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TSA TDC/Ivcc request for comments

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Old Nov 8, 2016, 4:35 pm
  #1  
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TSA TDC/Ivcc request for comments

As published in the Federal Register (Volume 81, Number 216 (Tuesday, November 8, 2016)] [Notices] [Pages 78623-78624]) TSA is requesting comments about the TDC/IVCC process.
The register entry explains that "a traveler without an acceptable verifying identity document must complete a Certification of Identity (COI) form (TSA Form 415) ... The IVCC searches various commercial and government databases using the name and address on the TSA Form 415 as key search criteria to find other identifying information about the traveler. The IVCC then asks the traveler a series of questions based on information found in the databases to verify the individual's identity."

TSA is looking to expand the information requested to "ensure that the identity verification process described above does not become a means for travelers to circumvent implementation of the REAL ID Act". The proposal, if implemented, would require that individuals provide their name, address, whether the individual has a state issued identification, what state it is from and whether the individual has been issued other identification. The comments period ends in January 2017.

DATES: Send your comments by January 9, 2017.

ADDRESSES: Comments may be emailed to [email protected] or delivered
to the TSA PRA Officer, Office of Information Technology (OIT), TSA-11,
Transportation Security Administration, 601 South 12th Street,
Arlington, VA 20598-6011.

FOR FURTHER INFORMATION CONTACT: Christina A. Walsh at the above
address, or by telephone (571) 227-2062.
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Old Nov 8, 2016, 6:00 pm
  #2  
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No ID should be required to travel and that is the type of comment I would like to see submitted.
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Old Nov 8, 2016, 6:06 pm
  #3  
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The rest of the world seems to understand that no pax has threatened aviation security just by flying with fake ID.

Just a slowdown that contributes nothing to aviation security and wastes actual working manpower.
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Old Nov 8, 2016, 6:59 pm
  #4  
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Having been on the receiving end of public comments, I suggest strongly that you and others make these kinds of comments. Copy your senators and representatives (whoever they happen to be after tonight).
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Old Jan 9, 2017, 10:24 pm
  #5  
 
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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/

Last edited by ehasbrouck; Jan 11, 2017 at 6:44 am Reason: more context for links
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