End of TWIC Extended Expiration Date (EED) Program

TSA TWIC administrators have been publicly stating that the EED program is at an end. Today the official announcement was posted on the TSA website. It should be noted that the deadline to take advantage of this program - which I do not support because it does not include any updated background review - is December 23.

"End of Extended Expiration Date (EED) TWICs: The opportunity to obtain an Extended Expiration Date (EED) TWIC ends this year.  After December 31, 2014 current TWIC holders will no longer be able to obtain a replacement card extending the expiration date of their current TWIC by three years.  Since August 2012, U.S. citizens and U.S. Nationals holding a TWIC expiring on or before December 31, 2014 could obtain an EED TWIC by placing their order before their current card expires and paying the $60 card replacement fee.  The EED TWIC option will end as scheduled at the end of this year and will not be extended or renewed.

Eligible TWIC holders who wish to obtain an EED TWIC should place their order as soon as possible.  There is no benefit in delaying an EED card order since the EED expiration date is based on the expiration date of the currently held TWIC; not when the order is placed.  Orders should be placed prior to December 23rd to ensure processing prior to the end of the program.

EED TWICs can be ordered on line here; by calling the TWIC Call Center at (855) 347-8371 between 8 a.m. and 10 p.m. Eastern Time; or by visiting a Universal Enrollment Service Center (to find a location click here or call the TWIC Call Center)."   

 http://www.tsa.gov/stakeholders/transportation-worker-identification-credential-twic

TSA issues notices about affects of contractor change-over: mobile enrollment and EYO, center hours

The Transportation Security Administration has issued two notices about the change-over from contractor Lockheed Martin to contractor MorphoTrust. This changeover will affect  mobile enrollment and Enroll Your Own (EYO) arrangements and enrollment center availability and hours.  Both notices are reproduced below.

 UPDATED 05/23/2013: Transportation Worker Identification Credential (TWIC) – Mobile Enrollment and Activation Services TSA has been contacted by a number of stakeholders interested in establishing mobile enrollment and activation services at their facilities. TSA understands the flexibility that mobile enrollment and activation services provide, not only for TWIC renewals but for Extended Expiration Date (EED) TWICs.

 TSA has been contacted by a number of stakeholders interested in establishing mobile enrollment and activation services at their facilities. TSA understands the flexibility that mobile enrollment and activation services provide, not only for TWIC renewals but for Extended Expiration Date (EED) TWICs.

In April 2013, TWIC enrollment services began transitioning to a new contractor, MorphoTrust, under a Universal Enrollment Services (UES) contract. The UES contract includes enhanced mobile enrollment services, Enroll Your Own (EYO), and bulk payment arrangements.

Mobile enrollment services include the following options below:

 Mobile Enrollment Only – Mobile enrollment service without a mobile activation service

 Mobile Enrollment Plus Activation - Mobile enrollment and corresponding activation service

 Extended Expiration Date (EED) Bulk Order/Activation - Mobile service available via bulk orders, which includes the mobile activation service

MorphoTrust is now accepting orders for these services and will begin service in mid-summer 2013. Please submit mobile enrollment requests to Win Noble, MorphoTrust UES Communications Manager, at wnoble@morphotrust.com

Further details about mobile enrollment services and EYO capabilities will be available on the UES website – https://universalenroll.dhs.gov/ 

Please note that Lockheed Martin’s capacity to provide mobile enrollment and activation capability has been filled through the end of their contract. Please consider alternate plans such as utilizing fixed enrollment centers or requesting mobile services after completion of the UES transition (scheduled for end of June 2013). 

(Available at http://www.tsa.gov/sites/default/files/publications/pdf/twic/mobile_enrollment_and_activation_05_23_2013.pdf)

_____________________________________________________________

TWIC Stakeholders:  

The following TWIC enrollment centers will be closed on the date noted in an effort to assist their transition to a new enrollment provider as part of the Transportation Security Administration (TSA) Universal Enrollment Services (UES) initiative.  

As enrollment centers transition, their individual web pages will be updated to reflect any new logistics (e.g., location updates, new hours of operation, payment details, etc.).  Current information on enrollment centers can be found at:   

           http://www.twicinformation.com/twicinfo/schedule.jsp  

Below is a schedule of enrollment centers for the week of May 27-31, 2013, in which a Center will need to be closed on a given date to assist its transition.  Please note that during the week a site is transitioning, appointments will be blocked and the site will likely be busier than usual.  For appointments following a site’s transition, applicants can call the UES Call Center at 1-855 DHS-UES1 (1-855-347-8371), Monday through Friday: 8:00 AM - 10:00 PM EST.

Enrollment Center	Date Closed for UES Transition (Wk. of May 27-May 31)
American Samoa	05/28/13
Cedar Rapids, IA	05/29/13
Eureka, CA	05/29/13
La Plata, MD	05/29/13
Longview, WA	05/29/13
Pasco, WA	05/29/13
Port Fourchon, LA	05/28/13
Portland, ME	05/28/13
Providence, RI	05/28/13
Traverse City, MI	05/29/13

*Note: Following a site’s effective transition closure date above, check or money order payments for enrollments should be made payable to 'MorphoTrust USA', check or money order payments for card replacements and Extended Expiration Date (EED) services should be made payable to 'Lockheed Martin'.  For additional information and updates on the TWIC program, please visit http://www.twicinformation.com/twicinfo/.  

(From TWIC Stakeholder communications email)

OMB Announcement Concerning TWIC Reader NPRM from Chemical Facility Security News

My colleague Patrick Coyle at Chemical Facility Security News has once more proved how important it is to be a daily reader of his blog at http://chemical-facility-security-news.blogspot.com. He alerted us to the notice that OMB sent out yesterday (03/12/2013) that OMB has completed its mandatory 90-day review of the TWIC reader NPRM.  Below is information from the OMB announcement at reginfo.gov, http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201210&RIN=1625-AB21 Title: Transportation Worker Identification Credential (TWIC); Card Reader Requirements  Abstract: The Coast Guard is establishing electronic card reader requirements for maritime facilities and vessels to be used in combination with TSA's Transportation Worker Identification Credential. Congress enacted several statutory requirements within the Security and Accountability For Every (SAFE) Port Act of 2006 to guide regulations pertaining to TWIC readers, including the need to evaluate TSA's final pilot program report as part of the TWIC reader rulemaking. During the rulemaking process, we will take into account the final pilot data and the various conditions in which TWIC readers may be employed. For example, we will consider the types of vessels and facilities that will use TWIC readers, locations of secure and restricted areas, operational constraints, and need for accessibility. Recordkeeping requirements, amendments to security plans, and the requirement for data exchanges (i.e., Canceled Card List) between TSA and vessel or facility owners/operators will also be addressed in this rulemaking.  Agency: Department of Homeland Security(DHS)  Priority: Other Significant  RIN Status: Previously published in the Unified Agenda Agenda Stage of Rulemaking: Proposed Rule Stage  Major: No  Unfunded Mandates: No  Overall Description of Deadline: The final rule is required 2 years after the commencement of the pilot program.

Statement of Need: The Maritime Transportation Security Act (MTSA) of 2002 explicitly required the issuance of a biometric transportation security card to all U.S. merchant mariners and to workers requiring unescorted access to secure areas of MTSA-regulated facilities and vessels. On May 22, 2006, the Transportation Security Administration (TSA) and the Coast Guard published a notice of proposed rulemaking (NPRM) to carry out this statute, proposing a Transportation Worker Identification Credential (TWIC) Program where TSA conducts security threat assessments and issues identification credentials, while the Coast Guard requires integration of the TWIC into the access control systems of vessels, facilities, and Outer Continental Shelf facilities. Based on comments received during the public comment period, TSA and the Coast Guard split the TWIC rule. The final TWIC rule, published in January of 2007, addressed the issuance of the TWIC and use of the TWIC as a visual identification credential at access control points. The ANPRM, published in March of 2009, proposed a risk-based approach to TWIC reader requirements and included proposals to classify MTSA-regulated vessels and facilities into one of three risk groups, based on specific factors related to TSI consequence, and apply TWIC reader requirements for vessels and facilities in conjunction with their relative risk-group placement. This rulemaking is necessary to comply with the SAFE Port Act and to complete the implementation of the TWIC Program in our ports. By requiring electronic card readers at vessels and facilities, the Coast Guard will further enhance port security and improve access control measures.

Summary of the Legal Basis: The statutory authorities for the Coast Guard to prescribe, change, revise, or amend these regulations are provided under 33 U.S.C. 1226, 1231; 46 U.S.C. chapter 701; 50 U.S.C. 191, 192; Executive Order 12656, 3 CFR 1988 Comp., p. 585; 33 CFR 1.05-1, 6.04-11, 6.14, 6.16, and 6.19; Department of Homeland Security Delegation No. 0170.1.

Alternatives: The implementation of TWIC reader requirements is mandated by the SAFE Port Act. The Coast Guard is currently considering several regulatory alternatives regarding how to implement the TWIC reader requirements. These alternatives will be further explored in the NPRM.

Anticipated Costs and Benefits: The main cost drivers of this proposal are the acquisition and installation of TWIC readers and the maintenance of the affected entity's TWIC reader system. Costs, which we would distribute over a phased-in implementation period, consist predominantly of the costs to purchase, install, and integrate approved TWIC readers to their current physical access control system. Recurring annual costs will be driven by costs associated with canceled card list updates, opportunity cost associated with delays and replacement of TWICs that cannot be read, and maintenance of the affected entity's TWIC reader system. At this time, we are still developing our estimates for the impacts of this proposed rule. The benefits of the rulemaking include the enhancement of the security of vessel ports and other facilities by ensuring that only individuals who hold valid TWICs are granted unescorted access to secure areas at those locations. It will also implement the 2002 MTSA transportation security card requirements, thereby ensuring compliance with those statutes.

Risks: USCG used risk-based decision-making to develop this proposed rule.

TWIC Renewal

Yesterday I began the steps to perform the 5-year renewal of my TWIC. I have the following to report:

Positives:

1. Both TSA HelpDesk personnel that I spoke with were extremely courteous, apologetic about the wait, and seemed to be informed about the process.

2.  I received email notification about the transaction within minutes of its completion.

Negatives:

1.  I was unable to use the website to pre-enroll, as directed by the TSA TWIC FAQs. When I entered my personal information, I was moved onto a screen that informed me that I already have a TWIC and needed to enter a UserID and password. I could not recall whatever it was that I had selected 5 years ago.  I attempted to use both the “forgot UserID” function and the “forgot password” function. Clicking on these links led to a screen in which I was required to enter the answer to two challenge questions. The screen would not accept my answers, although I know they were correct.  I tried mis-spelling combinations and even that was unsuccessful. I also got an error message once as I was moving between screens. There is no moving forward from the challenge question screen so I was stuck. The option to use the website to pre-enroll was now closed to me.

2.  I then called the HelpDesk and experienced a combined wait on hold of one hour.  When an agent came on the line, she advised me that you cannot enroll for a 5-year renewal via the website.  She stated, “We need to help you with that.”  She asked me if I had ever contacted the HelpDesk before. I had, and she pulled up a case number and my card information. She said I would need to remember the case number as she was going to transfer me to another agent for payment and he would need the number.  There was a second lengthy wait and another agent came on the line and to take my ID and payment information.  This agent stated that the only way to renew the card for 5 years was to walk into an enrollment center, but that he could renew my TWIC for 3 years under the EED program. I did opt for the 3 year EED although I disagree with its basic premise because it excludes the background checks. Later I asked the agent for clarification about the procedure for renewing for 5-years and he stated that you can pre-enroll online but it is just as quick to walk into the enrollment center. I told him about the problems I was having with the website.  He was apologetic but stated that the website was a different branch of the program. So I basically got two answers as to whether one can use the website for the 5-year renewal: “yes” and “no”.

3. It appears to me from my experience that you cannot use the HelpDesk for the 5-year renewal, and that the website is experiencing problems so you cannot pre-enroll via the website. This leaves open the question: is possible that TSA is funneling many renewal requests into the EED option? This would greatly speed up and streamline  the renewal process but it defeats the purpose of the card.  We need at least an every-five-year snapshot of the backgrounds of the people who are being granted unescorted access to the secure areas of regulated facilities and vessels.