There have also been issues of parking - like where to park trucks towing 50-foot trailers while the drivers enter a port office to sign up for TWIC. Some ports have had to consider off-site parking areas for such vehicles, adding another challenge to simplifying the process.
"They are so space constrained at many of our large ports that they don't have a place for truckers to park while they go in to register their TWIC with a PACS," said Zivney. "There are over 20 operators at that Port of Long Beach and seven operators at the Port of Los Angeles. They need to look at a shared enrollment site. Right now the operators are all prepared do that separately on their individual PACS. There wasn't money in the grant programs for the TWIC reader pilot for shared PACS registration facilities."
Getting ready for the pilot projects has also been a challenge, and that comes down to money again. One aspect of the pilot project is the testing of different reader solutions from different reader manufacturers.
"We're one of the companies that have bid on it, and we're already installed at some of the operators, and we'd like to be involved with the pilots. They haven't released the grant funds yet, and it doesn't look like vendors of readers would get a contract before August."
"One of the things the port operators have said is that they have to test it during the peak shipping period of August to October. It's unlikely that there will be sufficient pilots installed for larger ports in that timeframe, and if you don't hit that window, it could be until the end of 2010 before the pilot is done since you have to test this during the peak period."
As much as the timeline may present a challenge for the pilot projects, simply creating readers has been tough, too. The readers are typically called Initial Capability Evaluation (ICE) readers, a stamp that indicates the reader has been approved for evaluation during the pilot process. Becoming ICE approved, however, is no guarantee of final approval or even extensive evaluation or testing.
"Not a lot of companies have submitted readers. The readers have been a moving target. It's hard for many manufacturers to spend the time and money to build a custom reader for the pilot when it's highly possible that the final spec will be different."
The complexity of designing these TWIC readers has also extended into the issue of compatibility with physical access control systems (PACS). The initial thought was that the TWIC readers would stand separate from the PACS, but requirements like whitelists and blacklists of certain persons requires connections to PACS for a practical implementation.
Now the Coast Guard and TSA are also looking at issues of MARSEC (maritime security) threat levels. The government is studying how different MARSEC levels might affect different TWIC implementations, whereas a heightened MARSEC level might require extra validation, authentication factors, and enforcement.
In addition to the TWIC reader pilot, DHS and the Coast Guard recently published an Advance Notice of Proposed Rule Making (ANPRM) on March 27, 2009, which provides guidance on how to approach different modes of TWIC authentication factor implementations.
"The ANPRM is shopping around some information," explained Zivney. "They are establishing a risk management criteria. They are realizing that every situation is not a worst-case scenario. The idea is to match the right reader technology and authentication factors to the risk assessment of the facility. That is just good business."
No one ever said this was going to be easy, but it's too early to be negative about the program.
"Unfortunately, it's not going any faster," said Zivney, "but what they're doing with TWIC is very important work. It's going to be watched by the world and also by U.S. airports. We are now moving into the reader test phase. This is all about making new technology work for both security and commerce, so the pilot is absolutely necessary to get it right."
Links with Related Information on May 2009 standing for TWIC program initiative: