TSA Publishes Pipeline Safety 60-day ICR Revision
Yesterday, the TSA published a 60-day information collection request (ICR) revision notice in the Federal Register (90 FR 36446-36447) for their Critical Facility Information From the Top 100 Most Critical Pipeline Operators. The changes proposed include a minor revision of the title and removing one of the three current information collections.
The table below shows both the old (current) and new (proposed) burden estimates for this ICR.
Burden Details
The three currently approved information collections are (links to description in the notice)
Critical Facility Security Review (CFSR) Form,
CFSR Follow-up, and
The cybersecurity collection was added to the ICR during and emergency revision in May of 2021 as part of a pipeline cybersecurity Security Directive. While the other two collections are voluntary, the cybersecurity collection was mandatory. The notice reports that: “All of the owner/operators have satisfied the SD's requirements, and TSA expects that going forward, fewer than 10 owner/operators would respond to the collection annually.” This justifies the TSA removing this collection from the ICR as the definition of ‘information collection’ under 5 CFR 1320.3(c) sets a minimum threshold for collections from 10 persons.
The table below shows the burden estimate for each of the three covered collections.
Public Comments
The TSA is soliciting public comments on this ICR notice. Comments may be submitted via a button on the Federal Register page for this notice or by email to the TSA (TSAPRA@dhs.gov). Comments should be submitted by October 3rd, 2025.
Commentary
Readers of this blog will certainly be aware of my history of negative comments about the adequacy of ICR notices from TSA. None of those comments apply here. TSA has done a good job of laying out the information that someone would need to provide useable comments about the burden estimates in this notice. Covered pipeline organizations should review the data and take the opportunity to let TSA and OMB about the adequacy of those burden estimates.