HELICOPTER SAFETY ADVISORY CONFERENCE (HSAC) GULF OF MEXICO

Gentlemen: December 7, 2006

In researching the proposed and final rules concerning new passport requirements it states, in my opinion, that U.S. Citizens working on the OCS will not be required to posses a passport. The following is an excerpt from page 46162 of the Federal Register:

"Under applicable immigration law, sailing from a United States port into international waters, without a call at a foreign port, and returning to the United States, does not constitute a ''departure'' from the United States and, consequently, is not an ''entry'' into the United States that requires a passport under section 215(b) of the INA. Therefore, passports will not be required for persons (including commercial fishermen) onboard a vessel that sails from a United States port and returns without calling at a foreign port or place as the vessel is not considered to have departed the United States. Therefore, commercial fishermen would not be required to possess a passport unless they call at a foreign port or place."

Regarding passengers and crew arriving via helicopter from the OCS the following is final:

U.S. Crew/Pax arriving from the OCS will not require a passport unless they are arriving via a foreign port. Ex. "An individual who travels to a MODU from outside the United States OCS and, therefore, has not been previously inspected and admitted to the United States, would be required to possess a passport and visa when arriving at the United States port-of-entry by air."

"DHS and DOS note that offshore employees on MODUs underway, which are not considered attached, would not need to present a passport for re-entry to the United States mainland if they do not enter a foreign port or place during transit."