Those of us who were involved in CFATS discussions relative to research campuses back in the 2007 time frame may be interested in this Federal Register notice about a follow up study that compared the actual cost of compliance with projected cost of compliance.
The key finding of the study is:
"Based on the retrospective analysis, CISA believes that the regulatory impact assessment (RIA) for the 2007 CFATS IFR overestimated the costs of the program imposed on chemical facilities and that the actual costs are 83 percent lower than previously estimated.
"Because CFATS was a new regulatory program that was developed under a six-month Congressional deadline, there was limited time to conduct economic studies and collect data to establish the pre-statutory security baseline at high-risk chemical facilities.[2] As CFATS was a new program, there was no historical data that could inform the analysis. In order to meet the Congressional deadline, the Department relied heavily on the elicitation of subject matter expert (SME) judgment to estimate the cost of the regulation in the 2007 RIA.
"Now that CISA has fully implemented CFATS, CISA was able to replace the SME judgments with historical data provided by industry through the Chemical Security Assessment Tool, CFATS compliance data, and lessons learned. As a result, the retrospective analysis provides a more accurate estimate of the cost that the CFATS program imposed on chemical facilities between 2007 to 2017. The retrospective analysis resulted in a decrease in the estimated 10-year cost, discounted at 7%, of CFATS from $9.84 billion to $1.68 billion. The main drivers of this substantial reduction in cost were the 2007 CFATS IFR's overestimation of: (1) The number of chemical facilities that would be covered by CFATS; and (2) the costs of security measures implemented by CFATS covered facilities."
It makes me wonder about some of the statements being made about the pandemic response we're going through now.
- Ralph
From: Federal Register Subscriptions <subscriptions**At_Symbol_Here**mail.federalregister.gov>
Subject: [FR] Documents citing 79 FR 48693
Date: June 20, 2020 at 4:20:33 AM GMT-4
subscription results for Monday, June 22nd, 20201 matching document
Documents citing 79 FR 48693
MATCHING DOCUMENTS
Homeland Security Department
Proposed Rule
Retrospective Analysis of the Chemical Facility Anti-Terrorism Standards
FR Document: 2020-13147
Citation: 85 FR 37393 PDF Pages 37393-37394 (2 pages)
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Abstract: Through this document, the Cybersecurity and Infrastructure Security Agency (CISA) is making available a retrospective analysis of the data, assumptions, and methodology used to support the 2007 interim final rule for the Chemical Facility Anti-Terrorism Standards (CFATS) program. The purpose of the retrospective analysis is to provide an updated assessment of the costs and burdens of the CFATS program. Based on data observed by the program for over ten years, CISA estimates that the actual...
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