The Identity Project and the Cyber Privacy Project filed comments objecting to the proposal as contrary to the Administrative Procedure Act (APA), the Paperwork Reduction Act (PRA), and the Privacy Act.

According to those comments, "The notice miscategorizes the proposal, fails to provide adequate or accurate notice to the public, and includes materially false statements about the proposal and the history and status of TSA Form 415....

The notice attempts to use the PRA procedures for approval of a form to effect a sweeping, highly controversial, substantive change in the scope of authority over air travelers claimed and exercised by the TSA. Even if such a change were authorized by a valid statute, it would require a different procedure: notice-and-comment rulemaking by the TSA pursuant to the
APA. The significance of these procedural violations is heightened because the proposal implicates the ability of individuals to exercise their right – pursuant to Federal statutes, the U.S. Constitution, and international human rights treaties – to travel by air by common carrier."

According to the Identity Project blog, the PRA requires that, If the TSA disregards our objections and requests approval of this scheme from OMB, as they have said they intend to do, there will be another public notice in the Federal Register and another 30-day window of opportunity for the public to submit comments to OMB. We’ll be sure to let you know if this happens."

Comments of the Identity Project and the Cyber Privacy Project:
https://papersplease.org/wp/wp-conte...5-9JAN2017.pdf

Blog post, "IDP comments on TSA proposal to require ID to fly":
https://papersplease.org/wp/2017/01/...ire-id-to-fly/