REAL ID (or the alternative PASS ID proposal) would support and protects a system of so-called ‘gold standard’ drivers licenses. It would also increase the document requirements to confirm a license holder’s identity and require the digitization of identity documents in order to facilitate identity confirmation and avoid issuing duplicate licenses. USACM believes in order to accomplish this safely and securely, the system must make sure license data and associated information are available only to those who should have access, and that the system must work very quickly. This would require an extensive nationwide investment in information technology. The state-of-practice for building such large systems and satisfying requirements for security, reliability, survivability and guaranteed real-time performance is lacking. As a result, there is a large possibility of major cost overruns and significant shortcomings. And by making the licenses such an important credential REAL ID could shift the focus of identity thieves away from social security and credit card numbers. A forged REAL ID poses a greater threat given the increased trust placed in it, and related identity theft would be much harder to restore. USACM sees problems with REAL ID in several areas, including accountability, privacy and security.