Review – TSA Publishes Surface Transportation Security ICR Notice

On Monday TSA will publish (available online yesterday) a 60-day information collection request (ICR) revision notice in the Federal Register (90 FR 16697-16698). The TSA is intending to combine two existing ICRs into a single document to support their surface transportation security program. The combined ICR would be reported under RIN# 1652-0051. The two existing ICRs are:

1652-0051 - Rail Transportation Security, and

1652-0066 - Security Training Program for Surface Transportation Employees

The table below shows the current burden estimates for the two ICRs as well as the combined burden being reported in Monday’s ICR Notice. There is one ‘apples and oranges’ problem with this data, the ICR notice reports the number of ‘respondents’ not the number of responses.

TSA has not explained the drastic decrease in burden estimate for the combined ICR.

Public Comments

TSA is soliciting public comments on the accuracy of the data presented in this ICR notice. Comments may be submitted via email (TSAPRA@dhs.gov). Comments should be submitted by June 20^th, 2025.

Commentary

The TSA has a long history of providing inadequate information to support changes to the burden estimates in their ICR notices. This makes it difficult for the affected public to provide meaningful comments on “the accuracy of the agency’s estimate of the burden of the proposed collection of information” being proposed by the TSA as required by 44 USC 3506(c)(2)(A)(ii). Unfortunately, OIRA only apparently cares about the supporting information provided to them after the 30-day ICR notice is published as OIRA has never taken TSA to task for their inadequate information sharing.

 

For more information on this ICR notice, including a look at why the burden estimate is almost certainly too low, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/tsa-publishes-surface-transportation-e9b - subscription required.