Lake Carrier's Association

Lake Carriers’ Association
The Greatest Ships on the Great Lakes

J AMES H. I. W EAKLEY , P RESIDENT
440-333-9995  [email protected]

June 3, 2013
DOCKET NO. TSA-2006-24191
Via E-Mail: [email protected]
TSA PRA Officer
Office of Information Technology (OIT), TSA-11
Transportation Security Administration
601 South 12th St.
Arlington, VA 20598-6011
Dear Sir or Madam:
Intent to Request Renewal from OMB of One Current Public Collection of Information:
Transportation Worker Identification Credential (TWIC) Program
Federal Register, Thursday, May 30, 2013
Volume 78, Number 104, Pages 32417-32418
Lake Carriers’ Association (LCA) represents 17 American companies that operate 57 U.S.-flag vessels (lakers)
on the Great Lakes. Their vessels carry the raw materials that drive the nation’s economy: iron ore and
fluxstone for the steel industry, aggregate and cement for the construction industry, coal for power generation,
as well as salt, sand, grain and gypsum. Collectively, our members can transport more than 115 million tons of
dry-bulk cargo per year, and those cargos generate and sustain more than 103,000 jobs in the eight Great
Lakes.
The 1,600-plus men and women who work on our members’ vessels are required to have a valid TWIC card.
They are also required to have a valid Merchant Mariner Credential and/or license issued by the U.S. Coast
Guard. We believe this dual requirement creates an unnecessary burden, both in terms of cost and the time
involved in obtaining and/or renewing a TWIC card. Prior to the TWIC card the U.S. Coast Guard thoroughly
investigated the background and habits of life of individuals seeking a document or license. There never was
any need for mariners on vessels registered in the United States to have a TWIC card. The requirement to
have a TWIC card is and always will be duplicative.
We realize it is not the purpose of this public comment period to address the necessity of requiring mariners
licensed and documented by the U.S. Coast Guard to have a TWIC card, but we do wish to have our position
be part of the official record.
Very respectfully,

James H. I. Weakley
President
G:\WEAKLEY\LETTERS\2013\053113 TWIC.docx

20325 Center Ridge Rd., Ste. 720  Rocky River, OH 44116  www.lcaships.com
T h e A s so c i a t i o n R e p r e se n t i n g O p e r a t o r s o f U . S . - F l a g V e ss e l s o n t h e G r e a t L a k e s S i n c e 1 8 8 0
AMERICAN STEAMSHIP C OMPANY  ANDRIE INC .  ARMSTRONG STEAMSHIP COMPANY  BELL STEAMSHIP COMPA NY
CENTRAL MARINE LOGISTICS , INC .  GRAND RIVER NAVIGATI ON COMPANY , INC .  GREAT LAKES FLEET / KEY LAKES , INC .
INLAND LAKES MANAGEMENT , INC .  THE INTERLAKE STEAMSHIP COMPANY  LAKES S HIPPING COMPANY
LAKE MICHIGAN CARFER RY SERVICE  PERE MARQUETTE SHIPPING  P ORT CITY MARINE SERVICES  P ORT CITY STEAMSHIP SERVICES
SOO MARINE SUPPLY , INC .  UPPER LAKES TOWING C OMPANY , INC .  V AN ENKEVORT TUG & BARGE INC .