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Our Comments.pdf

idp-imaging-comments-18jun2013.pdf
Preview of our comments
🔗 Source: papersplease.org
📊 Size: 107 KB
📄 Pages: 16 pages
⬇️ Downloads: 97

Summary

The Identity Project (IDP) submits comments in response to the TSA's proposed rule on passenger screening using advanced imaging technology, objecting on grounds that:
1. The TSA fails to recognize travel by air as a right, not a privilege, and thus the proposed rule is subject to strict scrutiny.
2. The TSA errs in claiming individuals are not "small entities" under the Regulatory Flexibility Act, and must publish a new analysis considering the impact on individuals.
3. The rules are unconstitutionally vague and overbroad, lacking definitions of "submit" and "screening", and denying the right to travel to individuals who pose no threat.
The IDP argues that the proposed rule should be withdrawn, and if not, rejected by the OMB for failure to include the required analysis, and that the TSA should open a notice-and-comment rulemaking to define "submit" and "screening" with sufficient specificity.

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Description

The Identity Project (IDP) submits comments in response to the TSA's proposed rule on passenger screening using advanced imaging technology, objecting on...

Technical Information

  • File Format: PDF
  • File Size: 107 KB
  • Pages: 16
  • Language: EN
  • Total Downloads: 97
  • Last Updated: 3 weeks ago

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