I already posted about this Request for Information (RFI) on LinkedIn and Facebook, but I wanted to highlight the details of the Department of Homeland Security’s recent request (see PDF or text version).
The RFI delves into a number of questions about treating mobile (i.e. smartphone) driver’s licenses as REAL ID-compliant. The RFI itself states:
DHS invites comments on any aspect of this RFI, and welcomes any additional comments and information that would promote an understanding of the broader implications of acceptance of mobile or digital driver’s licenses by Federal agencies for official purposes. This includes comments relating to the economic, privacy, security, environmental, energy, or federalism impacts that might result from a future rulemaking based on input received as a result of this RFI. In addition, DHS includes specific questions in this RFI immediately following the discussion of the relevant issues.
The RFI can be responded to by any member of the general public, although it is expected that the majority of responses will come from mobile driver’s license vendors and various interest groups. And trust me, there is a wide range of interest groups that are interested in this topic, and in the broader topic of REAL ID in general. Federalism itself is a popular topic when discussing REAL ID.
(Although personally, I believe that if the Federal Government is controlling air travel, and if the Federal Government is…obviously…controlling Federal facilities, then the Federal Government can implement rule-making regarding access. Needless to say, since all 50 states and several territories have adopted REAL ID, the decision has been made.)
While respondents can conceivably talk about anything in their responses, DHS (as noted above) has 15 specific questions to which it is seeking information (see section IV beginning on page 20325). Some are general, such as general questions about security, and some are more specific, such as question 4, which specifically focuses on DHS adoption of requirements derived from “Industry Standard ISO/IEC 18013–5: Communication Interfaces Between mDL Device and Federal Agency, and Federal Agency and DMV.”
Responses to the RFI must be submitted by June 18, and are submitted electronically. (Read the Commenter’s Checklist, and note that DHS prefers that respondents address all 15 questions.) I’m sure that a number of companies and organizations are already starting to think about their responses.
Shameless plug: if you need assistance in managing, organizing, writing, or checking your response, contact me. As some of you already know, I have extensive experience in responding to RFIs, RFPs, and similar documents, and have been helping multiple companies with such responses under my Bredemarket consultancy.