Documents Required for Travelers Entering the United States at Sea and Land Ports-of-Entry from within the Western Hemisphere

DEPARTMENT OF HOMELAND SECURITY DOCKET NO. USCBP-2007-0061, RIN 1651-AA69 Documents Required for Travelers Departing From or Arriving in the United States at Sea and Land Ports-of-Entry from within the Western Hemisphere Comments of the American Bus Association (ABA) On the Notice of Proposed Rulemaking August 27, 2007 The American Bus Association (ABA) appreciates the opportunity to comment on the Department of Homeland Security (DHS) and Department of State?s (DOS) Notice of Proposed Rulemaking (NPRM) in the above titled proceeding. The ABA is the premier private bus industry trade association in North America. The ABA is home to some 3600 member companies, with approximately 800 bus company members, 300 tour operators, and 2500 travel industry attractions and destination marketing organizations. The bus operator members provide all manner of transportation services to the public including: fixed route scheduled service, charter and tour, airport shuttle and commuter services throughout North America. ABA supports the efforts of both DOS and DHS to simplify the processing of cross-border land and sea travelers, while maintaining the integrity of our national security systems and enabling continued secure transportation. ABA believes that the Western Hemisphere Travel Initiative (WHTI) could have a significant economic impact on travel, tourism, and the affiliated industries within the tourism supply chain. Principally, ABA is concerned that without widespread access to approved travel documents, appropriate reader devices in place to facilitate expedient border crossings, and a common understanding by the public of the travel requirements that cross-border travel and tourism-related commerce will be negatively impacted and suffer as a result of WHTI implementation for land and sea travelers. The ABA is very supportive of the efforts of DHS and DOS to respond to concerns over document requirements for children and young adults (under the age of 19) by removing certain WHTI requirements for land and sea travel. By allowing children traveling with school, religious or sports-groups to cross the border with their birth certificates as their approved travel document helps to ensure widespread access to approved travel documents and will facilitate travel. However, by requiring children of the same age that are traveling with their parents to produce a passport or passport card and comply with a different set of travel procedures, seems to confuse the intent and clarity of the rule. ABA also supports the availability of alternative documentation for WHTI implementation for land travel. In having the opportunity to apply for and utilize documents such as NEXUS, FAST, passport cards, and enhanced driver?s licenses (with pilots currently underway in WA and VT), access to approved travel documents will be greatly increased. With application fees for the aforementioned alternative documents running about $45 on average, these documents provide a realistic alternative to travelers seeking to avoid the time consuming and costly passport application process, and they could even provide some valuable lessons learned as the passport application process is overhauled in coming years. However, ABA would hope that DHS and DOS would ensure that a critical mass of these approved documents is in circulation before full implementation is achieved. As, the enhanced driver?s licenses are only beginning to be tested through pilot programs and the passport card has yet to be made available, the Congressionally mandated implementation date of June 2009 would offer the most efficient solution to ensuring wide spread compliance with the WHTI document requirements. The extensive passport application backups witnessed during the recent full implementation of the air-related WHTI requirements would likely be magnified without the multiple access points offered by the alternative documents for land trav…