fe ® LOUISIANA MID-CONTINENT re OIL AND GAS ASSOCIATION row ~— 730 NORTH BOULEVARD, BATON ROUGE, LA 70802 ‘TELEPHONE (225) 387-3205 Pax (228) 44-5502 ‘August 11, 2008 US. Customs and Border Protection Office of International Trade, Regulation and Rulings A ic and Commercial Regulations Branch "799 9 Sees, N. W., Mint Annex ‘Washington, D.C. 20229 RE: Custom and Border Protection (CBP) proposed modifications and revocations of previous ralings in reference (0 the “Jones Act,” as It relates to coastwise laws to certain merchandise and ‘vessel equipment. ‘The Louisiana Mid-Continent Oi! and Gas Assocation (LMOGA) representing the integrated and majee independent oil end gas companies operating in the Gulf of Mexico respectfully request «60-day comment period extension fo allow adequate public input in response tothe July 17, 2008, notice published in the Cision Bulla as referenced above. With the comment period expiring on August 17, 2009, the ‘proposed modifications to decades of previous Customs rulings, under existing law, could go ino effet by the end 2008, |As noted inthe Custom Bulletin, Sly 17, 2008, CBP intends to limit or redefine is interpretation of the terme: “transportation of merchandise” “vestel equipment” “materials and tool.” “foreseen and tanfreseen repairs.” "on or from tht veste,"“pipelayin.” ec. Any modifications or revocation ofraling letters could have broad implications and severely impact the offshore oll and gas industry and our member companies. LLMOGA filly supports the Jones Act which states no vessel may transport cargo between two U.S, points unless they afe owned by Americans, crewed by Americans, and built in America. AS tade association bso! in the sate of Louisiane, LMOGA proudly promotes American mariners, American shipyards, and “American offshore supply companies. These sevice industries are vital othe offshore oil and gas industry and erica othe U8. exonamy. We respectflly submit the current proposed modificstions and revocations of previous rulings are complicated issues requiring more input, discussion and time befere any implementation, “Thank you for your consideration to our thoughts and views. Please call on us when we can provide ssitional information to you,