Comments for TWIC Reader NPRM – 3-31-13

Just a little over a week since the Coast Guard published their NPRM to implement the use of TWIC Readers there is a public response on the public docket on the Federal eRulemaking Portal. There are also links to three supporting documents on the site.

Supporting Documents

The three supporting documents are:

• Homeland Security Institute IV&V of TWIC Reader Requirements;

• TWIC Reader Pilot Program Final Report

• Preliminary Regulatory Analysis and Initial Regulatory Flexibility Analysis

The first is an independent verification and validation of the TWIC Reader requirement. There have been more and more calls for this type of peer review of DHS assessments and requirements. It is important for this document to be included in this docket.

Comments

With just a little over a week into the comment period it is not unusual for there to be only a single comment on the NPRM posted. As is to be expected it is from a single individual, not a company or organization; they take longer to formulate their replies. Just as expected, it is a negative comment about the TWIC program and not an actual comment on the NPRM. Even though they will have no effect on the TWIC Reader implementation I expect that we will see more of these types of comments.