Statement of Richard Smith, Westar Marine Services On behalf of The American Waterways Operators

Transcription

1 Statement of Richard Smith, Westar Marine Services On behalf of The American Waterways Operators Before the U.S. Coast Guard and the Transportation Security Administration Regarding the Transportation Worker Identification Credential Docket Numbers: USCG ; TSA June 7, 2006 Long Beach, California

2 Good morning. I am Rich Smith, the General Manager of Westar Marine Services in San Francisco, California. I am here today in my capacity as Pacific Region Chairman of the American Waterways Operators (AWO). AWO is the national trade association representing the tugboat, towboat, and barge industry. I want to thank you for the opportunity to express my industry s concerns with both the Transportation Worker Identification Credential (TWIC). The U.S. tugboat, towboat, and barge industry is a vital segment of America s transportation system. The industry safely and efficiently moves over 800 million tons of cargo each year, including more than 60 percent of U.S. export grain, energy sources such as coal and petroleum, including most of New England s home heating oil and gasoline, and other bulk commodities that are the building blocks of the U.S. economy. The fleet consists of nearly 4,000 tugboats and towboats, and over 27,000 barges of all types. These vessels transit 25,000 miles of inland and intracoastal waterways, the Great Lakes, and the Atlantic, Pacific, and Gulf coasts. The tugboat, towboat, and barge industry provides the nation with a safe, secure, low-cost, environmentallyfriendly means of transportation for America s domestic commerce. Our industry comprises the largest segment (fully 80%) of the U.S.-flag fleet. This means that our vessels are American-owned and American-crewed. Domestic mariners are the eyes and ears on the water and are fully committed to protecting the security of our nation. However, the development of the TWIC as a mechanism to improve security is an unnecessarily onerous requirement that could in its current form substantially inhibit domestic commerce. Our industry -2-

3 has four fundamental concerns with the proposal regarding its impact on both maritime security and waterborne commerce. First, there is no provision to allow new employees to work while they are waiting to receive their TWIC. The towing industry continues to face a serious challenge in meeting all of its manpower needs. The extended waiting period to obtain a TWIC, already projected at 60 days, will impede the ability of companies to bring new mariners into the industry in a quick and efficient manner. This will exacerbate the towing industry s already acute vessel personnel shortage problem. (A 60 day wait is itself problematic, but I am frankly also concerned with the actual ability of TSA and the Coast Guard to issue these documents even within that projected schedule.) Similarly, the time away from the job in order to travel to a TWIC enrollment location and the cost of travel and application fees pose real burdens on individual mariners. These further delays and costs could well impact the smooth flow of commerce as vessels are unable to sail because sufficient crews are not available. We suggest an alternative procedure. For a newly hired employee who has completed the initial TWIC application process and other company-specific entry requirements, it seems reasonable to allow such an employee to be placed in service on a vessel, perhaps on a probationary basis. This would allow us to hire, train and place employees on vessels during the 60 day waiting period, both addressing our manpower shortage concerns and allowing the new employee to begin earning an income. As I mentioned, all of our crew members are U.S. citizens, so this seems like a reasonable alternative from a security perspective too. -3-

4 Second, the expenses associated with purchasing and maintaining biometric readers for every vessel and facility will impose enormous costs on our companies. This financial burden on an industry with approximately 4,000 vessels is monumental. We estimate the total start-up cost to our industry for vessels alone to be over $40 million. For an industry that has been in the forefront of the proactive development of the Alternative Security Program, and with a lower risk profile, this is a completely unreasonable requirement. In addition to company costs, many of the applicants for maritime positions, especially entrylevel jobs, cannot afford to pay $149 for an identification card. The requirement for a mariner to pay such an amount will only deter them from entering the maritime workforce, further exacerbating the shortage of employees. Third, the requirement to place a card reader on board every vessel is unnecessary. Vessel crews are small and usually very familiar with one another. For an unknown person to go unnoticed on board a towing vessel is very unlikely. Crewmembers spend weeks at a time with one another in close quarters, and the opportunity for an unidentified individual to go overlooked is virtually impossible. Additionally, many vessels in the industry do not have internet or satellite service in order to access the most accurate records of TWIC card holders. At MARSEC Level 1, for example, each card holder would be required to validate their information on a weekly basis and more often as security levels increase. The majority of towing vessels do not have access to internet -4-

5 service for extended periods of time and would not be able to update their information frequently. Finally, while the NPRM alludes to the opportunity for mariners to choose a location to pick up their credential, it does not detail the process through which this could be accomplished. The industry fully supports the establishment of alternative pick-up locations. This must include establishing multiple locations for the issuance of a TWIC in order to greatly reduce time, travel, and financial impositions on companies and mariners and to avoid exacerbating the present REC workload problems. A mariner onboard a vessel may not have the luxury of being in the same location to pick up their TWIC card as that where they enrolled. AWO urges the TSA and the Coast Guard to ensure that the TWIC and MMC requirements are implemented in an effective, efficient way that does not impose overwhelming burdens on mariners and their employers, and that does not establish barriers to the smooth flow of waterborne commerce. The Coast Guard s original goal of doing no harm in the effort to modernize mariner credentialing was, and remains, the right one. This NPRM requires substantial revision to meet that standard. Thank you for your time and consideration.