After skimming through the REAL ID document just-released, here are a few comments. Source document: http://www.dhs.gov/xlibrary/assets/nprm_realid.pdf

As discussed below and in section II.E.6 of the NPRM, the recommended architecture for implementing these data exchanges does not create a national database, because it leaves the decision of how to conduct the exchanges in the hands of the States. Moreover, no Federal agency will operate the data exchanges affecting non-commercial driverbs licensing.

Translation: "REAL ID will not reside in a single database, but rather in a collaborative (clustered) environment, with each state's database constituting one portion of that environment (cluster.) And it's not a 'national' or 'federal' database because no Federal agency will operate it." Splitting hairs here, aren't we? A rose by any other name......

DHS believes that protecting the privacy of the personal information associated with implementation of the REAL ID Act is critical to maintaining the public trust that Government can provide basic services to its citizens while preserving their privacy.

Then to solidify the trust we're being asked to place in our government, DHS could start by calling this what it really is when you look past its wrappings and bureaucratic mumbo-jumbo: a National ID Card.

Further, in almost all cases there is no way to verify independently from documents presented that an address is a personbs principal address. A mortgage statement or lease may indicate that a person owns or rents property in a particular place, and while the landlord or bank holding the mortgage could verify this, it does not establish that this is the personbs principal residence, just that the ownership or rental is legitimate. In addition, the cost to States of verifying a multitude of documents presented to establish address, such as utility bills, leases, mortgages, or other documents, is potentially significant. In spite of these limitations, there is a need for some reliability in the information presented for principal residence, as evidenced by the experience of the 9/11 hijackers and how they obtained Virginia driverbs licenses (see section II.D.3). Therefore, DHS is 49 proposing that the States require each applicant to present at least two documents that include his or her name and current principal residence. However, the States will retain the flexibility to determine for themselves precisely which documents, or combination of documents, an applicant must present to satisfy this requirement and how a State will validate or verify this information. The proposed regulation would require States to establish a written policy identifying acceptable documents and how, or if, they will be independently validated or verified. The proposal would also require that States provide this information to DHS as part of their initial certification package and whenever this

Translation: "While it's really difficult, if not impossible, to verify independently someone's domicile address, it's important to ensure accurate location information on subjects listed in this new National ID database to prevent another 9/11 from happening. But because it's such a hard requirement to get our hands around -- Americans are just so darn free and mobile -- a utility bill or bank statement probably would be good enough....especially for government work."

The primary benefit of REAL ID is to improve the security and lessen the vulnerability of federal buildings, nuclear facilities, and aircraft to terrorist attack.

Memo to DHS: Reinforced cockpit doors fixed the primary vulnerability responsible for 9/11 and were a long-overdue countermeasure. And exactly how many members of the American public and/or visiting tourists just 'drop by' a nuclear facility that you need to confirm their IDs before granting entry? Are you saying that this is the case, and I can walk right into my local nuclear power plant and see the atoms in action? If so, you've got much bigger problems to worry about than verifying my ID.

The potential ancillary benefits of REAL ID are numerous, as it would be more difficult to fraudulently obtain a legitimate license and would be substantially more costly to create a false license. These other benefits include reducing identity theft, unqualified driving, and fraudulent activities facilitated by less secure driverbs licenses such as fraudulent access to government subsidies and welfare programs, illegal immigration, unlawful employment, unlawful access to firearms, voter fraud, and possibly underage drinking and smoking. DHS assumes that REAL ID would bring about changes on the margin that would potentially increase security and reduce illegal behavior. Because the 109 size of the economic costs that REAL ID serves to reduce on the margin are so large, however, a relatively small impact of REAL ID may lead to significant benefits.

Let's not forget making it easier for identity theft to occur via a closed networked cluster of databases containing very private information and the likely ability (abuse) to use this de facto National ID card for marketing purposes or other purposes not even remotely-related to the primary benefits you cited earlier. And this beauty, which is, quite literally, the LAST paragraph of this 160+ page document:

(a) States that issue driverbs licenses and identification cards that do not satisfy the standards of this Part after May 11, 2008, must ensure that such driverbs licenses and identification cards-- (1) Clearly state, on their face in bold lettering, as well as in the machine readable zone if the card contains one, that they may not be accepted by any Federal agency for Federal identification or other official purpose; and

161 (2) Have a unique design or color indicator that clearly distinguishes them from driverbs licenses and identification cards that meet the standards of this Part.

Meaning if you value your privacy and refuse to carry a REAL ID or if your state decides that REAL ID indeed is the cost-prohibitive sham for security that it is and decides to not play with DHS' desire to create a National ID card, its citizens will be branded with the post-9/11 version of the "Scarlett Letter" to let all who see their ID card know that they're "different" --- or at least not "one of the good guys." Stigmatized. Branded. Marked. Ostracized. Segregated. Will we have separate bathrooms, too? REAL ID *must* be stopped. For many reasons. -rf ------------------------------------------- Archives: http://v2.listbox.com/member/archive/247/@now Powered by Listbox: http://www.listbox.com ----- End forwarded message ----- -- Eugen* Leitl <a href="http://leitl.org">leitl</a> http://leitl.org ______________________________________________________________ ICBM: 48.07100, 11.36820 http://www.ativel.com 8B29F6BE: 099D 78BA 2FD3 B014 B08A 7779 75B0 2443 8B29 F6BE [demime 1.01d removed an attachment of type application/pgp-signature which had a name of signature.asc]