This is part of a continuing series of blog posts on the public comments filed in the previous week for the Coast Guard’s TWIC Reader NPRM. The previous posts in the series are listed below.
Half-way through the 60-day comment period on this notice of proposed rulemaking and the Coast Guard has received its first corporate comments. The four comments received in the last week were from:
• Passenger Vessel Association; and
The comments from the Lake Carriers’ Association were generally positive, supporting the failure to require TWIC readers for Risk Group B and C vessels and facilities. The American Institute of Architects comment was a copy of a slide presentation about TWIC Readers used in a continuing education course. The IBIA comments included a suggestion that the Coast Guard should expand the TWIC Reader requirement to include Risk Group B vessels and facilities. The Passenger Vessel Association comment objected to the use of the TWIC as an access control tool (instead of just a proof of vetting document) and suggested that the recurring access provisions include in the ANPRM should be restored, particularly for passenger vessels and terminals.
The IBIA comments were actually a copy of the prepared remarks that they presented at the TWIC Reader Meeting in Arlington, VA on April 18th. Unfortunately, the Coast Guard has yet to publish the transcripts of the comments from that meeting or the Houston, TX meeting on April 25th (okay, I’ll give them that that was just last week).
I expect that we will be seeing more corporate comments like these as we approach the end of the comment period on May 21st.