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.
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.