FR 2021-03404

The document in question originates from the Cybersecurity and Infrastructure Security Agency (CISA), part of the Department of Homeland Security (DHS). It involves a request for comments on a new information collection initiative concerning a training survey under the Interoperable Communications and Technical Assistance Program (ICTAP). The core aim is to collect feedback on three emergency communication courses: Communications Unit Leader (COML), Communications Unit Technician (COMT), and Information Technology Service Unit Leader (ITSL). The survey is intended to take about 10 minutes for completion and invites public comments until April 20, 2021.

General Summary

The document essentially calls for public participation in shaping training courses designed to bolster emergency communication capabilities across various governmental levels. Through ICTAP, participants will be able to influence crucial training elements by providing anonymous feedback on their experiences with the courses offered. The primary intended outcome is to refine, enhance, and keep the courses up to date with current needs and technologies.

Significant Issues

There are a few issues with the document that warrant attention. Firstly, there's redundancy in the description of the COML course, appearing twice, which adds unnecessary length and may dilute clear communication. Additionally, the document lacks insights into the effectiveness or prior feedback on these training courses, which makes it challenging to determine the necessity of this new survey. Moreover, while CISA outlines the potential cost burden for respondents, the methodology appears somewhat general and does not account for diversity in participant demographics or wage differences.

Impact on the Public

Broadly speaking, the survey provides an avenue for stakeholders in emergency communications to voice their opinions and contribute to improvements. However, the complexity of the comments submission process and the public nature of responses may deter potential contributors concerned about privacy or data use.

Impact on Specific Stakeholders

Emergency Responders and Government Personnel: The feedback gathered might lead to improved training, thereby equipping emergency personnel with better skills and knowledge to respond effectively to incidents. This can lead to more coordinated and efficient emergency responses across jurisdictions.

State, Local, Tribal, and Territorial Governments: These entities will benefit from improved emergency communication protocols resulting from enhanced training outcomes. Still, there is a need for a clearer explanation on how exactly the collected survey data will be transformed into actionable improvements.

CISA: For this agency, harnessing feedback will ideally provide a data-driven approach to enhancing their courses. However, the current survey approach may not fully capture the nuanced insights required to make substantive changes unless addressed more transparently and precisely.

Ultimately, the survey's success hinges not only on collecting input but also on how it converts that feedback into tangible course enhancements, which remains a point of concern given the document's lack of clarity on practical implications.

The document outlines the financial implications associated with the Interoperable Communications and Technical Assistance Program (ICTAP) Training Survey, a new initiative proposed by the Cybersecurity and Infrastructure Security Agency (CISA), part of the Department of Homeland Security (DHS).

Cost Estimations and Methodology

The agency has provided detailed calculations to estimate the cost of conducting the survey. To arrive at an estimated cost, CISA used a mean hourly wage reference from the "All Occupations" category, which is $25.72. This baseline is then adjusted using a load factor of 1.4597, leading to a fully loaded average hourly wage of $37.54. This adjustment accounts for additional costs such as benefits and overheads. However, while this calculation provides a clear figure, it does not consider the variations in respondents' actual wages or demographic differences that might influence these figures. The specificity in this calculation, while detailed, might lack granularity due to these omissions.

Respondent and Government Costs

The total estimated respondent cost burden for participating in the survey is $1,877, calculated over 50 hours required for 300 respondents, each spending about 10 minutes on the survey. The opportunity cost for respondents is briefly mentioned as $1,877.16, indicating a minimal adjustment to the primary estimate. Importantly, the text notes that respondents will incur no out-of-pocket costs, which should encourage participation without financial barriers.

Moreover, the document outlines a Total Annualized Government Cost of $4,082.67. This figure is presented without a breakdown of specific expenditures or allocations, which could improve transparency in how these government funds are justified and spent.

Analysis and Issues with Financial References

The financial references relate closely to several identified issues. For instance, while the document details how costs are estimated and allocated, it does not explicitly link these expenses to expected improvements in the courses offered by ICTAP. This raises questions about the practical utility of such financial outlays. Without a comprehensive analysis or past feedback on course effectiveness, it remains unclear how these financial investments will directly enhance the agency's functions or emergency communication strategies.

Furthermore, although the methodology used to estimate costs is detailed, the lack of external validation or references might affect the perceived reliability of these figures. Providing such data could strengthen the justification for the expenditure.

In conclusion, while the document offers a thorough financial breakdown related to the ICTAP Training Survey, the broader impact and justification for these financial commitments are less evident. Clarifying the specific outcomes expected from these allocations and improving transparency on government cost deployment could enhance the document's accountability and effectiveness.