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.
This week saw only four new comments posted on the TWIC Reader
docket on the Federal eRulemaking Portal. Again this is still early in the
comment period for the major players to have comments posted so it is not
unusual that this week’s comments come from three individuals and an LLC.
Anti-TWIC
The TWIC program has many detractors and two of this week’s
commenters are certainly counted in that group. Kenneth
Deloach makes an interesting observation in his comment:
“Homeland security is looking at
our industry from the wrong direction. Why try to take over a tow when you can
launch a pleasure boat filled with explosives from a public boat ramp and
access all docks and commercial marine vessels from the waterways.”
Harry
Thompson adds this observation:
“But believe me (I am a Barge
Captain for over 30 years) when I say this ‘A child could gain access to most
terminals’ without anyone knowing it.”
Periodic Risk Group A
The problems of facilities that only fall under the Risk
Group A definition periodically have legitimate concerns about bearing the
cost of a TWIC Reader when it will only be required to be used for very limited
periods of time. Both Greer
McKeen and Gunther
Hoock describe their situation in this regards.
I don’t see the Coast Guard making substantive changes to
the Risk Group A requirements. This will almost certainly lead to port security
firms offering portable TWIC Readers as a service for these types of
situations.
Posts
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