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Government Update/Maritime Security TWIC: A Bridge Too Far? Chief Petty Officer Adam Dixon and Petty Officer Second Class David Houck check the holograms, watermarks and photos of the passport of one of a 22-member crew aboard the Captain Corelli during a security boarding at the Port of Anchorage today. In addition they checked all 22 passports against the crew manifest and the I259 form provided by the Bureau of Customs and Immigration for the 15 members of the crew without visas who may not come ashore. The Captain Corelli is a 529-ft. cargo vessel from Hong Kong. (USCG photo by PA2 Sara Francis) Dennis Bryant, Senior Counsel, Holland & Knight LLP On September 17, 1944, thousands of British paratroopers landed up to 100 miles behind German lines in Holland to secure bridges so that Allied forces could circumvent the Siegfried Line and hopefully bring World War II in Europe to a swift conclusion. Unfortunately, Operation Market Garden didn't work out. The bridge at Arnhem proved to be 'a bridge too far' and was outside the reach of supporting ground troops. The Allies were forced to retire and regroup and the end of the conflict was delayed many months, resulting in numerous additional casualties. The Transportation Worker Identification Credential (TWIC) program may be headed down the same path. TWIC is mandated by the Maritime Transportation Security Act of 2002 (MTSA). The statute has several very distinct provisions. It broadly defines the TWIC; describes the physical boundaries within which a TWIC is required; designates who is potentially eligible to have a TWIC; identifies persons who may not have a TWIC; and establishes restrictions on use of information obtained during the TWIC application process. The rationale for the TWIC program is somewhat inarticulately stated as follows: This provision "establishes a national standard for issuance of transportation security cards whose purpose is to control access to ensure terminal areas to only authorized personnel." Like Operation Market Garden, though, the TWIC program has proven to be highly complex and to rely for its success on numerous sub-programs. Many of those sub-programs have failed to deliver as expected and the TWIC program is in serious danger of collapse unless it regroups. The TWIC program has been in development since 2002, but it was not until May of 2006 that the official Notice of Proposed Rulemaking (NPRM) was published in the Federal Register. That was followed by four hastily-arranged public meetings and a short 45-day comment period. The few public meetings and the short comment period were both heavily criticized by the maritime community. The MTSA directs that the TWIC include biometric data, but does not define any particular parameters for what data is to be incorporated or how the incorporation is to be effected. TSA has elected to utilize the same Federal Information Processing Standard (FIPS) as has been established for personal identity verification of federal employees and contractors. This decision, when made, was wise, because then the TWIC cards and readers could be based on proven technology. The biometric data to be collected for the TWIC process would consist of the following: (1) a full set of fingerprints used to perform law enforcement checks as part of the identity proofing and registration process; (2) an electronic facial image used for printing the facial image on the card as well as for performing visual authentication during card usage; and (3) two electronic fingerprints to be stored on the card for automated authentication during card usage. The fly-in-the-ointment is that the FIPS program has not been completed. While the basic FIPS standard has been recently approved, numerous details have yet to be resolved before the program can be implemented for its intended audience. It will not be possible to roll out the TWIC program until the underlying structure of FIPS has been fully completed and implemented. The MTSA directs that the TWIC be 22 Maritime Reporter & Engineering News