Sunday, May 19, 2013

Comments for TWIC Reader NPRM – 5-18-13

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 we have 14 submissions, two of which come from the same person and one from a previous commentor. There is no indication that any of these commenters were affected by the recent congressional hearing on the TWIC Reader Pilot, but it may be just too soon to expect responses to reflect that hearing.

Flash Pass for Each Entry

The requirement for a TWIC holder to present the TWIC for visual inspection upon each entry to secure spaces on board vessels continues to be identified as a concern by many commenters, particularly passenger vessel operators.

TWIC Readers on Vessels

An individual commenter made an interesting observation about requiring TWIC Readers on Vessels. He noted that all vessel entries are via facilities thus entry onto a vessel is already covered by a TWIC Reader at the facility. This does not take into account the entry of personnel at foreign ports or access to vessels underway (pilots for instance).

TWIC Reader Pilot Participant

A commenter that was a participant in the TWIC Reader Pilot noted that they experienced “failed readers, failed hot-list, excessive time burden (and) lost data”. They note that: “As a TWIC Pilot Program (sic) participant, we strongly believe the pilot has not adequately demonstrated the justification of the cost of the program.”

Vessel vs Facility Reader Requirements

A commenter noted that they were told at a regional public meeting that passenger facilities handling vessels certified to carry over 1,000 passengers would be required to utilize TWIC Readers even if the vessels serving the facility were not because of the 14-person provisions. The commenter argues that facility reader requirements should be more closely linked to the reader requirements of the vessels that serve the facility.

Comment Period Extension

The original comment period for this NPRM would have ended this coming Tuesday. We would have expected to see a surge in comments being submitted on Monday and Tuesday. With the one month extension already having been announced, it will be interesting to see if this has any significant effect on those expected submissions.

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