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 is the first week into the comment
extension period. One comment was published before the old comment period
end on Tuesday and the remaining five comments were posted on Friday.
GAO Report
The GAO report was mentioned this
week. A private
individual had a comment just on the GAO issues, suggesting that the “GAP performance
issues” need to be resolved before the TWIC Reader Rule moves forward. A maritime
union recommended that the GAO recommendation for a security assessment of
the TWIC program (not just the TWIC Reader) is conducted
Every Entry Rule
Complaints continue (here,
here
and
here) about the requirement to use the TWIC as a flash pass every time an
individual enters a secure space on Risk Group B and C vessels.
Facilities Serving Multiple Passenger Vessels
One commenter
wanted clarification about the risk group status of a facility that only served
Risk Group B and C vessels, but that might have multiple vessels being serviced
at the same time putting it over the 1000 passenger limit.
Need for TWIC Readers
An industry
association questioned the need for adding TWIC Readers to security plans
for Risk Group A vessels and facilities. They did not see how it would
materially increase security or reduce the potential occurrences of Terrorism
Security Incidents (TSI). A maritime
union agrees and extends that to the TWIC program in general. Neither
comment will be effective in this particular case because both the program and
the TWIC Reader have been mandated by Congress, not the Coast Guard.
Posts
No comments:
Post a Comment