Sunday, June 23, 2013

Comments for TWIC Reader NPRM – 6-22-13

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.

There were 10 comments posted this week, a record for this docket but hardly a major closing comment period for a rule that has been as long awaited or as recently debated in Congress as this one.  Maybe the port security community knows more about the TWIC Reader than does Congress or the GAO.

Address GAO Report Concerns

A chemical bulk terminal operator recommends that the final rule be delayed until the Coast Guard and TSA have a chance to address the concerns expressed in the recent GAO report on the TWIC Reader Pilot. This argument was also raised by a member of Congress, a barge operator.

Expand TWIC Reader Requirements

A port security consultant recommends that the TWIC Reader requirements be extended to any Group B or C facility that shares a fence line with a Risk Group A facility. They argue that the common fence line would be easier to access from a lower risk facility if that facility does not require biometric verification of identity and TWIC status. They also argue that each Risk Group B and C facility be required to have one portable TWIC Reader available to respond to sudden changes is security situation that might require the deployment of a TWIC Reader.

An identification card vendor association make the point that Congress did not specify differing security standards based upon some arbitrary risk group ranking. They note that the use of the TWIC as a visual flash pass ID makes it no more useful than any other printed ID card.

Multiple Entries

The chemical bulk terminal operator recommends that the multiple entry rule be changed to require that only during the initial entry to a facility in a 24-hour period should an individual have to utilize a TWIC Reader to gain access. During subsequent entries the TWIC could be used as a flash pass in accordance with USCG Policy Advisory Council (PAC) 08-09 [No link available, I’m sorry, but the CG Homeport page does not provide for permanent links to documents].

A local water taxi company makes a point made in multiple earlier comments that requiring the showing of a TWIC upon every entry to secured spaces on smaller vessels with limited crews makes no sense.

Exempt Smaller Facilities

A marine service organization thinks that automatically making barge fleeting facilities that handle Certain Dangerous Cargo (CDC) Risk Group A facilities ignores the security realities of these facilities, particularly the limited access that is available. An Alaskan cruise line operator expresses the same concern for small cruise facilities.

Crewmember Definition

The barge operator would like to see the final rule include a definition of ‘crewmember’ based upon the definition in Navigation Vessel Inspection Circular 03-07. This is particularly important when considering the 14-crewmember exemption for requiring a TWIC Reader on Risk Group A vessels.

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