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					Instructions for Completing the October 2006 Draft CBP Cruise Terminal Design Standards Comment Form

Background. This form provides individuals and organizations a common format for providing comments on the draft
         version of the U.S. Customs and Border Protection Cruise Terminal Design Standards for Passenger
         Processing Facilities. The design is intended to make it easy to merge comments from various respondents
         and arrange them in a single, consolidated matrix for review and incorporation into a final document.
         All respondents must utilize this form following the appropriate procedures as outline below.
         Comments submitted without correctly utilizing this form as directed will not be accepted.
Procedures
   1. On the first page, identify the individual and organization providing the comments and a point of contact
         (include name, phone number and e-mail).
   2. In the Page #, Paragraph#, columns, insert the page and paragraph number(s) pertaining to the comment.
   Note: For general comments that do not correspond to a specific page number, place the word ‘GEN’
         under the page # column.

   3. In the Comment Type column, indicate whether the comment is Critical (C), Substantive (S), or
         Administrative (A) in nature.
   4. In the Recomendation column, place only one comment per row and provide both the comment and
         recommendation.
   5. In the Rationale column, please identify why the change is being recommended.

Please email your completed comment form and/or questions to daniel.e.ziegelbauer@dhs.gov by C.O.B. 20 November, 2006.

LEGEND (Proposed Disposition)
1 = Adopted
2 = Not Adopted
3 = Requires Discussion
4 = Requires Language From Commenter
                               Comments from the American Association of Port Authorities

                                                                                                                        Organization/
           Paragraph/
Page No.                Type                      Recommendation                                Rationale                Reviewer/
              Line
                                                                                                                           Phone

                                                                                                                        AAPA
                                    CBP should clarify that this is a "Kit of Parts"                                    S.
                                    - it's purpose is to outline a variety of options                                   Monteverde
                                    to be negotiated on, depending on the                                               703-684-5700
                                    facility. Seaport design needs to be flexible The draft document can be             smonteverde
                                    to accommodate different uses and                 iterpreted as what everyone       @aapa-
General                  C          changing operations.                              needs.                            ports.org

                                                                                                                        CH2M HILL
                                                                                                                        R. Cox
                                    Draft Standard appears to be an edited                                              561-904-7400
                                    update of the 2002 INS Technical                                                    Ray.Cox@CH
General                  S          Requirements.                                                                       2M.com

                                                                                    Cruise terminals have been being    CH2M HILL
                                    Proposed Standard appears to be based on        constructed based on a "one         R. Cox
                                    International Airport operations and does not   stop" process in recent years,      561-904-7400
                                    account for the unique US homeported            versus the old INS first then       Ray.Cox@CH
General                  S          cruise line operations.                         Customs processing.                 2M.com

                                                                                                                        CH2M HILL
                                    The proposed Standard is confusing and                                              R. Cox
                                    has many conflicts. Dimensions,                                                     561-904-7400
                                    requirements, etc. are stated one way in one                                        Ray.Cox@CH
General                  S          place and something different elsewhere.                                            2M.com

                                                                                    CBP should recognize that with
                                                                                    homeported cruises, the travel of   CH2M HILL
                                                                                    the Passenger starts and ends in    R. Cox
                                    The proposed spaces and processes are           the US, unlike an airline where     561-904-7400
                                    not necessarily applicable to US                the passenger could have been       Ray.Cox@CH
General                  S          homeported cruise ships.                        in many countries.                  2M.com
              Comments from the American Association of Port Authorities


                                                                                                        CH2M HILL
                                                                                                        R. Cox
                   The Standards as written could cost the                                              561-904-7400
                   ports and/or cruise lines $100's if not                                              Ray.Cox@CH
General   S        millions of dollars to implement.                                                    2M.com

                                                                                                        CH2M HILL
                                                                                                        R. Cox
                   It is unclear who has the final say on the                                           561-904-7400
                   terminal layouts, local or headquarters. This                                        Ray.Cox@CH
General   A        should be clarified.                                                                 2M.com

                                                                                                 CH2M HILL
                                                                                                 R. Cox
                   The time to process each step of the various Long and repeatative reviews can 561-904-7400
                   reviews is not identified and therefore could delay terminal completions and  Ray.Cox@CH
General   A        be at the whim of the reviewer(s).            schedules of the cruise lines.  2M.com

                                                                    Local building officials and fire   CH2M HILL
                                                                    marshalls have at times not         R. Cox
                   There does not appear to be any way to           allowed some of the layouts or      561-904-7400
                   appeal directives by local or headquarters       construction details indicated in   Ray.Cox@CH
General   A        directives.                                      the proposed standards.             2M.com

                   It is unclear as to what level the CBP area is                                       CH2M HILL
                   constructed and equiped by the terminal                                              R. Cox
                   operator. Does the work stop at the hard                                             561-904-7400
                   walls, etc. or does it also include furniture,                                       Ray.Cox@CH
General   S        computers, paper, pencils, etc.?                                                     2M.com

                   Detailed comments are difficult to provide as                                        CH2M HILL
                   we have significant marks on almost every                                            R. Cox
                   page and/or section. We therefore have                                               561-904-7400
                   only included herein highlights of some of                                           Ray.Cox@CH
General   S        the critical and/or substantive issues.                                              2M.com
              Comments from the American Association of Port Authorities


                                                                                                       CH2M HILL
                                                                                                       R. Cox
                   The term "Standard" is not recommended                                              561-904-7400
                   as it implies a minimum code that must be                                           Ray.Cox@CH
General   C        adhered to. Recommend using "Guideline".                                            2M.com
                   While we acknowledge the need for border
                   security, the Editor of the standard needs to                                       CH2M HILL
                   spend time with the cruise lines, ports, and                                        R. Cox
                   consultants to get input on real life                                               561-904-7400
                   operations and what effects this proposal                                           Ray.Cox@CH
General   C        has on the industry.                                                                2M.com

                                                                   Typically in the FIS area are       CH2M HILL
                                                                   stevedores, cruise line crew and    R. Cox
                                                                   agents, provisioning deliveries,    561-904-7400
                                                                   port staff, port and/or local law   Ray.Cox@CH
General   S        Who defines "FIS authorized personnel"?         enforcement, etc.                   2M.com

                                                                                                       Bermello
                                                                                                       Ajamil
                                                                                                       L. Ajamil
                                                                                                       305-860-3731
                   The guidelines should deal with two                                                 LAjamil@ber
                   categories of ports - those that have                                               melloajamil.c
General   C        permanent staff and those that do not.                                              om

                                                                                                       Bermello
                                                                                                       Ajamil
                                                                                                       L. Ajamil
                                                                                                       305-860-3731
                                                                                                       LAjamil@ber
                   The guidelines should tie the level of                                              melloajamil.c
General   C        facilities to the level of annual traffic.                                          om
                      Comments from the American Association of Port Authorities


                                                                                   Bermello
                                                                                   Ajamil
                           BCBP should consider guidelines with ports              L. Ajamil
                           with more than one terminal, trying to                  305-860-3731
                           centralize facilities at one location and not           LAjamil@ber
                           repeat the same facilities many times in the            melloajamil.c
General           A        same port.                                              om

                                                                                   Bermello
                                                                                   Ajamil
                                                                                   L. Ajamil
                                                                                   305-860-3731
                           BCBP should consider the usability of these             LAjamil@ber
                           spaces. These types of facilities are mostly            melloajamil.c
General           S        empty wherever they have been built.                    om

                           While the general purpose of this document
                           is described herein, our experience is that             CH2M HILL
                           the local agents do not follow what is being            R. Cox
                           outlined herein. Each Port tends to operate             561-904-7400
                           as they feel best for the locale. Which                 Ray.Cox@CH
  1-2     1.1     S        controls, the standards or local?                       2M.com

                                                                                   CH2M HILL
                           Who has ultimate jurisdiction over the CPB              R. Cox
                           facilities, local officials (building departments       561-904-7400
                           and fire marshalls) or CBP/DHS when                     Ray.Cox@CH
  1-4     1.1.4   S        conflict occur?                                         2M.com

                                                                                   Bermello
                                                                                   Ajamil
                           The code must provide guidelines as to how              L. Ajamil
                           ports deal with the conflicts that arise                305-860-3731
                           between BCBP requirements and local                     LAjamil@ber
                           codes. Usually issues arise dealing with                melloajamil.c
  1-4     1.1.4   A        bathroom capacity and exit requirements.                om
                Comments from the American Association of Port Authorities


                                                                 Ship size and need to clear the
                                                                 vessel rapidly for turn around
                                                                 affects the supposed processing         CH2M HILL
                                                                 rate. If the facility is not designed   R. Cox
                     Facilities are noted as sized based on peak or staffed for the actual rate of       561-904-7400
                     hour processing. Who determines what this passengers through-put, the               Ray.Cox@CH
2-1   2.2   C        processing speed is?                        designiated size is meaningless.        2M.com

                                                                   Typical operations only process
                                                                   the disembarkating passenger,
                                                                   which is normally done in 3 to 4
                                                                   hours, and only on cruise days.
                                                                   Staff is normally only sent to the    CH2M HILL
                                                                   terminal on cruise call days,         R. Cox
                     Cruise ship facilities are typcially non-     which vary from port to port,         561-904-7400
                     staffed, except at international ferry type   season by season, and cruise          Ray.Cox@CH
2-2   2.2   C        facilities.                                   line by cruise line.                  2M.com

                                                                                                         Bermello
                                                                                                         Ajamil
                                                                                                         L. Ajamil
                                                                                                         305-860-3731
                                                                                                         LAjamil@ber
                     BCBP should tie itself down to providing                                            melloajamil.c
2-2   2.2   A        timely approvals.                                                                   om
                                                                 Each step can potentially change
                                                                 or delay the agreements from
                                                                 prior steps. There have even
                                                                 been instances of close
                     The number of design steps for the process coordination with CBP all the way
                     is too extensive and each one can overide through construction and then             CH2M HILL
                     or send the process back to the previous    new requirements demanded               R. Cox
                     steps. Once the "Schematic Design" is       during the "Acceptance,                 561-904-7400
                     agreed to, no substantial changes should be Occupancy, and Commissioning"           Ray.Cox@CH
2-2   2.3   C        required or made.                           stage.                                  2M.com
                  Comments from the American Association of Port Authorities


                                                                                                      CH2M HILL
                       Space requirements are indicated to be set                                     R. Cox
                       by local, but HQ is noted as the final           Need a single point of        561-904-7400
                       authority. Who really is in charge and sets      responsibility and decision   Ray.Cox@CH
2-4   2.3.2   C        the parameters?                                  making.                       2M.com

                                                                                                      Bermello
                                                                                                      Ajamil
                                                                                                      L. Ajamil
                                                                                                      305-860-3731
                       Does BCBP want to get involved in site                                         LAjamil@ber
                       selection? That is a complicated process                                       melloajamil.c
2-4   2.3.2   A        which does not require this level of scrutiny.                                 om

                                                                                                      Bermello
                                                                                                      Ajamil
                                                                                                      L. Ajamil
                                                                                                      305-860-3731
                       Should define who at BCBP issues the letter                                    LAjamil@ber
                       of approval - headquarters or the local                                        melloajamil.c
2-4   2.3.2   A        office.                                                                        om

                                                                                                      CH2M HILL
                                                                                                      R. Cox
                       With CBP Field Office requiring periodic                                       561-904-7400
                       inspections, the pace of the Construction is                                   Ray.Cox@CH
2-5   2.3.7   S        at the mercy of the FO.                                                        2M.com

                       If the facility layout is being controlled by                                  CH2M HILL
                       CBP/DHS, how do the "other Federal                                             R. Cox
                       Agencies" fit into the process and who           Need a single point of        561-904-7400
                       determines if they will be present in the        responsibility and decision   Ray.Cox@CH
2-8   2.5     C        facility?                                        making.                       2M.com
                           Comments from the American Association of Port Authorities


                                                                                                                    CH2M HILL
                                                                                                                    R. Cox
                                Except for international ferries (US to                                             561-904-7400
                                Canada or Mexico), and some transocean             For US based cruise ships, the   Ray.Cox@CH
  2-11       2.6.2     S        liners, the country of origin is the US.           US is the "host country".        2M.com

                                                                                                                    CH2M HILL
                                If the cruise operations are only one of many                                       R. Cox
                                CBP services in the area (i.e. airports, cargo                                      561-904-7400
                                seaports, etc.), why would the cruise                                               Ray.Cox@CH
  2-11       2.6.3     S        operations be the "central faciltiy"?                                               2M.com

                                                                                                                    Bermello
                                                                                                                    Ajamil
                                                                                                                    L. Ajamil
                                                                                                                    305-860-3731
                                                                                                                    LAjamil@ber
                                                                                                                    melloajamil.c
  2-11       2.6.3     A        Who pays the port administrative facilities?                                        om

                                Text implies that the passenger will claim                                          CH2M HILL
                                luggage before any CBP processing. Flow                                             R. Cox
                                chart implies that passengers are first                                             561-904-7400
2-13 / 2-                       checked at primary, then claim baggage                                              Ray.Cox@CH
   15       2.8.3 ff   S        before proceeding to secondary.                                                     2M.com

                                                                                                                    Bermello
                                                                                                                    Ajamil
                                                                                                                    L. Ajamil
                                                                                                                    305-860-3731
                                This description is in conflict with the rest of                                    LAjamil@ber
                                the document. Does a passenger collect                                              melloajamil.c
  2-13       2.8.3     S        after or before primary?                                                            om
                   Comments from the American Association of Port Authorities


                                                                                Bermello
                                                                                Ajamil
                                                                                L. Ajamil
                                                                                305-860-3731
                                                                                LAjamil@ber
                        For all practical purposes, 99% of the ports            melloajamil.c
3-1    3.1     C        are "large" facilities.                                 om

                                                                                Bermello
                                                                                Ajamil
                                                                                L. Ajamil
                                                                                305-860-3731
                                                                                LAjamil@ber
                                                                                melloajamil.c
3-19   3.5.2   A        Who pays for the X-ray machines?                        om

                                                                                Bermello
                                                                                Ajamil
                                                                                L. Ajamil
                                                                                305-860-3731
                                                                                LAjamil@ber
                        Requires emergency generation - most                    melloajamil.c
6-4    6.3.5   S        ports do not have this.                                 om
                       Comments from the American Association of Port Authorities


Proposed Disposition
Comments from the American Association of Port Authorities
Comments from the American Association of Port Authorities

				
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