The Honorable Michael Chertoff
Secretary Department of Homeland Security
On behalf of the International Association of Chiefs of Police (IACP), I am writing to provide our views regarding the Docket # DHS-2006-0030, Notice of Proposed Rule Making (NPRM)
on Minimum Standards for Driver's Licenses and Identification Cards Acceptable by Federal Agencies for Federal Purposes.
Founded in 1893, the IACP is the world's oldest and largest association of law enforcement executives, representing over 21,000 members in 100 countries. The goals of the IACP are to advance the science and art of police services; to develop and disseminate improved administrative, technical and operational practices and promote their use in police work; to foster police cooperation and the exchange of information and experience among police administrators throughout the world; to bring about recruitment and training in the police profession of qualified persons; and to encourage adherence of all police officers to high professional standards of performance and
Of particular concern is the ability of law enforcement to use identification cards in an efficient and non-burdensome manner - it is for these reasons that we are commenting on DHS-2206-0030.
Specifically, we are extremely concerned about section 37.19, which would require the use of encryption technology in the machine readable zone (MRZ) of ID cards.
The IACP is strongly opposed to encrypting MRZ ID data that is currently attained through bar codes. It is imperative that law enforcement agencies and officers be able to readily verify that the information that is human-readable on the front is the same information contained electronically within the card. If this data were encrypted, as proposed in section 37.19, the process would likely take an inordinate amount of time.
This would have the potential to cause an array of problems - most notably it could put the officer at risk because of the inability to verify the identity of the individual whose ID they are checking.
Also a concern to the IACP with the use of encryption technology is the cost that may be born to state, tribal and local law enforcement if they were required to purchase machines that interface with the encrypted information. Most agencies in this country are small to mid-sized departments whose budgets are already stretched thin and will not be able to afford this type of technology.
In this vein, it is our understanding that at least seventeen states are in the process of implementing Traffic and Criminal Software (TraCS) for the purpose of electronically recording driver and vehicle data during traffic stops or the completion of traffic crash reports. This process allows real-time information on traffic stops captured by
electronically recording barcode information in the police cruiser. The cost to state, tribal, and local municipalities to alter their existing TraCS software and equipment would be burdensome and have a negative impact on state, tribal, and local law enforcement efficiencies.
The IACP understands and recognizes fully the importance of identification security and the need to operate a secure driver's license and identification card issuance policy.However, this must not be done at the expense of law enforcement being able to successfully perform
their duties.
Law enforcement's ability to readily access readable ID data is crucial - as we know, while planning, conducting surveillance or securing the resources necessary to mount their attacks, terrorists often live in our communities, travel on our highways, and shop in our stores. As we discovered in the aftermath of September 11th, several of the terrorists involved in those attacks had routine encounters with state and local law enforcement officials in the weeks and months before the attack. State, tribal, and local law enforcement officers must easily and instantly verify who they are encountering so that they may identify and apprehend suspected terrorists before they strike.
Thank you for attention to this important matter. IACP stands ready to assist you in anyway possible.
Sincerely,
Joseph C. Carter
President, International Association of
Chiefs of Police
515 North Washington Street
Alexandria, VA 22314-2357
