WHTI Call-to-Action - Buffalo Niagara Partnership

My last e-mail to you was about the continued confusion regarding what will be required personal identification at CanAm border crossings in the Western Hemisphere Travel Initiative (WHTI). This e-mail addresses a related WHTI issue of the implementation of its requirements as expressed in a "Notice of Proposed Rulemaking (NPRM)."

A "Notice of Proposed Rulemaking" is issued by the US government when one of its regulatory agencies wishes to add, remove, or change a rule or regulation. Congress created this rule to ensure that these federal agencies solicit and respond to comments from those who will likely be affected by the proposed change.

The NPRM regarding implementation of WHTI has features that we support such as removing children from the WHTI documentation requirements, and suggesting alternative documents to the passport, including enhanced American and Canadian driver's licenses.

However, the rule's proposed timeline for WHTI's implementation creates very serious economic consequences for communities - like ours - along the CanAm Border. This is a very important concern to us.

We believe that the proposed rule must be strengthened to require the Department of Homeland Security (DHS) and the Department of State (DOS) to work more closely with the Canadian government and state governments in the US to ensure that implementation is smooth, effective and facilitates travel and trade across our border with Canada. Additionally, the federal government should recognize the states' need for financial and technical assistance in order to implement the enhanced driver's license.

It is our position that implementing WHTI right is better than implementing it quickly, and thus we want DHS and DOS to amend the proposed rule to allow sufficient time to implement the procedures proposed in the NPRM.

In this matter, I again call for help from our members. Please contact the DHS to let your voice be heard. The deadline for comments is August 27. Attached is the text of a proposed letter for you to send to DHS and DOS officials (Microsoft Word file). I encourage you to print it on your letterhead and mail it in right away. Contact your co-workers and family to do the same.

While a "Notice of Proposed Rulemaking" sounds arcane, let me assure you, it is a crucial part of an important issue for our region. A significant portion of Buffalo Niagara's economy and our life in general is tied to us being a bi-national community, the very essence of which is threatened by adoption of the proposed rule as is.

Also keep in mind that a prior notice of the proposed rule generated fewer than 1,000 responses, which prompted DHS officials to comment that that this must not be an important issue since more people did not write!

Please join me in letting DHS and DOS know exactly how important the appropriate implementation of WHTI is for the continued economic viability of our region.

Andrew J. Rudnick
President & CEO