
                                                                               



Transportation Worker Identification Credential (TWIC) - Reader Requirements

Final Rule

Regulatory Analysis and Final Regulatory Flexibility Analysis 


USCG-2007-28915 
RIN:  1625-AB21    


November 2015




Prepared by:

United States Coast Guard (USCG)
Office of Standards Evaluation and Development
Standards Evaluation and Analysis Division
USCG Headquarters
Washington, DC



 





Contents
Figures	3
Tables	3
Acronyms	6
Executive Summary	8
A-4 Accounting Statement	13
1) Introduction	14
1.1 Summary of Requirements Resulting in Costs	14
1.2 Objective of the Rulemaking	17
1.3 Statement of Need	17
1.4 Changes in Regulatory Analysis from NPRM to Final Rule	18
1.5 Treatment of Costs	25
2) Regulated Industry and Affected Population	27
2.1 Risk-Based Affected Vessel and Facility Populations	27
2.2 Movement Between Risk Groups	31
2.3 Estimated TWIC-Holder Population	31
2.4 Facility Access Points	34
3) Data Sources and Independent Research	37
3.1 Homeland Security Institute Study	37
3.2 TSA Pilot Program	38
3.2.1 Background	38
3.2.2 Pilot Participants	39
3.3 Pilot Results	41
3.4 Use of Pilot Data	41
4) Costs of Electronic TWIC Inspection Requirements	42
4.1 Costs to Facilities	42
4.1.1 TWIC Reader Costs	43
4.1.2 Maintenance Costs	53
4.1.3 Operational Costs for Facilities	55
4.1.4 Total Facility Costs	61
4.2 Vessel Costs	61
4.2.1 Reader Costs for Vessels	61
4.2.2 Maintenance Costs	63
4.2.3 Operational Costs for Vessels	64
4.3 Additional Delay, Travel and TWIC Replacement Costs due to TWIC Failures	69
4.3.1 Delay Costs Due to an Invalid Electronic TWIC Inspection	70
4.3.2 Costs to Replace Faulty TWICs	75
4.3.3 Increased Use of Personal Identification Number (PIN)	77
4.3.4 Use of Escorts	78
4.3.5 Summary of Additional Costs	78
4.4 Total Industry Costs	79
4.5 Cost Mitigation	81
4.6 Government Cost	81
5) Benefits	84
5.1 Beneficial Impacts of the Final Rule	84
5.2 Benefits Based on Coast Guard Enforcement Data	85
5.3 Evaluating the Beneficial Impacts with the Risk Framework and MSRAM	85
5.4 Potential Consequences of a TSI	90
5.5 Monetization of TSI Consequences Derived from MSRAM	93
5.6 Break-even or Threshold Analysis	95
6) Alternatives	98
6.1 Alternatives	100
7) Final Regulatory Flexibility Analysis	103
7.1 Overview of the Final Regulatory Flexibility Act Analysis	103
8) Collection of Information	112
Appendix A: Baseline Matrix	115
Appendix B: TWIC Pilot Participants	122
Appendix C: Reader Cost Information	123
Appendix D: Capital Costs Per Reader	125
Appendix E: BLS Wages for NAICS 483000, May 2012	128
Appendix F: Cumulative TWIC Programmatic Costs	166
Appendix G: Costs by Provision	170

Figures
Figure 2.1 Risk Groups for MTSA-Regulated Vessels	28
Figure 2.2 Risk Groups for MTSA-Regulated Facilities*	29
Figure 3.1 Rank-Ordered AHP Scores, with Current TWIC Risk Groupings	38
Figure 5.1 MSRAM: Result of Mitigation Strategies	89
Figure C1: ICE List Approved TWIC Readers  -  Hardware Price	123
Figure C2: ICE List Approved TWIC Readers  -  Software Price	124
Figure C3: Sample of Other Biometric Readers from GSA Schedule	124
Figure C4: Qualified Technology List (QTL) TSA Approved TWIC Readers	124
Figure D1: Installation Costs per Reader	125
Figure D2: Infrastructure Costs per Reader	126
Figure D3: PACS Costs per Reader	127
Figure F.1 Overview of TWIC Programmatic Costs ($ Millions)	167

Tables
Table ES-1 Summary of Costs and Benefits	8
Table ES-2 Revenue Impacts on Affected Small Business  -  Facilities	11
Table 1.1 Change in Requirements, ANPRM, NPRM, and Final Rule	16
Table 1.2 Changes in Regulatory Analysis from NPRM to Final Rule	18
Table 2.1 Vessels by Risk Group	30
Table 2.2 Affected Facilities by Risk Group	30
Table 2.3 OCS Facilities	31
Table 2.4 Affected Number of Facilities and Vessels	31
Table 2.5 Estimated Population of TWIC-Holders at Pilot Participants,	32
by Facility Type	32
Table 2.6 TWIC-Holders by Facility Type	33
Table 2.7 Estimated National TWIC-Holder Population, by Facility Type	33
Table 2.8 TWIC-Holders in Risk Group A	33
Table 2.9 TWIC-Holder Population by Risk Group	34
Table 2.10 Facility Access Points	35
Table 2.11 Readers Per Access Point	36
Table 3.1 Summary of TWIC Pilot Study Data	40
Table 4.1 Facility Access Points	44
Table 4.2 Readers per Access Point, by Facility Type	45
Table 4.3 Estimate of Average Number of Readers per Facility Type*	46
Table 4.4 Estimate of Total Readers*	47
Table 4.5 Average Reader Costs	49
Table 4.6 Estimated National Reader Costs	49
Table 4.7 Installation Costs for TWIC Readers	51
Table 4.8 Infrastructure Costs for TWIC Readers	52
Table 4.9 PACS Costs for TWIC Readers	53
Table 4.10 Total Facility Capital Costs, Implementation Period	53
Table 4.11 Annual Maintenance Costs for TWIC Readers	54
Table 4.12 Costs for TWIC Amendments	56
Table 4.13 Costs to Create and Maintain Recordkeeping Systems	57
Table 4.14 Costs for Frequent CCL Downloads	58
Table 4.15 Training Costs for Facilities	59
Table 4.16 Operational Costs for Facilities	60
Table 4.17 Total Facility Costs ($ Millions)	61
Table 4.18 Vessel Reader Costs, First Year	62
Table 4.19 Costs to Install Readers and Software	62
Table 4.20 Maintenance Costs for Vessel TWIC Readers	64
Table 4.21 Costs for TWIC Amendments	64
Table 4.22 Costs to Create Recordkeeping Systems	66
Table 4.23 Costs to Download CCLs (Non-discounted)	66
Table 4.24 Cost of Training for Vessel Personnel	67
Table 4.25 Vessel Operational Costs	68
Table 4.26 Total Costs to Vessels	69
Table 4.27 TWIC-Holder Population, from TWIC Pilot	70
Table 4.28 TWIC-Holder Population by Facility Type	72
Table 4.29 TWIC-Holders per Facility, by Facility Type	72
Table 4.30 TWIC-Holder Population, by Facility Type and Risk Group	72
Table 4.31 Annual Number of Electronic TWIC Inspections	73
Table 4.32 Annual Invalid TWIC Transactions	73
Table 4.33 Cost of Delays Due to Invalid Transaction Per Year,	75
for Risk Group A Facilities	75
Table 4.34 Invalid TWIC Reader Transactions	75
Table 4.35 TWIC-Holder Population, by Facility Type	76
Table 4.36 Additional Costs	78
Table 4.37 Ten-year Total Costs, by Facility Type* ($ Millions)	79
Table 4.38 Total Industry Cost, Facilities and Vessels ($ Millions)	80
Table 4.39 Government Costs	82
Table 4.40 Combined Industry and Government Costs* ($ Millions)	83
Table 5.1 Overall Impact of Electronic TWIC Inspection on Risk	89
Table 5.2 Description of Consequence Factors in MSRAM*	90
Table 5.3 Relative Disutility Factors by Injury Severity Level (AIS)	91
Table 5.4 Average Maximum Consequence by Attack Type	92
Table 5.5 Equivalent Fatalities At Risk, by Target Group	93
Table 5.6 Monetary Value of Consequences at Risk, by Target Group ($ Millions)	94
Table 5.7 Annual Risk Reduction Required for Costs to Equal Benefits,	97
by Regulatory Alternative	97
Table 6.1 Annual Cost of Delay for Container Facilities	98
Table 6.2 Regulatory Alternatives	99
Table 6. 3 Summary of Required Risk Reduction by Regulatory Alternative Overall ($ Millions)	102
Table 7.1 Ten Most Frequent Industries Affected by the Proposed Rule - Facilities	108
Table 7.2 Revenue Impacts on Affected Small Businesses - Facilities	109
Table E1: NAICS 483000 - Water Transportation	129
Table F1 TWIC Programmatic Costs by Cost Component	167
Table F2 TWIC Costs by Type of Entity	169
Table G1: Ten Year Costs by Provision (7% Discount Rate)	170
Table G2: Annualized Costs by Provision (7% Discount Rate)	170
Acronyms
AIS
Abbreviated Injury Scale
ANRPM...........
Advanced Notice of Proposed Rulemaking
ASP
Alternative Security Program
BLS
Bureau of Labor Statistics
CCL
Canceled Card List
CDC...........
Certain Dangerous Cargoes
CFR...........
Code of Federal Regulations
CSO...........
Company Security Officer
DHS
Department of Homeland Security
DOT
Department of Transportation
FASC-N...........
Federal Agency Smart Credential Number
FRFA
Final Regulatory Flexibility Analysis
FSO...........
Facility Security Officer
FSP...........
Facility Security Plan
GAO
Government Accountability Office
GSA............
General Services Administration
HSI
Homeland Security Institute
IRFA...........
Initial Regulatory Flexibility Analysis
IMO...........
International Maritime Organization
MARSEC Level...........
Maritime Security Level
MISLE...........
Marine Information Safety and Law Enforcement System
MSRAM...........
Maritime Security Risk Analysis Model
MTSA...........
Maritime Transportation Security Act of 2002
NAICS...........
North American Industry Classification System
NIPP...........
National Infrastructure Protection Plan
NIST
National Institute of Standards and Technology
NPRM.........
Notice of Proposed Rulemaking
OCS...........
Outer Continental Shelf
OMB...........
Office of Management and Budget
OSLTF...........
Oil Spill Liability Trust Fund
PACS...........
Physical Access Control System
RA...........
Regulatory Analysis
RBDM...........
Risk-Based Decision Making
RFA...........
Regulatory Flexibility Act
RUA...........
Recurring Unescorted Access
SAFE Port Act...........
Security and Accountability For Every Port Act of 2006
SBA
Small Business Administration
ST&E..........
Systems Test and Evaluation
TSA...........
Transportation Security Administration
TSI..........
Transportation Security Incident
TWIC..........
Transportation Worker Identification Credential
USCG........
United States Coast Guard
VSL..........
Value of a Statistical Life
VSO..........
Vessel Security Officer
VSP..........
Vessel Security Plan


Executive Summary
Under Executive Order 12866, as supplemented by Executive Order 13563, the Coast Guard is required to assess the costs and benefits of its rulemakings.  This final rule is significant under section 3(f) of that order.  This Regulatory Analysis (RA) provides an assessment of potential costs and benefits from the Transportation Worker Identification Credential (TWIC)  -  Reader Requirements final rule [USCG-2007-28915].  

This report does not attempt to exactly replicate the regulatory language of the final rule or any other supporting documentation; the regulatory text, not the text of this report, is legally binding.  We urge the reader to review the final rule before reviewing this report.

The Coast Guard proposes amending its regulations on certain Maritime Transportation Security Act of 2002 (MTSA)-regulated facilities and vessels to include requirements for electronic TWIC inspection to be used for access control for unescorted access to secure areas of facilities and vessels.

The following table summarizes the undiscounted costs and benefits of this rule.
      
Table ES-1 Summary of Costs and Benefits
                                   Category
                                  Final Rule
                                 Applicability
High-risk, MTSA-regulated facilities and high-risk, MTSA-regulated vessels with greater than 20 crew.
                              Affected Population
                                   1 vessel

                                525 facilities
                     Costs
($ millions, 
7% discount rate)
                              $21.9 (annualized)

                               $153.8 (10-year)
                                     Costs
                                 (Qualitative)
         Time to retrieve or replace lost PINs for use with TWIC cards
                            Benefits
(Qualitative)
Standardization of access control and credential verification among high-risk facilities and vessels

Enhanced access control and security at U.S. maritime facilities and onboard U.S.-flagged vessels

Reduction of human error when checking identification and manning access points

In this final rule, the Coast Guard will require owners and operators of certain vessels and facilities regulated by the Coast Guard under 33 CFR Chapter I, subchapter H, to use electronic readers designed to work with TWIC as an access control measure.  This final rule will also implement additional requirements associated with Electronic TWIC readers or the Physical Access Control System (PACS) equivalent, including recordkeeping requirements for those owners/operators required to use an electronic TWIC reader, and amendments to security plans previously approved by the Coast Guard to incorporate TWIC requirements.  

This final rule will enhance the security of vessels, ports, and other facilities by ensuring that only individuals who hold valid TWICs are granted unescorted access to secure areas at those locations.  It will also implement the MTSA transportation security card requirement, as well as the Security and Accountability For Every Port Act of 2006 (SAFE Port Act) electronic TWIC inspection requirements.  

The Coast Guard estimates that this final rule will specifically affect owners and operators of certain MTSA-regulated U.S.-flagged vessels and domestic facilities.  We obtained population data from the Coast Guard's Marine Information Safety and Law Enforcement (MISLE) database.  Based on these data, we estimate the following population of MTSA-regulated entities:  3,647 unique owners/operators of 13,825 vessels, 2,046 unique owners/operators of 3,270 facilities, and 19 unique owners/operators of 56 Outer Continental Shelf (OCS) facilities.  Of these entities, 525 facilities and 1 vessel will have to comply with new electronic TWIC inspection requirements.  The Coast Guard used a risk-based tiering approach to apply these regulatory requirements  -  the net result is less than 5% of the MTSA-regulated population are impacted which represented approximately 80% of the potential consequences.  This risk-based hierarchy is described in Chapter 2.

We estimate the annualized cost of this rule to industry to be approximately $21.9 million at a 7% discount rate.  The main cost drivers of this rule are the acquisition and installation of TWIC readers and the maintenance of the affected entity's electronic TWIC inspection system.  The cost estimates in this regulatory analysis are likely to overstate costs, as we do not have actual costs for what facilities will spend out of their own funds for infrastructure and installation, and we cannot quantitatively account for several methods of relief that will be afforded industry in this final rule.  In addition, the increased flexibility provided by this final rule allows for the use of an existing PACS with minor modifications and increases the pool of available reader technology will decrease the burden on industry.  However, our cost estimates do not reflect any cost savings that may result from this flexibility and assume that all entities would comply by installing new TWIC readers.  Costs, which we distribute over a 2-year implementation phase in our calculations, consist predominantly of the costs to purchase, install, and integrate approved TWIC readers to their current physical access control system.  Recurring annual costs will be driven by costs associated with canceled card list updates, training, opportunity cost associated with delays and replacement of TWICs that cannot be read, and maintenance of the affected entity's electronic TWIC inspection system. 

The benefits of the rulemaking include the enhancement of the security of vessels, ports, and other facilities by ensuring that only individuals who hold valid TWICs are granted unescorted access to secure areas at those locations.  TWIC readers will allow for enhanced verification of personal identity, card authentication and validation of TWICs, all of which will improve access control at high-risk, MTSA-regulated facilities and vessels.  They will also reduce potential vulnerability by establishing earlier the temper and intent of perpetrators who attempt to bypass or thwart the readers, triggering more capable security assets.  TWIC readers will contribute as potential deterrent given enhanced security and attacker desire to maximize success.  Another benefit of TWIC readers is in reducing the consequence given increased likelihood of stopping the attack at the checkpoint, farther from the main target and immediately identifying intent and a greater chance of implementing protective measures (e.g., shutdown of sensitive systems).  They also contribute to the removal of the current patchwork of credentials and reader technologies used throughout the maritime industry, and will serve to standardize the use of readers at high-risk facilities and vessels.  It will also implement the 2002 MTSA transportation security card requirement, as well as the 2006 SAFE Port Act electronic TWIC inspection requirements, thereby ensuring compliance with those statutes.  Since the primary function of the TWIC card and of electronic TWIC inspection is to enhance access control and identity verification and validation, we evaluated three specific attack scenarios (Truck Bomb, Terrorist Assault Team and Passenger/Passerby Explosives/Improvised Explosive Device, or IED) that are most likely to be mitigated by the implementation of electronic TWIC inspection program.  However, the electronic TWIC inspection requirements will not address potential attacks from outside a target, attacks at lower risk facilities or the verification and validation of a duly issued TWIC obtained using fraudulent documents.  We present qualitative benefits and a break-even analysis in Chapter 5 of this final RA. 

We considered several alternatives in the formulation of this final rule.  These alternatives were based on several different combinations of facility and vessel populations facing electronic TWIC inspection requirements.  The selected alternative allowed the Coast Guard to target the highest risk entities while minimizing the overall burden.  For a complete discussion of the alternatives, see Chapter 6 of this RA.

Under the Regulatory Flexibility Act (RFA, 5 U.S.C. 601-612), we have considered whether this final rule will have a significant economic impact on a substantial number of small entities.  The term "small entities" comprises small businesses, not-for-profit organizations that are independently owned and operated and are not dominant in their fields, and governmental jurisdictions with populations of fewer than 50,000 people.

For this final rule, we reviewed recent company size and ownership data from the Coast Guard MISLE database, and public business revenue and size data for our affected population.  Of these 525 facilities that will be affected by the electronic TWIC inspection requirements, we found 306 unique owners.  Among these 306 entities, there were 31 government-owned entities, 0 not-for-profits, and 275 businesses.  Of the 275 businesses, 114 companies exceed Small Business Administration (SBA) small business size standards, 88 companies are considered small by the SBA, and 73 companies have no available information.  For the purposes of this analysis, we consider all entities for which information was not available to be small.  The businesses considered small for this analysis comprise 58% of the total population of unique owners. 

We were able to find revenue information for 64 of the 88 businesses deemed small by SBA standards.  We then determined the impacts of the final regulation on these companies by dividing the total costs of the regulation by the number of regulated entities to determine a cost per entity for the regulation.  We estimate these costs to be on average $195,715 per entity per year during the implementation period, and $12,312 per entity in annual cost.  By comparing average costs to revenue, we determined what percent impact on revenue the final regulation will have based on implementation costs and annual costs.  Table ES-2 presents the impacts on small businesses that own and operate facilities during implementation and annually.  

Table ES-2 Revenue Impacts on Affected Small Business  -  Facilities

                                       
                       Impacts from Implementation Costs
                           Impacts from Annual Costs
                            Revenue Impact Range 
                              Number of Entities
                              Percent of Entities
                              Number of Entities
                              Percent of Entities
                             0% < Impact <= 1%
                                      33
                                      52%
                                      57
                                      89%
                             1% < Impact <= 3%
                                       4
                                      6%
                                       6
                                      9%
                             3% < Impact <= 5%
                                       5
                                      8%
                                       1
                                      2%
                            5% < Impact <= 10%
                                       8
                                      13%
                                       0
                                      0%
                                   Above 10%
                                      14
                                      22%
                                       0
                                      0%
                                     Total
                                      64
                                     100%
                                      64
                                     100%
Note: Values may not total due to rounding.

The greatest impact will occur during the implementation phase when 48 percent of small businesses that we were able to find revenue data on will experience an impact of greater than 1 percent, and 22 percent of small businesses with available revenue data will experience an impact greater than 10 percent.  After implementation, the impacts decrease and 89 percent of affected small businesses will see an impact less than 1 percent.  We expect the revenue impacts for years with equipment replacement to be between those for implementation and annual impacts.  During those years with equipment replacement, we estimate that approximately 42 percent of businesses will see an impact of greater than 1 percent.  Of the 31 government jurisdictions, 7 are less than the RFA's 50,000 population threshold to be considered small, and all have revenue levels such that there will not be an impact greater than 1% of revenue.  For vessels, we found that the 1 vessel that will be affected by this final rule is not a small business. 

Under the provisions of the final rule, the affected facilities and vessel will be required to update their security plans, and to create and maintain a system of recordkeeping within 2 years of the final rule's promulgation.  This requirement will be added to an existing collection with Office of Management and Budget control number 1625-0077 entitled Security Plans for Ports, Vessels, Facilities, Outer Continental Shelf (OCS) Facilities and Other Security-Related Requirements.  The total additional burden from the final rule is estimated at 17,128 respondents (65 for vessels + 17,063 for facilities) in Year 1, 18,644 respondents (6 for vessels + 18,638 for facilities) in Year 2, and 3,156 respondents (6 for vessels + 3,150 for facilities) in Year 3.  The current annual burden listed in this collection of information is 1,108,043.  The new burden, as a result of this final rule, in Year 1 is 1,125,171 (1,108,043 + 17,128).  In Year 2 the new burden is 1,126,687 (1,108,043 + 18,644) and in Year 3 it is 1,111,199 (1,108,043 + 3,156).  The average annual additional burden across the 3 years is 12,976.

 

A-4 Accounting Statement

Agency/Program Office:  U.S. Coast Guard
Rule Title:  Transportation Worker Identification Credential (TWIC)  -  Reader Requirements
RIN#:  1625-AB21  
Date:  November 2015
                                   Category
                               Primary Estimate
                               Minimum Estimate
                                 High Estimate
                                    Source
                                   Benefits
Annualized monetized  benefits ($ Millions) 
                                      --
                                      7%
                                      --
                                      7%
                                      --
                                      7%
                                       

                                      --
                                      3%
                                      --
                                      3%
                                      --
                                      3%
                                       
Annualized quantified, but unmonetized, benefits
                                      --
                                       
Unquantifiable Benefits
Reduced regulatory uncertainty by clarifying SAFE Port Act and MTSA requirements 
                                      RA

           Standardization of reader technology throughout industry
                                       

Access control strengthened by enhanced identity verification, card authentication and card validation; reduced consequence given increased likelihood of stopping the attack at the checkpoint, farther from the main target; reduced consequence by immediate identification of intent and a greater chance of implementing measures; and, a potential deterrent given enhanced security and attacker desire to maximize success 
                                       

Reduction of human error when checking identification and manning access points
                                       
                              Costs (in Millions)
Annualized monetized 
costs ($ Millions)
                                     $21.9
                                      7%
                                      N/A
                                      7%
                                      N/A
                                      7%
                                      RA

                                     $20.4
                                      3%
                                      N/A
                                      3%
                                      N/A
                                      3%
                                      RA
Annualized quantified, but unmonetized, costs
                                      --
                                       
Qualitative (un-quantified) costs
     Costs associated with notification of access control system failures
                                       
                                   Transfers
Annualized monetized transfers: "on budget"
                                      n/a
                                      n/a
                                      n/a
                                       
From whom to whom?
                                       
                                       
Annualized monetized transfers: "off-budget"
                                      n/a
                                      n/a
                                      n/a
                                       
From whom to whom?
                                      n/a
                                      n/a
                                      n/a
                                       
                        Miscellaneous Analyses/Category
Effects on State, local, and/or tribal governments
                                      No 
                                    RA/FRFA
Effects on small businesses
           We expect this rule to have an impact on small businesses
                                    RA/FRFA
Effects on wages
                               No determination
                               No determination
                               No determination
                                       
Effects on growth
                               No determination
                               No determination
                               No determination
                                       
Notes: 
(1) Discount rate appears to the right of the estimates.
(2) Annualized monetized costs include both industry and government costs.
1) Introduction
This RA provides an assessment of potential impacts to industry and the economy from the Transportation Worker Identification Credential (TWIC)  -  Reader Requirements final rule [USCG-2007-28915].  This report does not attempt to exactly replicate the regulatory language of the final rule or the language of any other supporting documentation; the regulatory text, not the text of this RA, is legally binding.  We urge the reader to review the final rule before reviewing this RA.

This RA provides supporting documentation for certain regulatory requirements addressed in the final rule, specifically, the economic impact analysis related to Executive Order 12866 as amended by Executive Order 13563 and the assessment of small entity (business) impacts related to the RFA (5 U.S.C. 601-612).  It does not provide supporting documentation for other regulatory requirements, environmental impacts, risk assessments, or technology and operational performance issues involved with this rulemaking.
1.1 Summary of Requirements Resulting in Costs
This final rule will require owners and operators of certain vessels and facilities regulated by the Coast Guard to use electronic TWIC inspection through approved TWIC reader systems ("TWIC readers"), or the PACS equivalent, as an access control measure.  This rulemaking separates the affected population of vessels, facilities, and OCS facilities into risk groups with tiered requirements for access control based on risk hierarchy; see the "Discussion of Comments and Changes to the Final Rule" section of the preamble for more details of the development of this rulemaking and the risk-based approach and methodology.  The risk hierarchy methodology determines if owners and operators will or will not be required to install and use card reader systems, focusing on those with the greatest potential consequences. 

The final rule will require all facilities and one vessel in Risk Group A to comply with additional electronic worker identity authentication and additional TWIC authentication and validation provisions over and above the current requirements to use the TWIC as a flash pass.  These provisions necessitate that owners and operators acquire, install and operate approved card reader technology, perform regular Canceled Card List (CCL) downloads, and comply with access control recordkeeping requirements.  The final rule will also require all owners and operators to amend their security plans based on how they will comply with the new requirements.

The following sections of the final rule result in additional impacts to industry:

   * 101.520 Electronic TWIC inspection.
   * 101.535 Electronic TWIC inspection requirements for Risk Group A.
   * 104.235(b)(9) Vessel recordkeeping requirements.
   * 104.405 Format of the Vessel Security Plan (VSP).
   * 105.225(b)(9) Facility recordkeeping requirements.
   * 105.405(a)(10) Format and content of the Facility Security Plan (FSP).

In general, these provisions will require certain changes, and therefore bring additional costs and impacts, for certain owners and operators in all risk groups affected by this rulemaking.  The costs associated with these provisions are explained in detail in Chapter 4 of this RA.  Appendix A summarizes the cost impacts of the regulatory requirements.

The requirements set forth in this final rule differ from those discussed in the 2009 TWIC Advanced Notice of Proposed Rulemaking (ANPRM) and the 2013 TWIC Reader Requirements Notice of Proposed Rulemaking (NPRM).  Specifically, based on feedback received on the ANPRM and subsequent further analysis, in the NPRM, we narrowed the affected population in the NPRM to just Risk Group A.  Similarly, based on feedback to the NPRM, we further refined requirements exempting some facilities and most of the vessels.  The differences among the ANPRM, the NPRM, and the final rule are shown in Table 1.1.


Table 1.1 Change in Requirements, ANPRM, NPRM, and Final Rule

                                       
                                     ANPRM
                                     NPRM 
                                  Final Rule
           Classification of Facilities and Vessels into Risk Groups
                Three Risk Groups based on MSRAM and other data
                         Same requirements as ANPRM. 
The final rule removes barge fleeting facilities from Risk Group A and raises the threshold for vessels being exempted from TWIC reader requirements from 14 to 20 or fewer TWIC-holding crewmembers.
                TWIC Inspection Requirements 
for Risk Group A
Use an electronic TWIC reader to utilize the card's most protective measures for identity verification, card authentication, and card validation. This would require matching the cardholder's biometric information with that on the card.
Same requirements as ANPRM. This would increase the burden on industry compared to the current use of TWIC for visual inspection only. 
The final rule provides additional flexibility and choice with regard to electronic readers.
                TWIC Inspection Requirements 
for Risk Group B
Requirements would differ by MARSEC Level. At MARSEC Level 1, Risk Group B facilities would be required to use TWIC as a visual identity badge with random monthly verification checks using TWIC readers. These facilities and vessels would not be required to perform a biometric match.
Non Risk-group A vessels and facilities are required to use TWIC as a visual identity badge only (at all MARSEC Levels). As discussed in Chapter 6 of this RA, this change would result in a decreased cost to industry over that which was proposed in the ANPRM, as only those facilities with the highest risk (top 80% of consequences) would be required to have readers.
                                       
No change in burden for Risk Group B (that is now redefined as non-Risk Group A).
                TWIC Inspection Requirements 
for Risk Group C
             Required to use TWIC as a visual identity badge only.
Same requirements as the ANPRM. There would be no increased burden for Risk Group C.
                                       
No change in burden for Risk Group C (that is now redefined as non-Risk Group A).
                       Recurring Unescorted Access (RUA)
RUA would allow the owner/operator of a vessel or facility to grant up to 14 TWIC-holders the privilege of entering secure areas on a repetitive basis without having their TWICs scanned each time.
No RUA. No longer necessary, as vessels with fewer than 14 TWIC-holding crew will not require TWIC readers.
                                       
                                       
Designated Recurring Access Area (DRAA) replaces RUA in the final rule and potentially reduces burden for affected entities.
               TWIC Reader approval, calibration and compliance
The ANPRM proposed that owners/operators follow the standards/specifications that will be developed from the TWIC pilot. TWIC readers would be required to be inspected, tested, calibrated, and maintained in accordance with the manufacturers' recommendations, and that records of those actions be maintained as well.
                       Same requirements as the ANPRM.  
                                       
                                       
No longer necessary as the increased flexibility by the final rule will allow the use of existing systems with minor modifications and increase the pool of available reader technology. 
                            Security Plan Amendment
Requires all affected owners/operators to amend their security plans to include TWIC requirements within 6 months of promulgation of a final TWIC reader rule.
Same requirements as the ANPRM. There would be a burden associated with security plan amendments for Risk Group A.
                                       
                                       
                        Same requirements as the NPRM.
                                 Recordkeeping
The following must be recorded: For each individual granted unescorted access to a secure area, the: FASC-N; date and time that unescorted access was granted; and, if captured, the individual's name. Additionally, documentation to demonstrate that the owner or operator has updated the CCL with the frequency required in § 101.520 of this subchapter.
Same requirements as the ANPRM. There would be a burden associated with the recordkeeping requirement for Risk Group A.
                                       
                                       
                                       
                                       
                                       
                         Same requirements as the NPRM

The changes made from the ANPRM to the NPRM and the final rule represent a significant reduction in potential cost to industry, as is detailed in Chapter 6 of this RA.
1.2 Objective of the Rulemaking
We anticipate that this rulemaking will enhance the security of ports and vessels by providing an effective means to ensure that only persons who hold valid TWICs are granted unescorted access to secure areas on high-risk vessels and port facilities.  It will provide enhancements over the current level of security and access control currently required at certain types of facilities regulated under the MTSA.  It will also complete the implementation of the MTSA transportation security card requirement, as well as the requirements of the SAFE Port Act for regulations on electronic readers for use with TWICs.

The finalized electronic TWIC inspection requirements will enhance security procedures and protocols currently in place as a result of the 2006 MTSA regulations and the 2007 TWIC regulations found in 33 CFR Subchapter H.  Sections 104.265, 105.255 and 106.260, respectively, discuss security measures for access control at MTSA-regulated vessels, facilities, and OCS facilities.  These sections detail the requirements to deter the unauthorized introduction of dangerous substances and devices, secure dangerous substances and devices that are authorized, and control access, which includes preventing unescorted individuals from entering certain areas without a duly issued TWIC.  The introduction of electronic TWIC inspections will be an enhancement over the current security baseline.

1.3 Statement of Need
There exist potential port security risks related to not having sufficiently robust identity verification, card authentication and card validation as part of access control at the highest risk MTSA-regulated vessels and facilities.  To this end, the MTSA transportation security card requirement, as well as the SAFE Port Act electronic TWIC inspection requirements call for the installation and use of electronic readers to verify and validate the information presented on a TWIC upon requesting unescorted access to a secure area of a vessel or facility.  Owners and operators of these facilities and vessels have not implemented electronic readers despite congressional mandates for biometrically enabled cards that need such systems to be fully functional.  Facility and vessel owners want to protect their facilities, but may not fully incorporate into their decisionmaking the consequences of attacks (with more offsite consequences for the facilities impacted) and thus not see sufficient value to drive installation of readers.

The electronic TWIC inspection requirements will enhance access control and thus security by strengthening identity verification, card authorization and card validation.
1.4 Changes in Regulatory Analysis from NPRM to Final Rule

In this section, we summarize the changes in the RA as we moved from the NPRM to this final rule.  These changes to the RA came from either policy changes on the electronic TWIC inspection requirements, public comments received after the publication of the NPRM in March 2013, or simply from updating the data and information that informed our regulatory analysis.  Table 1.2 breaks down these changes by corresponding element in our regulatory analysis with the reason why our analysis needed to change as well as an explanation on each change. 

Table 1.2 Changes in Regulatory Analysis from NPRM to Final Rule

Element of Regulatory Analysis
Reason Changed
Explanation of Change
Affected Population
Policy change
a. Barge fleeting facilities were removed reducing the previous facility population of 532 to 525, and
b. Crew size changed to 20 (instead of 14) and thus reducing the number of vessels to 1.
Cost of TWIC Readers
Update to reflect current prices for TWIC readers 
The most recent prices of electronic TWIC readers as published in GSA schedule and TSA's QTL were significantly reduced. 

Comments received
Some public comments suggested that TWIC reader costs have declined since the NPRM RA data was collected.
Wages for transportation workers
More current BLS data 
Revised labor cost by using May 2012 BLS data.
Maintenance Cost of TWIC Readers
Comment received
Revised this cost assumption from 5% of the total cost of a TWIC Reader to 10%.
Number of TWIC Readers
Comment received
Per one large ferry passenger facility's input, incorporated this facility's higher number of readers in cost estimates.

 

1.5 Treatment of Costs

The requirements in the final rule do not specifically require the purchase and use of TWIC readers for the affected population of facilities and vessels, if a PACS or other system can accomplish the same process of electronic TWIC inspection.  This added compliance method provides flexibility to the affected population and allows them to leverage existing systems and infrastructure.  As the existing infrastructure and systems would be specific to each facility or vessel, and we are uncertain as to what portion of the affected population would chose to comply through this alternative approach, the remainder of the cost analysis in this RA estimates the cost of complying with electronic TWIC inspection requirements as the cost to purchase, install and use of electronic TWIC readers.  As facility and vessel owners will only use the alternatives to TWIC readers if these approaches are more cost-effective or more efficient for existing business practices; the cost estimates in this RA may overstate actual compliance costs.

2) Regulated Industry and Affected Population
This final rule will affect owners and operators of certain vessels and facilities regulated by the Coast Guard under 33 CFR chapter 1, subchapter H, commonly known as "MTSA-regulated" vessels and facilities.  This final rule segregates MTSA-regulated vessels, facilities, and OCS facilities into different risk groups.  Each risk group will have its own associated electronic TWIC inspection requirements.  

The Coast Guard estimates that this final rule will affect specific owners and operators of MTSA-regulated, U.S.-flagged vessels and domestic facilities.  We obtained population data from the U.S. Coast Guard's MISLE database.  Based on this data, we estimate the following population of MTSA-regulated entities: 3,647 unique owners/operators of 13,825 vessels, 2,046 unique owners/operators of 3,270 facilities, and 19 unique owners/operators of 56 OCS facilities.  This proposal will only impact a subset of the MTSA-regulated population, based on the risk-based hierarchy described below.
2.1 Risk-Based Affected Vessel and Facility Populations
The rulemaking separates MTSA-regulated vessels, facilities, and OCS facilities into different risk groups, as discussed in the ANPRM and the NPRM.  In this final rule, each risk group will have its own associated electronic TWIC inspection requirements.  Figures 2.1 and 2.2 summarize the criteria for the risk groups for vessels and vessel services subject to 33 CFR part 104, and facilities and facility services subject to 33 CFR part 105.  Risk Group A for vessels and facilities will consist of those vessels and facilities with highest consequence for a TSI.  Risk Group B will be comprised of facilities and vessels that make up the second tier of risk.  All OCS facilities will also be included in Risk Group B.  Risk Group C will be comprised of the lowest tier of risk.  For the purposes of the final rule, Risk Groups B and C have been combined and are referred to as "Non-Risk Group A".  This risk-based hierarchy was validated by the Homeland Security Institute (HSI), and is discussed further in Section 3.1 of this RA.

Figure 2.1 Risk Groups for MTSA-Regulated Vessels
--------------------------------------------------------------------------------
Risk Group A 
--------------------------------------------------------------------------------
(1) Vessels that carry Certain Dangerous Cargoes (CDC) in bulk;
--------------------------------------------------------------------------------
(2) Vessels certificated to carry more than 1,000 passengers; and
--------------------------------------------------------------------------------
(3) Towing vessels engaged in towing barges subject to paragraphs (1) or (2).
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
Non-Risk Group A
--------------------------------------------------------------------------------
(1) Vessels that carry hazardous materials other than CDC in bulk;
--------------------------------------------------------------------------------
(2) Vessels subject to 46 CFR chapter I, subchapter D, that carry any flammable or combustible liquid cargoes or residues.
--------------------------------------------------------------------------------
(3) Vessels certificated to carry 500 to 1,000 passengers; and
--------------------------------------------------------------------------------
(4) Towing vessels engaged in towing a barge or barges subject to paragraphs (1), (2), or (3). 
--------------------------------------------------------------------------------
(5) Vessels carrying non-hazardous cargoes that are required to have a vessel security plan;
--------------------------------------------------------------------------------
(6) Vessels certificated to carry fewer than 500 passengers;
--------------------------------------------------------------------------------
(7) Towing vessels engaged in towing barges subject to paragraphs (5) or (6);
--------------------------------------------------------------------------------
(8) Mobile Offshore Drilling Units; and
--------------------------------------------------------------------------------
(9) Offshore Supply Vessels (OSVs) subject to 46 CFR chapter I, subchapters L or I.
--------------------------------------------------------------------------------



Figure 2.2 Risk Groups for MTSA-Regulated Facilities*
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
Risk Group A
--------------------------------------------------------------------------------
(1) Facilities that handle CDC in bulk or receive vessels carrying CDC in bulk; and
--------------------------------------------------------------------------------
(2) Facilities that receive vessels certificated to carry more than 1,000 passengers.
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
Non-Risk Group A
--------------------------------------------------------------------------------
(1) Facilities that receive vessels that carry hazardous materials other than CDC in bulk;
--------------------------------------------------------------------------------
(2) Facilities that receive vessels subject to 46 CFR chapter I, subchapter D, that carry any flammable or combustible liquid cargoes or residues;
--------------------------------------------------------------------------------
(3) Facilities that receive vessels certificated to carry 500 to 1,000 passengers; and
--------------------------------------------------------------------------------
(4) Facilities that receive towing vessels engaged in towing a barge or barges carrying hazardous materials other than CDC in bulk, crude oil, or certificated to carry 500 to 1,000 passengers. 
--------------------------------------------------------------------------------
(5) MTSA-regulated facilities that receive vessels carrying non-hazardous cargoes that are required to have a vessel security plan; 
--------------------------------------------------------------------------------
(6) Facilities that receive towing vessels engaged in towing a barge or barges carrying non-hazardous cargoes; and
--------------------------------------------------------------------------------
(7) Facilities that receive vessels certificated to carry fewer than 500 passengers. 
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
* OCS facilities subject to 33 CFR part 106 fall into Non-Risk Group A.

The populations of MTSA-regulated vessels, facilities, and OCS facilities are broken down by risk group in the tables below.  These estimates are based on the MSRAM Analysis detailed in the "Discussion of Proposal" section of the NPRM and additional review by the Coast Guard Office of Port and Facility Activities and the Marine Safety Center.  This population is filtered here, with many vessel and facility types exempted.  As such, and as described below, the population in this proposed rule is a subset of the MTSA-regulated population.

The vessel population is separated into self-propelled vessels and barges.  We do not anticipate that barges will be impacted by this final rule given limited numbers of personnel on board.  For the purpose of our analysis, we assume that barges are manned with no more than 20 persons, and as such, will not be required to comply with electronic TWIC inspection requirements.  Removing barges from the Risk Group A population reduces our affected population from 3,313 vessels to 138 vessels.  Of these 138 vessels, 137 also have crew sizes less than 21 and are thus exempt from electronic TWIC inspection requirements.  This will further reduce the affected population from 138 vessels requiring TWIC readers to 1 vessel. 


Table 2.1 Affected Vessels by Risk Group
                                       
                               Owners/Operators
                                    Vessels
                                  Risk Group
                                Self-Propelled
                                    Barges
                                Self-Propelled
                                    Barges
                                       A
                                       1
                                       -
                                       1
                                       -
                                     Non-A
                                     1,864
                                      433
                                     5,221
                                     5,291

The facility population was adjusted to remove public access facilities and other facilities not required to have an Alternate Security Program (ASP) or Facility Security Plan (FSP), as well as facilities that are part of another FSP, and other facilities that have been granted waivers from certain MTSA provisions.  This removes 653 facilities and 489 owners from the overall MTSA-regulated population as shown in Table 2.2.  These facilities will not be required to use TWIC readers because it will be technologically or operationally unfeasible to implement readers at this time as the total net benefit is less than it is for just Risk Group A facilities.  Table 2.2 decomposes the remaining facilities by risk group and accounts for the barge fleeting facilities that are not required to comply with this final rule, as discussed in the previous chapter.  While this rulemaking does not include container facilities in its definition of Risk Group A, there may be cases where the cargo being handled by a container facility or vessel (e.g., CDC) would necessitate a Risk Group A classification.  The affected population used for this rulemaking includes three such facilities.

Table 2.2 Affected Facilities by Risk Group
                                  Risk Group
                               Owners/Operators
                                  Facilities
                                       A
                                      340
                                      525
                                     Non-A
                                     1,334
                                     2,092
                                     Total
                                     1,674
                                     2,617









Based on the risk hierarchy, OCS facilities that are shown in Table 2.3 are not considered high-risk for this final rule, and as such, we do not analyze the impact of the electronic TWIC inspection rulemaking on this population given that they do not have requirements for readers.




Table 2.3 OCS Facilities Population
                               Owners/Operators
                                  Facilities
                                      19
                                      56
*All OCS facilities subject to 33 CFR part 106 fall into non-Risk Group A.  

In the analysis supporting the 2006 ANPRM that estimated previously proposed card reader requirements, the mandatory card reader requirement costs were estimated for 5,257 vessels, 3,492 facilities, and 42 OCS facilities.  For this final rule, we estimated mandatory card reader requirement costs for 1 vessel and 525 facilities due to the new requirements, which are focused on high-risk facilities as shown in Table 2.4 below.  

Table 2.4 Affected Number of Facilities and Vessels
                                  Facilities
                                    Vessels
                                      525
                                       1

2.2 Movement Between Risk Groups
This final rule allows for movement between risk groups, when specified in an approved security plan.  This provision will allow for a facility or vessel to operate at a different risk group depending on the cargo being carried or handled.  The purpose of this provision is to offer relief for facilities or vessels that handle Risk Group A type cargo infrequently, such as a facility that handles bulk CDC or receives vessels carrying bulk CDC only one or two times a year.  Because these facilities will be required to comply with all electronic TWIC inspection requirements for Risk Group A when handling CDC cargo or otherwise operating in a manner that will put them in Risk Group A, we expect any facilities to deploy appropriate electronic TWIC inspection infrastructure that will enable them to operate as a Risk Group A facility.  Because facilities taking advantage of this provision will have to purchase and install TWIC readers to comply with the requirements at the highest risk group they may operate under, we do not anticipate a reduction in implementation period costs for these facilities.  However, because we assign facilities or vessels into the risk groups based on their highest risk group determination, there may be some facilities or vessels in Risk Group A that incur fewer day to day operational costs than are estimated in this analysis, since they will not have to use a TWIC reader during the periods that they are not operating as a Risk Group A facility.  These potential cost savings, however, are not estimated in this RA.

2.3 Estimated TWIC-Holder Population
The TWIC Pilot Report lists estimates of the number of TWIC-holders by facility type for the pilot participants.  These numbers represent the estimated potential population of TWIC-holders who might access participating facilities by various means, including truck, vehicle, or pedestrian gate.  Table 2.5 shows these estimates.

Table 2.5 Estimated Population of TWIC-Holders at Pilot Participants,
 by Facility Type
                                 Facility Type
                                     Truck
                                    Vehicle
                                  Pedestrian 
                                     Total
                               Percent of Total 
                              Container Terminals
                                    19,200 
                                     100 
                                    4,700 
                                    24,000 
                                     72.4%
                       Large Passenger Vessels/Terminals
                                      20 
                                     200 
                                    1,700 
                                    1,920 
                                     5.8%
                             Break Bulk Terminals
                                     700 
                                     210 
                                     700 
                                    1,610 
                                     4.9%
                             Petroleum Facilities
                                     225 
                                     110 
                                    4,765 
                                    5,100 
                                     15.4%
                     Small Passenger/Vessel/Towboats/Other
                                     -   
                                     100 
                                     400 
                                     500 
                                     1.5%
                                     Total
                                    20,145 
                                     720 
                                    12,265 
                                    33,130 
                                    100.0%

We assume that the nationwide distribution of TWIC-holders by facility type is similar to that among TWIC-holders at pilot sites, and we apply Table 2.5's shares of TWIC-holders by facility type from the TWIC Pilot Program data to the current 2,200,000 total number of active TWIC-holders to estimate the total number of all TWIC-holders by facility type.  Table 2.6 shows the estimated breakdown of the TWIC-holding population based on the percentage of TWIC-holders reported in the TWIC Pilot Report.


Table 2.6 Active TWIC-Holders by Facility Type
                               Participant Group
                               Percent of Total 
                               Total Population
                              Container Terminals
                                      72.4%
   1,592,800
                       Large Passenger Vessels/Terminals
                                       5.8%
   127,600
                             Break Bulk Terminals
                                       4.9%
   107,800
                             Petroleum Facilities
                                      15.4%
   338,800
                     Small Passenger/Vessel/Towboats/Other
                                       1.5%
   33,000
                                     Total
                                      100.0%
   2,200,000

We then divided the estimated number of TWIC-holders in each type by the total number of facilities in each type to obtain an estimate of TWIC-holders per facility, by facility type, as shown in Table 2.7.

Table 2.7 Estimated National TWIC-Holder Population, by Facility Type 
                                 Facility Type
                              Total TWIC-Holders
                               Total Facilities
                           TWIC-Holders per Facility
                              Container Terminals
                                   1,592,800
                                      122
                                    13,056
                       Large Passenger Vessels/Terminals
                                    127,600
                                      555
                                      230
                             Break Bulk Terminals
                                    107,800
                                      510
                                      211
                      Petroleum Facilities (Bulk Liquid)
                                    338,800
                                     1,097
                                      309
                     Small Passenger/Vessel/Towboats/Other
                                    33,000
                                      333
                                      99
                                     Total
                                   2,200,000
                                     2,617
                                      841

Using the figures from Table 2.8 for the number of TWIC-holder per facility by facility type, we then estimate the total number of TWIC-holder for each risk group.  Tables 2.7 through 2.9 show how these values were estimated.

Table 2.8 TWIC-Holders in Risk Group A
                                       
                             Number of Facilities
                           TWIC-Holders per Facility
                              Total TWIC-Holders
                              Container Terminals
                                       3
                                    13,056
                                    39,168
                       Large Passenger Vessels/Terminals
                                      92
                                      230
                                    21,160
                             Break Bulk Terminals
                                      16
                                      211
                                     3,376
                      Petroleum Facilities (Bulk Liquid)
                                      290
                                      309
                                    89,610
                     Small Passenger/Vessel/Towboats/Other
                                      124
                                      99
                                    12,276
                                     Total
                                      525
                                       
                                    165,590
                                       


                                       
We then use the estimates for TWIC-holders by risk group to calculate the percent of all TWIC-holders by risk group.  Table 2.9 shows the breakdown for estimated TWIC-holder population by risk group. 

Table 2.9 TWIC-Holder Population by Risk Group
                                       
                            TWIC-Holder Population
                               Percent of Total
                                       A
                                   165,590 
                                     7.5%
                                     Non-A
                                  2,034,410 
                                     92.5%
                                     Total
                                  2,200,000 
                                    100.0%

Our methodology for estimating the number of TWIC-holders by risk group inherently assumes that the number of TWIC-holders per facility is constant across different risk groups.  This assumption may not hold if, for example, high-risk facilities have more employees than lower risk ones.  
2.4 Facility Access Points 
As a means to estimate the number of readers that will be required, we first determined the average number of access points at MTSA-regulated facilities by reviewing FSPs.  As outlined in 33 CFR 105.405(a), FSPs include the security administration and organization of the facility and security measures for access control, including designated public areas, among many other items.  Through the FSPs we sampled, we were able to estimate the number of access points by facility type.  Our analysis of affected facilities includes a review of facility security plans to estimate the average number of access points by aggregated facility grouping.  The facility grouping was compiled by facility type.  Table 2.10 shows the results of this analysis.  Although container facility is not a type specified in the risk group decision making, it is used as a facility type in the TWIC Pilot Program.  As such, we include this type to better assess impacts as a separate facility type.

From our review of FSPs, we found minimum, maximum, and average numbers of access points for the aggregated facility groupings.  We use the following data to estimate the costs to facilities.  Since facilities vary greatly in size, geography, and operation, we use the average number of access points as the basis of this analysis.  This average was developed and applied by facility type so as to better account for the differences between facility types.


Table 2.10 Facility Access Points
                 (Data collected from Facility Security Plans)
                        Aggregated Facility Groupings*
                                      Min
                                      Max
                                    Average
                         FSPs with Data (FSP Sampled) 
Bulk Liquids
                                       1
                                      18
                                       3
                                                                      220 (304)
Break Bulk & Solids 
                                       1
                                      28
                                       4
                                                                      101 (176)
Container
                                       1
                                      37
                                       8
                                                                      155 (204)
Passenger (Cruise)
                                       1
                                      11
                                       4
                                                                      210 (237)
Passenger (Ferry)*
                                      --
                                      --
                                       2
                                                                             --
Mixed Use
                                       1
                                      53
                                       6
                                                                        38 (50)
* Most ferry terminals have a variety of public and worker access points. 

An access point to a secure area may require more than one TWIC reader, depending on the type of access point and how it is defined in the FSP.  As such, we have estimated the number of readers required per access point for the facility groupings found in Table 2.8, based on data from the TSA's TWIC pilot.  Table 2.11 shows the average number of TWIC access points and TWIC readers per facility grouping, based on TWIC pilot data, along with the reader-to-access-point ratio.  Although the TSA TWIC pilot is not a statistically representative sample of Group A facilities, it is used here as it is the largest scale study of electronic TWIC inspection impacts, providing the best approximation of the average number of readers likely to be needed at each facility required to use TWIC readers. 

Table 2.11 Readers Per Access Point
                       (Data collected from TWIC Pilot)
                                 Facility Type
                    Average Number of TWIC Access Points[1]
                       Average Number of TWIC Readers[1]
                          Readers per Access Point[2]
                                  Bulk Liquid
                                      5.0
                                     10.3
                                      2.1
                             Break Bulk and Solids
                                      6.0
                                      8.3
                                      1.4
                                   Container
                                     10.4
                                     18.0
                                      1.7
                              Passenger (Cruise)
                                      9.0
                                     16.0
                                      1.8
                               Passenger (Ferry)
                                      1.0
                                      2.0
                                      2.0
                                   Mixed Use
                                      5.0
                                      4.0
                                      0.7
1 Values in these columns represent the average number of access points and readers by facility type for the TSA pilot. The number of readers includes any readers needed for backup in the case of some system failures.
2 This number represents the average of the individual ratios for each facility, by facility type. They may not equal the ratio of the aggregate readers to access points.
We use the population figures in conjunction with the estimates for access points and the calculation of readers per access point to extrapolate the TWIC Pilot cost estimates to the national population.  
3) Data Sources and Independent Research
With the completion of the TSA's TWIC Pilot Program, as well as published independent reports, the Coast Guard has been able to better focus the requirements in this final rule.  This chapter briefly discusses some of these data sources and how they affected the final rule.
3.1 Homeland Security Institute Study
At the direction of the Office of Management and Budget (OMB), the Coast Guard tasked the HSI to conduct an independent peer review of its TWIC implementation analysis.  This involved an independent verification and validation of the reader requirements development process including a verification and validation of the MSRAM-based risk hierarchy presented in the ANPRM.  Based in part on the findings and recommendations of this study, the Coast Guard adjusted the applicability of the reader requirements from the ANPRM in the NPRM.  As the HSI report shows, the distinction between Risk Groups A and B, based on the Analytic Hierarchy Process (AHP), is well defined, with Risk Group A scores greater or equal to a specified threshold.  The distinction between Risk Groups B and C, based on the HSI report, is not as clear as that between A and B with Risk Group B and Risk Group C having AHP scores lower than the threshold.  As such, for this final rule, we have removed the electronic TWIC inspection requirements for Risk Group B and will focus only on the requirements for Risk Group A.  In addition, for the final rule, we have removed the distinction between Risk Groups B and C, and now refer to the combined group as "Non-Risk Group A."  Figure 3.1 below shows the rank-ordered AHP scores for all 68 TWIC asset categories.  Current risk groupings considered in the TWIC report and the NPRM are also displayed.  As discussed below, we considered the costs and benefits when deciding which facilities should be required to install readers.  We concluded that the level of risk, discussed as consequence, associated with targets in Risk Groups B and C does not warrant the investment in readers at this time given current costs and benefits.  In contrast, facilities in Risk Group A have significantly higher risk and can be more cost-effectively protected through this rule.


Figure 3.1 Rank-Ordered AHP Scores, with Current TWIC Risk Groupings




3.2 TSA Pilot Program
3.2.1 Background
The TWIC Pilot Program was established under Section 104 of the SAFE Port Act.  The purpose of the TWIC pilot was to evaluate TWIC and electronic TWIC inspection interoperability and assess the impacts of implementing a transportation security card reader system.

The SAFE Port Act directed the Department of Homeland Security (DHS) to conduct the TWIC pilot to inform the use of TWICs with biometric readers.  The purpose of this report was to test the business processes, technology, and operational impacts required to deploy transportation security card readers at secure areas of the maritime transportation system.

3.2.2 Pilot Participants
Five main participant groups were established for the TWIC pilot in an attempt to capture a broad cross-section of the maritime industry.  These five groups were container terminals, large passenger vessel terminals, break-bulk terminals, petroleum facilities, and a fifth group that included small passenger vessel terminals, towboat and other facility types.  The pilot participants varied in size and traffic, both dimensions of which generally spanned the range of potentially regulated facilities.  For a list of the pilot participants, see Appendix B.

The TWIC pilot study conducted between August 2008 and May 2011, and subsequent report released February 27, 2012 provided a sample of costs associated with the implementation of a card reader system that we leveraged to estimate what a reader system would cost on a national scale.  These data included estimates for the costs associated with TWIC reader hardware and software, installation costs, infrastructure costs, and costs associated with upgrading or modifying current physical access control systems.  The table below shows the final cost data collected from the pilot participants.  These data provide a snapshot of what electronic TWIC inspection implementation could potentially cost across a wide spectrum of facility types.  While not all of the TWIC pilot participants were in Risk Group A (2 out of 17 participants), using the costs associated with electronic TWIC inspection at facilities not in Risk Group A does not adversely affect our overall estimates.  Potential electronic TWIC inspection implementation costs should not differ greatly across risk groups, as the size and geography of a facility is independent of its risk grouping.  The affected population is based on common characteristics of facilities.  The key difference between the risk groups is the potential consequences of a TSI at a particular facility, not the costs associated with potential electronic TWIC inspection deployment.  Again, although the data from the TWIC pilot is not from a statistically representative sample of the affected population of MTSA-regulated facilities and vessels affected by this final rule, the pilot presents the most complete information available regarding the costs associated with large-scale reader implementation and integration for access control.  Table 3.1 presents summary data from the pilot that we used in this RA.

Table 3.1 Summary of TWIC Pilot Study Data
                                  Participant
                                   Category
                              TWIC Access Points
                                 TWIC Readers
                                 Reader Costs
                                  PACS Costs
                             Infrastructure Costs
                        Installation/ Integration Costs
                                     Total
                                       1
                                   Petroleum
                                      10
                                      15
                                    $64,155
                                   $272,836
                                   $162,440
                                    $80,133
                                   $579,564
                                       2
                                       
                                       4
                                      15
                                   $152,000
                                   $103,500
                                   $301,000
                                   $142,500
                                   $699,000
                                       3
                                       
                                       1
                                       1
                                    $4,240
                                      $0
                                    $2,000
                                    $4,000
                                    $10,240
                                       4
                                  Break-Bulk
                                      11
                                      15
                                    $75,000
                                   $150,000
                                   $711,583
                                    $50,000
                                   $986,583
                                       5
                                       
                                       1
                                       4
                                   $109,203
                                   $138,625
                                    $8,000
                                    $12,000
                                   $267,828
                                       6
                                       
                                       6
                                       6
                                    $68,340
                                   $120,983
                                   $196,376
                                    $81,661
                                   $467,360
                                       7
                                   Container
                                       7
                                      21
                                   $239,914
                                   $184,342
                                   $216,494
                                   $467,099
                                  $1,107,849
                                       8
                                       
                                       5
                                       6
                                   $263,083
                                   $138,625
                                    $15,463
                                    $50,000
                                   $467,171
                                       9
                                       
                                       5
                                      11
                                   $172,967
                                   $138,625
                                    $90,000
                                    $50,000
                                   $451,592
                                      10
                                       
                                      11
                                      13
                                   $266,400
                                   $713,190
                                   $400,000
                                   $645,500
                                  $2,025,090
                                      11
                                       
                                      24
                                      39
                                   $245,463
                                   $646,707
                                   $592,893
                                   $724,925
                                  $2,209,988
                                      12
                            Large Passenger Vessel
                                       5
                                       5
                                    $53,903
                                      $0
                                      $0
                                    $9,933
                                    $63,836
                                      13
                                       
                                      13
                                      27
                                   $243,462
                                    $80,283
                                   $391,396
                                   $106,836
                                   $821,977
                                      14*
                    Small Passenger Vessel/ Towboat/ Other
                                       1
                                       2
                                    $15,845
                                      $0
                                      $0
                                      $0
                                    $15,845
                                      15

                                       2
                                       1
                                    $16,200
                                      $0
                                      $0
                                      $0
                                    $16,200
                                      16*

                                       1
                                       2
                                    $15,282
                                      $0
                                      $0
                                      $0
                                    $15,282
                                      17

                                       8
                                       7
                                    $83,405
                                    $69,000
                                   $350,000
                                   $455,060
                                   $957,465
* Note that in subsequent tables, these two pilot participants are separated out from this broad category and are discussed as small passenger facilities. The other two in this category will be discussed as Mixed Use in the subsequent analysis.
	


3.3 Pilot Results
The TSA TWIC pilot provided significant insights to advance the electronic TWIC inspection requirements.  The TWIC pilot brought to light some of the operational and technical difficulties at many pilot locations, but also demonstrated that many options are available to facility and vessel operators for validating the authenticity of a TWIC card and verifying the identity of the TWIC-holder.  The TWIC pilot affirmed the need for a performance-based standard to allow flexibility in the deployment of electronic TWIC inspection to provide a best-fit solution due to the uniqueness of each regulated facility and vessel operation.
3.4 Use of Pilot Data
The Coast Guard used the TWIC pilot findings in a number of ways.  The TWIC pilot findings were the source for data on the deployment costs of electronic TWIC inspection, as well as the number of readers per access point, throughput times, population of TWIC-holders by facility type, and failure rates of readers.  Pilot data was supplemented with other available data sources to provide preliminary estimates of costs and benefits.  Other data sources included MISLE for population figures, Facility Security Plans for the number of access points per facility, MSRAM for risk hierarchy and consequence data, the GSA schedule for reader hardware and software costs, U.S. Environmental Protection Agency data for estimates for truck throughput, and other literature for basic background on electronic TWIC inspection.

4) Costs of Electronic TWIC Inspection Requirements
This chapter discusses the estimated cost associated with the implementation of the electronic TWIC inspection requirements.  The costs associated with the electronic TWIC inspection requirements will be borne by MTSA-regulated entities based on a tiered system.  The following analysis is broken down into three sections.  Section 4.1 estimates the costs to waterfront facilities as a result of the electronic TWIC inspection requirements.  Section 4.2 estimates the associated costs to vessel owners.  Section 4.3 presents estimates of additional costs.  Section 4.4 summarizes total costs to industry.  Section 4.5 discusses cost mitigation, and Section 4.6 estimates government and total costs. 

For this final rule, we present costs by risk group for affected owners and operators of certain vessels, facilities, and OCS facilities.  The conclusion of this chapter aggregates these estimates into national (direct industry) cost estimates.  

Although the final rule refers to more stringent requirements under elevated Maritime Security (MARSEC) Levels, we assess the costs of this rule assuming operation under MARSEC Level 1.  The MARSEC Level has risen above MARSEC Level 1 few times, and not within the last five years.  As such, the requirements for elevated MARSEC Levels would infrequently occur.  Furthermore, overall costs associated with an increase in MARSEC Level would be targeted to a location and time, and in response to specific threat information.  Such changes would trigger a number of existing requirements, of which reader costs would be a small subset.  Additionally, the enhanced security afforded by the readers may cause Captains of the Ports (COTPs) to be less likely to initiate other potentially more expensive security changes in response to an elevated MARSEC level, thereby providing potential cost savings.  Neither these potential savings nor potential costs are assessed here, given the lack of data from these infrequent and targeted increases in MARSEC Levels.

We also present and discuss for each primary cost driver or key assumption in the below cost analysis section whether a public comment was received and if we modified or kept unchanged those assumptions and ensuing cost analyses or estimates based on such comment and continuous review of the current industry data.  
4.1 Costs to Facilities
The reader requirements will only apply to those 525 facilities in Risk Group A, as those facilities pose the greatest risk of, and highest consequence from, a TSI.  The remaining facilities will not incur costs under this final rule.  After the publication of the NPRM, we received several comments questioning whether barge fleeting facilities should have been required to implement an electronic TWIC inspection program.  Based on these comments and upon further consideration, this final rule excludes those barge fleeting facilities, and therefore, reducing the NPRM's affected population of 532 facilities to the current population of 525 facilities.    

There are ten primary cost drivers for this proposed rule:  
   1. TWIC reader, which includes hardware and software. 
   2. Installation of the TWIC readers at the facility.  
   3. Infrastructure updates required for the TWIC readers to operate or be installed in appropriate locations, including costs to integrate TWIC readers with existing PACS. 
   4. Maintenance.
   5. Amending the FSP.  
   6. Recordkeeping systems.  
   7. Updating the CCL.  
   8. Training personnel to perform electronic TWIC inspections.
   9. Delay costs due to reader failures.
   10. Additional delay, travel and TWIC replacement costs due to TWIC failures.
4.1.1 TWIC Reader Costs
To estimate the costs of the electronic TWIC inspection requirements, the Coast Guard had to estimate the number of readers needed nationwide.  To do this, we obtained data from the Coast Guard MISLE database, research conducted by subject matter experts in the Coast Guard's Office of Port and Facility Compliance, as well as data provided in the TWIC Reader Pilot Program conducted by the TSA.

Several steps were needed to estimate the number of TWIC readers required on a national scale.  The first step was to determine the number of access points per facility based on facility type.  To determine this, Coast Guard subject matter experts reviewed FSPs to compile a sample of facilities.  From this sample, the corresponding minimum, maximum, and average numbers of access points were generated.  Table 4.1 below shows the results of the survey of FSPs.


Table 4.1 Facility Access Points 
                 (Data from collected Facility Security Plans)
Aggregated Facility Groupings
Min
Max
Average
FSPs with Data Assessed (FSPs Sampled)
Bulk Liquids
1
18
3
220 (304)
Break Bulk & Solids 
1
28
4
101 (176)
Container
1
37
8
155 (204)
Passenger (Cruise)
1
11
4
210 (237)
Passenger (Ferry)*
--
--
2
--
Mixed Use
1
53
6
38 (50)
* Most ferry terminals have a variety of public and worker access points. Based on limited security plan data, we maintain that there would be an average of two access points for these facilities.

Next, we created an estimate of the number of TWIC readers needed per access point.  This ratio was based on the data from the TWIC pilot, and was calculated by dividing the number of readers for each pilot site by the number of access points for that pilot site.  Here we used the same grouping of facilities as was used for the access point calculation, we then took the average of the reader-to-access-point ratio by facility grouping to obtain our reader-to-access-point ratio by facility type.  The results can be seen in Table 4.2 below.

Table 4.2 Readers per Access Point, by Facility Type

                            (Data from TWIC Pilot)
                                  Participant
                                   Category
                              TWIC Access Points
                                 TWIC Readers
                           Readers per Access Point
                                       1
                                 
Bulk Liquid
                                      10
                                      15
                                      1.5
                                       2

                                       4
                                      15
                                      3.8
                                       3

                                       1
                                       1
                                      1.0
                                    Average
                                       
                                      5.0
                                     10.3
                                      2.1
                                       1
                                  Break-Bulk
                                       1
                                       4
                                      4.0
                                       2

                                       6
                                       6
                                      1.0
                                       3

                                      11
                                      15
                                      1.4
                                    Average
                                       
                                      6.0
                                      8.3
                                      2.1
                                       1
                                   Container
                                       7
                                      21
                                      3.0
                                       2

                                       5
                                       6
                                      1.2
                                       3

                                       5
                                      11
                                      2.2
                                       4

                                      11
                                      13
                                      1.2
                                       5

                                      24
                                      39
                                      1.6
                                    Average
                                       
                                     10.4
                                     18.0
                                      1.8
                                       1
                            Large Passenger Vessel
                                       5
                                       5
                                      1.0
                                       2

                                      13
                                      27
                                      2.1
                                    Average
                                       
                                      9.0
                                     16.0
                                      1.5
                                        1*
                    Small Passenger Vessel/ Towboat/ Other
                                       1
                                       2
                                      2.0
                                       3

                                       2
                                       1
                                      0.5
                                        2*

                                       1
                                       2
                                      2.0
                                       4

                                       8
                                       7
                                      0.9
                                   Average 
                                Small Passenger
                                      1.0
                                      2.0
                                      2.0
                                   Average 
                                   Mixed Use
                                      5.0
                                      4.0
                                      0.7
* Note that these two pilot participants are separated out from this broad category and are discussed as small passenger facilities. The other two in this category will be discussed as Mixed Use in the subsequent analysis. This breakdown is used to calculate the average values for Small Passenger and Mixed Use categories.

The next step was to combine the average number of access points by facility type with the corresponding reader-to-access-point ratio to estimate the number of readers required by facility type.  These results are shown in Table 4.3.


Table 4.3 Estimate of Average Number of Readers per Facility Type*
                                 Facility Type
                      Average Number of Access Points[1]
                                      (A)
                        Reader to Access Point Ratio[2]
                                      (B)
                      Average Number of Readers Required
                                    (A * B)
                                  Bulk Liquid
                                       3
                                      2.1
                                      6.3
                             Break Bulk and Solids
                                       4
                                      2.1
                                      8.5
                                   Container
                                       8
                                      1.8
                                     14.7
                                Large Passenger
                                       4
                                      1.5
                                      6.2
                                Small passenger
                                       2
                                      2.0
                                      4.0
                                   Mixed Use
                                       6
                                      0.7
                                      4.1
    * Values are rounded from actual calculations and may not average to the exact numbers presented in the table.
    1 Based on data collected from FSPs.
    [2] Based on data collected during the TWIC pilot. It should be noted that because the pilot was voluntary, when readers broke down, participants generally reverted to current visual TWIC inspection requirements. This final rule allows for a facility to revert to visual TWIC inspection for persons known to possess a TWIC and who have been previously granted unescorted access for up to 30 days if readers malfunction.

We then broke down the Risk Group A population of 525 facilities by facility type and multiplied the population numbers with the corresponding average number of readers required.  The last step in determining the number of readers required on a national scale was to apply a percentage of fixed and portable readers to the number of total readers required.  To obtain the numbers for fixed versus portable readers, we again turned to the TWIC pilot.  We reviewed the number of fixed and portable readers used by the pilot participants to estimate the percentages of fixed and portable readers needed by facility type and used these percentages to estimate the total number of fixed and portable readers required (see TWIC Pilot Study Report, Table 4.2).  These numbers are detailed below in Table 4.4.  

We received public comments on the number of readers stating that we underestimated the average number of readers in our cost analysis.   The one commenter that provided a specific estimate was a large ferry facility with an estimate for the number of readers needed at 62.  The average of 4 readers per facility used in the NPRM analysis represents the average number per facility derived from facility plans and TWIC pilot data.  To acknowledge that large passenger facilities at the high end of the distribution would have a larger number of readers, we use the 62 readers as the proxy for the top 5[th] percentile of passenger facilities. Thus, for 3 facilities (5 percent of 63 facilities), we assume 62 readers per facilities, and maintain the average number of readers per facility for the remaining 60 passenger facilities.   

Table 4.4 Estimate of Total Readers*
                                 Facility Type
                                Facility Count
                      Average Number of Readers Required
                                 Total Readers
                             Average Percent Fixed
                           Average Percent Portable
                                     Fixed
                                   Portable
                                  Bulk Liquid
                                      290
                                      6.3
                                     1,827
                                      84%
                                      16%
                                     1,535
                                      292
                             Break Bulk and Solids
                                      16
                                      8.5
                                      136
                                      67%
                                      33%
                                      91
                                      45
                                 Containerized
                                       3
                                     14.7
                                      44
                                      82%
                                      18%
                                      36
                                       8
                               Passenger Cruise
                                      92
                                      6.2
                                      566
                                      7%
                                      93%
                                      42
                                      524
                                Passenger Ferry
                                      63
                                      6.8
                                      426
                                      0%
                                     100%
                                       0
                                      426
                                                                        Average
                                      60
                                      4.0
                                      240
                                      0%
                                     100%
                                       0
                                      240
                                                          Large Passenger Ferry
                                       3
                                     62.0
                                      186
                                      0%
                                     100%
                                       0
                                      186
                                   Mixed Use
                                      61
                                      4.1
                                      252
                                      71%
                                      29%
                                      180
                                      72
                                     Total
                                      525
                                       
                                     3,251
                                       
                                       
                                     1,884
                                     1,367
* Values are rounded from actual calculations and may not average or total to the exact numbers presented in the table.

To complete the cost calculation for the readers, we next researched the equipment costs for all TWIC readers that have passed the TSA's test to conform with its TWIC reader requirements, and thus, placed on the QTL.  The NPRM RA's reader cost estimates relied on the ICE Test and utilized those equipment costs listed on the GSA price schedule as no readers were yet on the QTL.  The QTL includes all five readers that are currently approved by TSA for use in reading TWICs.  Instead of using GSA schedule listed prices for TWIC readers, as was the case for the NPRM RA, this time we utilized QTL's reader information to obtain an average cost for portable readers and used GSA schedule for fixed readers.  Table 4.5 below shows the results of this research.
  

Table 4.5 Average Reader Costs

Fixed*
Portable*
Total Average Cost
(includes hardware and software)
$5,373 
$7,035 
		
		* For portable readers we used the average of all four products listed on the 				QTL (Figure C4). For fixed readers, we took the average of fixed reader prices 				from GSA Schedule (Figure C3).  

The average reader costs were then multiplied by the estimated number of readers required to estimate the national cost to purchase readers.  Table 4.6 below shows the estimated national costs for readers at Risk Group A facilities.  These figures represent the estimated combined hardware and software costs for TWIC readers across all Risk Group A facilities.  We divide the initial costs of readers equally among the first 2 years of implementation.  Because we could not find reliable data on maintenance and lifespan of TWIC readers, we estimate that every fifth year after implementation, there will be a full replacement of readers equal to that of the implementation year cost.  We believe that 5 years is the expected life of readers, based in part on the experience that the Coast Guard has had with readers in the field.  

Table 4.6 Estimated National Reader Costs
 
                              Number of Readers*
                           Average Cost per Reader*
                            Estimated National Cost
Fixed
                                     1,884
                                    $5,373 
                                 $10,122,732 
Portable
                                     1,367
                                    $7,035 
                                  $9,616,845 
Total
                                     3,251
                                       
                                 $19,739,577 
* Both Number of Readers and Average Cost per Reader are rounded. Average Cost per Reader includes hardware and software.  

The TWIC Pilot captured several additional costs associated with the deployment of electronic TWIC inspections.  These costs include installation and integration, infrastructure costs, and costs associated with modifying PACS to be interoperable with TWIC readers.  The final regulation uses a performance-based approach, with owners/operators being given significant flexibilities to comply with the reader requirement.  At its most basic, owners/operators could merely deploy portable readers, which will require no new infrastructure (owners/operators must have access to control lists, computers and other required capabilities in order to comply with MTSA and other requirements) and little in the form of annual maintenance.  We expect this to be the approach used for vessels, and Appendix D shows that installation can come at no cost.  Other owners/operators may decide to use fixed readers, in order to increase throughput or for other business reasons.  Such installations will involve slightly more infrastructure, including a mounting mechanism for the reader, power to the reader and a communications link to the access control system.  As such, we expect these marginal costs to be small and require minimal annual maintenance.  Still other owners/operators may choose a more complicated installation, including more complex monitoring and decision support systems in their PACS and/or adding gates or extra lanes to further increase throughput.

The Coast Guard is using data on FY06 and FY07 grants, as captured in the TWIC pilot Study, to determine the costs of these reader installations.  It should be noted that these funds were not funds that facilities decided to spend out of their own resources.  These grant funds were used for installing TWIC readers and infrastructure to support the TWIC pilot and were not used to comply with specific regulatory requirements since none currently exist  --  specific national regulatory requirements for electronic TWIC inspections to meet standards for access control and credential verification is the subject of this rulemaking.  Therefore, expenditures used to support the TWIC pilot may not be needed to meet the narrow applicability and minimum performance standards of the regulatory requirements in this final rule.  As such, the data captured in the TWIC Pilot Report may overestimate the PACS, infrastructure, and installation costs as noted in our responses to public comments in Section 1.1 of this RA.  Absent other data sources, however, the Coast Guard used the data in the TWIC Pilot Report to inform this rulemaking.

To assess these costs for the affected population, we extrapolated the costs reported in the TWIC pilot by first determining a per reader cost for these components for each facility type grouping.  This per reader cost was then multiplied by the estimated total number of readers required as shown in Table 4.4.  Details are shown in Appendix D.  The results of this methodology are shown in Tables 4.7, 4.8, and 4.9.

Additional costs will be required to install and integrate TWIC readers into each facility's access control system.  These integration costs may vary greatly by facility based on facility type and whether fixed or portable readers are predominantly employed.  To provide an estimate of the installation costs of the electronic TWIC inspection program, we used the TWIC Pilot Program data in Table 3.1 to estimate an average installation cost per reader by facility type.  We did not change our installation costs assumptions based on public comments received on the NPRM, which provided only general characterization and not specific estimated information.  This average was then multiplied by the number of total readers per facility type estimated in Table 4.4.  Table 4.7 shows this calculation.  We estimate a total installation cost of $23.2 million to install and integrate electronic TWIC inspection programs at Risk Group A facilities.
Table 4.7 Installation Costs for TWIC Readers
                                 Facility Type
                               Number of Readers
                         Installation Cost Per Reader
                             Cost By Facility Type
                                  Bulk Liquid
                                     1,827
                                   $6,281  
                                 $11,475,387 
                             Break Bulk and Solids
                                      136
                                    $6,648 
                                   $904,128 
                                   Container
                                      44
                                   $20,673 
                                   $909,612 
                                Large Passenger
                                      566
                                    $2,972 
                                  $1,682,152 
                                Small passenger
                                      426
                                      $0 
                                      $0 
                                   Mixed Use
                                      252
                                   $32,504  
                                  $8,191,008 
                                     Total
                                     3,251
                                       
                                 $23,162,287 

Based on the TWIC Pilot Program, we also estimate that there will be infrastructure costs associated with implementing the electronic TWIC inspection requirements.  These costs include required supporting investments, such as running power and fiber optics to fixed readers at facilities.  It should be noted that participants in the Pilot Program also made several discretionary investments, including installing guard stations, lift gates, fencing, and others that are not directly related to the electronic TWIC inspection requirements.  We included these costs in our estimate of installation costs, however the inclusion of these costs may lead to an overestimate of this cost component to the extent that these are unnecessary for security or to facilitate an electronic TWIC inspection program.  We calculated the estimates for infrastructure costs the same way we estimated the installation and integration costs.  To provide an estimate of the infrastructure costs of the electronic TWIC inspection program, we used the TWIC Pilot Program data in Table 3.1 to estimate an average infrastructure cost per reader by facility type.  As in the case of installation costs that we discussed in the previous section, we did not change our infrastructure costs assumptions based on public comments received.  Table 4.8 shows these infrastructure costs, by facility type.  We estimate a $34.8 million infrastructure cost during the period of implementation.


Table 4.8 Infrastructure Costs for TWIC Readers
                                 Facility Type
                               Number of Readers
                        Infrastructure Cost Per Reader
                             Cost By Facility Type
                                  Bulk Liquid
                                     1,827
                                   $10,965 
                                 $20,033,055 
                             Break Bulk and Solids
                                      136
                                   $27,389 
                                  $3,724,904 
                                   Container
                                      44
                                   $13,408 
                                   $589,952 
                                Large Passenger
                                      566
                                    $7,248 
                                  $4,102,368 
                                Small passenger
                                      426
                                      $0 
                                      $0 
                                   Mixed Use
                                      252
                                   $25,000 
                                  $6,300,000 
                                     Total
                                     3,251
                                       
                                 $34,750,279 

Infrastructure costs also include those costs related to integrating the TWIC readers into existing PACS.  Based on the Pilot Study, integration of TWIC into current PACS may be more cost effective and efficient than implementing TWIC independent of any current systems, due to fewer operational and technical integration issues.  For this reason, we include these costs.  The cost reduction for existing PACS was captured through the use of pilot data.  Pilot participants who saw a savings due to their current infrastructure would have reported lower costs associated with the pilot, which were then used to calculate the overall average cost per reader.  These cost savings would effectively be represented in the average costs per reader.

Based on TSA Pilot Program data, we estimated the average PACS cost per reader installed by facility type, and applied that estimate to the total number of readers by facility type in Risk Group A.  To provide an estimate of the PACS costs of the electronic TWIC inspection program, we used the TWIC Pilot Program data in Table 3.1 to estimate an average PACS cost per reader by facility type.  As discussed in the derivation of our installation and infrastructure cost estimates earlier, we left our PACS cost estimates unchanged.  There were no specific public comments addressing these costs providing any information or data.  

Table 4.9 shows these PACS related costs, by facility type.  We estimate a $21.3 million implementation cost to integrate TWIC with current PACS.


Table 4.9 PACS Costs for TWIC Readers
                                 Facility Type
                               Number of Readers
                             PACS Cost Per Reader
                             Cost By Facility Type
                                  Bulk Liquid
                                     1,827
                                    $8,363 
                                 $15,279,201 
                             Break Bulk and Solids
                                      136
                                   $21,607 
                                  $2,938,552 
                                   Container
                                      44
                                   $23,186 
                                  $1,020,184 
                                Large Passenger
                                      566
                                    $1,487 
                                   $841,642 
                                Small passenger
                                      426
                                      $0 
                                      $0 
                                   Mixed Use
                                      252
                                    $4,929 
                                  $1,242,108 
                                     Total
                                     3,251
                                       
                                 $21,321,687 

Based on these costs, we estimate that the electronic TWIC inspection requirements will cost facilities approximately $99.0 million in capital costs for full implementation as shown in Table 4.10.  This includes $19.7 million in TWIC reader costs, and $79.2 million in costs associated installation, infrastructure, and PACS.  We assume that facilities will face similar TWIC reader costs 5 years after implementation, due to equipment replacement.

Table 4.10 Total Facility Capital Costs, 2-Year Implementation Period 
(Years 1 and 2)
                                 Facility Type
                             Number of Facilities
                                 Total Readers
                              Total Reader Costs
                                  Total Costs
                              Total Capital Cost
                                       
                                       
                                     Fixed
                                   Portable
                                     Fixed
                                   Portable
                                 Installation
                                Infrastructure
                                     PACS
                                       
                                  Bulk Liquid
                                      290
                                     1,535
                                      292
                                  $8,247,555 
                                  $2,054,220 
                                 $11,475,387 
                                 $20,033,055 
                                 $15,279,201 
                                 $57,089,418 
                             Break Bulk and Solids
                                      16
                                      91
                                      45
                                   $488,943 
                                   $316,575 
                                   $904,128 
                                  $3,724,904 
                                  $2,938,552 
                                  $8,373,102 
                                   Container
                                       3
                                      36
                                       8
                                   $193,428 
                                   $56,280 
                                   $909,612 
                                   $589,952 
                                  $1,020,184 
                                  $2,769,456 
                               Large Passenger 
                                      92
                                      42
                                      524
                                   $225,666 
                                  $3,686,340 
                                  $1,682,152 
                                  $4,102,368 
                                   $841,642 
                                 $10,538,168 
                                Small Passenger
                                      63
                                       0
                                      426
                                      $0 
                                  $2,996,910 
                                      $0 
                                      $0 
                                      $0 
                                  $2,996,910 
                                   Mixed Use
                                      61
                                      180
                                      72
                                   $967,140 
                                   $506,520 
                                  $8,191,008 
                                  $6,300,000 
                                  $1,242,108 
                                 $17,206,776 
                                     Total
                                      525
                                     1,884
                                     1,367
                                 $10,122,732 
                                  $9,616,845 
                                 $23,162,287 
                                 $34,750,279 
                                 $21,321,687 
                                  $98,973,830

4.1.2 Maintenance Costs
We assume an annual maintenance cost equivalent to 10% of the cost of the TWIC readers (hardware and software combined) in addition to a cost for replacing readers every five years.  Because TWIC readers will be used in the harsh maritime environment, we assume that there will be an annual maintenance component to the cost of TWIC readers.  Table 4.11 shows the calculation for the TWIC reader maintenance costs.  Based on these calculations, we estimate an annual cost of $2.0 million for reader maintenance.  

Table 4.11 Annual Maintenance Costs for TWIC Readers
                                       
                                     Fixed
                                   Portable
                               Number of Readers
                                     1,884
                                     1,367
                                Cost Per Reader
                                    $5,373
                                    $7,035
                   Maintenance Cost (Percent of Reader Cost)
                                      10%
                                      10%
                            Total Maintenance Cost
                                  $1,012,273
                                   $961,685

We do not include maintenance costs for infrastructure and PACS that may accompany the TWIC reader installation in this RA and the Final Regulatory Flexibility Analysis (FRFA).  Based on our observations during the TWIC pilot implementation, the infrastructure and PACS modifications for TWIC reader installations involve existing infrastructure, such as extended power or communications cables to existing access points, and will not result in additional maintenance costs.  

While we expect there to be no additional maintenance costs for infrastructure and PACS, we provide a sensitivity analysis to reveal whether, and to what extent, the results of the cost analysis are sensitive to this assumption.  We provide an estimate of maintenance costs by using the 10% annual maintenance cost assumption and methodology above for TWIC readers and applying it to the infrastructure and PACS implementation costs in Table 4.10, Total Facility Capital Costs.  This will present an estimate of infrastructure and PACS maintenance costs if we found all of the TWIC pilot expenditures resulted in direct compliance costs for this final rule.  

As previously discussed, we expect the infrastructure and PACS-related costs collected from the TWIC pilot to be an overestimate and not include additions that require substantive annual maintenance.  As a result, we use half of the total infrastructure and PACS implementation costs for the purposes of a sensitivity analysis.  Using this information, the undiscounted annual recurring maintenance cost for infrastructure and PACS will be $2,803,598 per year for Risk Group A facilities after the 2-year implementation period.   If we add this to the undiscounted costs of the final rule, then it will increase the annual recurring industry costs from about $8.1 million to about $10.9 million (increase by about 34%) and the total 10-year industry costs from about $198.4 million to about $201.2 million (increase by 14%).  Total industry costs of the final rule are presented in Section 4.4 for comparison.  This cost differential applies across the alternative shown in Table 6.3, and thus the Final Rule Alternative remains the most cost effective, requiring the least amount of averted attacks to break even.


4.1.3 Operational Costs for Facilities
The final rule will require facilities regulated by 33 CFR part 105 to update their security plans to reflect the incorporation of TWIC readers, maintain records on individuals accessing their properties, and modify their access control procedures to integrate TWIC readers.  These requirements will impose costs on owners and operators of Risk Group A facilities regulated by part 105 that install TWIC readers.

The final rule will require facilities to submit an amendment to their security plans that will detail how TWIC readers will be incorporated into their security measures.  This represents a financial impact to regulated entities as an employee will need to draft an addendum and submit it to the Coast Guard.  The Coast Guard estimates that it will take 25 hours for each facility to create an addendum, and that the average loaded wage of someone performing this work will equal $71.12 per hour, which is the estimated wage for a Facility Security Officer (FSO).  One commenter said it should not take 25 hours to update a facility security plan for TWIC. We believe that for some facilities it may take fewer hours, but for others it will take more than 25 hours, especially if changes to security plans are reviewed by multiple people, and therefore, we kept it unchanged as it represents a reasonable average.  See Table 4.12 for the cost for amendments.  As only Risk Group A facilities will be required to implement an electronic TWIC inspection program, we anticipate 525 MTSA-regulated facilities in Risk Group A to amend their FSPs to include information related to electronic TWIC inspections.  

Table 4.12 Costs for TWIC Amendments
                                     Year
                                  Facilities
                                     Hours
                                   Unit Cost
                                   Total = 
                                       
                                       A
                                       B
                                       C
                                   A x B x C
                                       1
                                      263
                                      25
                                    $71.12
                                   $467,614
                                       2
                                      262
                                      25
                                    $71.12
                                   $465,836
                                       3
                                       0
                                      25
                                    $71.12
                                      $0
                                       4
                                       0
                                      25
                                    $71.12
                                      $0
                                       5
                                       0
                                      25
                                    $71.12
                                      $0
                                       6
                                       0
                                      25
                                    $71.12
                                      $0
                                       7
                                       0
                                      25
                                    $71.12
                                      $0
                                       8
                                       0
                                      25
                                    $71.12
                                      $0
                                       9
                                       0
                                      25
                                    $71.12
                                      $0
                                      10
                                       0
                                      25
                                    $71.12
                                      $0
                                     Total
                                       
                                       
                                       
                                   $933,450

The final rule requires a new recordkeeping requirement for facilities that perform electronic TWIC inspections, mandating that they maintain records of all individuals who access the facility for 2 years.  Current MTSA requirements account for the protection of sensitive security information (SSI).  Furthermore, an electronic TWIC inspection will typically capture three pieces of information when an individual's TWIC is scanned: (1) Federal Agency Smart Credential Number (FASC - N), (2) date, and (3) time.  Electronic TWIC inspection does not capture the name of the TWIC-holder unless the TWIC is being read by a contact reader and the Personal Identification Number (PIN) has been entered.  We assume this will require additional labor.  We employ the same wage rate used to estimate the cost to amend the FSP and determined that it will take 40 hours to create an adequate recordkeeping system to fulfill the requirements of the final rule.  We anticipate the recordkeeping system to be predominantly automated, requiring little maintenance and upkeep.  It will consist of reviewing and backing up files on a monthly basis.  As such, we estimate that there will also be a burden of approximately 30 minutes per month to conduct maintenance of the recordkeeping system.  This will add an additional 6 hours of burden per facility per year.  Based on information from USCG subject matter experts and facility observations, it is assumed that the majority of PACS currently in place already possess this capability, and a number of approved TWIC readers also can independently perform this function.  We did not receive any public comments on these cost assumptions and therefore, they are unchanged from the NPRM RA.  See Table 4.13 for recordkeeping costs.  For this requirement, only those facilities performing electronic TWIC inspections will need to comply.  

 Table 4.13 Costs to Create and Maintain Recordkeeping Systems
                                     Year
                                  Facilities
                                     Hours
                                   Unit Cost
                                    Total =
                                       
                                       A
                                       B
                                       C
                                   A x B x C
                                       1
                                      263
                                      40
                                    $71.12
                                   $748,182
                                       2
                                      262
                                      46
                                    $71.12
                                   $857,138
                                       3
                                      525
                                       6
                                    $71.12
                                   $224,028
                                       4
                                      525
                                       6
                                    $71.12
                                   $224,028
                                       5
                                      525
                                       6
                                    $71.12
                                   $224,028
                                       6
                                      525
                                       6
                                    $71.12
                                   $224,028
                                       7
                                      525
                                       6
                                    $71.12
                                   $224,028
                                       8
                                      525
                                       6
                                    $71.12
                                   $224,028
                                       9
                                      525
                                       6
                                    $71.12
                                   $224,028
                                      10
                                      525
                                       6
                                    $71.12
                                   $224,028
                                     Total
                                       
                                       
                                       
                                  $3,397,544
      
We estimate the CCL download to take approximately 30 minutes based on information from the TSA HAZMAT Threat Assessment Program.  During the public comment period after the publication of the NPRM in March 2013, some commenters stated that the Coast Guard overestimated the amount of time needed for a CCL update, and that updates to the CCL should be an automated function taking about five seconds.  Therefore, the CCL update should not be included as an ongoing item with assigned labor expense in the RA.  While we recognize that some larger facilities may be able to automate this process, we do not believe that all facilities will have such an automated solution.  Therefore, we did not change our estimate that this will constitute, on average, 30 minutes per week per facility for 26 annual hours of labor.  We also changed wages to reflect loaded wage rates for FSOs.  See Table 4.14 for cost associated with CCL downloads.             
Table 4.14 Costs for Frequent CCL Downloads
                                     Year
                                  Facilities
                                     Hours
                                   Unit Cost
                               Total = A x B x C

                                       A
                                       B
                                       C

                                       1
                                      263
                                      26
                                    $71.12
                                   $486,319
                                       2
                                      262
                                      26
                                    $71.12
                                   $484,469
                                       3
                                      525
                                      26
                                    $71.12
                                   $970,788
                                       4
                                      525
                                      26
                                    $71.12
                                   $970,788
                                       5
                                      525
                                      26
                                    $71.12
                                   $970,788
                                       6
                                      525
                                      26
                                    $71.12
                                   $970,788
                                       7
                                      525
                                      26
                                    $71.12
                                   $970,788
                                       8
                                      525
                                      26
                                    $71.12
                                   $970,788
                                       9
                                      525
                                      26
                                    $71.12
                                   $970,788
                                      10
                                      525
                                      26
                                    $71.12
                                   $970,788
                                     Total
                                       
                                       
                                       
                                  $8,737,092
	
The Coast Guard also assumes that there will be a training component necessary for the full implementation of the electronic TWIC inspection requirements, so that facility personnel can properly use the readers.  We estimate that this training will be done on the job, as it will be facility-specific based on the hardware, software, and physical layout of the facility.  We estimate that training will require 4 hours and that all FSOs and facility personnel with security duties will need to undergo electronic TWIC inspection training.  Because familiarization with TWIC and identity verification was required in the first TWIC rulemaking, the training discussed here will focus solely on the electronic TWIC inspections.  Using Coast Guard data, including a review of FSPs as well as work-shift hour information, we determined the average number of FSOs and personnel with security duties for all Risk Group A facilities: 1 FSO per facility and 6.46 personnel with security duties.  We assume that electronic TWIC inspection training will take an estimated 4 hours to complete.  The cost of this training is the opportunity cost of time spent in training, which is equal to the wage of the employee multiplied by the number of hours spent training.  We did not receive any public comments on these training hours assumptions, and therefore, we kept them unchanged for this final rule's RA.  The loaded wage for an FSO is the same as used above ($71.12) and the loaded wage for personnel with security duties is $30.84.  

      Hours of training (first year) x loaded wage for FSO x Number of FSOs = Cost of Training 
      
      4 x $71.12 x 525 = $149,352
      
      Hours of training (first year) x loaded wage for Personnel with Security Duties x Number of Personnel with Security Duties = Cost of Training 
      
      4 x $30.84 x 3,392 = $418,437
	
We divide these costs evenly over the 2-year implementation period, based on the assumption that approximately 50% of the regulated entities will comply each year of the implementation period.  We also include an estimated one hour of training each subsequent year for both FSOs and personnel with security duties to account for additional electronic TWIC inspection-related training that will be included in the existing annual required facility-specific MTSA training.

Table 4.15 below shows the costs of training for facility personnel.

Table 4.15 Training Costs for Facilities
                                     Year
                                      FSO
                        Personnel With Security Duties
                               Cost of Training
                                       1
                                    $74,676
                                   $209,219
                                   $283,895
                                       2
                                    $93,345
                                   $261,523 
                                   $354,868
                                       3
                                    $37,338
                                   $104,609
                                   $141,947
                                       4
                                    $37,338
                                   $104,609
                                   $141,947
                                       5
                                    $37,338
                                   $104,609
                                   $141,947
                                       6
                                    $37,338
                                   $104,609
                                   $141,947
                                       7
                                    $37,338
                                   $104,609
                                   $141,947
                                       8
                                    $37,338
                                   $104,609
                                   $141,947
                                       9
                                    $37,338
                                   $104,609
                                   $141,947
                                      10
                                    $37,338
                                   $104,609
                                   $141,947
                                     Total
                                       
                                       
                                  $1,774,341
       
Based on these costs, we estimate that the electronic TWIC inspection requirements will cost facilities approximately $2.0 million in the first two years in operational costs, with recurring costs of approximately $1.3 million combining results shown in Table 4.12 through 4.15.  Table 4.16 shows the 10-year undiscounted operational costs for this rulemaking.


Table 4.16 Operational Costs for Facilities
                                       
                                       
                                       
                                       
                                   Training
                                       
                                       
                                  Amendments
                                 Recordkeeping
                              Canceled Card List
                                   Personnel
                                      FSO
                                     Total
                                       1
                                   $467,614 
                                   $748,182 
                                   $486,319 
                                   $209,219 
                                   $74,676 
                                  $1,986,009 
                                       2
                                   $465,836 
                                   $857,138 
                                   $484,469 
                                   $261,523 
                                   $93,345 
                                  $2,162,312 
                                       3
                                      $0 
                                   $224,028 
                                   $970,788 
                                   $104,609 
                                   $37,338 
                                  $1,336,763 
                                       4
                                      $0 
                                   $224,028 
                                   $970,788 
                                   $104,609 
                                   $37,338 
                                  $1,336,763 
                                       5
                                      $0 
                                   $224,028 
                                   $970,788 
                                   $104,609 
                                   $37,338 
                                  $1,336,763 
                                       6
                                      $0 
                                   $224,028 
                                   $970,788 
                                   $104,609 
                                   $37,338 
                                  $1,336,763 
                                       7
                                      $0 
                                   $224,028 
                                   $970,788 
                                   $104,609 
                                   $37,338 
                                  $1,336,763 
                                       8
                                      $0 
                                   $224,028 
                                   $970,788 
                                   $104,609 
                                   $37,338 
                                  $1,336,763 
                                       9
                                      $0 
                                   $224,028 
                                   $970,788 
                                   $104,609 
                                   $37,338 
                                  $1,336,763 
                                      10
                                      $0 
                                   $224,028 
                                   $970,788 
                                   $104,609 
                                   $37,338 
                                  $1,336,763 
                                     Total
                                   $933,450 
                                  $3,397,544 
                                  $8,737,092 
                                  $1,307,616 
                                   $466,725 
                                 $14,842,427 
4.1.4 Total Facility Costs
When we combine the capital and operational costs, we get the total estimated costs for facilities.  The 10-year total cost to facilities will be approximately $124.1 million at a 7 percent discount rate and $137.8 million at a 3 percent discount rate.  The annualized cost will be $17.7 million and $15.1 million discounted at 7 percent and 3 percent, respectively.  The total cost figures can be seen in table 4.17 below.

Table 4.17 Total Facility Costs ($ Millions)
                                       
                                 Capital Costs
                               Maintenance Costs
                               Operational Costs
                              Undiscounted Total
                                      7%
                                      3%
                                       1
                                    $49.5 
                                     $0.0 
                                     $2.0 
                                    $51.5 
                                    $48.1 
                                    $50.0 
                                       2
                                    $49.5 
                                     $1.0 
                                     $2.2 
                                    $52.6 
                                    $46.0 
                                    $49.6 
                                       3
                                     $0.0 
                                     $2.0 
                                     $1.3 
                                     $3.3 
                                     $2.7 
                                     $3.0 
                                       4
                                     $0.0 
                                     $2.0 
                                     $1.3 
                                     $3.3 
                                     $2.5 
                                     $2.9 
                                       5
                                     $0.0 
                                     $2.0 
                                     $1.3 
                                     $3.3 
                                     $2.4 
                                     $2.9 
                                       6
                                     $9.9 
                                     $2.0 
                                     $1.3 
                                    $13.2 
                                     $8.8 
                                    $11.0 
                                       7
                                     $9.9 
                                     $2.0 
                                     $1.3 
                                    $13.2 
                                     $8.2 
                                    $10.7 
                                       8
                                     $0.0 
                                     $2.0 
                                     $1.3 
                                     $3.3 
                                     $1.9 
                                     $2.6 
                                       9
                                     $0.0 
                                     $2.0 
                                     $1.3 
                                     $3.3 
                                     $1.8 
                                     $2.5 
                                      10
                                     $0.0 
                                     $2.0 
                                     $1.3 
                                     $3.3 
                                     $1.7 
                                     $2.5 
                                     Total
                                    $118.7 
                                    $16.8 
                                    $14.8 
                                    $150.3 
                                    $124.1 
                                    $137.8 
Annualized
 
 
 
                                       
                                    $17.7 
                                    $16.2 

4.2 Vessel Costs
4.2.1 Reader Costs for Vessels
The proposal will require certain vessels in Risk Group A to implement electronic TWIC inspections to control access to all restricted areas.  As discussed in the Affected Population chapter of this RA, this final rule affects vessels in Risk Group A with greater than 20 TWIC-holding crewmembers, which brings the total current number of affected vessels to 1.  The TWIC pilot did not include vessels, so we relied on expert elicitations to estimate vessel costs.  As discussed in the facility costs section above, we received several public comments on our cost assumptions.  However, none of them provided any specific information and data.  Therefore, our assumptions in estimating vessel costs remained unchanged.  

Coast Guard subject matter experts from the Domestic Ports Division estimate that this vessel will require 2 portable readers, for a total reader cost of approximately $14,070.  This is based on the same average cost for reader hardware and software used to estimate the reader costs for facilities.  We also assume that first-year costs will be repeated in Year 6 due to replacement of equipment, as we saw with facilities.  Because the affected population is small, we assume that the vessel will comply within the first year of implementation.  See Table 4.18 below for reader costs for vessels.
                                       
                                       
Table 4.18 Vessel Reader Costs, First Year
                                       
                                     Price
                                 Vessel Count
                              Readers Per Vessel
                                     Cost
                                Portable Reader
                                    $7,035 
                                       1
                                       2
                                   $14,070 

Based on estimates from the Coast Guard Office of Port and Facility Activities, we assume a technician or labor equivalent will need to install the software and set up the readers for each vessel.  The Coast Guard assumes it will take one technician, earning an hourly rate of $58.81 per hour, 4 hours to set up a handheld system.  See Table 4.19 for installation costs.

Table 4.19 Costs to Install Readers and Software
                                     Year
                                    Vessels
                                     Hours
                                   Unit Cost
                                     Cost
                                       1
                                       1
                                       4
                                    $58.81
                                     $235 
                                       2
                                       0
                                       4
                                    $58.81
                                      $0 
                                       3
                                       0
                                       4
                                    $58.81
                                      $0 
                                       4
                                       0
                                       4
                                    $58.81
                                      $0 
                                       5
                                       0
                                       4
                                    $58.81
                                      $0 
                                       6
                                       1
                                       4
                                    $58.81
                                     $235 
                                       7
                                       0
                                       4
                                    $58.81
                                      $0 
                                       8
                                       0
                                       4
                                    $58.81
                                      $0 
                                       9
                                       0
                                       4
                                    $58.81
                                      $0 
                                      10
                                       0
                                       4
                                    $58.81
                                      $0 
                                     Total
                                       
                                     $470 

4.2.2 Maintenance Costs
We estimate an annual maintenance cost equivalent to 10% of the cost of the TWIC readers (hardware and software combined) in addition to a cost for replacing readers every five years.  Because TWIC readers will be used in the harsh maritime environment, we assume that there will be an annual maintenance component to the cost of electronic TWIC inspections.  Because we assume that vessels will deploy portable readers, we assign the maintenance costs based only for that type of reader.  Table 4.20 shows this calculation.  We estimate an annual cost of $1,407 for vessel reader maintenance.



Table 4.20 Maintenance Costs for Vessel TWIC Readers
                               Number of Vessels
                                       1
                              Readers Per Vessel
                                       2
                                Cost Per Reader
                                    $7,035
                   Maintenance Cost (Percent of Reader Cost)
                                      10%
                            Total Maintenance Cost
                                    $1,407

4.2.3 Operational Costs for Vessels
The final rule will require owners and operators of the one affected vessel to create and submit amendments to their security plans that detail how they will comply with the final regulations.  This vessel represents all self-propelled vessels in Risk Group A, as defined in Chapter 2 of this RA, that have a total crew size greater than 20 TWIC-holding crewmembers.  The Coast Guard estimates that it will take 25 hours to create an addendum for each Vessel Security Plan (VSP), and that the average loaded wage of someone performing this work will equal $53.54 per hour, which is the estimated wage for a Vessel Security Officer (VSO).  See Table 4.21 for the cost for amendments.  

Table 4.21 Costs for TWIC Amendments
                                     Year
                                    Vessels
                                     Hours
                                   Unit Cost
                                   Total = 
                                       
                                       A
                                       B
                                       C
                                   A x B x C
                                       1
                                       1
                                      25
                                    $53.54
                                    $1,339
                                       2
                                       0
                                      25
                                    $53.54
                                      $0
                                       3
                                       0
                                      25
                                    $53.54
                                      $0
                                       4
                                       0
                                      25
                                    $53.54
                                      $0
                                       5
                                       0
                                      25
                                    $53.54
                                      $0
                                       6
                                       0
                                      25
                                    $53.54
                                      $0
                                       7
                                       0
                                      25
                                    $53.54
                                      $0
                                       8
                                       0
                                      25
                                    $53.54
                                      $0
                                       9
                                       0
                                      25
                                    $53.54
                                      $0
                                      10
                                       0
                                      25
                                    $53.54
                                      $0
                                     Total
                                       
                                       
                                       
                                    $1,339

The final rule will require owners and operators of vessels that are implementing an electronic TWIC inspection program to maintain detailed records of access to the vessel.  Based on information from the 2006 ANPRM analysis, at least some owners and operators of regulated vessels currently practice similar recordkeeping as part of normal business practice, as individuals are sometimes required to log in and log out.  Furthermore, some of the card readers that are compatible with TWIC have the ability to record access information by reader area, worker ID, date, and time.  However, based on the findings of the 2006 ANPRM analysis, we assume that owners and operators of all vessels will need to only set up a system for keeping track of who is on and off the vessel and at what time.  

Based on Coast Guard subject matter experts from the Domestic Vessel Division, we assumed that it will take approximately 40 hours in the first year for a mid-level employee to complete this task.  For this RA, we assume that a VSO will likely perform all vessel-specific security tasks.  We increased the loaded hourly wage to $53.54 to reflect VSO-level wages.  We also estimate that there will be a burden of approximately 30 minutes per month to conduct maintenance of the recordkeeping system.  This will add an additional 6 hours of burden per facility per year.  See Table 4.22 for revised record keeping costs.


Table 4.22 Costs to Create Recordkeeping Systems
                                     Year
                                    Vessels
                                     Hours
                                   Unit Cost
                                   Total = 
                                       
                                       A
                                       B
                                       C
                                   A x B x C
                                       1
                                       1
                                      40
                                    $53.54
                                    $2,142
                                       2
                                       1
                                       6
                                    $53.54
                                     $321
                                       3
                                       1
                                       6
                                    $53.54
                                     $321
                                       4
                                       1
                                       6
                                    $53.54
                                     $321
                                       5
                                       1
                                       6
                                    $53.54
                                     $321
                                       6
                                       1
                                       6
                                    $53.54
                                     $321
                                       7
                                       1
                                       6
                                    $53.54
                                     $321
                                       8
                                       1
                                       6
                                    $53.54
                                     $321
                                       9
                                       1
                                       6
                                    $53.54
                                     $321
                                      10
                                       1
                                       6
                                    $53.54
                                     $321
                                     Total
                                       
                                       
                                       
                                    $5,031

We estimate the CCL download to take approximately 30 minutes based on information from the TSA HAZMAT Threat Assessment Program.  We anticipate that this will constitute, on average, 30 minutes per week per vessel for 26 annual hours of labor.  We base this cost on the loaded wage rates for VSOs.  See Table 4.23, Costs to Download CCLs.

Table 4.23 Costs to Download CCLs (Non-discounted)
                                     Year
                                    Vessels
                                     Hours
                                   Unit Cost
                                   Total = 
                                       
                                       A
                                       B
                                       C
                                   A x B x C
                                       1
                                       1
                                      26
                                    $53.54
                                    $1,392 
                                       2
                                       1
                                      26
                                    $53.54
                                    $1,392 
                                       3
                                       1
                                      26
                                    $53.54
                                    $1,392 
                                       4
                                       1
                                      26
                                    $53.54
                                    $1,392 
                                       5
                                       1
                                      26
                                    $53.54
                                    $1,392 
                                       6
                                       1
                                      26
                                    $53.54
                                    $1,392 
                                       7
                                       1
                                      26
                                    $53.54
                                    $1,392 
                                       8
                                       1
                                      26
                                    $53.54
                                    $1,392 
                                       9
                                       1
                                      26
                                    $53.54
                                    $1,392 
                                      10
                                       1
                                      26
                                    $53.54
                                    $1,392 
                                     Total
                                       
                                  $13,920  

In order to properly implement the electronic TWIC inspection requirements, we also assume that vessel personnel will need to be trained how to use the readers properly.  Using Coast Guard published rule on Implementation of Veseel Security Officer Training and Certification Requirements: International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978 as amended (73 FR 98 29060-29017), we determined the average number of VSOs and personnel with security duties by vessel type.  We then multiplied the personnel numbers by the vessel count by type in Risk Group A: 2 VSOs and 14.2 personnel with security duties.  We assume that electronic TWIC inspection training will take an estimated 4 hours to complete.  The cost of this training is the opportunity cost of time spent in training, which is equal to the wage of the employee multipled by the number of hours spent training.  The loaded wage for a VSO is the same as used above ($53.54), and the loaded wage for personnel with security duties is $28.15.  Table 4.24 shows the total cost of training vessel personnel.

      Hours of training x loaded wage for Personnel with Security Duties x Number of Personnel with Security Duties = Cost of Training 
      
      4 x $28.15 x 14.2 = $1,600
      
      Hours of training x loaded wage for VSO x Number of VSOs = Cost of Training 
      4 x $53.54 x 2 = $428

We also include an estimated 1 hour of training each subsequent year for both VSOs and personnel with security duties to account for additional electronic TWIC inspection-related training that will be included in the existing annual required facility-specific MTSA training.
      
Table 4.24 Cost of Training for Vessel Personnel
                                     Year
                        Personnel with Security Duties
                                      VSO
                              Total Training Cost
                                       1
                                    $1,600 
                                     $428 
                                    $2,028 
                                       2
                                     $400 
                                     $107 
                                     $507 
                                       3
                                     $400 
                                     $107 
                                     $507 
                                       4
                                     $400 
                                     $107 
                                     $507 
                                       5
                                     $400 
                                     $107 
                                     $507 
                                       6
                                     $400 
                                     $107 
                                     $507 
                                       7
                                     $400 
                                     $107 
                                     $507 
                                       8
                                     $400 
                                     $107 
                                     $507 
                                       9
                                     $400 
                                     $107 
                                     $507 
                                      10
                                     $400 
                                     $107 
                                     $507 
                                     Total
                                    $5,200 
                                    $1,392 
                                    $6,592 

Based on these costs, we estimate that the electronic TWIC inspection requirements will cost vessels approximately $6,900 in the first year in operational costs, with recurring costs of approximately $2,200.  Table 4.25 shows the 10-year undiscounted operational costs for this rulemaking.

Table 4.25 Vessel Operational Costs
                                       
                                       
                                       
                                       
                                   Training
                                       
                                     Year
                                  Amendments
                                 Recordkeeping
                              Canceled Card List
                                   Personnel
                                      VSO
                                     Total
                                       1
                                    $1,339 
                                    $2,142 
                                    $1,392 
                                    $1,600 
                                     $428 
                                    $6,901 
                                       2
                                      $0 
                                     $321 
                                    $1,392 
                                     $400 
                                     $107 
                                    $2,220 
                                       3
                                      $0 
                                     $321 
                                    $1,392 
                                     $400 
                                     $107 
                                    $2,220 
                                       4
                                      $0 
                                     $321 
                                    $1,392 
                                     $400 
                                     $107 
                                    $2,220 
                                       5
                                      $0 
                                     $321 
                                    $1,392 
                                     $400 
                                     $107 
                                    $2,220 
                                       6
                                      $0 
                                     $321 
                                    $1,392 
                                     $400 
                                     $107 
                                    $2,220 
                                       7
                                      $0 
                                     $321 
                                    $1,392 
                                     $400 
                                     $107 
                                    $2,220 
                                       8
                                      $0 
                                     $321 
                                    $1,392 
                                     $400 
                                     $107 
                                    $2,220 
                                       9
                                      $0 
                                     $321 
                                    $1,392 
                                     $400 
                                     $107 
                                    $2,220 
                                      10
                                      $0 
                                     $321 
                                    $1,392 
                                     $400 
                                     $107 
                                    $2,220 
                                     Total
                                    $1,339 
                                    $5,031 
                                  $13,920  
                                    $5,200 
                                    $1,392 
                                   $26,881 

Based on the above costs, we estimate that the electronic TWIC inspection requirements will cost an estimated $21,000 in the first year and approximately $3,600 annually thereafter, except Year 6, which will experience higher costs due to equipment replacement.  We estimate a 10-year cost of $7,300 at a 7-percent discount rate and $7,000 at 3 percent.  Table 4.26 presents the total non-discounted and discounted costs to vessels.



Table 4.26 Total Costs to Vessels
                                     Year
                                 Capital Costs
                               Maintenance Costs
                               Operational Costs
                                 Undiscounted
                                      7%
                                      3%
                                       1
                                    $14,070
                                      $0
                                    $6,901
                                    $20,971
                                    $19,599
                                    $20,360
                                       2
                                      $0 
                                    $1,407
                                    $2,220
                                    $3,627
                                    $3,168
                                    $3,419
                                       3
                                      $0 
                                    $1,407
                                    $2,220
                                    $3,627
                                    $2,961
                                    $3,319
                                       4
                                      $0 
                                    $1,407
                                    $2,220
                                    $3,627
                                    $2,767
                                    $3,222
                                       5
                                      $0 
                                    $1,407
                                    $2,220
                                    $3,627
                                    $2,586
                                    $3,129
                                       6
                                   $14,070 
                                    $1,407
                                    $2,220
                                    $17,697
                                    $11,792
                                    $14,821
                                       7
                                      $0 
                                    $1,407
                                    $2,220
                                    $3,627
                                    $2,259
                                    $2,949
                                       8
                                      $0 
                                    $1,407
                                    $2,220
                                    $3,627
                                    $2,111
                                    $2,863
                                       9
                                      $0 
                                    $1,407
                                    $2,220
                                    $3,627
                                    $1,973
                                    $2,780
                                      10
                                      $0 
                                    $1,407
                                    $2,220
                                    $3,627
                                    $1,844
                                    $2,699
                                     Total
                                   $28,140 
                                    $12,663
                                    $26,879
                                    $67,682
                                    $51,058
                                    $59,560
                                  Annualized
                                       
                                       
                                       
                                       
                                    $7,270
                                    $6,982

4.3 Additional Delay, Travel and TWIC Replacement Costs due to TWIC Failures
Part 101 requires persons requiring unescorted access to secure areas to have a valid TWIC before accessing such locations, and that such TWICs must be provided for machine reads and the accompanying biometric/PIN upon request.  As part of efforts to ensure that TWICs being used are valid and functional, the Coast Guard and TSA have deployed hundreds of readers to the field to conduct the enhanced inspections envisioned under this rule.  As such, the requirement for a valid, machine-readable TWIC has been in place and has been the subject of an increased inspection rate, which this final rule will further increase.  

The increased likelihood of detecting invalid/broken TWICs will result in additional delay, and potentially travel and TWIC replacement costs.  We estimate there will be additional costs since the use of TWIC readers will increase the likelihood of faulty TWICs (TWICs that are not machine readable) being identified and the need for secondary screening procedures so affected workers and operators can address these issues.  

If a worker's TWIC cannot be read by a TWIC reader, then there may be delay costs while the worker and the facility or vessel operator implement secondary screening procedures.  If a worker's card is faulty and cannot be read, the worker will need to travel to a TWIC enrollment center to get a replacement TWIC, which results in additional travel and replacement costs.  This section also evaluates costs associated with card failures and the use of secondary processing options, such as PINs and escorts.
4.3.1 Delay Costs Due to an Invalid Electronic TWIC Inspection
To account for potential opportunity costs associated with the delays as a result of the electronic TWIC inspection requirements, we estimate a cost of delay associated with failed reads.  A description of the different types of TWIC reader failures can be found in Table 4.34.  We provide a range of delay costs based on different delays in seconds and also based on the number of times a TWIC-holder may have their card read on a weekly basis.  The TWIC pilot estimates the number of TWIC-holders who might access participating facilities by participant group.  As discussed in Chapter 2 of this RA, we used these estimates to extrapolate across the affected population to obtain a national estimate of TWIC-holders by facility type.  Table 4.27 shows the TWIC-holder populations as estimated in the TWIC pilot.

Table 4.27 TWIC-Holder Population, from TWIC Pilot
                                 Facility Type
                                     Truck
                                    Vehicle
                                  Pedestrian 
                                     Total
                               Percent of Total 
                              Container Terminals
                                    19,200 
                                     100 
                                    4,700 
                                    24,000 
                                     72.4%
                       Large Passenger Vessels/Terminals
                                      20 
                                     200 
                                    1,700 
                                    1,920 
                                     5.8%
                             Break Bulk Terminals
                                     700 
                                     210 
                                     700 
                                    1,610 
                                     4.9%
                             Petroleum Facilities
                                     225 
                                     110 
                                    4,765 
                                    5,100 
                                     15.4%
                     Small Passenger/Vessel/Towboats/Other
                                     -   
                                     100 
                                     400 
                                     500 
                                     1.5%
                                     Total
                                    20,145 
                                     720 
                                    12,265 
                                    33,130 
                                    100.0%

As shown above, container terminals account for 72.4% of the total TWIC-holder population in the TWIC pilot, and 95% of the truck population.  As most container facilities are not required to implement an electronic TWIC inspection program, the vast majority of potential congestion delays are avoided in the preferred alternative.

To assess the delays due to failed card reads, we extended the TWIC pilot cardholder data to the full affected population.  First, we determined the total number of TWIC-holders by facility type by applying the percentages from the TWIC pilot to the estimated TWIC-holder population of 2,200,000.  Table 4.28 shows the breakdown of total TWIC-holder population by facility type.



Table 4.28 TWIC-Holder Population by Facility Type
                                 Facility Type
                               Percent of Total
                               Total Population
                              Container Terminals
                                     72.4%
                                   1,592,800
                       Large Passenger Vessels/Terminals
                                     5.8%
                                    127,600
                             Break Bulk Terminals
                                     4.9%
                                    107,800
                             Petroleum Facilities
                                     15.4%
                                    338,800
                     Small Passenger/Vessel/Towboats/Other
                                     1.5%
                                    33,000
                                     Total
                                    100.0%
                                   2,200,000

We then divide the total number of TWIC-holders for each facility type by the total number of facilities to obtain the number of TWIC-holders per facility, as shown in Table 4.29.  Using the number of TWIC-holders per facility, by facility type, we are able to then extrapolate the number of TWIC-holders for each risk group, by facility type, as shown in Table 4.30.

Table 4.29 TWIC-Holders per Facility, by Facility Type
                                 Facility Type
                              Total TWIC-Holders
                               Total Facilities
                           TWIC-Holders per Facility
                              Container Terminals
                                   1,592,800
                                     122 
                                    13,056
                       Large Passenger Vessels/Terminals
                                    127,600
                                     555 
                                      230
                             Break Bulk Terminals
                                    107,800
                                     510 
                                      211
                      Petroleum Facilities (Bulk Liquid)
                                    338,800
                                    1,097 
                                      309
                     Small Passenger/Vessel/Towboats/Other
                                    33,000
                                     333 
                                      99
                                     Total
                                   2,200,000
                                    2,617 
                                    13,905

Table 4.30 TWIC-Holder Population, by Facility Type and Risk Group
                                Facility Type 
                                       A
                                       B
                                       C
                                     Total
                              Container Terminals
                                    39,168
                                    261,121
                                   1,292,511
                                   1,592,800
                       Large Passenger Vessels/Terminals
                                    21,160
                                    69,230
                                    37,210
                                    127,600
                             Break Bulk Terminals
                                     3,376
                                    101,301
                                     3,123
                                    107,800
                      Petroleum Facilities (Bulk Liquid)
                                    89,610
                                    248,572
                                      618
                                    338,800
                     Small Passenger/Vessel/Towboats/Other
                                    12,276
                                     4,617
                                    16,107
                                    33,000
                                     Total
                                    165,590
                                    684,841
                                   1,349,569
                                   2,200,000

The next step in calculating the delay was to determine the number of electronic TWIC inspection interfaces per year.  As we do not have data on the number of TWIC reads per year, we performed a sensitivity analysis where we considered the impacts of each TWIC-holder encountering a TWIC reader one to five times a week.  We then multiplied this number by 50 weeks per year to get an annual estimate of electronic TWIC inspection interfaces for each risk group.  Table 4.31 shows the number of electronic TWIC inspection interfaces for the risk groups.

Table 4.31 Annual Number of Electronic TWIC Inspections
                                  Risk Group
                                1 Read per Week
                               2 Reads per Week
                               3 Reads per Week
                               4 Reads per Week
                               5 Reads per Week
                                       A
                                   8,279,500
                                  16,559,000
                                  24,838,500
                                  33,118,000
                                  41,397,500
                                       B
                                  34,242,050
                                  68,484,100
                                  102,726,150
                                  136,968,200
                                  171,210,250
                                       C
                                  67,478,450
                                  134,956,900
                                  202,435,350
                                  269,913,800
                                  337,392,250
                                       
The reader success rates from the TWIC Pilot Systems Test & Evaluation (ST&E) reports show that across all pilot participants, there was an approximately 82.9% validation rate for electronic TWIC inspections.  The invalid transactions include the full range of possibilities for an invalid transaction, such as any type of biometric failure, user error, and invalid, expired or canceled card, and card issuer certificates.  The number of annual electronic TWIC inspections was then multiplied by a failure rate of 17.1%, which was the combined rate for invalid electronic TWIC inspections, as reported in the TWIC Pilot Final ST&E reports.  Table 4.32 shows the results of this calculation.  Because this invalid transaction rate includes all types of invalid transactions, there exists a range of options regarding secondary processing to grant the TWIC-holder access, such as use of visual TWIC inspection mode, or use of escorted access.

Table 4.32 Annual Invalid TWIC Transactions
                                  Risk Group
                                1 Read per Week
                               2 Reads per Week
                               3 Reads per Week
                               4 Reads per Week
                               5 Reads per Week
                                       A
                                   1,415,795
                                   2,831,589
                                   4,247,384
                                   5,663,178
                                   7,078,973
                                       B
                                   5,855,391
                                  11,710,781
                                  17,566,172
                                  23,421,562
                                  29,276,953
                                       C
                                  11,538,815
                                  23,077,630
                                  34,616,445
                                  46,155,260
                                  57,694,075

The number of invalid transactions was then used to calculate a cost of delay associated with failed TWIC authentication.  For this step, we provide a range of costs based on three different delay times.  The TWIC Pilot Study contains estimates of the duration for TWIC activities: 6 seconds duration to conduct a visual TWIC inspection and 8 seconds for electronic TWIC inspection.  We calculate a delay cost for a failed TWIC reader transaction followed by an immediate visual inspection to be 6 seconds.  We also calculate the delay cost for a second attempt at an automated TWIC authentication followed by a visual authentication of 14 seconds and a 30-second delay to account for additional actions to be taken as necessary.   We also include 60-second and 120-second delays in our calculation to account for situations in which a longer delay may arise.  Once the delay times were calculated, we multiply the delay time by $39.98, which is the mean wage for an employee in the labor category Deep Sea, Coastal and Great lakes Water Transportation.  Table 4.33 shows the results of these calculations for Risk Group A facilities.  By using a range of delay costs, we are able to account for multiple scenarios where an invalid electronic TWIC inspection will lead to the use of a secondary processing operation, such as a visual TWIC inspection, additional identification validation, or other provisions as set forth in the FSP. 

In response to our request in the NPRM RA on the accuracy of delay and cost estimates used in that analysis, we received numerous comments from the public and addressed them in the Responses to Economic Comments section where we specifically discussed them under the Transaction Times subsection.  One commenter suggested 3.5-second average transaction time using TWIC reader for card validation and fingerprint verification based on their own facility operations.  Another commenter estimated 20-30 seconds for each TWIC reader transaction without any further explanation or justification.  We had used in the NPRM and Final Rule RAs' 8-second estimation for each TWIC reader transaction.  Many others did not provide any specific information regarding their transaction times they have been experiencing and simply made overall statements regarding the performance of TWIC validation and associated biometric functions as time consuming.  We believe our assumption of 8-second per transaction estimate is reasonable based on pilot data collected over two years in various participant facilities.  After careful review and consideration of these comments, we kept our NPRM RA cost assumptions and therefore our related estimates unchanged. 


Table 4.33 Cost of Delays Due to Invalid Transaction Per Year, 
for Risk Group A Facilities
 
                                1 Read per Week
                               2 Reads per Week
                                   3 Reads 
                                   per Week
                               4 Reads per Week
                               5 Reads per Week
                                    Average
                                   6 Seconds
                                                                       $94,339 
                                                                      $188,678 
                                                                      $283,017 
                                                                      $377,356 
                                                                      $471,696 
                                                                      $283,017 
                                   14 Second
                                                                      $220,125 
                                                                      $440,249 
                                                                      $660,374 
                                                                      $880,498 
                                                                    $1,100,623 
                                                                      $660,374 
                                  30 Seconds
                                                                      $471,696 
                                                                      $943,391 
                                                                    $1,415,087 
                                                                    $1,886,782 
                                                                    $2,358,478 
                                                                    $1,415,087 
                                  60 Seconds
                                                                      $943,391 
                                                                    $1,886,782 
                                                                    $2,830,173 
                                                                    $3,773,564 
                                                                    $4,716,955 
                                                                    $2,830,173 
                                  120 Seconds
                                                                    $1,886,782 
                                                                    $3,773,564 
                                                                    $5,660,346 
                                                                    $7,547,129 
                                                                    $9,433,911 
                                                                    $5,660,346 
                                    Average
                                                                      $723,266 
                                                                    $1,446,533 
                                                                    $2,169,799 
                                                                    $2,893,066 
                                                                    $3,616,332 
                                                                    $2,169,799 

For the purposes of this analysis, we used the cost of delay estimate of $2,169,799, which represents the average delay across all iterations of delay times and reader interface.
4.3.2 Costs to Replace Faulty TWICs 
As reader use is not currently universal, we anticipate that some of the cards that were issued properly will still not be readable in TWIC readers.  To account for this, we estimate a cost for a percentage of TWIC-holders to obtain replacement cards.  Based on the ST&E reports provided by the individual pilot participants, we estimate a 17.1% rate for invalid electronic TWIC inspections.  Invalid electronic TWIC inspections can be categorized as shown in Table 4.34. 


Table 4.34 Invalid TWIC Reader Transactions
Failure Mode
Description
1. Card on Canceled Card List (CCL)
Card listed on TSA's CCL. This is not technically a failure, as the card cannot be legally used.
2. Card Invalid
Card not a legitimate TWIC. This is not technically a failure, as the card cannot be legally used.
3. Biometric Failure
Card not able to be matched to biometrics.
4. Card Failure
Card unable to be read in contactless mode.
5. Otherwise Unreadable Card
Card otherwise not able to be read.
6. User Error
TWIC-holder misuses reader.
7. Reader Failure
TWIC reader not able to process TWICs.

As noted, the first two "failures" are actually successes; in these two conditions, the card should be rejected, so the TWIC readers are performing as expected.  However these successful transactions, along with the next five failures, are captured in the 17% failure rate identified in the TWIC pilot.  Since the TWIC pilot did not decompose these failures further in the data provided, we assume a uniform distribution of these failures across the 7 failure modes (2.43% for each).  Of the seven types of invalid electronic TWIC inspections, we focus on the two that will identify previously undetected unreadable TWICs.  These two card failure modes are identified in Table 4.34 above as "4. Card Failure" and "5. Otherwise Unreadable Card."  We estimate these two failure modes account for approximately 5% of invalid transactions.  We use this rate to estimate the number of TWIC cards that will need replacing due to the new requirements.  Table 4.35 shows the total TWIC-holder population, based on data from the TWIC Pilot Report. 

Table 4.35 TWIC-Holder Population, by Facility Type
                                       
                                       A
                                       B
                                       C
                                     Total
                              Container Terminals
                                    39,168
                                    261,121
                                   1,292,511
                                   1,592,800
                       Large Passenger Vessels/Terminals
                                    21,160
                                    69,230
                                    37,210
                                    127,600
                             Break Bulk Terminals
                                     3,376
                                    101,301
                                     3,123
                                    107,800
                      Petroleum Facilities (Bulk Liquid)
                                    89,610
                                    248,572
                                      618
                                    338,800
                     Small Passenger/Vessel/Towboats/Other
                                    12,276
                                     4,617
                                    16,107
                                    33,000
                                     Total
                                    165,590
                                    684,841
                                   1,349,569
                                   2,200,000

We estimate 165,590 TWIC-holders work at, or access, Risk Group A facilities.  Using the 5% rate for invalid electronic TWIC inspections as calculated based on the TWIC pilot data, we estimate that 8,280 TWIC-holders attempting to access Risk Group A facilities will not successfully pass electronic TWIC inspection.  According to the TSA, approximately 26,000 previously issued TWICs were improperly encoded and may not work with TWIC readers, which will be replaced for free by TSA.  To factor in these no-cost replacements, we distributed the 26,000 known faulty cards across the risk groups by the percent of total TWIC-holders per risk group, resulting in an approximate 2,000 TWIC-holders in Risk Group A that will receive a free replacement TWIC.  

We assume that mariners will drive 100 miles (round-trip) to travel to a TWIC enrollment center.  This round-trip commute will take about 3.125 hours at an average 32 mph commuting speed.  An average enrollment and wait time of 30 minutes at TWIC enrollment centers is added to the commuting time for a total sum of commuting, enrollment, and wait time of 3.625 hours.  The Coast Guard used an average loaded wage rate of $39.98 to value the opportunity cost of the mariners' time.  In addition to these opportunity cost estimates, the Coast Guard added $56 to the total estimate in order to account for commuting motor vehicle costs at $.56 per mile, and used $204.93 for each trip to TWIC enrollment center. 

(3.625 hours x $39.98/hour) + (100 miles x $0.56/mile) = $144.93 + $56 = $200.93
                                       
In addition to the costs associated with traveling to an enrollment center, we also include the cost to replace a TWIC at the time of reporting it lost, stolen or damaged, which is $60.  If 6,280 (8,280 TWIC holders minus 2,000 receiving free replacements) TWIC-holders will need to obtain a replacement, we estimate that this will cost mariners approximately $2.04 million per year. 

               ($200.93 * 8,280) + ($60 * 6,280) = $2,040,500.4
                                       
We assess this as an annual cost, though we anticipate that the percent of invalid TWIC transactions will decrease as TWIC-holders become more familiar with the requirements and using TWIC readers.  At this time, we do not have sufficient data to estimate the rate at which future invalid electronic TWIC inspections will occur.  However, since all initial TWIC cards have been already re-issued to all TWIC-holders, the initially faulty TWICs should have already been replaced.  This will further help decrease the percent of invalid TWIC transactions.  
4.3.3 Increased Use of Personal Identification Number (PIN)
This final rule accounts for TWIC inspection requirements in special circumstances.  One of these contingencies is the use of a PIN.  When an individual has poor quality fingerprints, a TWIC reader may not be able to consistently perform the biometric identity verification function.  Also, a small number of TWIC cards will be issued that contain either poor quality fingerprint templates, mostly due to badly damaged fingers, or no fingerprint minutiae in the case of amputations.  Owners and operators will describe the exception handling process to be used in such cases in their security plans.  The exception handling process may include granting unescorted access after the individual has successfully provided a PIN.  In Section 4.3.2 of this RA, we discuss the costs associated with TWIC-holders replacing their TWICs due to invalid electronic TWIC inspections.  In that section, we discuss a subset of failures for biometric failure.  We expect that a subset of this group will need to travel to a TWIC enrollment center to retrieve their PIN (as the cardholder may have forgotten their PIN) so that it may be used as an alternative means of access in cases where the TWIC-holder's biometrics cannot be read by a reader.  At this time, we have no information regarding the number of TWIC-holders that may need to use a PIN in lieu of biometrics, nor do we have information regarding the use of PIN as an alternate means of identification, or an estimate of the percentage of card holders that may have forgotten their PIN.  No data were provided in response to the NPRM to enable this estimate.
4.3.4 Use of Escorts
Another option for access when a valid electronic TWIC inspection does not occur is the use of an escort. For the costs associated with this contingency, we have some preliminary data for another project (Seafarer's Access, required by the Coast Guard Authorization Act of 2010) indicating that 90% of facilities have provisions for escorts through secure areas and that at least some do so with existing, non-dedicated personnel on an ad hoc basis.  As discussed in Section 4.5 of this RA, there are other means of gaining access in instances of an invalid electronic TWIC inspection.  Therefore, we do not foresee the use of escorts increasing substantially due to this rulemaking.  Additionally, no data were provided in response to the NPRM to cause us to modify this assessment.   
4.3.5 Summary of Additional Costs
Based on these costs, we estimate that the electronic TWIC inspection requirements will cost an additional $4.2 million each year due to delays and TWIC replacements.  Table 4.36 shows the 10-year undiscounted additional costs for this rulemaking.

Table 4.36 Additional Costs
                                     Year
                             Delay Due to Failure
                        Replacement of Unreadable TWIC
                              Total Undiscounted
                                       1
                                   $2,169,799 
                                   $2,040,500 
                                   $4,210,300 
                                       2
                                   $2,169,799 
                                   $2,040,500 
                                   $4,210,300 
                                       3
                                   $2,169,799 
                                   $2,040,500 
                                   $4,210,300 
                                       4
                                   $2,169,799 
                                   $2,040,500 
                                   $4,210,300 
                                       5
                                   $2,169,799 
                                   $2,040,500 
                                   $4,210,300 
                                       6
                                   $2,169,799 
                                   $2,040,500 
                                   $4,210,300 
                                       7
                                   $2,169,799 
                                   $2,040,500 
                                   $4,210,300 
                                       8
                                   $2,169,799 
                                   $2,040,500 
                                   $4,210,300 
                                       9
                                   $2,169,799 
                                   $2,040,500 
                                   $4,210,300 
                                      10
                                   $2,169,799 
                                   $2,040,500 
                                   $4,210,300 
                                     Total
                                   $21,697,995 
                                   $20,405,004 
                                   $42,102,999 

4.4 Total Industry Costs
Because the costs for this rulemaking will vary greatly depending on the type and size of facility, we present the estimated 10-year total costs to industry by facility group in Table 4.37.  This includes all capital, maintenance, operational, and additional costs related to delays and TWIC replacement for facilities, as shown in Tables 4.10, 4.11, 4.16, and 4.36.

The reader should note that our total industry costs do not capture two cost elements: (1) cost savings due to the optional DRAA flexibility, and (2) potential costs due to the new COTP notification requirement if and when an access control system fails to operate.  By designating a limited RUA area,   facility and vessel operations are expected to become less repeated and redundant for certain workers who use that area frequently throughout their work hours.  For example, a TWIC card holder needs to enter a vessel only once during their work hours to meet the requirements of electronic TWIC inspection because the final rule allows the vessel owner and operator to define the entire vessel as a DRAA instead of different areas of the vessel to which the worker needs to enter and exit dozens of times during work hours.  However, these potential cost savings are not estimated directly as we don't know how many facility and vessel operator will choose to implement the DRAA.  Similarly, we don't have any past or current data to estimate the frequency and the resulting potential costs of requiring the owner or operator to notify the COTP of access control system failure that might suspend operations or permit the operations to continue.    
Table 4.37 Ten-year Total Costs, by Facility Type* ($ Millions)
                                     Year
                                  Bulk Liquid
                             Break Bulk and Solids
                                   Container
                                Large Passenger
                                Small Passenger
                                   Mixed Use
                                     Total
                                       1
                                    $31.3 
                                     $2.3 
                                     $0.8 
                                     $9.7 
                                     $7.3 
                                     $4.3 
                                    $55.7 
                                       2
                                    $31.9 
                                     $2.4 
                                     $0.8 
                                     $9.9 
                                     $7.4 
                                     $4.4 
                                    $56.8 
                                       3
                                     $4.2 
                                     $0.3 
                                     $0.1 
                                     $1.3 
                                     $1.0 
                                     $0.6 
                                     $7.5 
                                       4
                                     $4.2 
                                     $0.3 
                                     $0.1 
                                     $1.3 
                                     $1.0 
                                     $0.6 
                                     $7.5 
                                       5
                                     $4.2 
                                     $0.3 
                                     $0.1 
                                     $1.3 
                                     $1.0 
                                     $0.6 
                                     $7.5 
                                       6
                                     $9.8 
                                     $0.7 
                                     $0.2 
                                     $3.0 
                                     $2.3 
                                     $1.3 
                                    $17.4 
                                       7
                                     $9.8 
                                     $0.7 
                                     $0.2 
                                     $3.0 
                                     $2.3 
                                     $1.3 
                                    $17.4 
                                       8
                                     $4.2 
                                     $0.3 
                                     $0.1 
                                     $1.3 
                                     $1.0 
                                     $0.6 
                                     $7.5 
                                       9
                                     $4.2 
                                     $0.3 
                                     $0.1 
                                     $1.3 
                                     $1.0 
                                     $0.6 
                                     $7.5 
                                      10
                                     $4.2 
                                     $0.3 
                                     $0.1 
                                     $1.3 
                                     $1.0 
                                     $0.6 
                                     $7.5 
                              Total Undiscounted
                                    $108.1 
                                     $8.1 
                                     $2.6 
                                    $33.5 
                                    $25.2 
                                    $14.9 
                                    $192.4 
                            Total Discounted at 7%
                                    $86.3 
                                     $6.4 
                                     $2.1 
                                    $26.7 
                                    $20.1 
                                    $11.9 
                                    $153.6 
                            Total Discounted at 3%
                                    $97.6 
                                     $7.3 
                                     $2.4 
                                    $30.2 
                                    $22.8 
                                    $13.5 
                                    $173.7 
* This table includes the costs to facilities as well as additional costs such as delay, travel and TWIC replacement costs due to TWIC failures. Figures may not total due to rounding 

We estimate the present value average costs of this rulemaking on industry for a 10-year period as summarized in Table 4.38 (which combines the estimates from Tables 4.17, 4.26, and 4.37).  This includes all costs to facilities, vessels, and TWIC-holders.  The costs are discounted at 3 and 7 percent as set forth by guidance in OMB Circular A-4.  

Table 4.38 Total Industry Cost, Facilities and Vessels ($ Millions)
                                     Year
                                   Facility
                                    Vessel
                               Additional Costs*
                                 Undiscounted 
                                     Total
                                      7%
                                      3%
                                       1
                                    $51.5 
                                     $0.0 
                                     $4.2 
                                    $55.7 
                                    $52.1 
                                    $54.1 
                                       2
                                    $52.6 
                                     $0.0 
                                     $4.2 
                                    $56.9 
                                    $49.7 
                                    $53.6 
                                       3
                                     $3.3 
                                     $0.0 
                                     $4.2 
                                     $7.5 
                                     $6.1 
                                     $6.9 
                                       4
                                     $3.3 
                                     $0.0 
                                     $4.2 
                                     $7.5 
                                     $5.7 
                                     $6.7 
                                       5
                                     $3.3 
                                     $0.0 
                                     $4.2 
                                     $7.5 
                                     $5.4 
                                     $6.5 
                                       6
                                    $13.2 
                                     $0.0 
                                     $4.2 
                                    $17.4 
                                    $11.6 
                                    $14.6 
                                       7
                                    $13.2 
                                     $0.0 
                                     $4.2 
                                    $17.4 
                                    $10.8 
                                    $14.1 
                                       8
                                     $3.3 
                                     $0.0 
                                     $4.2 
                                     $7.5 
                                     $4.4 
                                     $5.9 
                                       9
                                     $3.3 
                                     $0.0 
                                     $4.2 
                                     $7.5 
                                     $4.1 
                                     $5.8 
                                      10
                                     $3.3 
                                     $0.0 
                                     $4.2 
                                     $7.5 
                                     $3.8 
                                     $5.6 
                                     Total
                                    $150.3 
                                     $0.1 
                                    $42.1 
                                    $192.5 
                                    $153.7 
                                    $173.8 
                                  Annualized
                                       
                                       
                                       
                                       
                                    $21.9 
                                    $20.4 
* This includes additional delay, travel and TWIC replacement costs due to TWIC failures.
Figures may not total due to rounding

Based on this final rule and recent data, we estimated the average first-year cost of this rulemaking to be approximately $52.1 million at 7% or $54.1 million at 3% discount rate, respectively.  The undiscounted annual recurring cost for this proposal is approximately $7.5 million in every year except years 6 and 7, due to equipment replacement 5 years after implementation.  The annualized cost of this proposal is $21.9 million at 7 percent and $20.4 million at 3 percent.  The 10-year cost of this rulemaking to industry is approximately $153.7 million at a 7% discount rate, and $173.8 million at a 3% discount rate, respectively.  Appendix F discusses the cumulative impacts of the TWIC program.
4.5 Cost Mitigation
The cost estimates in this RA are likely to overstate costs, as we do not have actual costs for what facilities will spend out of their own funds for infrastructure and installation (versus the TWIC pilot, where grant funds were used), and we cannot quantitatively account for several methods of relief that will be afforded industry in this final rule.  The increased flexibility provided by this final rule allows for the use of an existing PACS with minor modifications and increases the pool of available reader technology, which will decrease the burden on industry.  However, our cost estimates do not reflect any cost savings that may result from this flexibility and assume that all affected entities would comply by installing new TWIC readers.  The flexibility in this rule includes the ability to redefine secure areas, provisions to allow for a facility to have areas designated as different risk groups, and movement between risk groups.  While we expect these provisions to provide a certain amount of relief to industry, we do not have any estimate of how much relief or how widespread the use of these relief mechanisms will be.  Additionally, in Section 2.2 of this RA, we discuss one of these relief mechanisms in some detail, movement between risk groups.  As stated, we expect there to be some operational reduction of burden, but do not know the extent to which this provision will be used.

Furthermore, in the original 2007 Transportation Worker Identification Credential (TWIC) Implementation in the Maritime Sector; Hazardous Materials Endorsement for a Commercial Driver's License (TWIC 1) final rule, we provided greater flexibility to facility owners and operators by allowing them the option, in revised 33 CFR 105.115, to redefine their secure area as only that portion of their access control area that is directly related to maritime transportation.  Although this provision already exists, we anticipate that an increased number of facilities may take advantage of this when deploying electronic TWIC inspection programs in an attempt to reduce the number of facility access points requiring TWIC readers.  For the purposes of this rulemaking, we assess the cost of readers based on the average number of access points by facility type.  We also considered allowing multiple risk group designations within one facility, to account for situations where one portion of a facility handles dangerous cargoes and another portion does not.
 
We also discuss relief in the form of alternative compliance through the use of PINs as a secondary verification option, the use of escorts, which is already in place under current regulations, and flexibilities to allow for temporary use of TWIC as a visual identification under certain circumstances.  These flexibilities are in place to ensure that electronic TWIC inspection does not adversely impact business operations.

Finally, as indicated in footnote 24 above and displayed in Figure C3 of Appendix C, actual costs for TWIC readers are likely to be less than the average reader costs as reported in Table 4.5 if facility and vessel owners and operators choose to implement different design requirements (and, therefore, other biometric readers) in complying with the three aspects of TWIC inspection as discussed in the final rule. 
4.6 Government Cost
As this rule will require amendments to security plans, we estimate a cost to the government to review these amendments during the implementation period.  There may be additional costs for COTP's to review notifications of reader system failures.  However, we do not have data on the frequency of these events and have not quantified that potential cost to government.  

To review an amended FSP will take an estimated 4 labor hours.  Assuming a 2-year, phased-in implementation, approximately 262.5 FSPs will be amended in each of the first 2 years, for a total of 1,050 hours in each of the first 2 years.  Amendments to FSPs are reviewed by Coast Guard personnel at an hourly wage of $49.  As such, the government cost for FSP amendment review will be approximately $51,450 ($49 * 1,050) in each year of implementation.  For VSPs, we estimate an average of 3 labor hours per amendment for a total of 3 hours in the first year of implementation, assuming the only affected vessel to amend its plan in first year of implementation.  According to the Coast Guard Vessel Security Division, the persons responsible for VSP review earn, on average $55.25 an hour.  As such, the government cost for VSP amendment review will be approximately $166 ($55.25 * 3).  For the total implementation period, the total government cost will be $103,066 (($51,450 * 2) + $166).  Table 4.39 shows the 10-year government costs.



Table 4.39 Government Costs
                                    Year 
                                      FSP
                                      VSP
                              Total Undiscounted
                                      7%
                                      3%
                                       1
                                   $51,450 
                                     $166 
                                   $51,616 
                                   $48,239 
                                   $50,112 
                                       2
                                   $51,450 
                                      $0 
                                   $51,450 
                                   $44,938 
                                   $48,497 
                                       3
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                       4
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                       5
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                       6
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                       7
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                       8
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                       9
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                      10
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                      $0 
                                     Total
                                   $102,900 
                                     $166 
                                   $103,066 
                                   $93,177 
                                   $98,609 
Annualized
                                   $13,266 
                                   $11,560 

Except for reviewing security plan amendments, we do not expect the preferred alternative in this final rule to require additional government resources to implement.  The Coast Guard and TSA will use existing resources related to the TWIC program and port security to implement the electronic TWIC inspection requirements for the preferred alternative.  Other alternatives could have resource implications for USCG and TSA.

As discussed in Section 4.4 (Total Industry Costs) above, we didn't estimate any potential costs of requiring the owner or operator when the access control system fails.  Likewise, our government costs do not include any such potential impact on government costs, as there is no past or current data to estimate the frequency of such eventuality.

Table 4.40 shows the combined industry and government costs of this final rule.  We estimate the average first-year cost of this final rule (combined industry and government) to be about $52.1 million or $54.1 million at a 7% discount rate or a 3% discount rate, respectively.  The undiscounted annual recurring cost for this proposal is approximately $7.5 million in every year except Years 6 and 7, due to equipment replacement 5 years after implementation.  The annualized cost of this final rule is $21.9 million at 7% discount rate and $20.4 million at 3% discount rate.  The 10-year cost to industry and government of this proposed rule is approximately $153.8 million at a 7% discount rate, and $173.9 million at a 3% discount rate, respectively.



Table 4.40 Combined Industry and Government Costs* ($ Millions)
                                     Year
                                   Industry
                                  Government
                                 Undiscounted
                                      7%
                                      3%
                                       1
                                    $55.7 
                                     $0.1 
                                    $55.8 
                                    $52.1 
                                    $54.1 
                                       2
                                    $56.9 
                                     $0.1 
                                    $56.9 
                                    $49.7 
                                    $53.6 
                                       3
                                     $7.5 
                                     $0.0 
                                     $7.5 
                                     $6.1 
                                     $6.9 
                                       4
                                     $7.5 
                                     $0.0 
                                     $7.5 
                                     $5.7 
                                     $6.7 
                                       5
                                     $7.5 
                                     $0.0 
                                     $7.5 
                                     $5.4 
                                     $6.5 
                                       6
                                    $17.4 
                                     $0.0 
                                    $17.4 
                                    $11.6 
                                    $14.6 
                                       7
                                    $17.4 
                                     $0.0 
                                    $17.4 
                                    $10.8 
                                    $14.1 
                                       8
                                     $7.5 
                                     $0.0 
                                     $7.5 
                                     $4.4 
                                     $5.9 
                                       9
                                     $7.5 
                                     $0.0 
                                     $7.5 
                                     $4.1 
                                     $5.8 
                                      10
                                     $7.5 
                                     $0.0 
                                     $7.5 
                                     $3.8 
                                     $5.6 
                                     Total
                                    $192.5 
                                     $0.1 
                                    $192.6 
                                    $153.8 
                                    $173.9 
                                  Annualized
                                       
                                       
                                       
                                    $21.9 
                                    $20.4 
* Figures may not total due to rounding.


5) Benefits
We expect that this rulemaking will enhance the security of ports and vessels by increasing the likelihood that only persons who possess a duly issued TWIC are granted unescorted access to secure areas on vessels and facilities.   

There exist potential port security risks related to not having consistent access control, identification, and security background checks for transportation workers accessing and/or interfacing with high-risk U.S. port facilities and vessels (e.g., higher consequence targets of terrorist acts).  To this end, the MTSA transportation security card requirement and the SAFE Port Act electronic TWIC inspection requirements call for the installation and use of electronic readers to verify and validate the information presented on a TWIC upon requesting unescorted access to a secure area of a vessel or facility.  Absent a legal requirement, owners and operators of these facilities and vessels are not likely to develop, acquire, and/or install a universal technology to provide an access control systems on a national scale that will perform and update background checks and provide worker identification for access to all high-risk facilities and vessels due to the costs associated with acquiring and installing readers.  Facility and vessel owners want to protect their facilities, but may focus on systems that do not provide the nationwide interoperability needed to avoid multiple proprietary cards/interfaces for card holders and increased compliance challenges.  The electronic TWIC inspection requirements will create a more standardized access control process that will potentially reduce confusion for workers accessing multiple facilities.

In this chapter, we provide examples of the consequences of a TSI and discuss the benefits that may accrue from this final rule.  We cannot derive any specific values for the benefits of the final rule due to the fact that we cannot assign probabilities to the TSI events analyzed, or calculate risk mitigation for these events.

The Benefits chapter is organized in the following manner:
   * Beneficial Impacts of the Final Rule
   * Benefits Based on USCG Enforcement Actions
   * Risk Framework and the Maritime Security Risk Analysis Model (MSRAM)
   * Potential Consequences of a TSI 
   * Monetization of TSI Consequences
   * Break-even Analysis
5.1 Beneficial Impacts of the Final Rule
This rule seeks to prevent terrorist attacks by enhancing access control  -  a foundational element of security.  The objective of the TWIC reader is to provide an additional layer of security and access control at high-risk facilities and vessels.  Implementation and use of TWIC readers will make identification, validation, and verification of individuals attempting to gain unescorted access to a secure area more reliable, and also will help to alleviate potential sources of human error when checking credentials at access points.  Identity verification ensures that the individual presenting the TWIC is the same person to whom the TWIC was issued.  Card authentication ensures that the TWIC is not counterfeit and card validation ensures that the TWIC has not expired or been revoked by TSA, or reported as lost, stolen, or damaged.  
5.2 Benefits Based on Coast Guard Enforcement Data
To assess the potential vulnerabilities at U.S. high-risk maritime facilities, the Coast Guard reviewed USCG enforcement data from 2007 through 2010.  Based on the enforcement data, there were a total of 443 enforcement actions taken due to violations of 33 CFR part 105 relating to access control.  Among these, more than one-third (152) of violations could potentially be corrected or avoided through the electronic TWIC inspection requirement.  These violations were predominantly due to failures to perform appropriate access control, specifically guards not checking identification, and a general lack of awareness of access control protocol.  The implementation of an electronic TWIC inspection program will potentially address these failings by providing an additional layer of access control.  Also, the inclusion of TWIC readers to an access control system will be accompanied by updated security protocols and increased training, which could improve the awareness and effectiveness of access control protocols. 

The implementation of the electronic TWIC inspection requirements has the potential to reduce the human error in access control by requiring a more effective validation and verification of a person's credentials when attempting to access a secure area of a facility than reliance on a visual inspection of a credential.    

The Coast Guard believes that the final rule may help to reduce criminal activity, in addition to its effects on terrorist activity.  However, we do not discuss this potential benefit in this RA because we do not have any data specifically showing that an electronic TWIC inspection program will prevent criminal activity.  
5.3 Evaluating the Beneficial Impacts with the Risk Framework and MSRAM
The Coast Guard assesses vessels and facilities based on the vulnerabilities to potential security threats and the consequences of potential incidents.  We use a systematic process known as Risk-Based Decision Making (RBDM) to meet those needs.  Specifically, MSRAM is an analysis tool designed to assess risk for potential terrorist targets in the U.S. maritime domain.  The Coast Guard has used MSRAM extensively for the past 8 years, and considers it to be the best available tool for determining which maritime facilities and vessels should be considered a high risk.  We calculate risk in MSRAM by analyzing specific vessels and facilities and pairing each to various terrorist attack modes. 

The use of RBDM ensures a comprehensive evaluation by considering the relative risks of various targets and attack mode combinations or scenarios.  It provides a more realistic estimation of risk (and more efficient risk management activities) than a simple ``worst case scenario'' assessment, where only the worst possible consequences are considered.  In addition, the RBDM approach was based on the recommendations from the Government Accountability Office (GAO), and is consistent with DHS directives, including the National Infrastructure Protection Plan (NIPP).  Managing risk is one of the best tools to complete a security assessment and to determine appropriate security measures, as has been recommended by GAO in several studies (see, e.g., GAO - 01 - 822, GAO - 01 - 1158T, and GAO/NSIAD - 98 - 74). 

Risk management principles acknowledge that, while risk cannot be eliminated entirely, it can be reduced.  Risk reduction is done by adjusting operations to reduce consequence, threat, or vulnerability of a security threat.  The term ``consequence'' is the estimation of adverse effect from the target/attack scenario and is an important consideration in risk evaluation and security planning.  The term ``threat'' is a measure of the likelihood of an attack.  It represents the estimated probability of an attack based on collective intelligence through maritime domain awareness.  The term ``vulnerability'' measures the conditional probability of success given that a threat scenario occurs.  It evaluates the adequacy and effectiveness of safeguards (both existing and proposed).  We assess risk according to the risk equation:

	Risk = Threat * Consequence * Vulnerability

Generally, it is easier to reduce vulnerabilities by adding security measures than it is to reduce consequences or threats (although reductions in all three are possible).  Risk assessments provide visibility into those elements of the risk equation that exert the greatest influence on risk, and those elements become priorities in the risk management approach.  The goal for maritime security is to ensure that, if the level of threat increases, either the consequences or vulnerabilities (or both) decrease enough to offset that increase.

Initial MSRAM risk assessment is performed at the port level with input from members of the Area Maritime Security committees, ensuring industry and local government representatives are involved in the risk analysis process, and providing access to what are often the best data sources.  This initial assessment provides the maximum potential consequence for the total loss of a target using factors such as injury and loss of life, economic and environmental impact.  If a target's maximum potential consequence score surpasses a predetermined threshold, then the risk analysis continues with the evaluation of risk scenarios in terms of threat, vulnerability, and consequence to produce unique risk estimates for each scenario.  Data provided by the Coast Guard's Office of Port and Facility Activities, Cargo and Facilities Division cover 362 facilities, 17 vessels and 4 other targets regulated under MTSA that have been analyzed by MSRAM.  We were able to match 383 targets from our affected population to targets in MSRAM.  This discrepancy is due to differences in facility names in MISLE, which provided our initial MTSA-regulated population and the naming of facilities in MSRAM.  As such, we were unable to match our entire population to MSRAM consequence data.

Because the primary function of the TWIC card and of electronic TWIC inspection is to enhance access control and identity verification and validation, the attack scenarios evaluated within MSRAM to provide the consequence data for this analysis were limited to the following:

   * Truck Bomb
         o Armed terrorists use a truck loaded with explosives to attack the target focal point.  The terrorists will attempt to overcome guards and barriers if they encounter them. 
   * Terrorist Assault Team 
         o A team of terrorists using weapons and explosives attack the target focal point.  Assume the terrorists have done prior planning and surveillance, but have no insider support of assault. 
   * Passenger/Passerby Explosives/IED
         o Terrorists exploit inadequate access control and detonate carried explosives at the target focal point.  Assume the terrorists approach the target under cover of legitimate presence and are not armed.  Note: for this attack mode, terrorist is not an insider.

The focus on these three attack scenarios allows us to look at specific attack scenarios that are most likely to be mitigated by the use of TWIC readers.  We base our analysis on the highest consequence scenario of these three for each target.  These scenarios were chosen because they represent the scenarios most likely to benefit from the enhanced access control afforded by electronic TWIC inspections, as they require would-be attackers gaining access to the target in question.  For these three attack types, the aggressor will first need to gain access to the facility to inflict maximum damage.  Because the function of the electronic TWIC inspection is to enhance access control, the deployment of electronic TWIC inspection programs will increase the likelihood of identifying and denying access to an individual attempting terrorist acts.  The consequence of an attack scenario is dependent on both the target and the attack mode.  The attack modes selected for this analysis, as described above, serve to limit the potential maximum consequence compared to other potential attack modes, which often have more damage potential.  Typically, one or more threat, vulnerability, or consequence drivers will contribute significantly more to a target's risk scores than others; these are known as major risk drivers.  The local COTPs document major risk drivers such as inherent limitations on access control or the potential death and injury during the analysis process.

Specifically, the use of electronic TWIC inspection primarily addresses the vulnerability component of risk, although electronic TWIC inspection may also impact the other components as well.  For the Truck Bomb scenario, use of electronic TWIC inspection would preclude terrorists from driving a truck into the facility without an operative TWIC card, reducing vulnerability.  If the terrorists cannot reach their primary target, they may still detonate a truck at the perimeter of the facility (i.e., they may change the location of the threat).  For the scenario of detonating the truck at the perimeter of the facility, the deterrence from electronic TWIC inspections displaces the attack away from the primary target, providing a greater distance from the blast radius, and thereby reducing the potential consequences.  Thus, the use of electronic TWIC inspection addressed at least two risk components by reducing the vulnerability of the facility through denying access, and by reducing consequences by moving the detonation away from the primary target, and possibly addresses a third component, depending on the level of deterrent impact an electronic TWIC inspection has on would-be attackers.

Similarly, for the scenario of attempting to break through the gates or protective barriers at a facility, the nature of the threat is changed from a surreptitious act to an overt and immediately recognizable threat.  The very act of trying to bypass electronic TWIC inspection immediately signals harmful intent, increasing the likelihood of intercepting and stopping the attack before the target is reached (reducing both vulnerability and consequence).

For the Terrorist Assault Team scenario, the use of electronic TWIC inspection would preclude persons not holding a duly issued TWIC from obtaining unescorted access to the secure areas of a facility or vessel, thus reducing the potential for a terrorist action to take place there (reducing vulnerability).  As with the Truck Bomb scenario, electronic TWIC inspection could cause the nature of the threat to change by forcing the incident to be perpetrated outside the perimeter of a facility (reducing consequences), or by forcing the terrorist assault team to break through the gates or barriers by force (providing clear signs of an attack and triggering the use of more capable security response measures). 

Lastly, for the Passenger/passerby IED scenario, by ensuring that only those persons possessing a duly issued TWIC can access secure areas, electronic TWIC inspection would mitigate the possibility of a person bringing an explosive device into a secure area.  Electronic TWIC inspection would have the same impacts on the attacks on the perimeter and breaking through the gates as they have on the Truck Bomb and Terrorist Assault Team scenarios.

Overall effects of electronic TWIC inspection on risk are shown in Table 5.1.


Table 5.1 Overall Impact of Electronic TWIC Inspection on Risk
Risk Component Addressed
How Risk is Addressed
Threat
Potential deterrent given enhanced security and attacker desire to maximize success
Vulnerability
Access control strengthened by enhanced identity verification (TWIC card and reader), card authentication (TWIC reader) and card validation (TWIC reader).  

Potential vulnerability reduction by establishing temper and intent earlier, triggering more capable security assets.
Consequence
Reduced consequence given increased likelihood of stopping the attack at the checkpoint, farther from the main target.  

Reduced consequence by immediate identification of intent and a greater chance of implementing protective measures (e.g., shutdown of sensitive systems).

The implementation of an electronic TWIC inspection program enables better detection of attempted TSIs, which in turn increases the effectiveness of active measures to defend the target and/or defeat the attack.  By enhancing a facility's or vessel's ability to detect a potential threat, electronic TWIC inspection programs increase the likelihood of avoiding a TSI.  The final rule seeks to reduce the likelihood of a TSI as well as the consequences thereof (e.g., earlier detections that do not result in an explosive being detonated at the intended target, but for which detonation is triggered earlier and in a less vulnerable location).  Figure 5.1 illustrates the multidimensional impact of the electronic TWIC inspection.


Figure 5.1 MSRAM: Result of Mitigation Strategies
                                       

5.4 Potential Consequences of a TSI
MSRAM contains information on the potential consequences at risk for each target in six categories, as detailed in Table 5.2.  For the purposes of this rulemaking, we analyze the consequence of the relevant attack scenarios only for death and injury.  

Table 5.2 Description of Consequence Factors in MSRAM*
Consequence Factors
Definitions
Death/serious injury
Represents the expected number of deaths/serious injuries from a successful attack. This includes both deaths at the time of attack, and deaths that occur later but are still clearly a direct result of the attack (e.g., burn victims, or victims who become sick and die from exposure to chemical or biological agents).
Economic - primary
Represents the expected property damage and immediate business interruption from a successful attack. This includes the actual costs of replacing or repairing maritime infrastructure, as well as business losses resulting from the attack.
Environmental
Represents the expected environmental impacts of a successful attack. This impact predominately captures impacts from oil and oil-like substances.
National security
Represents the expected impact of a successful attack on a target involved in providing national security.
Symbolic
Represents the symbolic impact of a successful attack based on the iconic value of the target in terms of its local, regional, national, and international importance.
Economic - secondary
Represents the expected follow-on economic effects of a successful attack. For example, an attack on a fuel refinery could interrupt energy production and distribution, which is considered a secondary economic effect. This assessment should take into account redundancy and resiliency of the target.
* Note: Even though the MSRAM includes the above consequence factors, the break-even analysis used in this rule only considers and quantifies the "Death/serious injury" factor.

For its consequence estimates, MSRAM only considers serious, severe and critical injuries.  This is done to focus scarce analytic resources on the highest consequence scenarios of national significance quickly, without having to assess all scenarios.  As such, MSRAM does not account for the consequences of minor and moderate injuries, and these are not included in this RA.  To calculate the value of injuries as well as fatalities, MSRAM assigns an equivalency of 10 injuries to 1 fatality (1 injury is equal to 10% of a fatality).  For comparison purposes, according to the Department of Transportation (DOT) Abbreviated Injury Scale (AIS), a serious injury is equivalent to 10.5% of an unsurvivable accident (a fatality); this 10.5% value is greater than the value MSRAM places on all serious, severe and critical injuries and suggests MSRAM may be underestimating the value of injuries.  

Table 5.3 Relative Disutility Factors by Injury Severity Level (AIS)
                                   AIS Level
                                   Severity
                                Fraction of VSL
                                     AIS 1
                                     Minor
                                     0.003
                                     AIS 2
                                   Moderate
                                     0.047
                                     AIS 3
                                    Serious
                                     0.105
                                     AIS 4
                                    Severe
                                     0.266
                                     AIS 5
                                   Critical
                                     0.593
                                     AIS 6
                                 Unsurvivable
                                       1

Since MSRAM counts serious, severe and critical injuries equally, as 10% of a "value of a statistical life" (VSL), when determining consequence scores, it can be argued that the value of a MSRAM injury may be undervalued, based on the AIS scale, which counts severe injuries as 26.6% of a VSL and Critical Injuries as 59.3% of a VSL.  For example, if there was an explosion that left 1 person critically injured and another person severely injured, the MSRAM will equate the cost to be $1.82 million ($9.1 million VSL * 10% * 2 people) however, using the AIS scale, the cost will be $7.82 million ($9.1 million VSL * 0.266 for the severely injured person + $9.1 million * 0.593 for the critically injured person).  

For the purposes of this RA, we focus on equivalent fatalities for our valuation of consequences (for example 50 injuries are considered to be 5 "equivalent fatalities").  We do not consider primary economic loss or environmental loss in our estimate of consequences for the break-even analysis, since MSRAM includes potential individual business losses in its estimates of primary economic loss, which may not represent the overall net loss to the economy.   The valuation of environmental loss is quantified in barrels, and not monetized or distinguished for damages associated with petroleum spills or releases of other substances, such as CDC, which is only considered in Risk Group A.  MSRAM consequence data are initially collected at the local level with input from Coast Guard resources and stakeholders such as owners/operators, first responders, and local, State and other law enforcement.  Coast Guard staff at the District, Area, and Headquarters level then review the data to ensure consistency between ports and across Districts to allow for a national aggregation of data.  The Coast Guard updates the data periodically to reflect changes over time.

Data on equivalent fatalities provided by the Office of Port and Facility Activities, Cargo and Facilities Division cover 362 facilities, 17 vessels, and 4 other targets (for a total of 383 targets) that might come under attack in such a way that TWIC readers could prove to be effective in interdiction have been analyzed by MSRAM.  We then look at these targets by attack type to provide an overview of the different threats associated with each target as well as the potential consequences of the three attack scenarios presented.  MSRAM assesses attack scenarios for specific targets, and as such, not all scenarios are estimated for each target, as specific targets may not be vulnerable to a particular attack type.  Table 5.4 shows the number of targets analyzed and the average maximum consequence by attack type.

Table 5.4 Average Maximum Consequence by Attack Type 
                              Attack Scenarios 
                           Count of Target Scenarios
                          Average Maximum Consequence
                                 ($ Millions)
                       Attack by Terrorist Assault Team
                                      139
                                   $5,082.5
                       Passenger/Passerby Explosives/IED
                                      360
                                   $1,403.5
                                  Truck Bomb
                                      366
                                   $2,275.8

To develop scenarios for further use, we extract consequences from the list of 383 targets.  To obtain the maximum average consequence across the three attack types analyzed, we use the maximum consequence scenario for each of the 383 targets.  We then calculated the average of the maximum consequence scenarios to estimate the average maximum consequence of the three attack modes across the full affected population.  We present the average maximum consequence for several target classes and combinations.  Table 5.5 presents the average potential equivalent fatalities for three target combinations.  



Table 5.5 Equivalent Fatalities At Risk, by Target Group

                                       
                               Number of Targets
                Average Maximum Number of Equivalent Fatalities
                                 Risk Group A
                                      383
                                      551
                                 Risk Group B
                                     1,162
                                      88
                                  Containers
                                      90
                                      58
                          Risk Group A and Containers
                                      474
                                      457
Risk Group A plus Petroleum Refineries, Non-CDC Bulk Hazardous Materials Facilities, and Petroleum Storage Facilities 
                                     1,025
                                      243
                              Risk Groups A and B
                                     1,546
                                      181

5.5 Monetization of TSI Consequences Derived from MSRAM
Valuation of Lives Lost
To monetize the value of fatalities and fatalities prevented, we use the concept of the "value of a statistical life" (VSL), which is commonly used in safety and security analyses.  The VSL does not represent the dollar value of a person's life, but the amount society would be willing to pay to reduce the probability of death.  We currently use a value of $9.1 million as an estimate of the VSL.  

Table 5.6 presents the monetized value of the consequences faced across several target groups based on the data from the MSRAM consequence data in Table 5.5.  These target groupings are used in Chapter 6 of this RA as part of our alternatives analysis.



Table 5.6 Monetary Value of Consequences at Risk, by Target Group ($ Millions)
 
                                 Target Group
                               Number of Targets
                    Average Number of Equivalent Fatalities
                     Average Max Consequence ($ millions)
                                 Risk Group A
                                      383
                                      551
                                   $5,014.1
                                 Risk Group B
                                     1,162
                                      88
                                    $800.8
                                  Containers
                                      90
                                      58
                                    $527.8
                          Risk Group A and Containers
                                      474
                                      457
                                   $4,158.7
Risk Group A plus Petroleum Refineries, Non-CDC Bulk Hazardous Materials Facilities, and Petroleum Storage Facilities
                                     1,025
                                      243
                                   $2,211.3
                              Risk Groups A and B
                                     1,546
                                      181
                                   $1,647.1

The facilities and vessel represented in Risk Group A include fuel storage facilities (which have high potential infrastructure consequences), facilities and vessels that handle CDCs (which have high potential environmental consequences), and passenger ships and terminals (which have high potential fatalities).  Facilities that handle CDCs present a high risk based on the cargo that they handle and the potential impacts of an incident occurring on that facility.  These CDCs include items such as ammonium nitrate or liquefied chlorine gas, and other items that could be weaponized or used to cause severe casualties in the case of a TSI.  Large passenger facilities present a high risk because of the number of persons that would be vulnerable to a TSI.  In 2011, the average number of passengers on cruises embarking at U.S. ports was 2,301 passengers per cruise.  This volume of persons vulnerable to an attack makes cruise terminals attractive and high-risk.  The targets represented in Risk Groups A and B includes all the high-risk targets in Risk Group A, along with the medium risk population.  Each group's monetized consequence is the average of all scenarios for that group.  The average for all scenarios is the consequence shown for the overall group.  These consequences are taken as representing potential benefit, as there have been no TSIs at MTSA-regulated entities to evaluate and we do not have publicly releasable information on expected TSIs in the future.  We use this average maximum consequence data to evaluate the target groups and scenarios with actual, verified consequence data in a break-even analysis.

5.6 Break-even or Threshold Analysis
The primary impetus of this rule is the security benefit afforded by the implementation of electronic TWIC inspection requirements.  The quantification and monetization of the beneficial security effects of this regulation will involve two steps.  Estimating the initial probability and reduction in the probability of a successful terrorist attack resulting from implementation of the regulation and the consequences of the avoided event (the risk associated with a potential terrorist attack).  We do not have data available to estimate the initial and reduction in probability of a successful terrorist attack and can therefore not directly quantify benefits, thus we use break-even analysis.

Break-even analysis is useful when it is not possible to quantify the benefits of a regulatory action.  OMB Circular A-4 recommends a "threshold" or "break-even" analysis when non-quantified benefits are important to evaluating the benefits of a regulation.  Threshold or break-even analysis answers the question, "How small could the value of the non-quantified benefits be (or how large would the value of the non-quantified costs need to be) before the rule would yield zero net benefits?"  For this rulemaking, we calculate a potential range of break-even results using attack scenarios representing casualties and terrorist events that result in loss of life.  

One of the benefits of this regulation is to avoid the likelihood of future terrorist attacks.  As such, the effectiveness of the regulation can be measured by the change (reduction) from the current state of risk/loss (Lb) to the new resulting state of risk/loss after the regulation has become effective (Ln).  The point where the risk reduction is equal to the cost of the regulation (Cr) is the break-even point, which can be defined as: 

(1)	Lb  -  Ln = Cr

Since the percent change in risk reduction is defined as (Lb  -  Ln) / Lb, the first equation can be rewritten as follows to determine the percentage of risk reduction required for the regulation to be cost effective:

(2)	% Risk Reduction = (Lb  -  Ln) = Cr
                                                                     
                                                  Lb            Lb

For this analysis, the reduction in risk is measured by the expected number of equivalent fatalities saved and uses an estimate of $9.1 million as the VSL.  By only using the number of equivalent fatalities saved and not including any savings from avoided property damage, temporary shortages in trade goods, and/or environmental damage, we may be overstating the probability reductions required for benefits to equal the costs.  

In addition, annualized costs were used because we assume that the final rule will result in a constant probability reduction in every year following the rule's implementation.  In other words, we assume that the risk reduction resulting from this regulation is constant each year.  It is important to note that measuring benefits by focusing on specific scenarios avoided will not account for the possibility that the risk has been transferred but not reduced.  For this analysis, we use costs annualized at 7 percent over 10 years, since annualized costs do not differ greatly between 7 and 3 percent.  

Table 5.7 presents the results of this methodology.  From the results, an avoided terrorist attack at an average target is equivalent to $5,014.1 million in avoided consequences.  Using the estimated annualized cost of this regulation, the annual reduction in the probability of attack to a Risk Group A facility that would just equate avoided consequences with cost is less than 1 percent.  To state this another way, if implementing this regulation would lower the likelihood of a successful terrorist attack by 1 percent or more each year, then this would be a socially efficient use of resources.  In other words, this final rule is estimated to cost approximately $22.5 million annualized at 7%, and it will be cost effective if it prevented one terrorist attack with consequence equal to the average every 228.8 years ($5,014.1/$22.5).  These small changes in risk reduction suggest the potential benefits of the final rule justify the costs.  We include the calculations for the potential regulatory alternatives in Table 5.7 to demonstrate the differences in cost, consequence, risk reduction, and frequency of attacks averted for each alternative.  The affected populations for the regulatory alternatives are derived from the multiple target groups as shown in Tables 5.4 and 5.5.  The regulatory alternatives below include the estimated costs for facilities and vessels and the effected populations are different from those in Tables 5.5 and 5.6, which show the consequences only, which are based on MSRAM assets or targets, and which include a combination of facilities, vessels, and other targets.  These alternatives are discussed fully in Section 6.1 of this RA.



Table 5.7 Annual Risk Reduction Required for Costs to Equal Benefits, 
by Regulatory Alternative

                           TWIC Reader Requirement 
                       Annualize Cost,
7% Discount Rate
                              Average Consequence
                          Required Reduction in Risk
                                   Required
                         Frequency of Attacks Averted
                            Final Rule Alternative
                                     $21.9
                                   $5,014.1
                                     0.4%
                             One every 229.0 years
                               NPRM Alternative
                                     $21.9
                                   $5,014.1
                                     0.4%
                             One every 229.0 years
             Risk Group A facilities and all Risk Group A vessels
                                     $22.5
                                   $5,014.1
                                     0.4%
                             One every 222.8 years
Risk Group A and container facilities and Risk Group A vessels with more than 14 Crewmembers
                                     $26.0
                                   $4,158.7
                                     0.6%
                             One every 160.0 years
All Risk Group A facilities, plus additional high-consequence facilities including petroleum refineries, non-CDC bulk hazardous materials facilities, and petroleum storage facilities, and Risk Group A vessels with more than 14 crewmembers
                                     $44.1
                                   $2,211.30
                                     2.0%
                             One every 50.1 years
                              ANPRM Alternative:
Risk Groups A and B facilities and Risk Group A vessels with more than 14 Crewmembers
                                     $78.1
                                   $1,647.1
                                     4.7%
                             One every 21.1 years
.
 

6) Alternatives
When creating this final rule, the Coast Guard considered several alternatives.  These included several iterations of different populations for facilities and vessels that could require an electronic TWIC inspection program.  In the following sections, we examine these alternatives by looking at how the cost of the proposal would change based on different population assumptions.

The Final Rule Alternative evaluated all Risk Group A facilities with the exception of barge fleeting facilities as listed in Figure 2.2 . As for vessels, the evaluation included all Risk Group A vessels with a crew size greater than 20 TWIC-holding crewmembers. 

For the NPRM alternative, we assess that all Risk Group A facilities will be required to install and use TWIC readers.  On the vessel side, we assess that all Risk Group A vessels with a crew size greater than 14 TWIC-holding crewmembers will be required to carry 2 portable readers.  For this alternatives analysis, we look at three other alternatives.  

In calculating the alternatives for electronic TWIC inspection requirements for container facilities, we also included an estimated annual cost for delays due to congestion caused by the longer processing time required for a biometric read of a TWIC, as compared to a visual TWIC inspection.  The time difference for a biometric read as opposed to a visual TWIC inspection is estimated from the TWIC pilot to be about 2 seconds a transaction.  In the Draft Programmatic Environmental Assessment for this rulemaking, we estimate the delay, in hours, for electronic TWIC inspections versus visual TWIC inspections.  Using the average of these delay calculations and the mean wage for an employee in the labor category Deep Sea, Costal and Great lakes Water Transportation ($39.98), we are able to estimate the cost of delays for all 122 container facilities.  Table 6.1 shows this result.

Table 6.1 Annual Cost of Delay for Container Facilities
Number of Container Facilities
                                                                            122
Average Delay, in Hours
                                                                          1,531
Wage
                                                                        $39.98 
Annual Cost of Delays
                                                                    $7,467,544 

We anticipate that container facilities would present the greatest threat of congestion delays leading to opportunity costs.  Because we are not requiring electronic TWIC inspections at the majority of the container facilities, we assume that this final rule will not lead to increased costs due to congestion delays.  We only account for congestion delays at container facilities, as containers account for the majority of TWIC-holder vehicle traffic.  We anticipate that because vehicle traffic will not be unexpected, other facilities will be able to adjust their business practices so that the additional 2 seconds will not result in additional processing time or congestion delays.    Therefore, we do not account for congestion costs other than at container facilities.  Table 6.2 summarizes the alternatives considered.  The costs displayed in Table 6.2 are for both ten-year total and annualized at a 7% discount rate.

Table 6.2 Regulatory Alternatives
                                       
                                  Description
                              Facility Population
                               Vessel Population
                 Total Cost ($ millions, at 7% Discount Rate)
               Annualized Cost ($ millions, at 7% Discount Rate)
                            Final Rule Alternative
All Risk Group A facilities and Risk Group A vessels with more than 20 crewmembers
                                      525
                                       1
                                    $153.8
                                     $21.9
                               NPRM Alternative
All Risk Group A facilities and Risk Group A vessels with more than 14 crewmembers
                                      532
                                      38
                                    $153.5
                                     $21.9
                                 Alternative 2
     All Risk Group A facilities and Risk Group A vessels (except barges)
                                      532
                                      138
                                    $158.2
                                     $22.5
                                 Alternative 3
Risk Group A and all Container Facilities and Risk Group A vessels with more than 14 crewmembers
                                      651
                                      38
                                    $182.6
                                     $26.0
                                 Alternative 4
All Risk Group A facilities, plus additional high consequence facilities including petroleum refineries, non-CDC bulk hazardous materials facilities, and petroleum storage facilities, and Risk Group A vessels with more than 14 crewmembers
                                     1,174
                                      38
                                    $309.5
                                     $44.1
                                 Alternative 5
                              (ANPRM Alternative)
Risk Group A and B facilities and Risk Group A vessels with more than 14 crewmembers
                                     2,173
                                      38
                                    $548.9
                                     $78.1

When comparing alternatives, we also looked at the results of the break-even analysis for several different facility combinations.  Because the vessel population and cost are small compared to the population and cost for facilities, we focus our comparisons on the break-even results for the different facility type combinations.  We show the break-even comparison for the overall range of scenarios.  There exists a strong positive correlation between risk and consequence.  As such, the targets that would lead to the greatest consequence of a TSI should be considered in our analysis, as they are the most desirable targets.  In Table 6.3, we compare the costs, required risk reduction, and averted attack frequencies for the four regulatory alternatives.  This table shows that by focusing on the highest risk population, we have effectively reduced costs and maximized our required probability reduction and frequency of attacks averted.

6.1 Alternatives
Final Rule Alternative  -  Risk Group A Facilities Except Barge Fleeting Facilities and Vessels with More than 20 TWIC-holding Crewmembers

The analysis for this alternative is discussed in detail previously in the final rule RA, as it is the preferred alternative for this final rule.

NPRM Alternative  -  Risk Group A Facilities and Vessels with More than 14 TWIC-holding Crewmembers

The analysis for this alternative is discussed in detail in the NPRM RA, as it was the alternative proposed in the NPRM.  The difference in assessed costs and benefits are in the affected population with the NPRM alternative affecting 38 vessels (versus 1) and 532 facilities (versus 525).

Alternative 2  -  Risk Group A Facilities and all Risk Group A Vessels, Except Barges

This alternative would require readers to be used at all Risk Group A facilities and for all Risk Group A vessels, except barges.  This alternative would increase the burden on industry by increasing the affected population from 1 vessel to 138 vessels.  The number of facilities will be the same (532) as in the NPRM Alternative.  Under this alternative, annualized cost of this rulemaking would stay at $22.5 million, at a 7% discount rate.  The discounted 10-year costs will go from $153.8 million to $158.2 million.  While this alternative would not lead to a significant increase in costs, we rejected it because requiring electronic TWIC inspections on vessels with 20 or fewer TWIC-holding crewmembers is unnecessary, as crews with that few members are known to all on the vessel and identity verification at the vessel would not add significant benefit.

Alternative 3  -  Risk Group A and all Container Facilities and Risk Group A Vessels with More than 14 TWIC-holding Crewmembers

For this alternative, we assumed that only those facilities in Risk Group A, as previously defined, and all container facilities will be required to perform electronic TWIC inspections.  This alternative will increase the burden on industry by increasing the affected population from 525 facilities to 651 facilities, and from 1 vessel to 38 vessels.  Under this scenario, the annualized cost of this rulemaking will increase from $21.9 million to $26.0 million, at a 7% discount rate.  The discounted 10-year costs will go from $153.8 million to $182.6 million.  The inclusion of container facilities will also potentially have adverse environmental impacts, due to increased air emissions from longer queuing times and congestion at facilities.

We considered this alternative because container facilities are perceived to pose a unique threat to the maritime environment due to the large number of people accessing container terminals from the shore side, and as such, they may benefit from the enhanced access control provided by electronic TWIC inspection.  As discussed in the preamble of the NPRM, many of the high-risk threat scenarios at container facilities would not be mitigated by electronic TWIC inspection.  The costs for TWIC readers at container facilities would not be justified by the amount of potential risk reduction at these facilities.  While container facilities pose an increased transfer risk  -  that is, there is a greater risk of a threat coming through a container facility and inflicting harm or damage elsewhere than with any other facility type  -  such threats are not mitigated by the use of TWIC readers.  Furthermore, the use of TWIC readers, or other access control features, would not mitigate the threat associated with the contents of a container.  Electronic TWIC inspection serves as an additional access control measure, but would not improve screening of cargoes for dangerous substances or devices. 

Alternative 4  -  Adding Certain High-consequence Facilities to Risk Group A,  including Petroleum Refineries, Non-CDC Bulk Hazardous Materials Facilities, and Petroleum Storage Facilities 

For this alternative, we moved three facility categories  -  petroleum refineries, non-CDC bulk hazardous materials facilities, and petroleum storage facilities  -  into Risk Group A from Risk Group B, based on the average maximum consequence for these facility types.  This alternative would increase the burden on industry by increasing the affected population from 525 facilities to 1,174 facilities and from 1 vessel to 38 vessels.  Under this scenario, the annualized cost of this rulemaking would increase from $21.9 million to $44.1 million, at a 7% discount rate.  The discounted 10-year costs would rise from $153.8 million to $309.5 million.

We considered this alternative based on the high MSRAM consequence scores associated with these three facility types, as well as due to the perception that petroleum facilities pose a greater security risk than other facility types.  Despite the high MSRAM consequence scores for these facility types, the overall risk score as determined in the AHP were not as high as those in the current Risk Group A, and therefore, we rejected this alternative and maintained the AHP-based risk groupings.  

Alternative 5  -  Risk Group A and Risk Group B Facilities and Risk Group A Vessels with More than 14 TWIC-holding Crewmembers

Alternative 5 represents the facility requirements that were presented in the Advanced Notice of Proposed Rulemaking.  This alternative would require readers to be used at all Risk Group A and Risk Group B facilities.  This alternative would increase the burden on industry by increasing the affected population from 525 facilities to 2,173 facilities and from 1 vessel to 38 vessels.  This increase in facilities would extend the affected population to facilities that fall under the second risk tier.  Under this alternative, annualized cost of this rulemaking would increase from $21.9 million to $78.1 million, at a 7% discount rate.  The discounted 10-year costs would rise from $153.8 million to $548.9 million.  Based on a recent study by the HSI, as discussed in the preamble of the NPRM, the difference in risk between Risk Group A and B facilities is great, indicating that the two risk groups do not require the same level of scrutiny for TWIC cards.  Further, as discussed in the Benefits section of this analysis, the break-even point for this alternative is much higher than that of the preferred alternative.  Moreover, many of the comments opposing electronic TWIC inspection requirements represented the interests of owners and operators of vessels or facilities assigned to Risk Group B.  For these reasons, we rejected this alternative.  For an example of what an impact of an incident at a Risk Group B petroleum facility could be, see Appendix F.

Table 6. 3 Summary of Required Risk Reduction by Regulatory Alternative Overall ($ Millions)
                            TWIC Reader Requirement
                       Annualize Cost, 7% Discount Rate
                              Average Consequence
                          Required Reduction in Risk
                                   Required
                         Frequency of Attacks Averted
                            Final Rule Alternative
                                     $21.9
                                   $5,014.1
                                     0.45%
                             One every 229.0 years
                               NPRM Alternative
                                     $21.9
                                   $5,014.1
                                     0.44%
                             One every 229.0 years
             Risk Group A facilities and all Risk Group A vessels
                                     $22.5
                                   $5,014.1
                                     0.45%
                             One every 222.8 years
Risk Group A and container facilities and Risk Group A vessels with more than 14 crewmembers
                                     $26.0
                                   $4,158.7
                                     0.63%
                             One every 160.0 years
All Risk Group A facilities, plus additional high-consequence facilities including petroleum refineries, non-CDC bulk hazardous materials facilities, and petroleum storage facilities, and Risk Group A vessels with more than 14 crewmembers
                                     $44.1
                                   $2,211.3
                                     1.99%
                             One every 50.1 years
                              ANPRM Alternative:
Risk Groups A and B facilities and Risk Group A vessels with more than 14 crewmembers
                                     $78.1
                                   $1,647.1
                                     4.74%
                             One every 21.1 years



7) Final Regulatory Flexibility Analysis
7.1 Overview of the Final Regulatory Flexibility Act Analysis
The RFA (Public Law 96-354) establishes "as a principle of regulatory issuance that agencies shall endeavor, consistent with the objectives of the rule and of applicable statutes, to fit regulatory and informational requirements to the scale of the businesses, organizations, and governmental jurisdictions subject to regulation.  To achieve this principle, agencies are required to solicit and consider flexible regulatory proposals and to explain the rationale for their actions to assure that such proposals are given serious consideration."  

When an agency promulgates a final rule under section 553 of the RFA, after being required by that section or any other law to publish a general notice of proposed rulemaking, or promulgates a final interpretative rule involving the internal revenue laws of the United States as described in section 603(a), the agency must prepare a FRFA or have the head of the agency certify pursuant to RFA section 605(b) that the rule will not, if promulgated, have a significant economic impact on a substantial number of small entities.  The RFA prescribes the content of the FRFA in section 604(a), which we discuss below.

In accordance with the RFA (5 U.S.C. 601-612), the Coast Guard prepared this FRFA that examines the impacts of the final rule on small entities (5 U.S.C. 601, et seq.).  A small entity may be:

   * A small independent business, defined as any independently owned and operated business not dominant in its field that qualifies as a small business per the Small Business Act (5 U.S.C. 632); 
   * A small not-for-profit organization; and;
   * A small governmental jurisdiction (locality with fewer than 50,000 people).

This FRFA addresses the following:

(1) a statement of the need for, and objectives of, the rule;
(2) a statement of the significant issues raised by the public comments in response to the initial regulatory flexibility analysis, a statement of the assessment of the agency of such issues, and a statement of any changes made in the proposed rule as a result of such comments;
(3) the response of the agency to any comments filed by the Chief Counsel for Advocacy of the SBA in response to the proposed rule, and a detailed statement of any change made to the proposed rule in the final rule as a result of the comments;
(4) a description of and an estimate of the number of small entities to which the rule will apply or an explanation of why no such estimate is available;
(5) a description of the projected reporting, recordkeeping and other compliance requirements of the rule, including an estimate of the classes of small entities which will be subject to the requirement and the type of professional skills necessary for preparation of the report or record;
(6) a description of the steps the agency has taken to minimize the significant economic impact on small entities consistent with the stated objectives of applicable statutes, including a statement of the factual, policy, and legal reasons for selecting the alternative adopted in the final rule and why each one of the other significant alternatives to the rule considered by the agency which affect the impact on small entities was rejected.

Below is a discussion of FRFA analysis by each of these six elements:


7.1.1 A statement of the need for, and objectives of, the rule

The need for Federal regulatory action is due to port security risks related to not having consistent access control, identification, and security background checks for transportation workers accessing or interfacing with high-risk U.S. port facilities and vessels (e.g., higher consequence targets of terrorist acts).  To this end, the MTSA transportation security card requirement, as well as the SAFE Port Act electronic TWIC reader requirements, call for the installation and use of electronic readers to verify and validate the information presented on a TWIC upon requesting unescorted access to a secure area of a vessel or facility.  

Owners and operators of these facilities and vessels are not likely to develop, acquire, and install a universal technology to provide an access control systems on a national scale that will perform and update background checks and provide worker identification for access to all high-risk facilities and vessels due to the costs associated with acquiring and installing readers.  Facility and vessel owners want to protect their facilities, but may focus on systems that do not provide the nationwide interoperability needed to avoid multiple proprietary cards/interfaces for cardholders and increased compliance challenges.  Therefore, the implementation of electronic TWIC inspection requirements will create a more standardized access control system that will potentially reduce confusion for workers accessing multiple facilities.

The objective of this regulatory action is to enhance the security of ports, facilities, and vessels by providing an effective means to ensure that only persons who hold valid TWICs are granted unescorted access to secure areas on high consequence vessels and port facilities.  This rule will provide enhancements over the current level of security and access control currently required at certain types of MTSA-regulated facilities.  It will also complete the implementation of the MTSA transportation security card requirement, as well as the requirements of the SAFE Port Act for regulations on electronic readers for use with TWICs. 

7.1.2 A statement of the significant issues raised by the public comments in response to the initial regulatory flexibility analysis, a statement of the assessment of the agency of such issues, and a statement of any changes made in the proposed rule as a result of such comments

On March 22, 2013, the Coast Guard published an NPRM (78 FR 17782) and received approximately 88 individual submissions.  We summarized these comments in the Discussion of Comments and Changes to the Final Rule section of the final rule.  The commenters raised issues related to the economic impact of the NPRM, such as the revenue impacts to small entities, the costs of electronic TWIC inspections, and the cumulative impact of security regulations on small businesses.  The significant issues raised by the public comments on the Initial Regulatory Flexibility Analysis were the following:

Revenue Impacts  -  One commenter expressed concern that its small profit margin will be negatively affected by new expenses on security due to changes to technology and additional regulations.  Cognizant of regulatory impacts on small businesses, the Coast Guard sought to minimize these impacts by allowing businesses to integrate electronic TWIC inspection requirements into their existing PACS, to choose from a variety of biometric scanners that may be less expensive than those approved by the TSA and listed on the TSA's QTL and to have the option of designate a DRAA, a limited form of RUA, that could minimize the burden on business operations due to cumbersome and redundant electronic TWIC inspections. 

Costs of TWIC readers  -  Several commenters believe that the Coast Guard did not appropriately address the overall costs of TWIC readers, specifically the relatively high costs to set up a TWIC Reader system for small vessels and facilities.  Some commenters felt that they will be incurring significant expenses to outfit their vessels and facilities with them.  Some others stated that the NPRM RA overestimated the cost of TWIC readers.  We note that, in the final rule, small vessels were excluded from the electronic TWIC inspection requirement, so many of these concerns are mooted.  The Coast Guard believes that the increased flexibility of this final rule is the most cost-effective way to meet the goals of the TWIC program and serve the needs of small businesses.  Also, the Coast Guard updated cost estimates for the readers to reflect the current market costs of the readers, which are significantly less than those reported in the NPRM RA.  

Cumulative Impact of Regulations on Small Businesses  -  Some commenters warned of the cumulative economic impacts of this rulemaking with several other finalized rules across the Federal agencies.  However, these comments did not provide specific data or information on these cumulative economic impacts.  Also, several of the comments were beyond the scope of this rulemaking when discussing the TWIC program generally and the costs of acquiring, using and maintaining TWIC cards.

We made two changes to the Final Rule requirements as a result of public comments that will reduce the impact on small entities: 

   1. We are  allowing additional flexibility with regard to electronic readers; instead of requiring the use of a TWIC reader on the TSA's QTL, small businesses can choose to fully integrate electronic TWIC inspection and biometric matching into their existing PACS, and 
   2. We are increasing the exemption from electronic TWIC inspection requirements to vessels with 20 or fewer TWIC-holding crewmembers that will effectively remove all small entities that own and operate MTSA-regulated vessels.

As explained in the final rule, we used a risk-based approach to apply these regulatory requirements to less than 5 percent of the MTSA-regulated population, which represents approximately 80 percent of the potential consequences of a TSI.  The provisions in this final rule target the highest risk entities while minimizing the overall burden of the rule. We conducted a robust alternatives analysis that considered the "break-even" point of several different alternatives and we chose the alternative that shows the final rule will be cost effective if it prevents 1 TSI with every 222.8 years.

Therefore, the Coast Guard already sought to minimize the cumulative impacts on industry by applying the final rule to as small of a population of MTSA-regulated entities as reasonably possible, and by increasing the flexibility of integrating other readers to their existing access control systems. 

Please see Appendix F (Cumulative TWIC Programmatic Costs) of this RA for the final rule for a discussion of the cumulative impacts of two TWIC rulemakings (which are both Congressional mandates): TWIC Final Rule issued in 2007 and TWIC Reader Final Rule.  We estimate the cumulative annualized costs of TWIC regulations to be about $319.03 million in 2016.  This includes $296.53 million from the 2007 TWIC Final Rule and $22.5 million from the TWIC Reader final rule (estimates discounted at 7 percent).  As previously discussed, these estimates may overestimate costs due to unquantified cost savings from flexibility to affected entities that the final rule allows.

7.1.3 The response of the agency to any comments filed by the Chief Counsel for Advocacy of the Small Business Administration in response to the proposed rule, and a detailed statement of any change made to the proposed rule in the final rule as a results of the comments

The Coast Guard did not receive any comments from the SBA's Office of Advocacy regarding the impact that the proposed rule would have on small entities. 

7.1.4 A description of and an estimate of the number of small entities to which the rule will apply or an explanation of why no such estimate is available

The final rule will affect the owners and operators of certain MTSA-regulated facilities and vessels.  Based on the Coast Guard's MISLE database, we identified 525 facilities and 1 vessel affected by this rule that are owned by 307 unique owners and operators. 

We used available operator name and address information to research public and proprietary databases for entity type (subsidiary or parent company), primary line of business, employee size, revenue, and other information.  We matched this information to the SBA's "Table of Small Business Size Standards" (January 2013 version) to determine if an entity is small in its primary line of business as classified in the North American Industry Classification System (NAICS).

For each of the 60 NAICS-coded industries in the final rule's affected population, we show below the 10 industries that appeared most frequently in the affected population of facilities.  

Table 7.1 Ten Most Frequent Industries Affected by the Proposed Rule - Facilities
                                  NAICS Code
                                  Description
                          Count of Facility Companies
                                    486110
                    Pipeline Transportation of Crude Oil  
                                       9
                                    493190
                        Other Warehousing and Storage  
                                       9
                                    324110
                            Petroleum Refineries4  
                                       7
                                    561510
                              Travel Agencies10  
                                       6
                                    325110
                         Petrochemical Manufacturing  
                                       5
                                    325199
               All Other Basic Organic Chemical Manufacturing  
                                       5
                                    325998
   All Other Miscellaneous Chemical Product and Preparation Manufacturing  
                                       5
                                    483212
                    Inland Water Passenger Transportation  
                                       5
                                    336611
                         Ship Building and Repairing  
                                       4
                                    488320
                            Marine Cargo Handling  
                                       4
 

Of the 1 vessel that will require an electronic TWIC inspection program, we identified 1 unique owner.  Based on current data provided by the Coast Guard's MISLE database, we estimate that there are potentially 3,647 distinct owners and operators of 13,825 active U.S.-flagged, MTSA-regulated vessels; 2,046 distinct owners and operators of 3,270 MTSA-regulated facilities; and 19 unique owners and operators of 56 OCS facilities that could be affected by this final rule.  For this final rule, we estimated mandatory card reader requirement costs for 1 vessel and 525 facilities based on the risk assessment hierarchy.  OCS facilities are not considered high-risk for this final rule, and as such they are out of scope of this analysis, and therefore, we did not analyze the impact of the electronic TWIC inspection requirements on this population.  Of these 525 facilities that will be affected by the electronic TWIC inspection requirements, we found 306 unique owners.  Among these 306 entities, there were 31 government-owned entities, 275 businesses, and 0 not-for-profit entities.  Of the 275 businesses, there were 114 companies that exceeded SBA small business size standards, 88 companies considered small by the SBA, and 73 companies for which no information was available.  For the purposes of this analysis, we consider all entities for which information was not available to be small We also assume that each entity owns 2 facilities on average.  

We were able to find revenue information for 64 of the 88 businesses deemed small by SBA standards.  We then determined the impacts of the final rule on these companies by dividing the total costs of the regulation by the number of regulated entities to determine a cost per entity for the regulation.  We estimate these costs to be on average $195,715 per entity per year during the implementation period and $12,612 per entity in annual cost.  We base our impact analysis on average cost to regulated entities due to the increased flexibility afforded by this final rule to owners and operators of individual facilities so they can determine how best to implement electronic TWIC inspection requirements.  We then found what percent impact on revenue the proposed regulation will have based on implementation costs and annual costs.  Table 7.2 presents the impacts on small businesses that own and operate facilities during implementation and annually.

Table 7.2 Revenue Impacts on Affected Small Businesses - Facilities
                                       
                       Impacts from Implementation Costs
                           Impacts from Annual Costs
                            Revenue Impact Range 
                              Number of Entities
                              Percent of Entities
                              Number of Entities
                              Percent of Entities
                             0% < Impact <= 1%
                                      33
                                      52%
                                      57
                                      89%
                             1% < Impact <= 3%
                                       4
                                      6%
                                       6
                                      9%
                             3% < Impact <= 5%
                                       5
                                      8%
                                       0
                                      0%
                            5% < Impact <= 10%
                                       8
                                      13%
                                       1
                                      2%
                                   Above 10%
                                      14
                                      22%
                                       0
                                      0%
                                     Total
                                      64
                                     100%
                                      64
                                     100%
Note: Values may not total due to rounding.
      
The greatest impact will occur during the implementation phase when 48 percent of small businesses that we were able to find revenue data on will experience an impact of greater than 1 percent, and 22 percent of small businesses that we were able to find revenue data on will experience an impact greater than 10 percent.  After implementation, the impacts decrease and 89 percent of affected small businesses will see an impact of less than 1 percent.  We expect the revenue impacts for years with equipment replacement to be between those for implementation and annual impacts.  During those years with equipment replacement, we estimate that approximately 42% of businesses will encounter an impact greater than 1 percent, and 11% will see an impact greater than 10 percent. 

Of the 31 government jurisdictions that will be impacted by this final rule, 24 exceed the 50,000 population threshold to be considered small, and the other 7 have revenue levels such that there will not be an impact greater than 1% of revenue.

We found that for the 1 vessel that will be affected by this rule, the owner is not a small business.  Therefore, we do not provide a revenue impact analysis for affected small businesses-owned vessels as we provided above for affected facilities. 

7.1.5 A description of the projected reporting, recordkeeping and other compliance requirements of the rule, including an estimate of the classes of small entities which will be subject to the requirement and the type of professional skills necessary for preparation of the report or record

Under the provisions of the final rule, 525 affected facilities and 1 vessel will be required to update their FSPs and VSPs, and to create and maintain a system of recordkeeping within 2 years of the final rule's promulgation.  This requirement will be added to an existing collection of information with the OMB control number 1625-0077.  Please see Paperwork Reduction Act (Chapter 8) of this RA for a detailed description and discussion of reporting and recordkeeping requirements of the rule.   

7.1.6 A description of the steps the agency has taken to minimize the significant economic impact on small entities consistent with the stated objectives of applicable statutes, including a statement of the factual, policy, and legal reasons for selecting the alternative adopted in the final rule and why each one of the other significant alternatives to the rule considered by the agency which affect the impact on small entities was rejected

The Coast Guard has made two changes from the rule proposed by the NPRM after consideration of public comments. A full discussion of comments and Coast Guard responses is found in the Discussion of Comments and Changes to the Final Rule section of the final rule.  The Coast Guard took the following steps to minimize the economic impact on small entities: 1. allowing additional flexibility with regard to electronic readers; instead of requiring the use of a TWIC reader on the TSA's QTL, small businesses can choose to fully integrate electronic TWIC inspection and biometric matching into their existing PACS, and 2. increasing the exemption from electronic TWIC inspection requirements to vessels with 20 or fewer TWIC-holding crewmembers that will effectively remove all small entities that own and operate MTSA-regulated vessels.

We used managing owner and operator contact information from Coast Guard data to research public and proprietary business databases for entity ownership status (subsidiary, parent company, government entity, etc.), employee size, and revenue, among other information.  By using the SBA's size standards and the NAICS code classifications, we are able to determine whether a business is small or not.  The SBA provides business size standards for all sectors of the NAICS. 

The Coast Guard will not retaliate against small entities that question or complain about this rule or any policy or action of the Coast Guard.

Small businesses may send comments on the actions of Federal employees who enforce, or otherwise determine compliance with, Federal regulations to the Small Business and Agriculture Regulatory Enforcement Ombudsman and the Regional Small Business Regulatory Fairness Boards.  The Ombudsman evaluates these actions annually and rates each agency's responsiveness to small business.  If you wish to comment on actions by employees of the Coast Guard, call 1-888-REG-FAIR (1-888-734-3247).

8) Collection of Information  
This proposed rule calls for a collection of information under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520).  As defined in 5 CFR 1320.3(c), a "collection of information" comprises reporting, recordkeeping, monitoring, posting, labeling, and other similar actions.  The title and description of the information collection, a description of those who must collect the information, and an estimate of the total annual burden follow.  The estimate covers the time for reviewing instructions, searching existing sources of data, gathering and maintaining the data needed, and completing and reviewing the collection.  

Under the provisions of the final rule, the affected facilities and vessels will be required to update their Facility and Vessel Security Plans (FSPs and VSPs), and to create and maintain a system of recordkeeping within 2 years of promulgation.  This requirement will be added to an existing collection with OMB control number 1625-0077.  
      
TITLE:  Security Plans for Ports, Vessels, Facilities, Outer Continental Shelf (OCS) Facilities and Other Security-Related Requirements
      
OMB Control Number:  1625-0077
      
SUMMARY OF THE COLLECTION OF INFORMATION:  This information collection is associated with the maritime security requirements mandated by the MTSA.  Security assessments, security plans and other security-related requirements are found in 33 CFR Chapter I, subchapter H.  The final rule requires certain vessels and facilities to use electronic readers designed to work with the TWIC as an access control measure.  Affected owners and operators will also face requirements associated with electronic TWIC inspection programs, including recordkeeping requirements for those owners and operators required to implement an electronic TWIC inspection program, and security plan amendments to incorporate TWIC requirements.  
      
PROPOSED USE OF INFORMATION:  The Coast Guard will use this information to ensure that facilities and vessels are properly implementing and utilizing TWIC readers.

DESCRIPTION OF THE RESPONDENTS:  The respondents are owners and operators of certain vessels and facilities regulated by the Coast Guard under 33 CFR Chapter I, subchapter H.

NUMBER OF RESPONDENTS:  The number of respondents as a result of this final rule is 525 facilities that are considered high risk will be required to modify their existing FSPs, and 1 vessel will be required to modify their VSPs to account for the electronic TWIC inspection requirements.  These same populations will be required to create and maintain recordkeeping systems as well. 

FREQUENCY OF RESPONSE:  The FSP and VSP will need to be amended once within 2 years of promulgation to include electronic TWIC inspection-related procedures.  Recordkeeping requirements will need to be met along a similar timeline.
      
BURDEN OF RESPONSE:  The estimated burden for facilities will be 17,063 in the first year, 18,638 hours in the second year, and 3,150 hours in the third year and all subsequent years.  The burden for vessels will be 65 burden hours in year 1, and 6 burden hours for all subsequent years.  This includes an estimated 25-hour burden to amend the FSP or VSP, along with an implementation period burden of 40 hours and an annual burden of 6 hours for recordkeeping for each facility or vessel, which includes recordkeeping costs associated with the TSA's CCL.  
      
ESTIMATE OF TOTAL ANNUAL BURDEN:  

Facilities:  The estimated burden over the 2-year implementation period for facilities is 25 hours per FSP amendment.  Since there are currently 525 facilities that will need to amend their FSPs, the total burden on facilities will be 13,125 hours (525 FSPs x 25 hours per amendment) during the 2-year implementation period, or 6,563 hours each year of the first 2 years.  Facilities will also face a recordkeeping burden of 21,000 hours during the 2-year implementation period (525 facilities x 40 hours per recordkeeping system), or 10,500 hours each year over the first 2 years.  There will also be an annual recordkeeping burden of 3,150 hours (525 facilities x 6 hours per year), starting in the third year.  In the second year, the 262 facilities that implemented in the first year will incur the 6 hours of annual recordkeeping, at a burden of 1,572 (262 facilities x 6 hours).  The total burden for facilities is estimated at 17,063 (6,563 + 10,500) in Year 1, 18,638 in Year 2 (6,563 + 10,500 + 1,575), and 3,150 in Year 3.  

Vessels:  For the 1vessel, the burden in the first year will be 25 hours (1 VSP x 25 hour per amendment).  The vessel will also face a recordkeeping burden of 40 hours during the 1-year implementation period (1 vessel x 40 hours per recordkeeping system).  There will also be an annual recordkeeping burden of 6 hours starting in year 2 (1 vessel x 6 hours per year).  The total burden for vessels is estimated at 65 (25 + 40) in Year 1 and 6 hours in Years 2 and 3.     

Total:  The total additional burden from the final rule is estimated at 17,128 (65 for vessels + 17,063 for facilities) in Year 1, 18,644 (6 for vessels + 18,638 for facilities) in Year 2, and 3,156 (6 for vessels + 3,150 for facilities) in Year 3.  The current annual burden listed in this collection of information is 1,108,043.  The new burden, as a result of this final rule, in Year 1 is 1,125,171 (1,108,043 + 17,128).  In Year 2 the new burden is 1,126,687 (1,108,043 + 18,644) and in Year 3 it is 1,111,199 (1,108,043 + 3,156).  The average annual additional burden across the 3 years is 12,976.

As required by the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)), we have submitted a copy of this proposed rule to the OMB for its review of the collection of information.

You need not respond to a collection of information unless it displays a currently valid control number from OMB.  Before the requirements for this collection of information becomes effective, we will publish a notice in the Federal Register of OMB's decision to approve, modify, or disapprove the proposed collection.
Appendix A: Baseline Matrix

                                    Section
                                     Topic
                              Regulatory Language
                                    Impact
                                    101.105
                                  Definitions
                                Add Definitions
                   No cost. Administrative: new definitions.
                                  101.112(a)
                                  Federalism
(a)  The regulations in 33 CFR parts 101, 103, 104, and 106 have preemptive effect over State or local regulation within the same field.
                    No cost. Administrative: clarification.
                                  101.112(b)
                                  Federalism
(b)  The regulations in 33 CFR part 105 have preemptive effect over State or local regulations insofar as a State or local law or regulation applicable to the facilities covered by part 105 would conflict with the regulations in part 105, either by actually conflicting or frustrating an overriding Federal need for uniformity.
                    No cost. Administrative: clarification.
                                    101.514
                                  Requirement
                             Remove § 101.514(e)
                No cost. Administrative: editorial realignment.
                                 101.515(d)(2)
                         TWIC/Personal Identification
Each person who has been issued or who possesses a TWIC must pass an electronic TWIC inspection and must submit his or her reference biometric, such as a fingerprint, and any other required information, such as a Personal Identification Number (PIN), upon a request from TSA, the Coast Guard, any other authorized DHS representative, or a Federal, State, or local law enforcement officer.
                      Text Modified, but no cost impact.
                                   101.520 
                          Electronic TWIC inspection
To conduct an electronic TWIC inspection, the owner or operator of a vessel or facility must ensure the following actions are performed. (a) Card Authentication: The TWIC must be authenticated by performing a change/response protocol using the Card Authentication Certificate (CAC) and the associated card authentication private key stored in the TWIC. (b) Card Validity Check: the TWIC must be checked against TSA's Canceled Card List (CCL), and no match on the CCL may be found; (c) Identity Verification: (1) one of the fingerprint templates stored in the TWIC must be matched to the TWIC-holder's live sample biometric; or (2) the TWIC-holder must enter the Personal Identification Number with the TWIC, and pass a visual TWIC inspection. 
Costs associated with the acquisition and installation and integration of TWIC readers to current access control systems for facilities and vessels detailed in RA.
                                  101.525(a)
                                       
                           Canceled Card List (CCL)
                                MARSEC Level 1
At Maritime Security (MARSEC) Level 1, the card validity check must be conducted using CCL information that is no more than 7 days old.
Costs associated with obtaining, installing, and operating TWIC Readers, as well as recordkeeping, training, and amendments to security plans, as detailed in RA.
                              101.525(b) and (c) 
                                       
                                       
                           Canceled Card List (CCL)
                             MARSEC Level 2 and 3
At these MARSEC Levels, the same procedures outlined in paragraph (a) of this section must be used, except that the card validity check must use CCL information that is no more than 1 day old.
    No estimated cost impact due to infrequency of changes in MARSEC level.
                                  101.525(d)
                                       
                                       
The CCL information used to conduct the card validity check must be updated within 12 hours of any increase in MARSEC level, no matter when the information was last updated.
No estimated cost impact due to infrequency and localized nature of changes in MARSEC level.
                                  101.525(e)
                                       
                                       
Only the most recently obtained CCL information must be used to conduct card validity checks.
        Costs associated with updating the CCL, as detailed in the RA..
                                    101.530
                      PACS Requirements for Risk Group A
This section lays out the requirements for PACS that may be used to meet the electronic TWIC inspection requirements of § 101.520.
Since this section will supersede the guidance in PAC 08-09, there will be no new costs.
                                    101.535
           Electronic TWIC inspection requirements for Risk Group A
Owners or operators of any vessel or facility subject to part 104 or 105 of this subchapter, that are assigned to Risk Group A in §§ 104.263 or 105.253 of this subchapter, must ensure that a Transportation Worker Identification Credential (TWIC) program is implemented as follows:
                                       
                                  101.535(a)
                     Requirements for Risk Group A Vessels
Prior to each boarding of the vessel, all persons who require access to a secure area of the vessel must pass an electronic TWIC inspection before being granted unescorted access to the vessel.

No new cost since electronic TWIC inspection costs are already covered in 101.525 above for vessels. 
                                  101.535(b)
                  Requirements for Risk Group A Facilities 

Prior to each entry into a secure area of the facility, all persons must pass an electronic TWIC inspection before being granted unescorted access to secure areas of the facility.
No new cost since electronic TWIC inspection costs are already covered in 101.525 above for facilities.
                                  101.535(c)
                                       
(c)  A Physical Access Control System that meets the requirements of § 101.530 of this subpart may be used to meet the requirements of this section.
Potential cost savings if vessels or facilities could comply with electronic TWIC inspection requirements by using their existing PACS.
                                  101.535(d)
                                       
(d)  The requirements of this section do not apply under certain situations described in §§ 101.550 or 101.555 of this subpart.
                   No cost. Administrative: clarifications.
                                  101.535(e)
                                       
(e)  Emergency access to secure areas, including access by law enforcement and emergency responders, does not require electronic TWIC inspection.
                             Current requirement.
                                    101.540
Electronic TWIC inspection requirements for vessels, facilities, and OCS facilities not in Risk Group A
A vessel or facility not in Risk Group A may use the electronic TWIC inspection requirements of § 101.535 of this subpart in lieu of visual TWIC inspection. If electronic TWIC inspection is used, the recordkeeping requirements of §§ 104.235(b)(9) and (c) of this subchapter, or 105.225(b)(9) and (c) of this subchapter, as appropriate, apply. 
No cost as no non-Risk Group A vessel or facility is expected to choose this alternative. 
                                    101.550
             TWIC inspection requirements in special circumstances
Owners or operators of any vessel, facility, or Outer Continental Shelf (OCS) facility subject to part 104, 105 or 106 of this subchapter must ensure a Transportation Worker Identification Credential (TWIC) program is implemented as follows:
                                       
                                  101.550 (a)
                                       
(a) Lost, Damaged or Stolen TWIC. If an individual cannot present a TWIC because it has been lost, damaged or stolen, and the individual previously has been granted unescorted access to secure areas and is known to have had a TWIC, the individual may be granted unescorted access to secure areas for a period of no longer than 30 consecutive calendar days if 
(1) The individual has reported the TWIC as lost, damaged, or stolen to the Transportation Security Administration (TSA) as required in 49 CFR 1572.19(f);
(2) The individual can present another identification credential .that meets the requirements of § 101.515 of this subpart; and
(3) There are no other suspicious circumstances associated with the individual's claim that the TWIC was lost, damaged, or stolen.
                                       
                               Current practice.
                                  101.550 (b)
                                       
(b) TWIC on the Canceled Card List. In the event an individual reports his or her TWIC as lost, damaged or stolen, and that TWIC is then placed on the CCL, the individual may be granted unescorted access by a Physical Access Control System (PACS) that meets the requirements of § 101.530 of this subpart for a period of no longer than 30 days. The individual must be known to have had a TWIC, and known to have reported the TWIC as lost, damaged, or stolen to TSA
                    No cost. Administrative: Clarification.
                                  101.550 (c)
                                       
(c) Special Requirements for Risk Group A Vessels and Facilities. If a TWIC reader or PACS cannot read an individual's fingerprints due to poor fingerprint quality or no fingerprint minutiae, the owner or operator may grant the individual unescorted access to secure areas based on secondary authentication procedures: 
(1) The owner or operator must conduct a visual TWIC inspection and require the individual to provide his or her Personal Identification Number.
(2) The owner or operator may require the person to present an alternative biometric that has been incorporated into the PACS. 
                    No cost. Administrative: Clarification.
                                  101.550 (d)
                                       
(d) If an individual cannot present a TWIC for any reason other than those outlined in paragraphs (a) or (b) of this section, the vessel or facility operator may not grant unescorted access to secure areas. The individual must be under escort at all times within the secure area.
                   No cost. Administrative: Clarification. 
                                  101.550 (e)
                                       
(e) With the exception of individuals granted access according to paragraph (a) or (b) of this section, all individuals granted unescorted access to secure areas of a vessel, facility, or OCS facility must be able to produce their TWICs upon request from the TSA, the Coast Guard or another authorized DHS representative, or a Federal, State or local law enforcement officer.
                    No cost. Administrative: Clarification.
                                  101.550 (f)
                                       
 (f) There must be disciplinary measures in place to prevent fraud and abuse.
                    No cost. Administrative: Clarification.
                                  101.550 (g)
                                       
(g) Owners or operators must establish the frequency of the application of any security measures for access control in their approved security plans, particularly if these security measures are applied on a random or occasional basis.
                   No cost. Administrative: Clarification. 
                                  101.550 (h)
                                       
(h) The vessel, facility or OCS facility operator should coordinate the TWIC Program, when practical, with identification and TWIC access control measures of other entities that interface with vessel, facility or OCS facility.
                    No cost. Administrative: Clarification.
                                    101.555
      Recurring Unescorted Access for Risk Group A vessels and facilities
This section describes how designated TWIC-holders may access certain secure areas on Risk Group A vessels and facilities on a continual and repeated basis without undergoing repeated electronic TWIC inspections.
                                       
                                  101.555 (a)
                                       
Definition of a Designated Recurring Access Area (DRAA) according to approved security plan, whether there are security personnel at the access points, whether those requesting Recurring Unescorted Access possess TWICs, and whether the personnel have passed an electronic TWIC inspection in the presence of the on-scene security personnel.
                  No cost. Administrative: Editorial change. 
                                  101.555 (b)
                                       
(b) The following requirements apply to DRAA:  (1) It must consist of an unsecured area where personnel will be moving into an adjacent secure area repeatedly. (2) The entire DRAA must be visible to security personnel. (3) During operation as a DRAA, there must be security personnel present at all times.
                                       
                   No cost. Administrative: Clarification. 
                                  101.555 (c)
                                       
(c) An area may operate as a DRAA during certain times, and during other times, access to secure areas may be obtained through the procedures in § 101.535 of this subpart.
                   No cost. Administrative: Clarification. 
                                  101.555 (d)
                                       
(d) Personnel may enter the secure areas adjacent to a DRAA at any time using the procedures in § 101.535 of this subpart.
                   No cost. Administrative: Clarification. 
                                  103.505 (f)
              Elements of the Area Maritime Security (AMS) Plan 
              Remove extraneous parenthetical reference to TWIC.
                          No cost. Editorial change.
                                    104.105
                                 Applicability
                                       
                   No cost. Administrative: Clarification. 
                                    104.110
                                  Exemptions
(c) Vessels with a minimum manning requirement of 20 or fewer TWIC-holding crewmembers are exempt from the requirements in 33 CFR 101.535(a)(1).
No new cost since electronic TWIC inspection costs are already covered in 101.525 above for vessels.
                                    104.115
                                  Compliance
                                       
                                       
                                  104.115 (c)
                                       
(c)  By (2 YEARS AFTER DATE OF PUBLICATION OF FINAL RULE), owners and operators of vessels subject to this part must amend their vessel security plans to indicate how they will implement the TWIC requirements in this subchapter.  By (2 YEARS AFTER DATE OF PUBLICATION OF FINAL RULE), owners and operators of vessels subject to this part must operate in accordance with the TWIC provisions found within this subchapter.
           Costs analyzed in RA are based on 2 year implementation.
                                  104.115 (d)
                                       
        Remove text describing a deadline which passed April 16, 2009.
                          No cost. Editorial change.
                                    104.120
                                 Amended text
                                 Definitional
                          No cost. Editorial change.
                                   104.125 
                                 Amended text
                                 Definitional
                          No cost. Editorial change.
                                    104.235
                       Vessel recordkeeping requirements
                                       
                                       
                                 104.235(b)(9)
                            Electronic Reader/PACS
For each individual granted unescorted access to a secure area, the: FASC-N; date and time that unescorted access was granted; and, if captured, the individual's name. Additionally, documentation to demonstrate that the owner or operator has updated the CCL with the frequency required in § 101.525 of this subchapter.
            Costs associated with recordkeeping assessed in the RA.
                                    104.263
                    Risk Group classifications for vessels
                                       
                                       
                                  104.263 (a)
                                       
(a) For purposes of the TWIC requirements of this subchapter, the following vessels subject to this part are in Risk Group A:

(1) Vessels that carry Certain Dangerous Cargoes (CDC) in bulk. 

(2) Vessels certificated to carry more than 1,000 passengers.

(3) Any vessel engaged in towing a vessel subject to paragraph (a)(1) or paragraph (a)(2) of this section.
                    No cost associated with classification.
                                  104.263 (b)
                                       
(b) Vessels may move from one Risk Group classification to another, based on the cargo they are carrying or handling at any given time. An owner or operator expecting a vessel to move between Risk Groups must explain, in the Vessel Security Plan, the timing of such movements, as well as how the vessel will move between the requirements of the higher and lower Risk Groups, with particular attention to the security measures to be taken moving from a lower risk group to a higher Risk Group.
           No cost associated with classification. Optional action.
                                    104.267
                  Security measures for newly hired employees
Remove final sentence of paragraph (a), which promises Coast Guard guidance on the issue.
                          No cost. Editorial change. 
                                  104.405 (b)
                   Format of the vessel security plan (VSP)
                Removes a deadline that passed March 27, 2007.
                          No cost. Editorial change.
                                    104.410
                                    Amended
                Removes deadlines that passed January 1, 2004.
                          No cost. Editorial change.
                                  105.110(b)
                                  Exemptions
A public access area designated under §105.106 of this subpart is exempt from the requirements for screening of persons, baggage, and personal effects and identification of persons in subpart E of part 101 of this subchapter, as applicable, in § 105.255 of this part, and in § 105.285(a)(1) of this part.
                    No cost. Administrative: Clarification.
                                  105.110(e)
                                  Exemptions
Barge fleeting facilities without shore side access are exempt from the requirements in 33 CFR 101.535(b)(1).
                    No cost affiliated with classification.
                                    105.115
                                  Compliance
                                       
                                       
                                  105.115 (d)
                                       
By (2 YEARS AFTER DATE OF PUBLICATION OF FINAL RULE), owners and operators of facilities subject to this part must amend their facility security plans to indicate how they will implement the TWIC requirements in this subchapter.  By (2 YEARS AFTER DATE OF PUBLICATION OF FINAL RULE), owners and operators of facilities subject to this part must be operating in accordance with the TWIC provisions found within this subchapter. 
                 Costs analyzed based on 2 year implementation
                                    105.120
                                    Amended
                 Removes a deadline that passed July 2, 2004.
                          No cost. Editorial change.
                                    105.225
                      Facility recordkeeping requirements
                                       
                                       
                                105.225 (b)(9)
                                       
Electronic Reader/PACS. For each individual granted unescorted access to a secure area, the: FASC-N; date and time that unescorted access was granted; and, if captured, the individual's name. Additionally, documentation to demonstrate that the owner or operator has updated the CCL with the frequency required in § 101.520 of this subchapter.
            Costs associated with recordkeeping assessed in the RA.
                                    105.253
                   Risk Group classifications for facilities
                                       
                                       
                                  105.253 (a)
                                       
For purposes of the TWIC requirements of this subchapter, the following facilities subject to this part are in Risk Group A:

(1)  Facilities, that handle Certain Dangerous Cargoes (CDC) in bulk or receive vessels carrying CDC in bulk.

(2)  Facilities that receive vessels certificated to carry more than 1,000 passengers.

                    No cost associated with classification.
                                  105.253 (b)
                                       
Facilities may move from one Risk Group classification to another, based on the material they handle or the types of vessels they receive at any given time. An owner or operator of a facility expected to move between Risk Groups must explain, in the Facility Security Plan, the timing of such movements, as well as how the facility will move between the requirements of the higher and lower Risk Groups, with particular attention to the security measures to be taken when moving from a lower Risk Group to a higher Risk Group.
          No cost associated with classification. Optional practice.
                                    105.257
                                    Amended
                                 Definitional
                          No cost. Editorial change.
                                    105.290
                                    Amended
                                 Definitional
                          No cost. Editorial change.
                                105.296 (a)(4)
                                    Amended
                                 Definitional
                          No cost. Editorial change.
                                    105.405
            Format and content of the Facility Security Plan (FSP)
                                       
                                       
                                105.405 (a)(10)
                                       
Security measures for access control, including the facility's TWIC program and designated public access areas;
                    Cost associated with the update of FSP.
                                      106
         Maritime Security - Outer Continental Shelf (OCS) Facilities
                                       
                   No cost.  No reader requirements for OCS.
                                  106.110 (c)
                               Compliance dates
By (2 YEARS AFTER DATE OF PUBLICATION OF FINAL RULE), owners and operators of OCS facilities subject to this part must amend their facility security plans to indicate how they will implement the TWIC requirements in this subchapter.  By (2 YEARS AFTER DATE OF PUBLICATION OF FINAL RULE), owners and operators of OCS facilities subject to this part must be operating in accordance with the TWIC provisions in this subchapter.
    No cost. No electronic TWIC inspection requirements for OCS facilities.
                                    106.200
                               Owner or operator
                       Introduction to 106.200 sections
                          No cost. Editorial changes.
                                    106.258
                 Risk Group classifications for OCS facilities
For purposes of this subchapter, no OCS facilities are considered Risk Group A.
              No cost. No reader requirements for OCS facilities.
                                    106.262
                  Security measures for newly-hired employees
  Removes statement that the Coast Guard will issue guidance on the subject.
                          No cost. Editorial change.
                                106.405 (a)(10)
                     Format of the Facility Security Plan
Security measures for access control, including the OCS facility's TWIC program;
    No cost. No electronic TWIC inspection requirements for OCS facilities.

Appendix B: TWIC Pilot Participants

                                  Location  
                               Participant Name  
                                Industry Group  
                    Port Authority of New York/New Jersey  
                             Staten Island Ferry  
                            Small Passenger Vessel/
                                Towboat/Other  
                    Port Authority of New York/New Jersey  
                                 APM Terminal  
                              Container Terminal  
                    Port Authority of New York/New Jersey  
                                Maher Terminal  
                              Container Terminal  
                    Port Authority of New York/New Jersey  
                           Brooklyn Marine Terminal  
                              Container Terminal  
                                Annapolis, MD  
                              Watermark Cruises  
                            Small Passenger Vessel/
                                Towboat/Other  
                                Vicksburg, MS  
                          Magnolia Marine Transport  
                             Small Passenger Vessel
                                Towboat/Other  
                                  Norco, LA  
                              Shell Chemical LP  
                             Petroleum Facilities  
                               Brownsville, TX  
                             Port of Brownsville  
                              Container Terminal  
                              Port of Long Beach  
                                      BP  
                             Petroleum Facilities  
                              Port of Long Beach  
                        Metropolitan Stevedore Company  
                                  Break-Bulk  
                              Port of Long Beach  
                        Total Terminals International  
                              Container Terminal  
                              Port of Long Beach  
                                  Sea Launch  
                            Small Passenger Vessel/
                                Towboat/Other  
                              Port of Long Beach  
                                  SSAMarine  
                              Container Terminal  
                             Port of Los Angeles  
                                NuStar Energy  
                             Petroleum Facilities  
                             Port of Los Angeles  
                             World Cruise Center  
                               Large Passenger  
                             Port of Los Angeles  
                                     APL  
                              Container Terminal  
                                 Seattle, WA  
                              Clipper Navigation  
                            Small Passenger Vessel/
                                Towboat/Other  

Appendix C: Reader Cost Information

To estimate the average cost of TWIC reader hardware and software, we used the GSA schedule to find the current market prices for TWIC reader hardware and software for models listed on the QTL List.  Although price information was not available for all models on the QTL List, we were able to obtain a sample of reader hardware and software prices to use in our analysis.  

The current QTL List is available at https://universalenroll.dhs.gov/permalinks/static/twic-reader-qtl. 
	
Prices for items on the GSA schedule can be found at: https://www.gsaadvantage.gov (with a search term of "TWIC" for TWIC readers or "Transparent Reader with Biometric" for other readers).  These prices were researched January 2, 2014, however, these prices may have changed since our research.

For purposes of comparison, we provide a sample of equipment costs that were provided on TSA's ICE List in 2013 when we estimated reader costs for the NPRM RA.  However, TSA discontinued the publication of ICE List.   


Figure C1: ICE List Approved TWIC Readers  -  Hardware Price
                                    Company
                                 Reader Model
                                Fixed/
Portable
                             Contact/
Contactless
                                Hardware Price
                                  Innometriks
                            RHINO-XSI-TWIC-OUTDOOR
                                     Fixed
                                  Contactless
                                    $3,086
                                  Morpho Trak
                                    MA120w
                                     Fixed
                                  Contactless
                                    $1,186

                                     MA521
                                     Fixed
                                  Contactless
                                    $1,729

                                OMA521 Outdoor
                                     Fixed
                                  Contactless
                                    $2,265
                                       
                                       
                                       
                                       
                                       
                                   Datastrip
                  DSV2+turbo-Hybrid,TWICcheck + Mobile/Audit
                                   Portable
                                     Both
                                    $10,049

                  DSV2+turbo-Hybrid,TWICcheck + Mobile/Audit
                                   Portable
                                     Both
                                    $6,402

                                   DSV II SC
                                   Portable
                                     Both
                                    $1,969

                                   DSV II SC
                                   Portable
                                     Both
                                    $3,467
                                   Mobilisa
                                    IM2700
                                   Portable
                                       
                                    $7,999
                                PSION Teklogix
                                 Workabout Pro
                                   Portable
                                  Contactless
                                    $2,837
                                  CrossMatch
                                  Be.U Mobile
                                   Portable
                                       
                                    $2,134



Figure C2: ICE List Approved TWIC Readers  -  Software Price
                                    Company
                                       
                             Codebench CoreStreet
                                       
                                  Price Point
                                   OMNICheck
                                   PIVCheck
                                   TWICCheck
                                   Portable
                                      Low
                                    $2,438
                                    $5,600
                                    $3,244

                                    Middle
                                       
                                   $6,746 
                                    $5,869

                                     High
                                    $3,314
                                    $7,830
                                    $8,055
                                       
                                       
                                       
                                       
                                       
                                     Fixed
                                      Low
                                       
                                    $4,450
                                       

                                     High
                                       
                                   $7,830 
                                       

Figure C3: Sample of Other Biometric Readers from GSA Schedule
                                    Company
                                 Reader Model
                                Fixed/
Portable
                         Hardware & Software Price
                                     XTec
                    Basic Enrollment Station (X040000-BES)
                                     Fixed
                                    $7,501
                               Quintron Systems
                             2 Reader HSPD12 PACS
                                     Fixed
                                    $5,283
                                     Telos
                    Biometrics Indoor Hand Geometry Reader
                                     Fixed
                                    $4,450
                                     TAPCO
                     Turnstile, Waist Catrax Master Model
                                     Fixed
                                    $4,259
                                       
                                       
                                       
                                       
                                     Telos
                    Biometric Outdoor Hand Geometry Reader
                                   Portable
                                    $6,250
                                      MDI
                        Biometric Hand Geometry Reader
                                   Portable
                                    $3,840
                                Amag Technology
                           4 Reader Biometric M2000
                                   Portable
                                    $2,453

Figure C4: Qualified Technology List (QTL) TSA Approved TWIC Readers 
                                    Company
                                 Reader Model
                                Fixed/
Portable
                                   Hardware
                                     Price
                                Software Price
                             Intellicheck Mobilisa
                            Fugitive Finder IM2610
                                   Portable
                                    $5,200*
                                       -
                             Intellicheck Mobilisa
                            Fugitive Finder IM2610
                                   Portable
                                    $5,470*
                                       -
                                  Morpho Trak
                               Morpho Check 200
                                   Portable
                                    $4,353
                                    $3,805

                               Morpho Check 250
                                   Portable
                                    $5,507
                                    $3,805
                                       
                                       
                                       
                                       
                                       
                              Schneider Electric
                                    PC3-TBR
                                     Fixed
                                    $6,600*
                                       -
* Includes software price.



Appendix D: Capital Costs Per Reader

This appendix shows the inputs and calculations used to determine the cost per reader for installation, infrastructure and PACS costs, as specified in the TWIC Pilot Program Final Report.  For our analysis, participant category `Small Passenger Vessel/Towboat/Other' has been broken down into two categories; Small Passenger and Mixed Use.  Participants 1 and 3 comprise the Small Passenger group and participants 2 and 4 comprise the Mixed Use group.

                   Figure D1: Installation Costs per Reader
                                  Participant
                                   Category
                               TWIC Readers (A)
                      Installation/ Integration Costs (B)
                           Cost Per Reader = (B)/(A)
                                       1
                                   Petroleum
                                      15
                                    $80,133
                                    $5,342
                                       2

                                      15
                                   $142,500
                                    $9,500
                                       3

                                       1
                                    $4,000
                                    $4,000
                              Average Bulk Liquid
                                      10
                                    $75,544
                                    $6,281
                                       1
                                  Break-Bulk
                                      15
                                    $50,000
                                    $3,333
                                       2

                                       4
                                    $12,000
                                    $3,000
                                       3

                                       6
                                    $81,661
                                    $13,610
                              Average Break-Bulk
                                       8
                                    $47,887
                                    $6,648
                                       1
                                   Container
                                      21
                                   $467,099
                                    $22,243
                                       2

                                       6
                                    $50,000
                                    $8,333
                                       3

                                      11
                                    $50,000
                                    $4,545
                                       4

                                      13
                                   $645,500
                                    $49,654
                                       5

                                      39
                                   $724,925
                                    $18,588
                               Average Container
                                      18
                                   $387,505
                                    $20,673
                                       1
                            Large Passenger Vessel
                                       5
                                    $9,933
                                    $1,987
                                       2

                                      27
                                   $106,836
                                    $3,957
                            Average Large Passenger
                                      16
                                    $58,385
                                    $2,972
                                      1*
                    Small Passenger Vessel/ Towboat/ Other
                                       2
                                      $0
                                      $0
                                       2

                                       2
                                      $0
                                      $0
                                      3*

                                       2
                                      $0
                                      $0
                                       4

                                       7
                                   $455,060
                                    $65,009
                            Average Small Passenger
                                       2
                                      $0
                                      $0
                               Average Mixed Use
                                       4
                                   $227,530
                                    $32,504

Figure D2: Infrastructure Costs per Reader
                                  Participant
                                   Category
                               TWIC Readers (A)
                           Infrastructure Costs 
(B)
                           Cost Per Reader = (B)/(A)
                                       1
                                   Petroleum
                                      15
                                   $162,440
                                    $10,829
                                       2

                                      15
                                   $301,000
                                    $20,067
                                       3

                                       1
                                    $2,000
                                    $2,000
                              Average Bulk Liquid
                                      10
                                   $155,147
                                    $10,965
                                       1
                                  Break-Bulk
                                      15
                                   $711,583
                                    $47,439
                                       2

                                       4
                                    $8,000
                                    $2,000
                                       3

                                       6
                                   $196,376
                                    $32,729
                              Average Break-Bulk
                                       8
                                   $305,320
                                    $27,389
                                       1
                                   Container
                                      21
                                   $216,494
                                    $10,309
                                       2

                                       6
                                    $15,463
                                    $2,577
                                       3

                                      11
                                    $90,000
                                    $8,182
                                       4

                                      13
                                   $400,000
                                    $30,769
                                       5

                                      39
                                   $592,893
                                    $15,202
                               Average Container
                                      18
                                   $262,970
                                    $13,408
                                       1
                            Large Passenger Vessel
                                       5
                                      $0
                                      $0
                                       2

                                      27
                                   $391,396
                                    $14,496
                            Average Large Passenger
                                      16
                                   $195,698
                                    $7,248
                                      1*
                    Small Passenger Vessel/ Towboat/ Other
                                       2
                                      $0
                                      $0
                                       2

                                       2
                                      $0
                                      $0
                                      3*

                                       2
                                      $0
                                      $0
                                       4

                                       7
                                   $350,000
                                    $50,000
                            Average Small Passenger
                                       2
                                      $0
                                      $0
                               Average Mixed Use
                                       4
                                   $175,000
                                    $25,000


Figure D3: PACS Costs per Reader
                                  Participant
                                   Category
                               TWIC Readers (A)
                                PACS Costs (B)
                           Cost Per Reader = (B)/(A)
                                       1
                                   Petroleum
                                      15
                                   $272,836
                                    $18,189
                                       2

                                      15
                                   $103,500
                                    $6,900
                                       3

                                       1
                                      $0
                                      $0
                              Average Bulk Liquid
                                      10
                                   $125,445
                                    $8,363
                                       1
                                  Break-Bulk
                                      15
                                   $150,000
                                    $10,000
                                       2

                                       4
                                   $138,625
                                    $34,656
                                       3

                                       6
                                   $120,983
                                    $20,164
                              Average Break-Bulk
                                       8
                                   $136,536
                                    $21,607
                                       1
                                   Container
                                      21
                                   $184,342
                                    $8,778
                                       2

                                       6
                                   $138,625
                                    $23,104
                                       3

                                      11
                                   $138,625
                                    $12,602
                                       4

                                      13
                                   $713,190
                                    $54,861
                                       5

                                      39
                                   $646,707
                                    $16,582
                               Average Container
                                      18
                                   $364,298
                                    $23,186
                                       1
                            Large Passenger Vessel
                                       5
                                      $0
                                      $0
                                       2

                                      27
                                    $80,283
                                    $2,973
                            Average Large Passenger
                                      16
                                    $40,142
                                    $1,487
                                      1*
                    Small Passenger Vessel/ Towboat/ Other
                                       2
                                      $0
                                      $0
                                       2

                                       2
                                      $0
                                      $0
                                      3*

                                       2
                                      $0
                                      $0
                                       4

                                       7
                                    $69,000
                                    $9,857
                            Average Small Passenger
                                       2
                                      $0
                                      $0
                               Average Mixed Use
                                       4
                                    $34,500
                                    $4,929


Appendix E: BLS Wages for NAICS 483000, May 2012

U.S. Bureau of Labor Statistics 
Occupational Employment Statistics http://www.bls.gov/oes/current/naics3_483000.htm 
May 2012 National Industry-Specific Occupational Employment and Wage Estimates NAICS 483000 - Water Transportation 
These national industry-specific occupational employment and wage estimates are calculated with data collected from employers of all sizes, in metropolitan and nonmetropolitan areas in every State and the District of Columbia, in NAICS 483000 - Water Transportation. 
Additional information, including the hourly and annual 10th, 25th, 75th, and 90th percentile wages, percent of establishments reporting the occupation, and the employment percent relative standard error, is available in the downloadable XLS files. 
SOC Major Groups in NAICS 483000 - Water Transportation: 
   * 00-0000 All Occupations 
   * 11-0000 Management Occupations 
   * 13-0000 Business and Financial Operations Occupations 
   * 15-0000 Computer and Mathematical Occupations 
   * 17-0000 Architecture and Engineering Occupations 
   * 23-0000 Legal Occupations 
   * 27-0000 Arts, Design, Entertainment, Sports, and Media Occupations 
   * 29-0000 Healthcare Practitioners and Technical Occupations 
   * 33-0000 Protective Service Occupations 
   * 35-0000 Food Preparation and Serving Related Occupations 
   * 37-0000 Building and Grounds Cleaning and Maintenance Occupations 
   * 39-0000 Personal Care and Service Occupations 
   * 41-0000 Sales and Related Occupations 
   * 43-0000 Office and Administrative Support Occupations 
   * 47-0000 Construction and Extraction Occupations 
   * 49-0000 Installation, Maintenance, and Repair Occupations 
   * 51-0000 Production Occupations 
   * 53-0000 Transportation and Material Moving Occupations 

Table E1: NAICS 483000 - Water Transportation 

                                Occupation code
                               Occupation title
                                  Employment
                               % of total empl.
                              Median hourly wage
                               Mean hourly wage
                               Annual mean wage
                                 Mean wage RSE
00-0000
All Occupations
                                                                      5,081,510
                                                                        100.00%
                                                                        $19.29 
                                                                        $21.72 
                                                                       $45,170 
                                                                          0.40%
11-0000
Management Occupations
                                                                        166,190
                                                                          3.27%
                                                                        $41.27 
                                                                        $47.96 
                                                                       $99,750 
                                                                          0.50%
11-1000
Top Executives
                                                                         67,120
                                                                          1.32%
                                                                        $45.08 
                                                                        $53.36 
                                                                      $110,990 
                                                                          0.70%
11-1011
Chief Executives
                                                                          4,370
                                                                          0.09%
                                                                        $76.16 
                                                                        $81.22 
                                                                      $168,940 
                                                                          1.50%
11-1021
General and Operations Managers
                                                                         62,740
                                                                          1.23%
                                                                        $43.91 
                                                                        $51.42 
                                                                      $106,950 
                                                                          0.70%
11-2020
Advertising, Marketing, Promotions, Public Relations, and Sales Managers
                                                                          9,770
                                                                          0.19%
                                                                        $47.90 
                                                                        $53.05 
                                                                      $110,350 
                                                                          1.00%
11-2021
Advertising and Promotions Managers
                                                                             70
                                                                             -7
                                                                        $42.40 
                                                                        $47.14 
                                                                       $98,060 
                                                                          6.50%
11-2022
Marketing and Sales Managers
                                                                          9,400
                                                                          0.18%
                                                                        $47.74 
                                                                        $52.94 
                                                                      $110,120 
                                                                          1.10%
11-2031
Marketing Managers
                                                                          1,980
                                                                          0.04%
                                                                        $51.34 
                                                                        $55.16 
                                                                      $114,740 
                                                                          2.30%
11-3000
Sales Managers
                                                                          7,420
                                                                          0.15%
                                                                        $46.70 
                                                                        $52.35 
                                                                      $108,890 
                                                                          1.10%
11-3011
Public Relations and Fundraising Managers
                                                                            300
                                                                          0.01%
                                                                        $54.59 
                                                                        $57.99 
                                                                      $120,630 
                                                                          3.80%
11-3021
Operations Specialties Managers
                                                                         61,400
                                                                          1.21%
                                                                        $41.66 
                                                                        $45.64 
                                                                       $94,930 
                                                                          0.90%
11-3031
Administrative Services Managers
                                                                          8,090
                                                                          0.16%
                                                                        $38.15 
                                                                        $40.95 
                                                                       $85,170 
                                                                          1.10%
11-3051
Computer and Information Systems Managers
                                                                          4,030
                                                                          0.08%
                                                                        $52.47 
                                                                        $55.13 
                                                                      $114,680 
                                                                          2.40%
11-3061
Financial Managers
                                                                          5,650
                                                                          0.11%
                                                                        $51.21 
                                                                        $55.95 
                                                                      $116,370 
                                                                          1.30%
11-3071
Industrial Production Managers
                                                                            860
                                                                          0.02%
                                                                        $43.00 
                                                                        $47.21 
                                                                       $98,190 
                                                                          3.70%
11-3111
Purchasing Managers
                                                                          1,080
                                                                          0.02%
                                                                        $48.61 
                                                                        $52.05 
                                                                      $108,250 
                                                                          2.70%
11-3121
Transportation, Storage, and Distribution Managers
                                                                         38,090
                                                                          0.75%
                                                                        $40.00 
                                                                        $43.49 
                                                                       $90,460 
                                                                          0.80%
11-3131
Compensation and Benefits Managers
                                                                            260
                                                                          0.01%
                                                                        $48.70 
                                                                        $56.17 
                                                                      $116,820 
                                                                          4.30%
11-9000
Human Resources Managers
                                                                          2,500
                                                                          0.05%
                                                                        $46.98 
                                                                        $50.39 
                                                                      $104,820 
                                                                          1.40%
11-9021
Training and Development Managers
                                                                            840
                                                                          0.02%
                                                                        $42.70 
                                                                        $46.20 
                                                                       $96,100 
                                                                          2.50%
11-9041
Other Management Occupations
                                                                         27,890
                                                                          0.55%
                                                                        $34.58 
                                                                        $38.27 
                                                                       $79,600 
                                                                          1.00%
11-9051
Construction Managers
                                                                          1,230
                                                                          0.02%
                                                                        $42.58 
                                                                        $44.05 
                                                                       $91,620 
                                                                          1.40%
11-9111
Architectural and Engineering Managers
                                                                          1,260
                                                                          0.02%
                                                                        $59.46 
                                                                        $65.41 
                                                                      $136,060 
                                                                          3.50%
11-9131
Food Service Managers
                                                                            180
                                                                             -7
                                                                        $27.62 
                                                                        $31.02 
                                                                       $64,510 
                                                                          5.60%
11-9141
Medical and Health Services Managers
                                                                             40
                                                                             -7
                                                                        $42.33 
                                                                        $42.83 
                                                                       $89,080 
                                                                          3.60%
11-9161
Postmasters and Mail Superintendents
                                                                         17,930
                                                                          0.35%
                                                                        $31.32 
                                                                        $31.89 
                                                                       $66,340 
                                                                          0.10%
11-9171
Property, Real Estate, and Community Association Managers
                                                                            280
                                                                          0.01%
                                                                        $41.62 
                                                                        $42.97 
                                                                       $89,370 
                                                                          3.50%
11-9199
Emergency Management Directors
                                                                             50
                                                                             -7
                                                                        $42.64 
                                                                        $43.88 
                                                                       $91,280 
                                                                          5.20%
2666211
Managers, All Other
                                                                          6,900
                                                                          0.14%
                                                                        $45.55 
                                                                        $48.77 
                                                                      $101,430 
                                                                          1.60%
13-0000
Business and Financial Operations Occupations
                                                                         95,580
                                                                          1.88%
                                                                        $30.28 
                                                                        $31.91 
                                                                       $66,380 
                                                                          0.70%
13-1000
Business Operations Specialists
                                                                         74,010
                                                                          1.46%
                                                                        $30.04 
                                                                        $31.65 
                                                                       $65,830 
                                                                          0.80%
13-1020
Buyers and Purchasing Agents
                                                                          7,700
                                                                          0.15%
                                                                        $27.16 
                                                                        $29.09 
                                                                       $60,510 
                                                                          1.10%
13-1021
Buyers and Purchasing Agents, Farm Products
                                                                            190
                                                                             -7
                                                                        $27.34 
                                                                        $28.78 
                                                                       $59,870 
                                                                          4.90%
13-1022
Wholesale and Retail Buyers, Except Farm Products
                                                                          1,690
                                                                          0.03%
                                                                        $24.45 
                                                                        $26.84 
                                                                       $55,820 
                                                                          3.30%
13-1023
Purchasing Agents, Except Wholesale, Retail, and Farm Products
                                                                          5,820
                                                                          0.11%
                                                                        $27.88 
                                                                        $29.76 
                                                                       $61,900 
                                                                          1.00%
13-1030
Claims Adjusters, Appraisers, Examiners, and Investigators
                                                                            590
                                                                          0.01%
                                                                        $28.74 
                                                                        $28.45 
                                                                       $59,170 
                                                                          1.90%
13-1031
Claims Adjusters, Examiners, and Investigators
                                                                            590
                                                                          0.01%
                                                                        $28.74 
                                                                        $28.45 
                                                                       $59,170 
                                                                          1.90%
13-1041
Compliance Officers
                                                                          4,730
                                                                          0.09%
                                                                        $33.21 
                                                                        $32.51 
                                                                       $67,610 
                                                                          1.60%
13-1051
Cost Estimators
                                                                          1,490
                                                                          0.03%
                                                                        $27.72 
                                                                        $29.66 
                                                                       $61,700 
                                                                          2.40%
13-1070
Human Resources Workers
                                                                         11,480
                                                                          0.23%
                                                                        $27.42 
                                                                        $28.78 
                                                                       $59,860 
                                                                          0.70%
13-1071
Human Resources Specialists
                                                                         10,150
                                                                          0.20%
                                                                        $26.88 
                                                                        $28.34 
                                                                       $58,940 
                                                                          0.70%
13-1075
Labor Relations Specialists
                                                                          1,330
                                                                          0.03%
                                                                        $31.88 
                                                                        $32.17 
                                                                       $66,900 
                                                                          1.10%
13-1081
Logisticians
                                                                          7,650
                                                                          0.15%
                                                                        $32.16 
                                                                        $33.59 
                                                                       $69,860 
                                                                          2.30%
13-1111
Management Analysts
                                                                          6,640
                                                                          0.13%
                                                                        $34.02 
                                                                        $36.69 
                                                                       $76,320 
                                                                          2.40%
13-1121
Meeting, Convention, and Event Planners
                                                                            160
                                                                             -7
                                                                        $24.34 
                                                                        $25.05 
                                                                       $52,110 
                                                                          2.80%
13-1141
Compensation, Benefits, and Job Analysis Specialists
                                                                          1,620
                                                                          0.03%
                                                                        $29.63 
                                                                        $30.18 
                                                                       $62,780 
                                                                          1.40%
13-1151
Training and Development Specialists
                                                                          7,720
                                                                          0.15%
                                                                        $25.81 
                                                                        $27.28 
                                                                       $56,750 
                                                                          1.50%
13-1161
Market Research Analysts and Marketing Specialists
                                                                          5,100
                                                                          0.10%
                                                                        $32.28 
                                                                        $33.18 
                                                                       $69,020 
                                                                          1.70%
13-1199
Business Operations Specialists, All Other
                                                                         19,110
                                                                          0.38%
                                                                        $32.04 
                                                                        $33.44 
                                                                       $69,560 
                                                                          1.40%
13-2000
Financial Specialists
                                                                         21,580
                                                                          0.42%
                                                                        $31.04 
                                                                        $32.83 
                                                                       $68,280 
                                                                          0.80%
13-2011
Accountants and Auditors
                                                                         16,100
                                                                          0.32%
                                                                        $30.43 
                                                                        $32.48 
                                                                       $67,570 
                                                                          0.90%
13-2021
Appraisers and Assessors of Real Estate
                                                                             60
                                                                             -7
                                                                        $39.31 
                                                                        $37.25 
                                                                       $77,470 
                                                                          7.50%
13-2031
Budget Analysts
                                                                            570
                                                                          0.01%
                                                                        $35.89 
                                                                        $36.07 
                                                                       $75,020 
                                                                          1.60%
13-2041
Credit Analysts
                                                                            220
                                                                             -7
                                                                        $26.17 
                                                                        $29.75 
                                                                       $61,870 
                                                                          4.90%
13-2050
Financial Analysts and Advisors
                                                                          2,820
                                                                          0.06%
                                                                        $32.21 
                                                                        $34.06 
                                                                       $70,840 
                                                                          1.60%
13-2051
Financial Analysts
                                                                          2,810
                                                                          0.06%
                                                                        $32.21 
                                                                        $34.06 
                                                                       $70,830 
                                                                          1.60%
13-2061
Financial Examiners
                                                                             40
                                                                             -7
                                                                        $39.06 
                                                                        $42.33 
                                                                       $88,040 
                                                                          8.40%
13-2070
Credit Counselors and Loan Officers
                                                                            270
                                                                          0.01%
                                                                        $24.64 
                                                                        $24.84 
                                                                       $51,680 
                                                                          9.30%
13-2072
Loan Officers
                                                                            270
                                                                          0.01%
                                                                        $24.75 
                                                                        $25.04 
                                                                       $52,080 
                                                                          9.00%
13-2099
Financial Specialists, All Other
                                                                          1,490
                                                                          0.03%
                                                                        $34.35 
                                                                        $34.46 
                                                                       $71,670 
                                                                          1.70%
15-0000
Computer and Mathematical Occupations
                                                                         27,850
                                                                          0.55%
                                                                        $34.92 
                                                                        $35.99 
                                                                       $74,870 
                                                                          1.10%
15-1100
Computer Occupations
                                                                         26,830
                                                                          0.53%
                                                                        $34.85 
                                                                        $35.97 
                                                                       $74,820 
                                                                          1.20%
15-1120
Computer and Information Analysts
                                                                          4,250
                                                                          0.08%
                                                                        $37.27 
                                                                        $38.58 
                                                                       $80,240 
                                                                          1.30%
15-1121
Computer Systems Analysts
                                                                          3,810
                                                                          0.07%
                                                                        $37.28 
                                                                        $38.79 
                                                                       $80,680 
                                                                          1.30%
15-1122
Information Security Analysts
                                                                            440
                                                                          0.01%
                                                                        $37.21 
                                                                        $36.76 
                                                                       $76,450 
                                                                          2.00%
15-1130
Software Developers and Programmers
                                                                          6,360
                                                                          0.13%
                                                                        $41.34 
                                                                        $41.53 
                                                                       $86,390 
                                                                          1.10%
15-1131
Computer Programmers
                                                                          1,830
                                                                          0.04%
                                                                        $37.56 
                                                                        $37.29 
                                                                       $77,560 
                                                                          1.70%
15-1132
Software Developers, Applications
                                                                          2,690
                                                                          0.05%
                                                                        $43.10 
                                                                        $43.82 
                                                                       $91,150 
                                                                          1.70%
15-1133
Software Developers, Systems Software
                                                                          1,410
                                                                          0.03%
                                                                        $45.21 
                                                                        $45.40 
                                                                       $94,440 
                                                                          1.50%
15-1134
Web Developers
                                                                            440
                                                                          0.01%
                                                                        $31.55 
                                                                        $32.70 
                                                                       $68,020 
                                                                          3.70%
15-1140
Database and Systems Administrators and Network Architects
                                                                          7,920
                                                                          0.16%
                                                                        $37.18 
                                                                        $38.33 
                                                                       $79,730 
                                                                          1.50%
15-1141
Database Administrators
                                                                          1,320
                                                                          0.03%
                                                                        $29.94 
                                                                        $34.45 
                                                                       $71,650 
                                                                          1.90%
15-1142
Network and Computer Systems Administrators
                                                                          5,650
                                                                          0.11%
                                                                        $36.59 
                                                                        $37.64 
                                                                       $78,280 
                                                                          1.30%
15-1143
Computer Network Architects
                                                                            950
                                                                          0.02%
                                                                        $47.44 
                                                                        $47.87 
                                                                       $99,570 
                                                                          1.80%
15-1150
Computer Support Specialists
                                                                          6,570
                                                                          0.13%
                                                                        $24.88 
                                                                        $26.12 
                                                                       $54,340 
                                                                          1.00%
15-1151
Computer User Support Specialists
                                                                          4,730
                                                                          0.09%
                                                                        $23.37 
                                                                        $25.22 
                                                                       $52,460 
                                                                          1.50%
15-1152
Computer Network Support Specialists
                                                                          1,840
                                                                          0.04%
                                                                        $27.53 
                                                                        $28.44 
                                                                       $59,170 
                                                                          1.30%
15-1199
Computer Occupations, All Other
                                                                          1,730
                                                                          0.03%
                                                                        $34.30 
                                                                        $35.70 
                                                                       $74,250 
                                                                          1.60%
15-2000
Mathematical Science Occupations
                                                                          1,020
                                                                          0.02%
                                                                        $36.15 
                                                                        $36.55 
                                                                       $76,030 
                                                                          1.80%
15-2031
Operations Research Analysts
                                                                            890
                                                                          0.02%
                                                                        $38.29 
                                                                        $37.45 
                                                                       $77,890 
                                                                          1.90%
15-2041
Statisticians
                                                                            120
                                                                             -7
                                                                        $30.91 
                                                                        $30.45 
                                                                       $63,340 
                                                                          2.70%
17-0000
Architecture and Engineering Occupations
                                                                         22,980
                                                                          0.45%
                                                                        $30.72 
                                                                        $36.33 
                                                                       $75,560 
                                                                          1.00%
17-1000
Architects, Surveyors, and Cartographers
                                                                            260
                                                                          0.01%
                                                                        $39.13 
                                                                        $37.36 
                                                                       $77,710 
                                                                          3.60%
17-1010
Architects, Except Naval
                                                                            120
                                                                             -7
                                                                        $44.96 
                                                                        $46.35 
                                                                       $96,400 
                                                                          3.10%
17-1011
Architects, Except Landscape and Naval
                                                                            100
                                                                             -7
                                                                        $43.28 
                                                                        $46.23 
                                                                       $96,150 
                                                                          3.00%
17-1020
Surveyors, Cartographers, and Photogrammetrists
                                                                            140
                                                                             -7
                                                                        $28.51 
                                                                        $29.86 
                                                                       $62,110 
                                                                          4.50%
17-1021
Cartographers and Photogrammetrists
                                                                             40
                                                                             -7
                                                                        $30.15 
                                                                        $32.72 
                                                                       $68,060 
                                                                          5.90%
17-1022
Surveyors
                                                                            100
                                                                             -7
                                                                        $27.80 
                                                                        $28.76 
                                                                       $59,820 
                                                                          5.70%
17-2000
Engineers
                                                                         12,830
                                                                          0.25%
                                                                        $39.38 
                                                                        $41.58 
                                                                       $86,480 
                                                                          1.30%
17-2011
Aerospace Engineers
                                                                          1,630
                                                                          0.03%
                                                                        $43.62 
                                                                        $44.61 
                                                                       $92,780 
                                                                          1.70%
17-2051
Civil Engineers
                                                                          1,280
                                                                          0.03%
                                                                        $41.48 
                                                                        $43.74 
                                                                       $90,970 
                                                                          2.60%
17-2061
Computer Hardware Engineers
                                                                             40
                                                                             -7
                                                                        $37.71 
                                                                        $37.78 
                                                                       $78,590 
                                                                          3.10%
17-2070
Electrical and Electronics Engineers
                                                                            660
                                                                          0.01%
                                                                        $38.71 
                                                                        $40.81 
                                                                       $84,890 
                                                                          2.50%
17-2071
Electrical Engineers
                                                                            310
                                                                          0.01%
                                                                        $41.54 
                                                                        $43.00 
                                                                       $89,440 
                                                                          2.10%
17-2072
Electronics Engineers, Except Computer
                                                                            350
                                                                          0.01%
                                                                        $36.10 
                                                                        $38.89 
                                                                       $80,890 
                                                                          4.00%
17-2081
Environmental Engineers
                                                                            160
                                                                             -7
                                                                        $40.37 
                                                                        $41.72 
                                                                       $86,780 
                                                                          2.80%
17-2110
Industrial Engineers, Including Health and Safety
                                                                          4,510
                                                                          0.09%
                                                                        $35.91 
                                                                        $36.71 
                                                                       $76,370 
                                                                          1.00%
17-2111
Health and Safety Engineers, Except Mining Safety Engineers and Inspectors
                                                                          1,180
                                                                          0.02%
                                                                        $34.09 
                                                                        $35.01 
                                                                       $72,820 
                                                                          3.30%
17-2112
Industrial Engineers
                                                                          3,330
                                                                          0.07%
                                                                        $36.38 
                                                                        $37.32 
                                                                       $77,620 
                                                                          1.10%
17-2121
Marine Engineers and Naval Architects
                                                                          1,030
                                                                          0.02%
                                                                        $39.82 
                                                                        $41.00 
                                                                       $85,280 
                                                                          3.30%
17-2131
Materials Engineers
                                                                            210
                                                                             -7
                                                                        $33.56 
                                                                        $36.40 
                                                                       $75,700 
                                                                          5.10%
17-2141
Mechanical Engineers
                                                                          1,150
                                                                          0.02%
                                                                        $40.04 
                                                                        $41.10 
                                                                       $85,480 
                                                                          2.30%
17-2171
Petroleum Engineers
                                                                            650
                                                                          0.01%
                                                                        $57.51 
                                                                        $68.86 
                                                                      $143,240 
                                                                          5.70%
17-2199
Engineers, All Other
                                                                          1,480
                                                                          0.03%
                                                                        $39.48 
                                                                        $41.05 
                                                                       $85,390 
                                                                          3.90%
17-3000
Drafters, Engineering Technicians, and Mapping Technicians
                                                                          9,900
                                                                          0.19%
                                                                        $30.29 
                                                                        $29.50 
                                                                       $61,360 
                                                                          0.60%
17-3010
Drafters
                                                                            300
                                                                          0.01%
                                                                        $26.57 
                                                                        $28.10 
                                                                       $58,440 
                                                                          3.50%
17-3011
Architectural and Civil Drafters
                                                                             40
                                                                             -7
                                                                        $35.87 
                                                                        $32.71 
                                                                       $68,030 
                                                                          5.70%
17-3012
Electrical and Electronics Drafters
                                                                             30
                                                                             -7
                                                                        $24.13 
                                                                        $22.36 
                                                                       $46,510 
                                                                          6.30%
17-3013
Mechanical Drafters
                                                                            180
                                                                             -7
                                                                        $25.86 
                                                                        $28.47 
                                                                       $59,220 
                                                                          4.70%
17-3019
Drafters, All Other
                                                                             60
                                                                             -7
                                                                        $26.91 
                                                                        $27.11 
                                                                       $56,390 
                                                                          2.50%
17-3020
Engineering Technicians, Except Drafters
                                                                          9,490
                                                                          0.19%
                                                                        $30.29 
                                                                        $29.52 
                                                                       $61,400 
                                                                          0.60%
17-3021
Aerospace Engineering and Operations Technicians
                                                                            570
                                                                          0.01%
                                                                        $28.56 
                                                                        $28.45 
                                                                       $59,180 
                                                                          6.30%
17-3022
Civil Engineering Technicians
                                                                             60
                                                                             -7
                                                                        $29.04 
                                                                        $28.36 
                                                                       $58,980 
                                                                          4.00%
17-3023
Electrical and Electronics Engineering Technicians
                                                                          7,700
                                                                          0.15%
                                                                        $30.29 
                                                                        $29.70 
                                                                       $61,780 
                                                                          0.50%
17-3024
Electro-Mechanical Technicians
                                                                            240
                                                                             -7
                                                                        $27.80 
                                                                        $28.54 
                                                                       $59,360 
                                                                         10.30%
17-3025
Environmental Engineering Technicians
                                                                             50
                                                                             -7
                                                                        $30.58 
                                                                        $29.64 
                                                                       $61,640 
                                                                          6.90%
17-3026
Industrial Engineering Technicians
                                                                            260
                                                                          0.01%
                                                                        $23.40 
                                                                        $25.52 
                                                                       $53,080 
                                                                          2.30%
17-3027
Mechanical Engineering Technicians
                                                                            410
                                                                          0.01%
                                                                        $31.92 
                                                                        $30.75 
                                                                       $63,950 
                                                                          3.40%
17-3029
Engineering Technicians, Except Drafters, All Other
                                                                            210
                                                                             -7
                                                                        $29.86 
                                                                        $29.76 
                                                                       $61,900 
                                                                          2.80%
17-3031
Surveying and Mapping Technicians
                                                                            100
                                                                             -7
                                                                        $32.29 
                                                                        $31.55 
                                                                       $65,620 
                                                                          8.20%
19-0000
Life, Physical, and Social Science Occupations
                                                                          1,200
                                                                          0.02%
                                                                        $29.53 
                                                                        $32.74 
                                                                       $68,090 
                                                                          2.30%
19-1000
Life Scientists
                                                                            110
                                                                             -7
                                                                        $38.42 
                                                                        $36.76 
                                                                       $76,450 
                                                                          6.30%
19-1020
Biological Scientists
                                                                             -8
                                                                             -8
                                                                        $40.81 
                                                                        $39.13 
                                                                       $81,400 
                                                                          5.20%
19-2000
Physical Scientists
                                                                            460
                                                                          0.01%
                                                                        $36.00 
                                                                        $37.81 
                                                                       $78,650 
                                                                          3.40%
19-2021
Atmospheric and Space Scientists
                                                                             50
                                                                             -7
                                                                        $33.05 
                                                                        $35.34 
                                                                       $73,510 
                                                                          5.60%
19-2030
Chemists and Materials Scientists
                                                                            130
                                                                             -7
                                                                        $27.27 
                                                                        $32.53 
                                                                       $67,670 
                                                                          6.30%
19-2031
Chemists
                                                                            130
                                                                             -7
                                                                        $27.27 
                                                                        $32.53 
                                                                       $67,670 
                                                                          6.30%
19-2040
Environmental Scientists and Geoscientists
                                                                            280
                                                                          0.01%
                                                                        $39.09 
                                                                        $40.49 
                                                                       $84,220 
                                                                          3.70%
19-2041
Environmental Scientists and Specialists, Including Health
                                                                            260
                                                                          0.01%
                                                                        $38.29 
                                                                        $38.22 
                                                                       $79,500 
                                                                          3.80%
19-3000
Social Scientists and Related Workers
                                                                            110
                                                                             -7
                                                                        $44.93 
                                                                        $44.44 
                                                                       $92,440 
                                                                          5.20%
19-3011
Economists
                                                                             60
                                                                             -7
                                                                        $53.87 
                                                                        $51.86 
                                                                      $107,870 
                                                                          1.90%
19-3030
Psychologists
                                                                             40
                                                                             -7
                                                                        $33.45 
                                                                        $36.16 
                                                                       $75,200 
                                                                          4.90%
19-3032
Industrial-Organizational Psychologists
                                                                             40
                                                                             -7
                                                                        $33.45 
                                                                        $36.16 
                                                                       $75,200 
                                                                          4.90%
19-4000
Life, Physical, and Social Science Technicians
                                                                            520
                                                                          0.01%
                                                                        $24.44 
                                                                        $24.96 
                                                                       $51,920 
                                                                          3.00%
19-4031
Chemical Technicians
                                                                            130
                                                                             -7
                                                                        $21.76 
                                                                        $22.66 
                                                                       $47,130 
                                                                          4.70%
19-4041
Geological and Petroleum Technicians
                                                                            140
                                                                             -7
                                                                        $27.13 
                                                                        $27.82 
                                                                       $57,870 
                                                                          4.80%
19-4090
Miscellaneous Life, Physical, and Social Science Technicians
                                                                            110
                                                                             -7
                                                                        $26.41 
                                                                        $27.80 
                                                                       $57,830 
                                                                          6.30%
19-4091
Environmental Science and Protection Technicians, Including Health
                                                                             40
                                                                             -7
                                                                        $30.19 
                                                                        $29.55 
                                                                       $61,460 
                                                                          7.00%
19-4099
Life, Physical, and Social Science Technicians, All Other
                                                                             50
                                                                             -7
                                                                        $20.01 
                                                                        $21.53 
                                                                       $44,790 
                                                                          4.80%
21-0000
Community and Social Service Occupations
                                                                             60
                                                                             -7
                                                                        $20.97 
                                                                        $21.97 
                                                                       $45,700 
                                                                          4.50%
21-1000
Counselors, Social Workers, and Other Community and Social Service Specialists
                                                                             60
                                                                             -7
                                                                        $21.41 
                                                                        $22.40 
                                                                       $46,600 
                                                                          4.60%
21-1090
Miscellaneous Community and Social Service Specialists
                                                                             40
                                                                             -7
                                                                        $20.69 
                                                                        $21.77 
                                                                       $45,290 
                                                                          6.10%
21-1099
Community and Social Service Specialists, All Other
                                                                             40
                                                                             -7
                                                                        $21.15 
                                                                        $22.04 
                                                                       $45,830 
                                                                          6.10%
23-0000
Legal Occupations
                                                                          1,890
                                                                          0.04%
                                                                        $51.02 
                                                                        $56.06 
                                                                      $116,610 
                                                                          4.10%
23-1000
Lawyers, Judges, and Related Workers
                                                                          1,270
                                                                          0.02%
                                                                        $65.26 
                                                                        $71.07 
                                                                      $147,820 
                                                                          3.00%
23-1010
Lawyers and Judicial Law Clerks
                                                                          1,260
                                                                          0.02%
                                                                        $65.26 
                                                                        $71.20 
                                                                      $148,090 
                                                                          3.00%
23-1011
Lawyers
                                                                          1,260
                                                                          0.02%
                                                                        $65.26 
                                                                        $71.20 
                                                                      $148,090 
                                                                          3.00%
23-2000
Legal Support Workers
                                                                            620
                                                                          0.01%
                                                                        $25.45 
                                                                        $25.50 
                                                                       $53,040 
                                                                          3.40%
23-2011
Paralegals and Legal Assistants
                                                                            310
                                                                          0.01%
                                                                        $30.26 
                                                                        $29.21 
                                                                       $60,750 
                                                                          1.90%
23-2090
Miscellaneous Legal Support Workers
                                                                            310
                                                                          0.01%
                                                                        $18.60 
                                                                        $21.82 
                                                                       $45,390 
                                                                          6.60%
23-2093
Title Examiners, Abstractors, and Searchers
                                                                            100
                                                                             -7
                                                                        $21.14 
                                                                        $24.88 
                                                                       $51,760 
                                                                          8.20%
23-2099
Legal Support Workers, All Other
                                                                            210
                                                                             -7
                                                                        $18.14 
                                                                        $20.20 
                                                                       $42,020 
                                                                          9.70%
25-0000
Education, Training, and Library Occupations
                                                                          1,010
                                                                          0.02%
                                                                        $22.57 
                                                                        $25.09 
                                                                       $52,200 
                                                                          6.60%
25-1000
Postsecondary Teachers
                                                                            140
                                                                             -7
                                                                             -4
                                                                             -4
                                                                       $67,370 
                                                                         12.90%
25-1190
Miscellaneous Postsecondary Teachers
                                                                            140
                                                                             -7
                                                                             -4
                                                                             -4
                                                                       $67,370 
                                                                         12.90%
25-1194
Vocational Education Teachers, Postsecondary
                                                                            140
                                                                             -7
                                                                        $32.28 
                                                                        $32.39 
                                                                       $67,370 
                                                                         12.90%
25-3000
Other Teachers and Instructors
                                                                            630
                                                                          0.01%
                                                                        $26.03 
                                                                        $24.95 
                                                                       $51,890 
                                                                          9.90%
25-3021
Self-Enrichment Education Teachers
                                                                             -8
                                                                             -8
                                                                        $15.25 
                                                                        $17.53 
                                                                       $36,470 
                                                                          7.10%
25-4000
Librarians, Curators, and Archivists
                                                                             -8
                                                                             -8
                                                                        $18.91 
                                                                        $19.66 
                                                                       $40,890 
                                                                          2.80%
25-4010
Archivists, Curators, and Museum Technicians
                                                                             -8
                                                                             -8
                                                                        $18.79 
                                                                        $19.37 
                                                                       $40,290 
                                                                          2.60%
25-4013
Museum Technicians and Conservators
                                                                             -8
                                                                             -8
                                                                        $18.70 
                                                                        $19.25 
                                                                       $40,040 
                                                                          4.40%
25-9000
Other Education, Training, and Library Occupations
                                                                            110
                                                                             -7
                                                                             -4
                                                                             -4
                                                                       $48,880 
                                                                         16.30%
25-9031
Instructional Coordinators
                                                                             50
                                                                             -7
                                                                        $36.08 
                                                                        $33.97 
                                                                       $70,650 
                                                                          5.60%
27-0000
Arts, Design, Entertainment, Sports, and Media Occupations
                                                                          2,810
                                                                          0.06%
                                                                        $25.04 
                                                                        $26.77 
                                                                       $55,670 
                                                                          2.00%
27-1000
Art and Design Workers
                                                                            720
                                                                          0.01%
                                                                        $19.62 
                                                                        $20.69 
                                                                       $43,030 
                                                                          3.80%
27-1010
Artists and Related Workers
                                                                             40
                                                                             -7
                                                                        $28.48 
                                                                        $32.09 
                                                                       $66,750 
                                                                          3.10%
27-1020
Designers
                                                                            680
                                                                          0.01%
                                                                        $18.84 
                                                                        $20.03 
                                                                       $41,670 
                                                                          4.00%
27-1021
Commercial and Industrial Designers
                                                                             40
                                                                             -7
                                                                        $32.01 
                                                                        $31.86 
                                                                       $66,270 
                                                                          3.90%
27-1024
Graphic Designers
                                                                            270
                                                                          0.01%
                                                                        $23.06 
                                                                        $23.44 
                                                                       $48,750 
                                                                          2.30%
27-1025
Interior Designers
                                                                             70
                                                                             -7
                                                                        $25.70 
                                                                        $26.38 
                                                                       $54,870 
                                                                          7.10%
27-1026
Merchandise Displayers and Window Trimmers
                                                                            270
                                                                          0.01%
                                                                        $11.28 
                                                                        $12.51 
                                                                       $26,030 
                                                                          5.50%
27-1029
Designers, All Other
                                                                             -8
                                                                             -8
                                                                        $27.54 
                                                                        $27.25 
                                                                       $56,690 
                                                                          6.00%
27-2000
Entertainers and Performers, Sports and Related Workers
                                                                            180
                                                                             -7
                                                                        $18.29 
                                                                        $21.18 
                                                                       $44,050 
                                                                         13.80%
27-2010
Actors, Producers, and Directors
                                                                             40
                                                                             -7
                                                                        $20.03 
                                                                        $34.11 
                                                                       $70,960 
                                                                          8.60%
27-2040
Musicians, Singers, and Related Workers
                                                                             80
                                                                             -7
                                                                        $22.41 
                                                                        $23.03 
                                                                             -4
                                                                          3.40%
27-2042
Musicians and Singers
                                                                             80
                                                                             -7
                                                                        $22.41 
                                                                        $23.03 
                                                                             -4
                                                                          3.40%
27-3000
Media and Communication Workers
                                                                          1,660
                                                                          0.03%
                                                                        $29.24 
                                                                        $30.85 
                                                                       $64,160 
                                                                          2.60%
27-3031
Public Relations Specialists
                                                                            820
                                                                          0.02%
                                                                        $31.52 
                                                                        $33.87 
                                                                       $70,440 
                                                                          3.10%
27-3040
Writers and Editors
                                                                            630
                                                                          0.01%
                                                                        $29.79 
                                                                        $30.37 
                                                                       $63,170 
                                                                          1.70%
27-3041
Editors
                                                                            100
                                                                             -7
                                                                        $33.53 
                                                                        $32.61 
                                                                       $67,820 
                                                                          2.00%
27-3042
Technical Writers
                                                                            410
                                                                          0.01%
                                                                        $29.83 
                                                                        $29.98 
                                                                       $62,350 
                                                                          2.50%
27-3043
Writers and Authors
                                                                            120
                                                                             -7
                                                                        $28.35 
                                                                        $29.83 
                                                                       $62,040 
                                                                          2.40%
27-3090
Miscellaneous Media and Communication Workers
                                                                            190
                                                                             -7
                                                                        $17.29 
                                                                        $19.63 
                                                                       $40,840 
                                                                         11.10%
27-3091
Interpreters and Translators
                                                                            110
                                                                             -7
                                                                        $15.34 
                                                                        $15.87 
                                                                       $33,020 
                                                                         20.00%
27-3099
Media and Communication Workers, All Other
                                                                             70
                                                                             -7
                                                                        $24.68 
                                                                        $25.47 
                                                                       $52,980 
                                                                          9.80%
27-4000
Media and Communication Equipment Workers
                                                                            260
                                                                          0.01%
                                                                        $19.21 
                                                                        $21.29 
                                                                       $44,290 
                                                                          6.10%
27-4021
Photographers
                                                                            200
                                                                             -7
                                                                        $15.22 
                                                                        $19.01 
                                                                       $39,530 
                                                                          5.60%
29-0000
Healthcare Practitioners and Technical Occupations
                                                                          5,000
                                                                          0.10%
                                                                        $25.66 
                                                                        $26.86 
                                                                       $55,860 
                                                                          2.40%
29-1000
Health Diagnosing and Treating Practitioners
                                                                            690
                                                                          0.01%
                                                                        $34.79 
                                                                        $39.10 
                                                                       $81,330 
                                                                          3.20%
29-1051
Pharmacists
                                                                            160
                                                                             -7
                                                                        $60.96 
                                                                        $59.88 
                                                                      $124,540 
                                                                          2.80%
29-1141
Registered Nurses
                                                                            470
                                                                          0.01%
                                                                        $30.29 
                                                                        $31.67 
                                                                       $65,870 
                                                                          2.80%
29-2000
Health Technologists and Technicians
                                                                          1,430
                                                                          0.03%
                                                                        $13.83 
                                                                        $15.54 
                                                                       $32,320 
                                                                          3.10%
29-2041
Emergency Medical Technicians and Paramedics
                                                                          1,160
                                                                          0.02%
                                                                        $13.54 
                                                                        $14.84 
                                                                       $30,860 
                                                                          3.20%
29-2050
Health Practitioner Support Technologists and Technicians
                                                                            200
                                                                             -7
                                                                        $14.81 
                                                                        $16.23 
                                                                       $33,760 
                                                                          5.00%
29-2052
Pharmacy Technicians
                                                                            200
                                                                             -7
                                                                        $14.81 
                                                                        $16.23 
                                                                       $33,760 
                                                                          5.00%
29-9000
Other Healthcare Practitioners and Technical Occupations
                                                                          2,880
                                                                          0.06%
                                                                        $29.75 
                                                                        $29.55 
                                                                       $61,450 
                                                                          2.70%
29-9010
Occupational Health and Safety Specialists and Technicians
                                                                          2,870
                                                                          0.06%
                                                                        $29.76 
                                                                        $29.55 
                                                                       $61,450 
                                                                          2.70%
29-9011
Occupational Health and Safety Specialists
                                                                          2,530
                                                                          0.05%
                                                                        $30.78 
                                                                        $30.26 
                                                                       $62,930 
                                                                          3.00%
29-9012
Occupational Health and Safety Technicians
                                                                            350
                                                                          0.01%
                                                                        $23.40 
                                                                        $24.35 
                                                                       $50,650 
                                                                          2.80%
31-0000
Healthcare Support Occupations
                                                                             40
                                                                             -7
                                                                        $16.17 
                                                                        $16.19 
                                                                       $33,670 
                                                                          5.50%
31-9000
Other Healthcare Support Occupations
                                                                             40
                                                                             -7
                                                                        $16.17 
                                                                        $16.19 
                                                                       $33,670 
                                                                          5.50%
31-9090
Miscellaneous Healthcare Support Occupations
                                                                             40
                                                                             -7
                                                                        $16.17 
                                                                        $16.19 
                                                                       $33,670 
                                                                          5.50%
33-0000
Protective Service Occupations
                                                                         26,120
                                                                          0.51%
                                                                        $13.84 
                                                                        $16.72 
                                                                       $34,780 
                                                                          1.50%
33-1000
Supervisors of Protective Service Workers
                                                                            910
                                                                          0.02%
                                                                        $27.18 
                                                                        $29.66 
                                                                       $61,700 
                                                                          1.50%
33-1010
First-Line Supervisors of Law Enforcement Workers
                                                                            200
                                                                             -7
                                                                             -8
                                                                             -8
                                                                             -8
                                                                             -8
33-1012
First-Line Supervisors of Police and Detectives
                                                                            200
                                                                             -7
                                                                             -8
                                                                             -8
                                                                             -8
                                                                             -8
33-1099
First-Line Supervisors of Protective Service Workers, All Other
                                                                            690
                                                                          0.01%
                                                                        $24.37 
                                                                        $26.93 
                                                                       $56,010 
                                                                          2.20%
33-2000
Fire Fighting and Prevention Workers
                                                                            100
                                                                             -7
                                                                        $20.63 
                                                                        $20.54 
                                                                       $42,720 
                                                                          3.90%
33-2011
Firefighters
                                                                            100
                                                                             -7
                                                                        $20.30 
                                                                        $20.47 
                                                                       $42,580 
                                                                          2.50%
33-3000
Law Enforcement Workers
                                                                          2,390
                                                                          0.05%
                                                                        $28.61 
                                                                        $30.81 
                                                                       $64,080 
                                                                          1.50%
33-3021
Detectives and Criminal Investigators
                                                                            520
                                                                          0.01%
                                                                        $40.71 
                                                                        $43.12 
                                                                       $89,690 
                                                                          1.20%
33-3050
Police Officers
                                                                          1,840
                                                                          0.04%
                                                                        $25.89 
                                                                        $27.65 
                                                                       $57,510 
                                                                          2.00%
33-3051
Police and Sheriff's Patrol Officers
                                                                            500
                                                                          0.01%
                                                                        $25.88 
                                                                        $25.57 
                                                                       $53,190 
                                                                          1.60%
33-3052
Transit and Railroad Police
                                                                          1,340
                                                                          0.03%
                                                                        $29.39 
                                                                        $28.42 
                                                                       $59,120 
                                                                          2.40%
33-9000
Other Protective Service Workers
                                                                         22,720
                                                                          0.45%
                                                                        $12.92 
                                                                        $14.70 
                                                                       $30,590 
                                                                          1.30%
33-9021
Private Detectives and Investigators
                                                                            930
                                                                          0.02%
                                                                        $30.75 
                                                                        $30.07 
                                                                       $62,540 
                                                                          1.40%
33-9030
Security Guards and Gaming Surveillance Officers
                                                                          6,980
                                                                          0.14%
                                                                        $12.70 
                                                                        $13.92 
                                                                       $28,950 
                                                                          1.30%
33-9032
Security Guards
                                                                          6,980
                                                                          0.14%
                                                                        $12.70 
                                                                        $13.92 
                                                                       $28,950 
                                                                          1.30%
33-9090
Miscellaneous Protective Service Workers
                                                                         14,810
                                                                          0.29%
                                                                        $12.63 
                                                                        $14.11 
                                                                       $29,360 
                                                                          1.90%
33-9093
Transportation Security Screeners
                                                                            830
                                                                          0.02%
                                                                        $15.49 
                                                                        $16.10 
                                                                       $33,480 
                                                                          3.60%
33-9099
Protective Service Workers, All Other
                                                                         13,970
                                                                          0.27%
                                                                        $12.38 
                                                                        $13.98 
                                                                       $29,080 
                                                                          1.70%
35-0000
Food Preparation and Serving Related Occupations
                                                                          7,560
                                                                          0.15%
                                                                        $11.72 
                                                                        $14.36 
                                                                       $29,860 
                                                                          2.30%
35-1010
Supervisors of Food Preparation and Serving Workers
                                                                            860
                                                                          0.02%
                                                                        $18.66 
                                                                        $22.35 
                                                                       $46,480 
                                                                          5.50%
35-1011
Chefs and Head Cooks
                                                                            360
                                                                          0.01%
                                                                        $22.10 
                                                                        $25.27 
                                                                       $52,560 
                                                                          4.70%
35-1012
First-Line Supervisors of Food Preparation and Serving Workers
                                                                            500
                                                                          0.01%
                                                                        $16.85 
                                                                        $20.23 
                                                                       $42,080 
                                                                          8.30%
35-2000
Cooks and Food Preparation Workers
                                                                          3,160
                                                                          0.06%
                                                                        $13.19 
                                                                        $15.18 
                                                                       $31,570 
                                                                          3.20%
35-2010
Cooks
                                                                          2,510
                                                                          0.05%
                                                                        $14.50 
                                                                        $16.37 
                                                                       $34,040 
                                                                          3.80%
35-2012
Cooks, Institution and Cafeteria
                                                                          1,450
                                                                          0.03%
                                                                        $14.41 
                                                                        $15.47 
                                                                       $32,180 
                                                                          4.30%
35-2014
Cooks, Restaurant
                                                                            480
                                                                          0.01%
                                                                        $11.74 
                                                                        $13.28 
                                                                       $27,620 
                                                                          6.30%
35-2015
Cooks, Short Order
                                                                             80
                                                                             -7
                                                                        $10.27 
                                                                        $12.68 
                                                                       $26,380 
                                                                         12.10%
35-2019
Cooks, All Other
                                                                            450
                                                                          0.01%
                                                                        $25.61 
                                                                        $23.84 
                                                                       $49,590 
                                                                          4.50%
35-2021
Food Preparation Workers
                                                                            650
                                                                          0.01%
                                                                        $10.18 
                                                                        $10.63 
                                                                       $22,100 
                                                                          1.90%
35-3000
Food and Beverage Serving Workers
                                                                          2,900
                                                                          0.06%
                                                                         $9.51 
                                                                        $11.81 
                                                                       $24,570 
                                                                          3.50%
35-3011
Bartenders
                                                                            450
                                                                          0.01%
                                                                        $10.35 
                                                                        $11.94 
                                                                       $24,830 
                                                                          4.00%
35-3020
Fast Food and Counter Workers
                                                                            970
                                                                          0.02%
                                                                         $9.63 
                                                                        $12.78 
                                                                       $26,570 
                                                                          7.30%
35-3021
Combined Food Preparation and Serving Workers, Including Fast Food
                                                                            880
                                                                          0.02%
                                                                         $9.36 
                                                                        $12.60 
                                                                       $26,210 
                                                                          8.10%
35-3022
Counter Attendants, Cafeteria, Food Concession, and Coffee Shop
                                                                             90
                                                                             -7
                                                                        $15.29 
                                                                        $14.59 
                                                                       $30,350 
                                                                          6.60%
35-3031
Waiters and Waitresses
                                                                          1,380
                                                                          0.03%
                                                                         $9.39 
                                                                        $11.25 
                                                                       $23,400 
                                                                          3.90%
35-3041
Food Servers, Nonrestaurant
                                                                            100
                                                                             -7
                                                                         $8.90 
                                                                         $9.68 
                                                                       $20,140 
                                                                          6.30%
35-9000
Other Food Preparation and Serving Related Workers
                                                                            640
                                                                          0.01%
                                                                         $9.80 
                                                                        $11.14 
                                                                       $23,170 
                                                                          3.60%
35-9011
Dining Room and Cafeteria Attendants and Bartender Helpers
                                                                            120
                                                                             -7
                                                                         $9.93 
                                                                        $11.07 
                                                                       $23,020 
                                                                          4.10%
35-9021
Dishwashers
                                                                            330
                                                                          0.01%
                                                                        $10.00 
                                                                        $10.72 
                                                                       $22,300 
                                                                          5.20%
35-9031
Hosts and Hostesses, Restaurant, Lounge, and Coffee Shop
                                                                            100
                                                                             -7
                                                                         $9.17 
                                                                         $9.70 
                                                                       $20,180 
                                                                          3.10%
35-9099
Food Preparation and Serving Related Workers, All Other
                                                                             80
                                                                             -7
                                                                        $14.83 
                                                                        $14.65 
                                                                       $30,470 
                                                                          7.30%
37-0000
Building and Grounds Cleaning and Maintenance Occupations
                                                                         33,490
                                                                          0.66%
                                                                        $19.44 
                                                                        $18.45 
                                                                       $38,370 
                                                                          0.60%
37-1010
First-Line Supervisors of Building and Grounds Cleaning and Maintenance Workers
                                                                            700
                                                                          0.01%
                                                                        $18.93 
                                                                        $20.50 
                                                                       $42,640 
                                                                          2.50%
37-1011
First-Line Supervisors of Housekeeping and Janitorial Workers
                                                                            680
                                                                          0.01%
                                                                        $18.69 
                                                                        $20.24 
                                                                       $42,110 
                                                                          2.60%
37-2000
Building Cleaning and Pest Control Workers
                                                                         31,400
                                                                          0.62%
                                                                        $19.29 
                                                                        $18.31 
                                                                       $38,080 
                                                                          0.60%
37-2010
Building Cleaning Workers
                                                                         31,400
                                                                          0.62%
                                                                        $19.29 
                                                                        $18.31 
                                                                       $38,080 
                                                                          0.60%
37-2011
Janitors and Cleaners, Except Maids and Housekeeping Cleaners
                                                                         30,410
                                                                          0.60%
                                                                        $20.05 
                                                                        $18.47 
                                                                       $38,410 
                                                                          0.60%
37-2012
Maids and Housekeeping Cleaners
                                                                            930
                                                                          0.02%
                                                                        $10.51 
                                                                        $13.39 
                                                                       $27,850 
                                                                         14.10%
37-2019
Building Cleaning Workers, All Other
                                                                             50
                                                                             -7
                                                                        $13.51 
                                                                        $15.22 
                                                                       $31,650 
                                                                         13.20%
37-3010
Grounds Maintenance Workers
                                                                          1,400
                                                                          0.03%
                                                                        $24.39 
                                                                        $20.57 
                                                                       $42,780 
                                                                          2.60%
37-3011
Landscaping and Groundskeeping Workers
                                                                            620
                                                                          0.01%
                                                                        $13.24 
                                                                        $14.36 
                                                                       $29,880 
                                                                          3.60%
37-3019
Grounds Maintenance Workers, All Other
                                                                            750
                                                                          0.01%
                                                                        $28.01 
                                                                        $25.96 
                                                                       $54,000 
                                                                          1.70%
39-0000
Personal Care and Service Occupations
                                                                         28,100
                                                                          0.55%
                                                                        $10.34 
                                                                        $11.53 
                                                                       $23,990 
                                                                          1.40%
39-1000
Supervisors of Personal Care and Service Workers
                                                                            740
                                                                          0.01%
                                                                        $17.12 
                                                                        $18.21 
                                                                       $37,870 
                                                                          4.10%
39-1021
First-Line Supervisors of Personal Service Workers
                                                                            740
                                                                          0.01%
                                                                        $17.11 
                                                                        $18.17 
                                                                       $37,790 
                                                                          3.60%
39-2000
Animal Care and Service Workers
                                                                            110
                                                                             -7
                                                                        $14.58 
                                                                        $15.02 
                                                                       $31,250 
                                                                          6.90%
39-2021
Nonfarm Animal Caretakers
                                                                            110
                                                                             -7
                                                                        $14.58 
                                                                        $15.02 
                                                                       $31,250 
                                                                          6.90%
39-3000
Entertainment Attendants and Related Workers
                                                                          1,320
                                                                          0.03%
                                                                        $10.27 
                                                                        $10.90 
                                                                       $22,680 
                                                                          2.50%
39-3090
Miscellaneous Entertainment Attendants and Related Workers
                                                                            530
                                                                          0.01%
                                                                         $9.24 
                                                                        $10.28 
                                                                       $21,390 
                                                                          5.40%
39-3091
Amusement and Recreation Attendants
                                                                            530
                                                                          0.01%
                                                                         $9.24 
                                                                        $10.28 
                                                                       $21,370 
                                                                          5.50%
39-6010
Baggage Porters, Bellhops, and Concierges
                                                                         12,670
                                                                          0.25%
                                                                         $9.60 
                                                                        $11.12 
                                                                       $23,120 
                                                                          2.10%
39-6011
Baggage Porters and Bellhops
                                                                         12,500
                                                                          0.25%
                                                                         $9.53 
                                                                        $10.97 
                                                                       $22,820 
                                                                          2.20%
39-6012
Concierges
                                                                            180
                                                                             -7
                                                                        $24.11 
                                                                        $21.59 
                                                                       $44,900 
                                                                          2.40%
39-7010
Tour and Travel Guides
                                                                          3,110
                                                                          0.06%
                                                                        $13.09 
                                                                        $13.96 
                                                                       $29,040 
                                                                          2.40%
39-7011
Tour Guides and Escorts
                                                                          2,920
                                                                          0.06%
                                                                        $13.03 
                                                                        $13.95 
                                                                       $29,020 
                                                                          2.60%
39-7012
Travel Guides
                                                                            180
                                                                             -7
                                                                        $13.51 
                                                                        $14.04 
                                                                       $29,210 
                                                                          4.50%
39-9000
Other Personal Care and Service Workers
                                                                         10,140
                                                                          0.20%
                                                                         $9.87 
                                                                        $10.87 
                                                                       $22,610 
                                                                          2.40%
39-9011
Childcare Workers
                                                                          7,060
                                                                          0.14%
                                                                        $10.09 
                                                                        $10.96 
                                                                       $22,790 
                                                                          3.20%
39-9021
Personal Care Aides
                                                                             -8
                                                                             -8
                                                                         $9.23 
                                                                         $9.61 
                                                                       $19,990 
                                                                          9.50%
39-9030
Recreation and Fitness Workers
                                                                             70
                                                                             -7
                                                                        $10.54 
                                                                        $18.88 
                                                                       $39,270 
                                                                         28.70%
39-9032
Recreation Workers
                                                                             50
                                                                             -7
                                                                         $9.64 
                                                                        $10.74 
                                                                       $22,350 
                                                                          8.50%
39-9099
Personal Care and Service Workers, All Other
                                                                          2,540
                                                                          0.05%
                                                                         $9.70 
                                                                        $10.66 
                                                                       $22,170 
                                                                          3.70%
41-0000
Sales and Related Occupations
                                                                         71,270
                                                                          1.40%
                                                                        $23.96 
                                                                        $27.36 
                                                                       $56,910 
                                                                          1.20%
41-1010
First-Line Supervisors of Sales Workers
                                                                          4,080
                                                                          0.08%
                                                                        $29.81 
                                                                        $32.76 
                                                                       $68,150 
                                                                          2.00%
41-1011
First-Line Supervisors of Retail Sales Workers
                                                                          1,410
                                                                          0.03%
                                                                        $20.11 
                                                                        $23.06 
                                                                       $47,970 
                                                                          3.10%
41-1012
First-Line Supervisors of Non-Retail Sales Workers
                                                                          2,660
                                                                          0.05%
                                                                        $34.13 
                                                                        $37.91 
                                                                       $78,860 
                                                                          2.00%
41-2000
Retail Sales Workers
                                                                         12,400
                                                                          0.24%
                                                                        $10.97 
                                                                        $13.13 
                                                                       $27,310 
                                                                          2.00%
41-2010
Cashiers
                                                                          3,610
                                                                          0.07%
                                                                         $9.79 
                                                                        $11.28 
                                                                       $23,470 
                                                                          2.20%
41-2011
Cashiers
                                                                          3,610
                                                                          0.07%
                                                                         $9.79 
                                                                        $11.28 
                                                                       $23,470 
                                                                          2.20%
41-2020
Counter and Rental Clerks and Parts Salespersons
                                                                          4,160
                                                                          0.08%
                                                                        $11.54 
                                                                        $13.71 
                                                                       $28,530 
                                                                          1.80%
41-2021
Counter and Rental Clerks
                                                                          3,850
                                                                          0.08%
                                                                        $11.39 
                                                                        $13.57 
                                                                       $28,220 
                                                                          1.90%
41-2022
Parts Salespersons
                                                                            310
                                                                          0.01%
                                                                        $14.27 
                                                                        $15.52 
                                                                       $32,280 
                                                                          4.00%
41-2031
Retail Salespersons
                                                                          4,630
                                                                          0.09%
                                                                        $11.22 
                                                                        $14.04 
                                                                       $29,210 
                                                                          3.80%
41-3000
Sales Representatives, Services
                                                                         42,710
                                                                          0.84%
                                                                        $27.15 
                                                                        $30.62 
                                                                       $63,690 
                                                                          1.40%
41-3011
Advertising Sales Agents
                                                                             50
                                                                             -7
                                                                        $23.37 
                                                                        $30.29 
                                                                       $63,010 
                                                                          8.20%
41-3041
Travel Agents
                                                                            920
                                                                          0.02%
                                                                        $16.69 
                                                                        $21.19 
                                                                       $44,070 
                                                                          6.50%
41-3099
Sales Representatives, Services, All Other
                                                                         41,720
                                                                          0.82%
                                                                        $27.33 
                                                                        $30.83 
                                                                       $64,120 
                                                                          1.40%
41-4010
Sales Representatives, Wholesale and Manufacturing
                                                                         10,500
                                                                          0.21%
                                                                        $25.99 
                                                                        $29.71 
                                                                       $61,800 
                                                                          1.90%
41-4011
Sales Representatives, Wholesale and Manufacturing, Technical and Scientific Products
                                                                            630
                                                                          0.01%
                                                                        $34.41 
                                                                        $36.80 
                                                                       $76,530 
                                                                          9.00%
41-4012
Sales Representatives, Wholesale and Manufacturing, Except Technical and Scientific Products
                                                                          9,870
                                                                          0.19%
                                                                        $25.61 
                                                                        $29.26 
                                                                       $60,870 
                                                                          2.00%
41-9000
Other Sales and Related Workers
                                                                          1,580
                                                                          0.03%
                                                                        $18.23 
                                                                        $21.50 
                                                                       $44,720 
                                                                          5.20%
41-9020
Real Estate Brokers and Sales Agents
                                                                             -8
                                                                             -8
                                                                        $28.64 
                                                                        $32.28 
                                                                       $67,140 
                                                                          6.20%
41-9022
Real Estate Sales Agents
                                                                             60
                                                                             -7
                                                                        $28.62 
                                                                        $32.42 
                                                                       $67,430 
                                                                          6.10%
41-9031
Sales Engineers
                                                                             70
                                                                             -7
                                                                        $31.76 
                                                                        $34.77 
                                                                       $72,320 
                                                                          3.70%
41-9041
Telemarketers
                                                                            440
                                                                          0.01%
                                                                        $11.66 
                                                                        $13.75 
                                                                       $28,600 
                                                                          6.80%
41-9090
Miscellaneous Sales and Related Workers
                                                                            940
                                                                          0.02%
                                                                        $22.01 
                                                                        $23.71 
                                                                       $49,320 
                                                                          5.10%
41-9099
Sales and Related Workers, All Other
                                                                            920
                                                                          0.02%
                                                                        $22.48 
                                                                        $24.10 
                                                                       $50,130 
                                                                          5.20%
43-0000
Office and Administrative Support Occupations
                                                                      1,329,300
                                                                         26.16%
                                                                        $19.93 
                                                                        $20.26 
                                                                       $42,150 
                                                                          0.20%
43-1011
First-Line Supervisors of Office and Administrative Support Workers
                                                                         63,720
                                                                          1.25%
                                                                        $28.68 
                                                                        $28.38 
                                                                       $59,020 
                                                                          0.40%
43-2000
Communications Equipment Operators
                                                                          1,490
                                                                          0.03%
                                                                        $12.24 
                                                                        $13.11 
                                                                       $27,280 
                                                                          2.10%
43-2011
Switchboard Operators, Including Answering Service
                                                                          1,420
                                                                          0.03%
                                                                        $12.12 
                                                                        $12.70 
                                                                       $26,420 
                                                                          2.20%
43-2099
Communications Equipment Operators, All Other
                                                                             50
                                                                             -7
                                                                        $27.93 
                                                                        $26.18 
                                                                       $54,450 
                                                                          4.40%
43-3000
Financial Clerks
                                                                         68,510
                                                                          1.35%
                                                                        $16.77 
                                                                        $17.52 
                                                                       $36,450 
                                                                          0.50%
43-3011
Bill and Account Collectors
                                                                          6,490
                                                                          0.13%
                                                                        $16.10 
                                                                        $16.69 
                                                                       $34,710 
                                                                          0.90%
43-3021
Billing and Posting Clerks
                                                                         15,400
                                                                          0.30%
                                                                        $15.75 
                                                                        $16.37 
                                                                       $34,040 
                                                                          0.70%
43-3031
Bookkeeping, Accounting, and Auditing Clerks
                                                                         38,460
                                                                          0.76%
                                                                        $17.10 
                                                                        $17.87 
                                                                       $37,160 
                                                                          0.60%
43-3051
Payroll and Timekeeping Clerks
                                                                          6,470
                                                                          0.13%
                                                                        $18.22 
                                                                        $19.00 
                                                                       $39,510 
                                                                          1.10%
43-3061
Procurement Clerks
                                                                          1,250
                                                                          0.02%
                                                                        $18.12 
                                                                        $18.64 
                                                                       $38,780 
                                                                          1.90%
43-3071
Tellers
                                                                            200
                                                                             -7
                                                                        $10.37 
                                                                        $11.26 
                                                                       $23,420 
                                                                          6.10%
43-3099
Financial Clerks, All Other
                                                                            240
                                                                             -7
                                                                        $17.34 
                                                                        $19.19 
                                                                       $39,910 
                                                                          7.70%
43-4000
Information and Record Clerks
                                                                        208,820
                                                                          4.11%
                                                                        $16.70 
                                                                        $16.98 
                                                                       $35,320 
                                                                          0.60%
43-4011
Brokerage Clerks
                                                                            450
                                                                          0.01%
                                                                        $23.19 
                                                                        $22.29 
                                                                       $46,350 
                                                                          6.80%
43-4021
Correspondence Clerks
                                                                            380
                                                                          0.01%
                                                                        $15.43 
                                                                        $16.72 
                                                                       $34,770 
                                                                          6.30%
43-4041
Credit Authorizers, Checkers, and Clerks
                                                                            140
                                                                             -7
                                                                        $19.58 
                                                                        $19.57 
                                                                       $40,710 
                                                                          2.40%
43-4051
Customer Service Representatives
                                                                         75,500
                                                                          1.49%
                                                                        $15.87 
                                                                        $16.66 
                                                                       $34,640 
                                                                          0.80%
43-4071
File Clerks
                                                                          1,740
                                                                          0.03%
                                                                        $13.06 
                                                                        $13.71 
                                                                       $28,510 
                                                                          1.60%
43-4141
New Accounts Clerks
                                                                             -8
                                                                             -8
                                                                        $12.57 
                                                                        $14.60 
                                                                       $30,360 
                                                                         13.10%
43-4151
Order Clerks
                                                                          8,560
                                                                          0.17%
                                                                        $14.89 
                                                                        $15.45 
                                                                       $32,140 
                                                                          2.30%
43-4161
Human Resources Assistants, Except Payroll and Timekeeping
                                                                          3,710
                                                                          0.07%
                                                                        $18.41 
                                                                        $18.86 
                                                                       $39,220 
                                                                          1.00%
43-4171
Receptionists and Information Clerks
                                                                          6,580
                                                                          0.13%
                                                                        $12.58 
                                                                        $13.40 
                                                                       $27,880 
                                                                          1.00%
43-4181
Reservation and Transportation Ticket Agents and Travel Clerks
                                                                        105,480
                                                                          2.08%
                                                                        $18.31 
                                                                        $17.35 
                                                                       $36,090 
                                                                          1.00%
43-4199
Information and Record Clerks, All Other
                                                                          6,180
                                                                          0.12%
                                                                        $20.56 
                                                                        $19.99 
                                                                       $41,570 
                                                                          1.50%
43-5000
Material Recording, Scheduling, Dispatching, and Distributing Workers
                                                                        842,930
                                                                         16.59%
                                                                        $23.97 
                                                                        $21.42 
                                                                       $44,550 
                                                                          0.30%
43-5011
Cargo and Freight Agents
                                                                         68,350
                                                                          1.35%
                                                                        $19.43 
                                                                        $21.05 
                                                                       $43,770 
                                                                          1.20%
43-5021
Couriers and Messengers
                                                                         21,300
                                                                          0.42%
                                                                        $12.65 
                                                                        $13.66 
                                                                       $28,420 
                                                                          1.90%
43-5030
Dispatchers
                                                                         81,980
                                                                          1.61%
                                                                        $17.63 
                                                                        $18.79 
                                                                       $39,080 
                                                                          0.80%
43-5032
Dispatchers, Except Police, Fire, and Ambulance
                                                                         81,930
                                                                          1.61%
                                                                        $17.63 
                                                                        $18.79 
                                                                       $39,080 
                                                                          0.80%
43-5041
Meter Readers, Utilities
                                                                            100
                                                                             -7
                                                                        $16.63 
                                                                        $17.64 
                                                                       $36,690 
                                                                          5.20%
43-5050
Postal Service Workers
                                                                        500,970
                                                                          9.86%
                                                                        $25.89 
                                                                        $23.90 
                                                                       $49,720 
                                                                          0.30%
43-5051
Postal Service Clerks
                                                                         71,910
                                                                          1.42%
                                                                        $25.88 
                                                                        $22.87 
                                                                       $47,570 
                                                                          0.20%
43-5052
Postal Service Mail Carriers
                                                                        307,480
                                                                          6.05%
                                                                        $27.16 
                                                                        $24.47 
                                                                       $50,890 
                                                                          0.20%
43-5053
Postal Service Mail Sorters, Processors, and Processing Machine Operators
                                                                        121,580
                                                                          2.39%
                                                                        $25.88 
                                                                        $23.09 
                                                                       $48,040 
                                                                          0.40%
43-5061
Production, Planning, and Expediting Clerks
                                                                         20,020
                                                                          0.39%
                                                                        $23.29 
                                                                        $22.33 
                                                                       $46,450 
                                                                          0.70%
43-5071
Shipping, Receiving, and Traffic Clerks
                                                                         74,450
                                                                          1.47%
                                                                        $14.83 
                                                                        $16.02 
                                                                       $33,330 
                                                                          0.70%
43-5081
Stock Clerks and Order Fillers
                                                                         69,140
                                                                          1.36%
                                                                        $14.05 
                                                                        $15.24 
                                                                       $31,710 
                                                                          1.50%
43-5111
Weighers, Measurers, Checkers, and Samplers, Recordkeeping
                                                                          6,620
                                                                          0.13%
                                                                        $16.63 
                                                                        $16.78 
                                                                       $34,890 
                                                                          1.30%
43-6010
Secretaries and Administrative Assistants
                                                                         50,060
                                                                          0.99%
                                                                        $16.25 
                                                                        $17.32 
                                                                       $36,020 
                                                                          0.60%
43-6011
Executive Secretaries and Executive Administrative Assistants
                                                                         10,590
                                                                          0.21%
                                                                        $22.69 
                                                                        $23.81 
                                                                       $49,520 
                                                                          0.90%
43-6012
Legal Secretaries
                                                                            140
                                                                             -7
                                                                        $24.77 
                                                                        $23.50 
                                                                       $48,880 
                                                                          2.80%
43-6014
Secretaries and Administrative Assistants, Except Legal, Medical, and Executive
                                                                         39,330
                                                                          0.77%
                                                                        $14.77 
                                                                        $15.55 
                                                                       $32,330 
                                                                          0.60%
43-9000
Other Office and Administrative Support Workers
                                                                         93,770
                                                                          1.85%
                                                                        $14.03 
                                                                        $15.39 
                                                                       $32,010 
                                                                          0.50%
43-9011
Computer Operators
                                                                          3,610
                                                                          0.07%
                                                                        $24.73 
                                                                        $22.25 
                                                                       $46,270 
                                                                          2.10%
43-9020
Data Entry and Information Processing Workers
                                                                          7,930
                                                                          0.16%
                                                                        $14.02 
                                                                        $14.93 
                                                                       $31,060 
                                                                          1.20%
43-9021
Data Entry Keyers
                                                                          7,830
                                                                          0.15%
                                                                        $14.02 
                                                                        $14.86 
                                                                       $30,910 
                                                                          1.20%
43-9022
Word Processors and Typists
                                                                            100
                                                                             -7
                                                                        $20.29 
                                                                        $20.70 
                                                                       $43,050 
                                                                          5.30%
43-9031
Desktop Publishers
                                                                            140
                                                                             -7
                                                                        $15.67 
                                                                        $16.62 
                                                                       $34,570 
                                                                          4.20%
43-9041
Insurance Claims and Policy Processing Clerks
                                                                            170
                                                                             -7
                                                                        $20.12 
                                                                        $20.52 
                                                                       $42,690 
                                                                          4.80%
43-9051
Mail Clerks and Mail Machine Operators, Except Postal Service
                                                                          1,120
                                                                          0.02%
                                                                        $11.51 
                                                                        $12.45 
                                                                       $25,890 
                                                                          3.90%
43-9061
Office Clerks, General
                                                                         76,550
                                                                          1.51%
                                                                        $13.73 
                                                                        $14.96 
                                                                       $31,110 
                                                                          0.60%
43-9071
Office Machine Operators, Except Computer
                                                                            730
                                                                          0.01%
                                                                        $15.19 
                                                                        $14.96 
                                                                       $31,110 
                                                                          2.90%
43-9081
Proofreaders and Copy Markers
                                                                             30
                                                                             -7
                                                                        $15.31 
                                                                        $16.11 
                                                                       $33,520 
                                                                          3.60%
43-9111
Statistical Assistants
                                                                            100
                                                                             -7
                                                                        $24.11 
                                                                        $23.31 
                                                                       $48,470 
                                                                          2.10%
43-9199
Office and Administrative Support Workers, All Other
                                                                          3,370
                                                                          0.07%
                                                                        $18.27 
                                                                        $19.39 
                                                                       $40,320 
                                                                          1.50%
45-0000
Farming, Fishing, and Forestry Occupations
                                                                          1,910
                                                                          0.04%
                                                                        $11.47 
                                                                        $13.33 
                                                                       $27,730 
                                                                          3.90%
45-1011
First-Line Supervisors of Farming, Fishing, and Forestry Workers
                                                                             80
                                                                             -7
                                                                        $25.12 
                                                                        $24.92 
                                                                       $51,830 
                                                                          7.10%
45-2000
Agricultural Workers
                                                                          1,320
                                                                          0.03%
                                                                        $10.21 
                                                                        $11.99 
                                                                       $24,950 
                                                                          4.00%
45-2011
Agricultural Inspectors
                                                                             40
                                                                             -7
                                                                        $20.23 
                                                                        $20.11 
                                                                       $41,820 
                                                                          5.30%
45-2041
Graders and Sorters, Agricultural Products
                                                                            320
                                                                          0.01%
                                                                         $9.08 
                                                                        $11.09 
                                                                       $23,060 
                                                                          6.90%
45-2090
Miscellaneous Agricultural Workers
                                                                            950
                                                                          0.02%
                                                                        $10.57 
                                                                        $11.96 
                                                                       $24,880 
                                                                          4.00%
45-2091
Agricultural Equipment Operators
                                                                            290
                                                                          0.01%
                                                                        $13.94 
                                                                        $14.51 
                                                                       $30,180 
                                                                          6.00%
45-2092
Farmworkers and Laborers, Crop, Nursery, and Greenhouse
                                                                            290
                                                                          0.01%
                                                                        $10.51 
                                                                        $11.83 
                                                                       $24,610 
                                                                          5.00%
45-2093
Farmworkers, Farm, Ranch, and Aquacultural Animals
                                                                            350
                                                                          0.01%
                                                                         $9.39 
                                                                        $10.16 
                                                                       $21,120 
                                                                          7.10%
45-3000
Fishing and Hunting Workers
                                                                             -8
                                                                             -8
                                                                        $13.52 
                                                                        $14.27 
                                                                       $29,690 
                                                                         10.50%
45-3011
Fishers and Related Fishing Workers
                                                                             -8
                                                                             -8
                                                                        $13.52 
                                                                        $14.27 
                                                                       $29,690 
                                                                         10.50%
45-4000
Forest, Conservation, and Logging Workers
                                                                            460
                                                                          0.01%
                                                                        $13.97 
                                                                        $15.13 
                                                                       $31,470 
                                                                          5.90%
45-4020
Logging Workers
                                                                            460
                                                                          0.01%
                                                                        $13.97 
                                                                        $15.13 
                                                                       $31,470 
                                                                          5.90%
45-4022
Logging Equipment Operators
                                                                            360
                                                                          0.01%
                                                                        $13.95 
                                                                        $15.42 
                                                                       $32,070 
                                                                          7.20%
45-4029
Logging Workers, All Other
                                                                             50
                                                                             -7
                                                                        $16.86 
                                                                        $16.80 
                                                                       $34,950 
                                                                          5.00%
47-0000
Construction and Extraction Occupations
                                                                         28,560
                                                                          0.56%
                                                                        $22.46 
                                                                        $23.40 
                                                                       $48,680 
                                                                          1.50%
47-1011
First-Line Supervisors of Construction Trades and Extraction Workers
                                                                          3,480
                                                                          0.07%
                                                                        $30.49 
                                                                        $31.19 
                                                                       $64,870 
                                                                          2.60%
47-2000
Construction Trades Workers
                                                                         11,470
                                                                          0.23%
                                                                        $23.01 
                                                                        $23.10 
                                                                       $48,060 
                                                                          1.90%
47-2011
Boilermakers
                                                                             30
                                                                             -7
                                                                        $25.99 
                                                                        $25.86 
                                                                       $53,790 
                                                                          4.50%
47-2031
Carpenters
                                                                          1,260
                                                                          0.02%
                                                                        $17.70 
                                                                        $19.51 
                                                                       $40,590 
                                                                          5.10%
47-2061
Construction Laborers
                                                                            770
                                                                          0.02%
                                                                        $14.81 
                                                                        $15.10 
                                                                       $31,410 
                                                                          5.00%
47-2070
Construction Equipment Operators
                                                                          3,330
                                                                          0.07%
                                                                        $19.24 
                                                                        $20.67 
                                                                       $42,980 
                                                                          2.80%
47-2071
Paving, Surfacing, and Tamping Equipment Operators
                                                                            300
                                                                          0.01%
                                                                        $17.08 
                                                                        $18.52 
                                                                       $38,530 
                                                                          4.60%
47-2073
Operating Engineers and Other Construction Equipment Operators
                                                                          3,030
                                                                          0.06%
                                                                        $19.49 
                                                                        $20.87 
                                                                       $43,420 
                                                                          2.90%
47-2111
Electricians
                                                                          2,600
                                                                          0.05%
                                                                        $27.72 
                                                                        $28.24 
                                                                       $58,740 
                                                                          2.10%
47-2140
Painters and Paperhangers
                                                                            290
                                                                          0.01%
                                                                        $27.03 
                                                                        $24.99 
                                                                       $51,980 
                                                                          3.80%
47-2141
Painters, Construction and Maintenance
                                                                            290
                                                                          0.01%
                                                                        $27.03 
                                                                        $24.99 
                                                                       $51,980 
                                                                          3.80%
47-2150
Pipelayers, Plumbers, Pipefitters, and Steamfitters
                                                                          1,330
                                                                          0.03%
                                                                        $24.11 
                                                                        $24.84 
                                                                       $51,680 
                                                                          3.20%
47-2152
Plumbers, Pipefitters, and Steamfitters
                                                                          1,320
                                                                          0.03%
                                                                        $24.23 
                                                                        $24.92 
                                                                       $51,840 
                                                                          3.20%
47-2181
Roofers
                                                                             -8
                                                                             -8
                                                                        $19.56 
                                                                        $19.36 
                                                                       $40,280 
                                                                          7.10%
47-2211
Sheet Metal Workers
                                                                          1,370
                                                                          0.03%
                                                                        $25.11 
                                                                        $24.57 
                                                                       $51,110 
                                                                          3.30%
47-2221
Structural Iron and Steel Workers
                                                                             60
                                                                             -7
                                                                        $26.61 
                                                                        $26.60 
                                                                       $55,330 
                                                                          5.30%
47-3010
Helpers, Construction Trades
                                                                             70
                                                                             -7
                                                                        $17.39 
                                                                        $16.32 
                                                                       $33,940 
                                                                          6.10%
47-3013
Helpers--Electricians
                                                                             40
                                                                             -7
                                                                        $19.19 
                                                                        $17.82 
                                                                       $37,070 
                                                                          6.90%
47-4000
Other Construction and Related Workers
                                                                         12,880
                                                                          0.25%
                                                                        $20.94 
                                                                        $21.63 
                                                                       $45,000 
                                                                          2.00%
47-4011
Construction and Building Inspectors
                                                                            210
                                                                             -7
                                                                        $28.93 
                                                                        $29.33 
                                                                       $61,010 
                                                                          3.20%
47-4041
Hazardous Materials Removal Workers
                                                                             80
                                                                             -7
                                                                        $17.07 
                                                                        $20.17 
                                                                       $41,960 
                                                                          7.20%
47-4051
Highway Maintenance Workers
                                                                            130
                                                                             -7
                                                                        $16.31 
                                                                        $16.55 
                                                                       $34,430 
                                                                          5.00%
47-4061
Rail-Track Laying and Maintenance Equipment Operators
                                                                         10,360
                                                                          0.20%
                                                                        $21.56 
                                                                        $21.82 
                                                                       $45,380 
                                                                          2.00%
47-4090
Miscellaneous Construction and Related Workers
                                                                          2,000
                                                                          0.04%
                                                                        $17.48 
                                                                        $20.33 
                                                                       $42,280 
                                                                          7.60%
47-4099
Construction and Related Workers, All Other
                                                                          2,000
                                                                          0.04%
                                                                        $17.48 
                                                                        $20.33 
                                                                       $42,280 
                                                                          7.60%
47-5000
Extraction Workers
                                                                            660
                                                                          0.01%
                                                                        $23.47 
                                                                        $22.74 
                                                                       $47,290 
                                                                          8.70%
47-5010
Derrick, Rotary Drill, and Service Unit Operators, Oil, Gas, and Mining
                                                                            320
                                                                          0.01%
                                                                        $24.75 
                                                                        $23.95 
                                                                       $49,810 
                                                                         17.30%
47-5012
Rotary Drill Operators, Oil and Gas
                                                                            120
                                                                             -7
                                                                        $27.65 
                                                                        $33.43 
                                                                       $69,540 
                                                                         12.90%
47-5013
Service Unit Operators, Oil, Gas, and Mining
                                                                            170
                                                                             -7
                                                                             -8
                                                                             -8
                                                                             -8
                                                                             -8
47-5031
Explosives Workers, Ordnance Handling Experts, and Blasters
                                                                             -8
                                                                             -8
                                                                        $16.40 
                                                                        $20.10 
                                                                       $41,800 
                                                                         18.20%
47-5071
Roustabouts, Oil and Gas
                                                                             -8
                                                                             -8
                                                                        $23.81 
                                                                        $22.85 
                                                                       $47,530 
                                                                          9.20%
47-5099
Extraction Workers, All Other
                                                                            100
                                                                             -7
                                                                        $21.24 
                                                                        $21.24 
                                                                       $44,180 
                                                                          5.40%
49-0000
Installation, Maintenance, and Repair Occupations
                                                                        293,330
                                                                          5.77%
                                                                        $23.63 
                                                                        $24.17 
                                                                       $50,280 
                                                                          0.60%
49-1011
First-Line Supervisors of Mechanics, Installers, and Repairers
                                                                         24,970
                                                                          0.49%
                                                                        $32.45 
                                                                        $32.57 
                                                                       $67,740 
                                                                          0.50%
49-2000
Electrical and Electronic Equipment Mechanics, Installers, and Repairers
                                                                         14,810
                                                                          0.29%
                                                                        $25.81 
                                                                        $26.50 
                                                                       $55,120 
                                                                          1.50%
49-2011
Computer, Automated Teller, and Office Machine Repairers
                                                                             -8
                                                                             -8
                                                                        $19.75 
                                                                        $19.95 
                                                                       $41,490 
                                                                          3.40%
49-2020
Radio and Telecommunications Equipment Installers and Repairers
                                                                             -8
                                                                             -8
                                                                        $26.29 
                                                                        $26.40 
                                                                       $54,920 
                                                                          3.10%
49-2021
Radio, Cellular, and Tower Equipment Installers and Repairers
                                                                             60
                                                                             -7
                                                                        $22.35 
                                                                        $23.73 
                                                                       $49,360 
                                                                          4.40%
49-2022
Telecommunications Equipment Installers and Repairers, Except Line Installers
                                                                             -8
                                                                             -8
                                                                        $27.15 
                                                                        $27.10 
                                                                       $56,360 
                                                                          3.00%
49-2090
Miscellaneous Electrical and Electronic Equipment Mechanics, Installers, and Repairers
                                                                         14,230
                                                                          0.28%
                                                                        $25.94 
                                                                        $26.64 
                                                                       $55,410 
                                                                          1.50%
49-2091
Avionics Technicians
                                                                          6,570
                                                                          0.13%
                                                                        $25.91 
                                                                        $26.42 
                                                                       $54,940 
                                                                          2.10%
49-2092
Electric Motor, Power Tool, and Related Repairers
                                                                             40
                                                                             -7
                                                                        $19.34 
                                                                        $22.31 
                                                                       $46,410 
                                                                          5.90%
49-2093
Electrical and Electronics Installers and Repairers, Transportation Equipment
                                                                          6,920
                                                                          0.14%
                                                                        $25.76 
                                                                        $26.74 
                                                                       $55,620 
                                                                          2.30%
49-2094
Electrical and Electronics Repairers, Commercial and Industrial Equipment
                                                                            420
                                                                          0.01%
                                                                        $27.56 
                                                                        $27.78 
                                                                       $57,780 
                                                                          2.70%
49-2095
Electrical and Electronics Repairers, Powerhouse, Substation, and Relay
                                                                            210
                                                                             -7
                                                                        $30.50 
                                                                        $31.17 
                                                                       $64,820 
                                                                          2.50%
49-2096
Electronic Equipment Installers and Repairers, Motor Vehicles
                                                                             50
                                                                             -7
                                                                        $23.69 
                                                                        $21.46 
                                                                       $44,630 
                                                                          4.30%
49-3000
Vehicle and Mobile Equipment Mechanics, Installers, and Repairers
                                                                        180,650
                                                                          3.56%
                                                                        $22.85 
                                                                        $23.70 
                                                                       $49,290 
                                                                          0.70%
49-3011
Aircraft Mechanics and Service Technicians
                                                                         68,690
                                                                          1.35%
                                                                        $27.07 
                                                                        $28.04 
                                                                       $58,320 
                                                                          1.20%
49-3020
Automotive Technicians and Repairers
                                                                         16,310
                                                                          0.32%
                                                                        $20.94 
                                                                        $21.19 
                                                                       $44,070 
                                                                          0.70%
49-3021
Automotive Body and Related Repairers
                                                                          1,760
                                                                          0.03%
                                                                        $20.47 
                                                                        $20.90 
                                                                       $43,470 
                                                                          1.50%
49-3023
Automotive Service Technicians and Mechanics
                                                                         14,550
                                                                          0.29%
                                                                        $21.03 
                                                                        $21.22 
                                                                       $44,140 
                                                                          0.80%
49-3031
Bus and Truck Mechanics and Diesel Engine Specialists
                                                                         73,610
                                                                          1.45%
                                                                        $19.80 
                                                                        $20.47 
                                                                       $42,580 
                                                                          0.40%
49-3040
Heavy Vehicle and Mobile Equipment Service Technicians and Mechanics
                                                                         19,620
                                                                          0.39%
                                                                        $23.84 
                                                                        $23.47 
                                                                       $48,820 
                                                                          1.30%
49-3042
Mobile Heavy Equipment Mechanics, Except Engines
                                                                          2,550
                                                                          0.05%
                                                                        $22.45 
                                                                        $23.14 
                                                                       $48,130 
                                                                          2.10%
49-3043
Rail Car Repairers
                                                                         17,040
                                                                          0.34%
                                                                        $24.00 
                                                                        $23.53 
                                                                       $48,940 
                                                                          1.50%
49-3050
Small Engine Mechanics
                                                                            930
                                                                          0.02%
                                                                        $18.27 
                                                                        $19.78 
                                                                       $41,130 
                                                                          6.60%
49-3051
Motorboat Mechanics and Service Technicians
                                                                            850
                                                                          0.02%
                                                                        $17.82 
                                                                        $18.50 
                                                                       $38,490 
                                                                          3.60%
49-3053
Outdoor Power Equipment and Other Small Engine Mechanics
                                                                             -8
                                                                             -8
                                                                        $39.59 
                                                                        $34.53 
                                                                       $71,820 
                                                                          7.60%
49-3090
Miscellaneous Vehicle and Mobile Equipment Mechanics, Installers, and Repairers
                                                                          1,490
                                                                          0.03%
                                                                        $14.71 
                                                                        $15.97 
                                                                       $33,210 
                                                                          3.50%
49-3093
Tire Repairers and Changers
                                                                          1,490
                                                                          0.03%
                                                                        $14.71 
                                                                        $15.97 
                                                                       $33,220 
                                                                          3.40%
49-9000
Other Installation, Maintenance, and Repair Occupations
                                                                         72,910
                                                                          1.43%
                                                                        $22.33 
                                                                        $22.00 
                                                                       $45,760 
                                                                          0.80%
49-9010
Control and Valve Installers and Repairers
                                                                          1,490
                                                                          0.03%
                                                                        $28.97 
                                                                        $28.25 
                                                                       $58,750 
                                                                          3.70%
49-9012
Control and Valve Installers and Repairers, Except Mechanical Door
                                                                          1,470
                                                                          0.03%
                                                                        $29.08 
                                                                        $28.29 
                                                                       $58,840 
                                                                          3.90%
49-9021
Heating, Air Conditioning, and Refrigeration Mechanics and Installers
                                                                          3,050
                                                                          0.06%
                                                                        $28.01 
                                                                        $26.22 
                                                                       $54,530 
                                                                          0.80%
49-9031
Home Appliance Repairers
                                                                            480
                                                                          0.01%
                                                                        $18.21 
                                                                        $18.91 
                                                                       $39,330 
                                                                          4.60%
49-9040
Industrial Machinery Installation, Repair, and Maintenance Workers
                                                                          9,620
                                                                          0.19%
                                                                        $24.23 
                                                                        $25.20 
                                                                       $52,430 
                                                                          3.30%
49-9041
Industrial Machinery Mechanics
                                                                          5,990
                                                                          0.12%
                                                                        $27.22 
                                                                        $27.92 
                                                                       $58,070 
                                                                          2.70%
49-9043
Maintenance Workers, Machinery
                                                                          3,360
                                                                          0.07%
                                                                        $18.65 
                                                                        $19.90 
                                                                       $41,390 
                                                                          3.50%
49-9044
Millwrights
                                                                            270
                                                                          0.01%
                                                                        $31.86 
                                                                        $31.01 
                                                                       $64,500 
                                                                          2.90%
49-9050
Line Installers and Repairers
                                                                            200
                                                                             -7
                                                                        $33.53 
                                                                        $33.50 
                                                                       $69,680 
                                                                          4.10%
49-9051
Electrical Power-Line Installers and Repairers
                                                                            180
                                                                             -7
                                                                        $34.17 
                                                                        $34.12 
                                                                       $70,970 
                                                                          4.30%
49-9060
Precision Instrument and Equipment Repairers
                                                                            190
                                                                             -7
                                                                        $23.18 
                                                                        $22.04 
                                                                       $45,850 
                                                                          3.40%
49-9069
Precision Instrument and Equipment Repairers, All Other
                                                                            160
                                                                             -7
                                                                        $23.57 
                                                                        $22.00 
                                                                       $45,770 
                                                                          7.70%
49-9071
Maintenance and Repair Workers, General
                                                                         38,700
                                                                          0.76%
                                                                        $22.15 
                                                                        $21.58 
                                                                       $44,880 
                                                                          0.60%
49-9090
Miscellaneous Installation, Maintenance, and Repair Workers
                                                                         19,170
                                                                          0.38%
                                                                        $19.16 
                                                                        $20.05 
                                                                       $41,690 
                                                                          1.60%
49-9091
Coin, Vending, and Amusement Machine Servicers and Repairers
                                                                            180
                                                                             -7
                                                                        $13.95 
                                                                        $15.03 
                                                                       $31,260 
                                                                          7.40%
49-9092
Commercial Divers
                                                                            180
                                                                             -7
                                                                        $18.93 
                                                                        $23.52 
                                                                       $48,930 
                                                                         14.00%
49-9095
Manufactured Building and Mobile Home Installers
                                                                             40
                                                                             -7
                                                                        $13.05 
                                                                        $14.32 
                                                                       $29,780 
                                                                         13.90%
49-9096
Riggers
                                                                          1,690
                                                                          0.03%
                                                                        $17.65 
                                                                        $19.02 
                                                                       $39,570 
                                                                          4.90%
49-9097
Signal and Track Switch Repairers
                                                                          6,350
                                                                          0.13%
                                                                        $25.93 
                                                                        $25.63 
                                                                       $53,300 
                                                                          1.20%
49-9098
Helpers--Installation, Maintenance, and Repair Workers
                                                                          6,420
                                                                          0.13%
                                                                        $12.12 
                                                                        $13.14 
                                                                       $27,340 
                                                                          1.60%
49-9099
Installation, Maintenance, and Repair Workers, All Other
                                                                          4,240
                                                                          0.08%
                                                                        $21.70 
                                                                        $22.79 
                                                                       $47,400 
                                                                          2.60%
51-0000
Production Occupations
                                                                         72,850
                                                                          1.43%
                                                                        $18.44 
                                                                        $20.20 
                                                                       $42,020 
                                                                          1.10%
51-1011
First-Line Supervisors of Production and Operating Workers
                                                                          6,400
                                                                          0.13%
                                                                        $27.18 
                                                                        $29.16 
                                                                       $60,660 
                                                                          1.50%
51-2000
Assemblers and Fabricators
                                                                         11,320
                                                                          0.22%
                                                                        $12.96 
                                                                        $14.31 
                                                                       $29,770 
                                                                          2.60%
51-2011
Aircraft Structure, Surfaces, Rigging, and Systems Assemblers
                                                                          1,860
                                                                          0.04%
                                                                        $19.34 
                                                                        $19.19 
                                                                       $39,920 
                                                                          3.20%
51-2020
Electrical, Electronics, and Electromechanical Assemblers
                                                                            400
                                                                          0.01%
                                                                        $17.42 
                                                                        $17.61 
                                                                       $36,630 
                                                                          2.20%
51-2022
Electrical and Electronic Equipment Assemblers
                                                                            400
                                                                          0.01%
                                                                        $17.42 
                                                                        $17.61 
                                                                       $36,630 
                                                                          2.20%
51-2041
Structural Metal Fabricators and Fitters
                                                                            300
                                                                          0.01%
                                                                        $19.61 
                                                                        $19.99 
                                                                       $41,570 
                                                                          7.50%
51-2090
Miscellaneous Assemblers and Fabricators
                                                                          8,750
                                                                          0.17%
                                                                        $12.03 
                                                                        $12.91 
                                                                       $26,860 
                                                                          2.40%
51-2091
Fiberglass Laminators and Fabricators
                                                                             70
                                                                             -7
                                                                        $17.32 
                                                                        $17.16 
                                                                       $35,690 
                                                                          7.10%
51-2092
Team Assemblers
                                                                          7,140
                                                                          0.14%
                                                                        $12.06 
                                                                        $12.99 
                                                                       $27,020 
                                                                          2.60%
51-2099
Assemblers and Fabricators, All Other
                                                                          1,540
                                                                          0.03%
                                                                        $11.26 
                                                                        $12.37 
                                                                       $25,730 
                                                                          5.60%
51-3000
Food Processing Workers
                                                                            480
                                                                          0.01%
                                                                        $14.01 
                                                                        $14.81 
                                                                       $30,810 
                                                                          3.90%
51-3011
Bakers
                                                                             40
                                                                             -7
                                                                             -8
                                                                             -8
                                                                             -8
                                                                             -8
51-3020
Butchers and Other Meat, Poultry, and Fish Processing Workers
                                                                            240
                                                                             -7
                                                                        $15.01 
                                                                        $14.69 
                                                                       $30,550 
                                                                          7.40%
51-3021
Butchers and Meat Cutters
                                                                            240
                                                                             -7
                                                                        $15.00 
                                                                        $14.64 
                                                                       $30,460 
                                                                          8.90%
51-3090
Miscellaneous Food Processing Workers
                                                                            200
                                                                             -7
                                                                             -8
                                                                             -8
                                                                             -8
                                                                             -8
51-3091
Food and Tobacco Roasting, Baking, and Drying Machine Operators and Tenders
                                                                             -8
                                                                             -8
                                                                        $12.31 
                                                                        $12.39 
                                                                       $25,770 
                                                                          4.90%
51-3092
Food Batchmakers
                                                                             70
                                                                             -7
                                                                        $12.77 
                                                                        $13.17 
                                                                       $27,400 
                                                                          5.40%
51-4000
Metal Workers and Plastic Workers
                                                                         16,520
                                                                          0.33%
                                                                        $20.94 
                                                                        $21.40 
                                                                       $44,520 
                                                                          1.40%
51-4010
Computer Control Programmers and Operators
                                                                             40
                                                                             -7
                                                                        $19.16 
                                                                        $19.87 
                                                                       $41,320 
                                                                          4.00%
51-4020
Forming Machine Setters, Operators, and Tenders, Metal and Plastic
                                                                             -8
                                                                             -8
                                                                        $17.68 
                                                                        $18.10 
                                                                       $37,640 
                                                                          9.00%
51-4030
Machine Tool Cutting Setters, Operators, and Tenders, Metal and Plastic
                                                                             -8
                                                                             -8
                                                                        $15.35 
                                                                        $16.94 
                                                                       $35,230 
                                                                         11.00%
51-4031
Cutting, Punching, and Press Machine Setters, Operators, and Tenders, Metal and Plastic
                                                                             -8
                                                                             -8
                                                                        $13.83 
                                                                        $15.13 
                                                                       $31,460 
                                                                          9.70%
51-4033
Grinding, Lapping, Polishing, and Buffing Machine Tool Setters, Operators, and Tenders, Metal and Plastic
                                                                             -8
                                                                             -8
                                                                        $15.38 
                                                                        $16.93 
                                                                       $35,210 
                                                                         13.60%
51-4041
Machinists
                                                                          6,640
                                                                          0.13%
                                                                        $22.21 
                                                                        $22.73 
                                                                       $47,290 
                                                                          2.20%
51-4070
Molders and Molding Machine Setters, Operators, and Tenders, Metal and Plastic
                                                                             -8
                                                                             -8
                                                                        $14.90 
                                                                        $16.12 
                                                                       $33,520 
                                                                          4.60%
51-4072
Molding, Coremaking, and Casting Machine Setters, Operators, and Tenders, Metal and Plastic
                                                                             -8
                                                                             -8
                                                                        $14.90 
                                                                        $16.12 
                                                                       $33,520 
                                                                          4.60%
51-4120
Welding, Soldering, and Brazing Workers
                                                                          8,670
                                                                          0.17%
                                                                        $20.18 
                                                                        $20.46 
                                                                       $42,560 
                                                                          1.20%
51-4121
Welders, Cutters, Solderers, and Brazers
                                                                          8,610
                                                                          0.17%
                                                                        $20.16 
                                                                        $20.44 
                                                                       $42,520 
                                                                          1.20%
51-4122
Welding, Soldering, and Brazing Machine Setters, Operators, and Tenders
                                                                             60
                                                                             -7
                                                                        $23.78 
                                                                        $23.02 
                                                                       $47,870 
                                                                          4.70%
51-4190
Miscellaneous Metal Workers and Plastic Workers
                                                                            140
                                                                             -7
                                                                        $21.25 
                                                                        $23.39 
                                                                       $48,660 
                                                                          8.10%
51-4192
Layout Workers, Metal and Plastic
                                                                             30
                                                                             -7
                                                                        $20.67 
                                                                        $21.29 
                                                                       $44,290 
                                                                          5.90%
51-4193
Plating and Coating Machine Setters, Operators, and Tenders, Metal and Plastic
                                                                             -8
                                                                             -8
                                                                        $21.77 
                                                                        $24.64 
                                                                       $51,250 
                                                                          5.60%
51-5110
Printing Workers
                                                                            290
                                                                          0.01%
                                                                        $17.30 
                                                                        $18.34 
                                                                       $38,140 
                                                                          2.70%
51-5111
Prepress Technicians and Workers
                                                                             60
                                                                             -7
                                                                        $15.55 
                                                                        $17.08 
                                                                       $35,530 
                                                                          8.60%
51-5112
Printing Press Operators
                                                                            220
                                                                             -7
                                                                        $17.73 
                                                                        $18.70 
                                                                       $38,890 
                                                                          2.00%
51-6000
Textile, Apparel, and Furnishings Workers
                                                                            980
                                                                          0.02%
                                                                        $13.46 
                                                                        $14.70 
                                                                       $30,570 
                                                                          2.70%
51-6031
Sewing Machine Operators
                                                                            100
                                                                             -7
                                                                        $12.80 
                                                                        $12.74 
                                                                       $26,500 
                                                                          3.80%
51-6050
Tailors, Dressmakers, and Sewers
                                                                             80
                                                                             -7
                                                                        $13.66 
                                                                        $13.51 
                                                                       $28,100 
                                                                          5.40%
51-6052
Tailors, Dressmakers, and Custom Sewers
                                                                             60
                                                                             -7
                                                                        $15.05 
                                                                        $14.87 
                                                                       $30,930 
                                                                          2.00%
51-6090
Miscellaneous Textile, Apparel, and Furnishings Workers
                                                                            700
                                                                          0.01%
                                                                        $14.27 
                                                                        $15.63 
                                                                       $32,510 
                                                                          4.40%
51-6093
Upholsterers
                                                                            410
                                                                          0.01%
                                                                        $17.41 
                                                                        $17.73 
                                                                       $36,880 
                                                                          3.20%
51-6099
Textile, Apparel, and Furnishings Workers, All Other
                                                                             -8
                                                                             -8
                                                                        $11.58 
                                                                        $12.59 
                                                                       $26,190 
                                                                          4.40%
51-7000
Woodworkers
                                                                            800
                                                                          0.02%
                                                                        $16.68 
                                                                        $17.18 
                                                                       $35,730 
                                                                          4.20%
51-7011
Cabinetmakers and Bench Carpenters
                                                                            400
                                                                          0.01%
                                                                        $16.70 
                                                                        $17.67 
                                                                       $36,750 
                                                                          5.40%
51-7021
Furniture Finishers
                                                                            230
                                                                             -7
                                                                        $18.20 
                                                                        $17.93 
                                                                       $37,290 
                                                                          1.80%
51-7040
Woodworking Machine Setters, Operators, and Tenders
                                                                            120
                                                                             -7
                                                                        $15.75 
                                                                        $15.08 
                                                                       $31,360 
                                                                          5.50%
51-7099
Woodworkers, All Other
                                                                             -8
                                                                             -8
                                                                        $13.82 
                                                                        $14.60 
                                                                       $30,360 
                                                                          2.80%
51-8000
Plant and System Operators
                                                                         10,250
                                                                          0.20%
                                                                        $30.65 
                                                                        $29.79 
                                                                       $61,950 
                                                                          1.00%
51-8010
Power Plant Operators, Distributors, and Dispatchers
                                                                             50
                                                                             -7
                                                                        $46.85 
                                                                        $42.77 
                                                                       $88,960 
                                                                          5.60%
51-8013
Power Plant Operators
                                                                             40
                                                                             -7
                                                                        $48.76 
                                                                        $45.15 
                                                                       $93,910 
                                                                          6.00%
51-8021
Stationary Engineers and Boiler Operators
                                                                            120
                                                                             -7
                                                                        $31.34 
                                                                        $30.67 
                                                                       $63,790 
                                                                          3.90%
51-8090
Miscellaneous Plant and System Operators
                                                                         10,050
                                                                          0.20%
                                                                        $30.62 
                                                                        $29.72 
                                                                       $61,830 
                                                                          1.00%
51-8092
Gas Plant Operators
                                                                          3,440
                                                                          0.07%
                                                                        $31.07 
                                                                        $30.43 
                                                                       $63,290 
                                                                          1.50%
51-8093
Petroleum Pump System Operators, Refinery Operators, and Gaugers
                                                                          6,290
                                                                          0.12%
                                                                        $30.37 
                                                                        $29.38 
                                                                       $61,110 
                                                                          1.40%
51-8099
Plant and System Operators, All Other
                                                                            320
                                                                          0.01%
                                                                        $30.50 
                                                                        $28.93 
                                                                       $60,180 
                                                                          6.00%
51-9000
Other Production Occupations
                                                                         25,810
                                                                          0.51%
                                                                        $14.66 
                                                                        $16.41 
                                                                       $34,130 
                                                                          1.30%
51-9010
Chemical Processing Machine Setters, Operators, and Tenders
                                                                            410
                                                                          0.01%
                                                                        $26.82 
                                                                        $26.52 
                                                                       $55,160 
                                                                          6.60%
51-9011
Chemical Equipment Operators and Tenders
                                                                            390
                                                                          0.01%
                                                                        $27.13 
                                                                        $26.80 
                                                                       $55,750 
                                                                          6.80%
51-9020
Crushing, Grinding, Polishing, Mixing, and Blending Workers
                                                                            510
                                                                          0.01%
                                                                        $16.45 
                                                                        $16.49 
                                                                       $34,310 
                                                                          4.30%
51-9021
Crushing, Grinding, and Polishing Machine Setters, Operators, and Tenders
                                                                             40
                                                                             -7
                                                                        $17.90 
                                                                        $19.13 
                                                                       $39,780 
                                                                          4.30%
51-9023
Mixing and Blending Machine Setters, Operators, and Tenders
                                                                            450
                                                                          0.01%
                                                                        $15.87 
                                                                        $16.18 
                                                                       $33,650 
                                                                          4.60%
51-9030
Cutting Workers
                                                                            120
                                                                             -7
                                                                        $12.97 
                                                                        $13.52 
                                                                       $28,110 
                                                                          5.40%
51-9032
Cutting and Slicing Machine Setters, Operators, and Tenders
                                                                            100
                                                                             -7
                                                                        $12.96 
                                                                        $13.64 
                                                                       $28,380 
                                                                          6.80%
51-9061
Inspectors, Testers, Sorters, Samplers, and Weighers
                                                                         10,590
                                                                          0.21%
                                                                        $16.56 
                                                                        $18.54 
                                                                       $38,570 
                                                                          1.60%
51-9111
Packaging and Filling Machine Operators and Tenders
                                                                          5,580
                                                                          0.11%
                                                                        $12.90 
                                                                        $13.44 
                                                                       $27,960 
                                                                          1.50%
51-9120
Painting Workers
                                                                          2,960
                                                                          0.06%
                                                                        $18.36 
                                                                        $19.34 
                                                                       $40,230 
                                                                          2.10%
51-9121
Coating, Painting, and Spraying Machine Setters, Operators, and Tenders
                                                                            340
                                                                          0.01%
                                                                        $15.44 
                                                                        $15.82 
                                                                       $32,900 
                                                                          4.80%
51-9122
Painters, Transportation Equipment
                                                                          2,610
                                                                          0.05%
                                                                        $18.71 
                                                                        $19.77 
                                                                       $41,130 
                                                                          2.20%
51-9190
Miscellaneous Production Workers
                                                                          5,600
                                                                          0.11%
                                                                        $11.36 
                                                                        $13.11 
                                                                       $27,260 
                                                                          3.50%
51-9192
Cleaning, Washing, and Metal Pickling Equipment Operators and Tenders
                                                                             30
                                                                             -7
                                                                         $8.91 
                                                                         $9.51 
                                                                       $19,770 
                                                                          3.90%
51-9193
Cooling and Freezing Equipment Operators and Tenders
                                                                            250
                                                                             -7
                                                                        $14.19 
                                                                        $15.44 
                                                                       $32,110 
                                                                          4.30%
51-9194
Etchers and Engravers
                                                                             -8
                                                                             -8
                                                                        $11.57 
                                                                        $12.64 
                                                                       $26,300 
                                                                          6.50%
51-9196
Paper Goods Machine Setters, Operators, and Tenders
                                                                             90
                                                                             -7
                                                                        $13.79 
                                                                        $14.26 
                                                                       $29,660 
                                                                          6.00%
51-9198
Helpers--Production Workers
                                                                          3,730
                                                                          0.07%
                                                                        $10.29 
                                                                        $12.03 
                                                                       $25,030 
                                                                          6.90%
51-9199
Production Workers, All Other
                                                                          1,430
                                                                          0.03%
                                                                        $14.28 
                                                                        $15.47 
                                                                       $32,180 
                                                                          4.70%
53-0000
Transportation and Material Moving Occupations
                                                                      2,864,430
                                                                         56.37%
                                                                        $17.58 
                                                                        $20.04 
                                                                       $41,680 
                                                                          0.60%
53-1000
Supervisors of Transportation and Material Moving Workers
                                                                        132,950
                                                                          2.62%
                                                                        $25.16 
                                                                        $26.26 
                                                                       $54,630 
                                                                          0.50%
53-1011
Aircraft Cargo Handling Supervisors
                                                                          4,910
                                                                          0.10%
                                                                        $21.49 
                                                                        $23.28 
                                                                       $48,420 
                                                                          1.70%
53-1021
First-Line Supervisors of Helpers, Laborers, and Material Movers, Hand
                                                                         52,580
                                                                          1.03%
                                                                        $23.12 
                                                                        $24.07 
                                                                       $50,060 
                                                                          0.50%
53-1031
First-Line Supervisors of Transportation and Material-Moving Machine and Vehicle Operators
                                                                         75,460
                                                                          1.48%
                                                                        $27.13 
                                                                        $27.99 
                                                                       $58,220 
                                                                          0.60%
53-2000
Air Transportation Workers
                                                                        186,910
                                                                          3.68%
                                                                             -4
                                                                             -4
                                                                       $80,320 
                                                                          2.30%
53-2010
Aircraft Pilots and Flight Engineers
                                                                         88,500
                                                                          1.74%
                                                                             -4
                                                                             -4
                                                                      $119,850 
                                                                          2.90%
53-2011
Airline Pilots, Copilots, and Flight Engineers
                                                                         68,090
                                                                          1.34%
                                                                             -4
                                                                             -4
                                                                      $131,800 
                                                                          3.00%
53-2012
Commercial Pilots
                                                                         20,410
                                                                          0.40%
                                                                             -4
                                                                             -4
                                                                       $79,970 
                                                                          3.10%
53-2020
Air Traffic Controllers and Airfield Operations Specialists
                                                                          5,760
                                                                          0.11%
                                                                        $26.48 
                                                                        $28.73 
                                                                       $59,750 
                                                                          2.70%
53-2021
Air Traffic Controllers
                                                                          1,710
                                                                          0.03%
                                                                        $33.45 
                                                                        $37.41 
                                                                       $77,820 
                                                                          3.90%
53-2022
Airfield Operations Specialists
                                                                          4,050
                                                                          0.08%
                                                                        $23.21 
                                                                        $25.06 
                                                                       $52,130 
                                                                          2.90%
53-2031
Flight Attendants
                                                                         92,660
                                                                          1.82%
                                                                             -4
                                                                             -4
                                                                       $43,840 
                                                                          1.90%
53-3000
Motor Vehicle Operators
                                                                      1,527,740
                                                                         30.06%
                                                                        $17.99 
                                                                        $19.11 
                                                                       $39,740 
                                                                          0.40%
53-3011
Ambulance Drivers and Attendants, Except Emergency Medical Technicians
                                                                          1,950
                                                                          0.04%
                                                                        $11.34 
                                                                        $12.34 
                                                                       $25,660 
                                                                          3.50%
53-3020
Bus Drivers
                                                                        262,910
                                                                          5.17%
                                                                        $14.46 
                                                                        $15.09 
                                                                       $31,380 
                                                                          0.80%
53-3021
Bus Drivers, Transit and Intercity
                                                                         70,420
                                                                          1.39%
                                                                        $14.45 
                                                                        $15.55 
                                                                       $32,340 
                                                                          1.30%
53-3022
Bus Drivers, School or Special Client
                                                                        192,490
                                                                          3.79%
                                                                        $14.47 
                                                                        $14.92 
                                                                       $31,020 
                                                                          0.90%
53-3030
Driver/Sales Workers and Truck Drivers
                                                                      1,176,270
                                                                         23.15%
                                                                        $19.55 
                                                                        $20.47 
                                                                       $42,590 
                                                                          0.40%
53-3031
Driver/Sales Workers
                                                                         12,390
                                                                          0.24%
                                                                        $15.58 
                                                                        $16.49 
                                                                       $34,290 
                                                                          3.50%
53-3032
Heavy and Tractor-Trailer Truck Drivers
                                                                        922,190
                                                                         18.15%
                                                                        $19.40 
                                                                        $20.19 
                                                                       $42,000 
                                                                          0.40%
53-3033
Light Truck or Delivery Services Drivers
                                                                        241,680
                                                                          4.76%
                                                                        $20.94 
                                                                        $21.76 
                                                                       $45,250 
                                                                          0.80%
53-3041
Taxi Drivers and Chauffeurs
                                                                         79,690
                                                                          1.57%
                                                                        $11.27 
                                                                        $12.49 
                                                                       $25,980 
                                                                          1.30%
53-3099
Motor Vehicle Operators, All Other
                                                                          6,930
                                                                          0.14%
                                                                        $16.23 
                                                                        $17.27 
                                                                       $35,920 
                                                                          2.70%
53-4000
Rail Transportation Workers
                                                                        107,550
                                                                          2.12%
                                                                        $25.47 
                                                                        $26.27 
                                                                       $54,650 
                                                                          1.40%
53-4010
Locomotive Engineers and Operators
                                                                         42,010
                                                                          0.83%
                                                                        $24.73 
                                                                        $25.92 
                                                                       $53,900 
                                                                          1.90%
53-4011
Locomotive Engineers
                                                                         35,600
                                                                          0.70%
                                                                        $25.51 
                                                                        $26.72 
                                                                       $55,570 
                                                                          2.20%
53-4012
Locomotive Firers
                                                                          1,850
                                                                          0.04%
                                                                        $21.58 
                                                                        $23.03 
                                                                       $47,910 
                                                                          2.80%
53-4013
Rail Yard Engineers, Dinkey Operators, and Hostlers
                                                                          4,560
                                                                          0.09%
                                                                        $19.92 
                                                                        $20.81 
                                                                       $43,290 
                                                                          2.10%
53-4021
Railroad Brake, Signal, and Switch Operators
                                                                         23,590
                                                                          0.46%
                                                                        $24.42 
                                                                        $23.93 
                                                                       $49,780 
                                                                          2.40%
53-4031
Railroad Conductors and Yardmasters
                                                                         38,650
                                                                          0.76%
                                                                        $27.06 
                                                                        $28.04 
                                                                       $58,310 
                                                                          1.80%
53-4041
Subway and Streetcar Operators
                                                                             -8
                                                                             -8
                                                                        $26.64 
                                                                        $25.31 
                                                                       $52,650 
                                                                          4.50%
53-4099
Rail Transportation Workers, All Other
                                                                             -8
                                                                             -8
                                                                        $26.93 
                                                                        $27.44 
                                                                       $57,080 
                                                                          4.70%
53-5000
Water Transportation Workers
                                                                         53,180
                                                                          1.05%
                                                                        $25.67 
                                                                        $29.63 
                                                                       $61,620 
                                                                          2.20%
53-5011
Sailors and Marine Oilers
                                                                         20,950
                                                                          0.41%
                                                                        $18.26 
                                                                        $19.69 
                                                                       $40,960 
                                                                          2.20%
53-5020
Ship and Boat Captains and Operators
                                                                         25,060
                                                                          0.49%
                                                                        $32.71 
                                                                        $35.45 
                                                                       $73,740 
                                                                          2.50%
53-5021
Captains, Mates, and Pilots of Water Vessels
                                                                         22,880
                                                                          0.45%
                                                                        $34.54 
                                                                        $37.23 
                                                                       $77,440 
                                                                          2.50%
53-5022
Motorboat Operators
                                                                          2,180
                                                                          0.04%
                                                                        $14.50 
                                                                        $16.74 
                                                                       $34,810 
                                                                          5.00%
53-5031
Ship Engineers
                                                                          7,160
                                                                          0.14%
                                                                        $35.20 
                                                                        $38.30 
                                                                       $79,660 
                                                                          3.60%
53-6000
Other Transportation Workers
                                                                         53,800
                                                                          1.06%
                                                                        $15.77 
                                                                        $18.21 
                                                                       $37,880 
                                                                          1.50%
53-6011
Bridge and Lock Tenders
                                                                             -8
                                                                             -8
                                                                        $24.25 
                                                                        $23.04 
                                                                       $47,920 
                                                                          3.00%
53-6021
Parking Lot Attendants
                                                                            560
                                                                          0.01%
                                                                         $9.56 
                                                                        $10.89 
                                                                       $22,650 
                                                                          4.80%
53-6031
Automotive and Watercraft Service Attendants
                                                                          1,690
                                                                          0.03%
                                                                        $11.94 
                                                                        $12.80 
                                                                       $26,630 
                                                                          3.70%
53-6051
Transportation Inspectors
                                                                          9,170
                                                                          0.18%
                                                                        $28.58 
                                                                        $30.70 
                                                                       $63,860 
                                                                          2.40%
53-6061
Transportation Attendants, Except Flight Attendants
                                                                         13,090
                                                                          0.26%
                                                                        $12.42 
                                                                        $13.48 
                                                                       $28,040 
                                                                          2.40%
53-6099
Transportation Workers, All Other
                                                                         28,870
                                                                          0.57%
                                                                        $16.25 
                                                                        $16.77 
                                                                       $34,890 
                                                                          2.00%
53-7000
Material Moving Workers
                                                                        802,310
                                                                         15.79%
                                                                        $13.92 
                                                                        $15.11 
                                                                       $31,430 
                                                                          0.70%
53-7011
Conveyor Operators and Tenders
                                                                         13,340
                                                                          0.26%
                                                                        $14.78 
                                                                        $16.15 
                                                                       $33,600 
                                                                          1.70%
53-7021
Crane and Tower Operators
                                                                          6,300
                                                                          0.12%
                                                                        $26.68 
                                                                        $27.87 
                                                                       $57,960 
                                                                          3.80%
53-7030
Dredge, Excavating, and Loading Machine Operators
                                                                            980
                                                                          0.02%
                                                                        $16.84 
                                                                        $18.74 
                                                                       $38,980 
                                                                          4.80%
53-7032
Excavating and Loading Machine and Dragline Operators
                                                                            970
                                                                          0.02%
                                                                        $16.88 
                                                                        $18.77 
                                                                       $39,030 
                                                                          4.80%
53-7041
Hoist and Winch Operators
                                                                            590
                                                                          0.01%
                                                                        $31.55 
                                                                        $30.11 
                                                                       $62,630 
                                                                          3.10%
53-7051
Industrial Truck and Tractor Operators
                                                                        127,010
                                                                          2.50%
                                                                        $15.59 
                                                                        $16.85 
                                                                       $35,040 
                                                                          1.80%
53-7060
Laborers and Material Movers, Hand
                                                                        632,300
                                                                         12.44%
                                                                        $13.34 
                                                                        $14.33 
                                                                       $29,800 
                                                                          0.40%
53-7061
Cleaners of Vehicles and Equipment
                                                                         22,350
                                                                          0.44%
                                                                        $11.32 
                                                                        $13.41 
                                                                       $27,890 
                                                                          1.30%
53-7062
Laborers and Freight, Stock, and Material Movers, Hand
                                                                        526,670
                                                                         10.36%
                                                                        $13.22 
                                                                        $14.31 
                                                                       $29,770 
                                                                          0.50%
53-7063
Machine Feeders and Offbearers
                                                                         21,090
                                                                          0.42%
                                                                        $18.39 
                                                                        $18.15 
                                                                       $37,760 
                                                                          0.70%
53-7064
Packers and Packagers, Hand
                                                                         62,190
                                                                          1.22%
                                                                        $13.19 
                                                                        $13.50 
                                                                       $28,080 
                                                                          1.20%
53-7070
Pumping Station Operators
                                                                          3,610
                                                                          0.07%
                                                                        $27.14 
                                                                        $26.89 
                                                                       $55,940 
                                                                          1.60%
53-7071
Gas Compressor and Gas Pumping Station Operators
                                                                          2,020
                                                                          0.04%
                                                                        $27.69 
                                                                        $27.93 
                                                                       $58,090 
                                                                          1.10%
53-7072
Pump Operators, Except Wellhead Pumpers
                                                                          1,460
                                                                          0.03%
                                                                        $26.42 
                                                                        $26.12 
                                                                       $54,320 
                                                                          3.50%
53-7073
Wellhead Pumpers
                                                                            130
                                                                             -7
                                                                        $19.69 
                                                                        $19.48 
                                                                       $40,530 
                                                                          5.90%
53-7081
Refuse and Recyclable Material Collectors
                                                                            360
                                                                          0.01%
                                                                        $19.44 
                                                                        $19.54 
                                                                       $40,650 
                                                                          4.30%
53-7121
Tank Car, Truck, and Ship Loaders
                                                                          8,530
                                                                          0.17%
                                                                        $20.97 
                                                                        $22.55 
                                                                       $46,910 
                                                                          3.40%
53-7199
Material Moving Workers, All Other
                                                                          9,300
                                                                          0.18%
                                                                        $21.14 
                                                                        $21.59 
                                                                       $44,920 
                                                                          3.90%

About May 2012 National Industry-Specific Occupational Employment and Wage Estimates 
(1) Estimates for detailed occupations do not sum to the totals because the totals include occupations not shown separately. Estimates do not include self-employed workers. 
(2) Annual wages have been calculated by multiplying the hourly mean wage by a "year-round, full-time" figure of 2,080 hours; for those occupations where there is not an hourly mean wage published, the annual wage has been directly calculated from the reported survey data. 
(3) The relative standard error (RSE) is a measure of the reliability of a survey statistic. The smaller the relative standard error, the more precise the estimate. 
(5) This wage is equal to or greater than $90.00 per hour or $187,199 per year. 
(8) Estimate not released. 
Other OES estimates and related information: May 2012 National Occupational Employment and Wage Estimates (cross-industry estimates) May 2012 State Occupational Employment and Wage Estimates (cross-industry estimates) May 2012 Metropolitan and Nonmetropolitan Area Occupational Employment and Wage Estimates (cross-industry estimates) May 2012 National Industry-Specific Occupational Employment and Wage Estimates May 2012 Occupation Profiles Technical notes 
Last Modified Date: March 29, 2013 


Appendix F: Cumulative TWIC Programmatic Costs

In this section, we discuss the history of the TWIC maritime program and the cumulative programmatic costs.

F.1 Transportation Worker Identification Credential
Section 102 of the MTSA requires the Secretary of the DHS to issue a biometric transportation security card to individuals with unescorted access to secure areas of vessels and facilities.  Under this authority, DHS, through the Coast Guard and the TSA, published a notice of proposed rulemaking (TWIC 1 NPRM) to implement the TWIC program in the maritime sector.  On January 27, 2007, DHS, through the Coast Guard and TSA, issued a final rule (TWIC 1 final rule) that required all credentialed merchant mariners and individuals granted unescorted access to secure areas of MTSA-regulated vessels or facilities to obtain a TWIC.  To date, TSA has issued approximately 2.5 million TWIC cards, which have functioned primarily as a visual identity badge.

In this final rule, the Coast Guard requires owners and operators of certain vessels and facilities regulated by the Coast Guard under 33 CFR Chapter I, subchapter H, to use electronic readers designed to work with TWIC as an access control measure.  This also adds new requirements associated with electronic TWIC inspection programs, including recordkeeping requirements for those owners/operators required to implement an electronic TWIC inspection program, and amendments to security plans previously approved by the Coast Guard to incorporate TWIC requirements.

F.2 TWIC Programmatic Costs: TWIC Final Rule and TWIC NPRM
Figure F.1 displays an estimation of the costs associated with the TWIC maritime program requirements as codified by the Coast Guard and TSA.  


Figure F.1 Overview of TWIC Programmatic Costs ($ Millions)
                                       
                                       

The cost estimate for the 2007 TWIC Final Rule contained a variety of costs, such as costs to mariners to obtain TWIC cards and costs to TSA to develop and maintain the TWIC system.  The TWIC Reader final rule will not impact most of the costs categories and affected entities listed in the 2007 TWIC Final Rule.  There will be no difference in the underlying costs to produce and obtain TWIC cards.  Approximately half of the costs for the 2007 TWIC Final Rule will not be impacted by the TWIC Reader final rule, as demonstrated in Table F1.  
 
Table F1 TWIC Programmatic Costs by Cost Component
Component
                                     2007 
                            TWIC 1 Final Rule Cost
                         TWIC Reader Final Rule Cost*
                             Impact of Final Rule
Enrollment Opportunity Costs
                                                                       $196.70 
                                                                         $0.00 
                                   No change
Enrollment Service Costs
                                                                        $94.90 
                                                                         $0.00 
                                   No change
Security Threat Assessments
                                                                        $57.90 
                                                                         $0.00 
                                   No change
TSA System Costs
                                                                        $44.30 
                                                                         $0.00 
                                   No change
Appeals and Waivers Opportunity Costs
                                                                         $5.90 
                                                                         $0.00 
                                   No change
Card Production
                                                                        $31.90 
                                                                         $0.00 
                                   No change
Issuance Opportunity Costs
                                                                       $329.20 
                                                                         $0.00 
                                   No change
Program Office Support
                                                                        $19.90 
                                                                         $0.00 
                                   No change
Operational Costs, Facilities
                                                                       $326.50 
                                                                       $153.64 
                      Cost of readers for 525 facilities
Operational Costs, Vessels
                                                                       $638.80 
                                                                         $0.07 
                         Cost of readers for 1 vessel
Operational Costs, OCS Facilities
                                                                        $10.10 
                                                                         $0.00 
                                   No change
TOTAL
                                                                     $1,756.10 
                                                                       $153.71 
                                       
* Note: The final rule includes costs due to card replacement and delays due to failed reads.

A subset of facilities and a small subset of vessels will incur additional costs under the final rule to implement electronic TWIC inspection programs.  Figure F.3 displays the industry costs for vessels and facilities by year for the TWIC Final Rule and the TWIC Reader final rule.  The highest burden occurs in the years in which the readers are installed or replaced.  We show costs from 2006-2025 to account for the first year of TWIC 1 through the 10-year period of analysis estimated in this RA for the electronic TWIC inspection requirements.



Table F2 TWIC Costs by Type of Entity
                                       
                                    Vessels
                                  Facilities
                                       
                            2007 TWIC 1 Final Rule
                               Reader Final Rule
                                     Total
                            2007 TWIC 1 Final Rule
                               Reader Final Rule
                                     Total
                                     2006
                                     $639 
                                    $0.00 
                                     $639 
                                     $327 
                                      $0 
                                     $327 
                                     2007
                                     $656 
                                    $0.00 
                                     $656 
                                     $335 
                                      $0 
                                     $335 
                                     2008
                                     $669 
                                    $0.00 
                                     $669 
                                     $342 
                                      $0 
                                     $342 
                                     2009
                                     $674 
                                    $0.00 
                                     $674 
                                     $344 
                                      $0 
                                     $344 
                                     2010
                                     $682 
                                    $0.00 
                                     $682 
                                     $349 
                                      $0 
                                     $349 
                                     2011
                                     $696 
                                    $0.00 
                                     $696 
                                     $356 
                                      $0 
                                     $356 
                                     2012
                                     $709 
                                    $0.00 
                                     $709 
                                     $362 
                                      $0 
                                     $362 
                                     2013
                                     $720 
                                    $0.00 
                                     $720 
                                     $368 
                                      $0 
                                     $368 
                                     2014
                                     $732 
                                    $0.00 
                                     $732 
                                     $374 
                                      $0 
                                     $374 
                                     2015
                                     $745 
                                    $0.00 
                                     $745 
                                     $381 
                                      $0 
                                     $381 
                                     2016
                                     $758 
                                    $0.02 
                                     $758 
                                     $387 
                                     $21 
                                     $409 
                                     2017
                                     $771 
                                    $0.02 
                                     $771 
                                     $394 
                                     $22 
                                     $416 
                                     2018
                                     $784 
                                    $0.02 
                                     $784 
                                     $401 
                                     $22 
                                     $423 
                                     2019
                                     $798 
                                    $0.02 
                                     $798 
                                     $408 
                                     $23 
                                     $430 
                                     2020
                                     $811 
                                    $0.02 
                                     $811 
                                     $415 
                                     $23 
                                     $438 
                                     2021
                                     $825 
                                    $0.02 
                                     $825 
                                     $422 
                                     $23 
                                     $445 
                                     2022
                                     $839 
                                    $0.02 
                                     $839 
                                     $429 
                                     $24 
                                     $453 
                                     2023
                                     $854 
                                    $0.02 
                                     $854 
                                     $436 
                                     $24 
                                     $461 
                                     2024
                                     $869 
                                    $0.02 
                                     $869 
                                     $444 
                                     $25 
                                     $469 
                                     2025
                                     $884 
                                    $0.02 
                                     $884 
                                     $452 
                                     $25 
                                     $477 


Appendix G: Costs by Provision

The following tables break down the costs described in the regulatory analysis by the general provision as written in the proposed regulation.  The costs by provision have been broken down for vessels and facilities.  While we were able to approximate the costs by provision, there is no way to break down the benefits of this rulemaking by provision.  The primary provision of this final rule is the electronic TWIC inspection requirements, which spell out whether or not a vessel or facility will be required to implement electronic TWIC inspection programs.  The subsequent provisions for security plan amendments, recordkeeping, and CCL updates will only be required if electronic TWIC inspections are required.  As such, without the primary requirement in place, the other provisions are not necessary.  As such, we view these provisions as complementary and cannot distinguish independent benefits from a specific provision, but rather must consider benefits as a whole.

The following figures detail the costs by provision for the 10-year period of analysis at a 7% discount rate.

Table G1: Ten Year Costs by Provision (7% Discount Rate)
                                       
                                    Vessels
                                  Facilities
                                     Total
                         TWIC Inspection Requirements
                                       
                                       
                                       
                                                           Risk Group A 101.520
                                   $22,525 
                                 $144,240,671 
                                 $144,263,195 
                                                           Risk Group B 101.525
                                       
                                       
                                       
                                                           Risk Group C 101.530
                                       
                                       
                                       
                   Security Plan Amendment 104.405; 105.405
                                    $1,251 
                                   $843,902 
                                   $845,153 
                        Recordkeeping 104.235; 105.225
                                    $3,956 
                                  $2,616,325 
                                  $2,620,282 
                      Cancelled Card List Updates 101.520
                                    $9,777 
                                  $5,940,864 
                                  $5,950,641 
                                     Total
                                   $37,509 
                                 $153,641,761 
                                 $153,679,271 

Table G2: Annualized Costs by Provision (7% Discount Rate)
                                       
                                    Vessels
                                  Facilities
                                     Total
                         TWIC Inspection Requirements
                                       
                                       
                                       
                                                           Risk Group A 101.520
                                    $3,207 
                                 $20,326,626 
                                 $20,329,834 
                                                           Risk Group B 101.525
                                       
                                       
                                       
                                                           Risk Group C 101.530
                                       
                                       
                                       
                   Security Plan Amendment 104.405; 105.405
                                     $178 
                                   $372,506 
                                   $372,684 
                        Recordkeeping 104.235; 105.225
                                     $563 
                                   $352,247 
                                   $352,810 
                      Cancelled Card List Updates 101.520
                                    $1,392 
                                   $845,845 
                                   $847,237 
                                     Total
                                    $5,340 
                                 $21,897,225 
                                 $21,902,565 


