FR 2021-03723

The recent notice from the Transportation Security Administration (TSA), published in the Federal Register, announces changes to the collection of information for the Transportation Worker Identification Credential (TWIC®) Program. The TSA aims to revise its existing processes, primarily for reducing costs and time commitments for those who apply for or renew a TWIC® card. The changes include online renewals and fee reductions for specific applicants such as certain merchant mariners, reflecting ongoing efforts to streamline the credentialing process.

Summary of the Document

In essence, this notice indicates that the TSA is collaborating with the Office of Management and Budget (OMB) to revise their procedures for collecting data. This is part of their compliance with the Paperwork Reduction Act (PRA). The TSA collects both biographical and biometric information to perform security threat assessments (STA) for those applying for or holding a TWIC®. Applicants are now encouraged to participate in an optional satisfaction survey to provide feedback on their experience during this process.

Significant Issues and Concerns

The document is replete with technical terms that may be challenging for a layperson to comprehend, such as "OMB control number" and "security threat assessment (STA)." These terms are not widely understood by the general public and could hinder transparency and understanding of what the process entails.

Moreover, the TSA does not provide details on how the sensitive biographic and biometric information of applicants will be stored or protected, raising potential privacy concerns. Another area of ambiguity pertains to the fee reductions, particularly for specific merchant mariners, as the criteria or rationale for these fee adjustments is not fully explained, which might appear inequitable.

Furthermore, the document does not offer a detailed breakdown of the costs associated with this program, which total approximately $64.8 million annually. Such a financial outline may foster skepticism regarding the efficient use of resources.

Public and Stakeholder Impact

For the general public, these procedural revisions may result in a quicker, less expensive process for acquiring or renewing a TWIC®. This is especially relevant for individuals who require unescorted access to secure areas within national transportation systems—including maritime facilities regulated by the Maritime Transportation Security Act.

For specific stakeholders, particularly those in the maritime industry or transportation sectors, the changes could have significant implications. The option for online renewals may substantially lessen the burden of physically visiting enrollment centers, thus saving time and resources. However, the ambiguous criteria for fee reductions and lack of specific detail on data security measures might lead to unease among applicants and current cardholders.

Overall, while efforts to streamline operations could positively affect many applicants' experiences, the TSA must strike a balance by providing clearer guidelines and ensuring that sensitive information is adequately protected. Providing transparency in processes, such as fee assessments and data handling, would enhance trust and satisfaction among stakeholders.

The document from the Federal Register outlines the revisions related to the Transportation Worker Identification Credential (TWIC®) Program handled by the Transportation Security Administration (TSA). This commentary will focus on the financial references mentioned within the document and how these allocations tie into identified issues.

The document specifies several financial aspects related to the TWIC® Program:

1. Enrollment Fee: During the enrollment process for the TWIC® Program, TSA charges a standard fee of $125.25. This fee covers the necessary procedures to verify the identity of applicants and conduct a comprehensive security threat assessment (STA).

2. Replacement Card Fee: If a TWIC® card is lost, damaged, or stolen, the cardholder is responsible for notifying TSA. To receive a replacement, a fee of $60.00 is required. This provision ensures that cardholders maintain their credentials but at a cost that could be burdensome for some individuals, especially if multiple replacements are necessary.

3. Fee Reduction for Certain Mariners: The document identifies that certain Merchant Mariners may be eligible for a fee reduction. If these mariners choose not to receive the physical TWIC® card, the fee is reduced by $27 to reflect only the enrollment and vetting segments. However, the text does not elaborate on how this reduction is determined, which might raise questions about the transparency and fairness in the calculation and justification of this fee variance.

4. Estimated Annual Cost: The overall estimated annual cost attributed to the TWIC® Program is stated to be $64,842,153. This substantial amount, however, lacks a detailed breakdown of how costs are allocated across various program components. Without such transparency, it becomes challenging to assess potential inefficiencies or areas of wasteful spending.

The financial considerations in the document align with several identified issues:

• Fee Transparency and Fairness: The document references a fee reduction for some mariners but doesn't provide enough detail on its calculation or justification, which might lead to concerns about fairness and consistency. Such a lack of clarity could impact stakeholders' understanding and trust in the program's financial administration.

• Cost Breakdown: The absence of a clear breakdown of the estimated annual cost of over $64 million makes it difficult for stakeholders to evaluate the financial efficiency of the program. This omission could lead to questions about possible wasteful spending and whether the fees charged to applicants align appropriately with the operational costs of administering the TWIC® Program.

These financial elements are central to understanding the economic implications of the TWIC® Program and directly impact applicants and operational transparency. Greater clarity and detailed justification of fees and costs could enhance the program's accountability and the stakeholders' confidence in its financial governance.