Sunday, April 7, 2013

Comments for TWIC Reader NPRM – 4-6-13

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.


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.

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