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PJ,Regarding your next-to-last paragraph, I’m not so sure that the deatbe would shift to alternate means of TWIC activation. I don’t think the Congressional types who advocate mailing TWICs are knowledgeable about the distinction between delivery and activation. I suspect they think that a TWIC is ready to go as soon as it’s delivered. If they were to realize TWICs need to be activated, the deatbe would still be over worker convenience versus security. Those still in favor of convenience for their constituents would simply want to see activated TWICs delivered by mail. Secondly, if the main points of the Coast Guard ANPRM on TWIC readers make it into the Final Rule, a lot of facilities (although probably not most chemical facilities) will still be using TWICs as flash passes most of the time. In this situation, mailing even unactivated TWICs will continue to present a significant security risk. Ironically, mailing TWICs might not be that great a convenience. The GAO Report identifies a problem involving mail sent to people who have moved (and I suspect that the maritime population is more prone to frequent moves than most). Think of the inconvenience of not having a TWIC because it was bouncing around in the mail system, trying to catch up with you (assuming you left a forwarding address).As to use of TWICs in non-maritime CFATS facilities (your last paragraph), TSA’s TWIC Program Manager briefed the National Maritime Security Advisory Committee last Tuesday on the status of the TWIC Pilot Program. In response to a question about allowing non-maritime employees of cross-modal operators to obtain TWICs so that the cross-modal operators could have a single identification system, he was less than enthusiastic. His lack of enthusiasm for issuing TWICs to these transportation workers seemed to me to involve more than just his specific answer that it would require a regulatory change. If that’s the attitude of TSA generally, they’d likely be even less in favor of providing TWICs to non-transportation workers. Not to say that the higher ups in DHS couldn’t impose it on TSA.Regards,JCWB

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