form is voluntary. The 60-day ICR notice was published on October 20^th, 2022.

While CISA admits in the Supporting Document (pg 6) provided to OIRA that it really does not know how many respondents there will be for this ICR it uses the number of 450 for the purposes of the burden calculation. The Supporting Document provides an interesting breakdown of the types of people that ECD expects to complete their form. With an expected 5 minutes to complete the form (understated by almost an order of magnitude, I am pretty sure) this provides CISA with an annual burden estimate of 38 hours.

One comment was received in response to the ICR notices published in the Federal Register. The commentor wanted to make sure that CISA was not duplicating the FCC reporting requirements on cell phone companies and the like.

This is one of those new ICR’s where it is really hard to find fault with the estimates because of a lack of prior history. It will be interesting to see how these estimates change when the ICR is renewed in three years.