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eign workers engaged in OCS activities offshore are already required to obtain a B-1 (OCS) visa in order to proceed offshore or make a port call in the United States pursuant to the current OCS manning regime. Among other things, the practical effect would be to require foreign-flag vessels to obtain qualified U.S. citizens or permanent residents to crew foreign-flag vessels. Many of the large construction vessels that assist in construction, anchor handling, and other OCS-related activities require highly trained crew members to operate complex equipment aboard these vessels. In short, this would almost certainly result in foreign-flag vessels ceasing work on the U.S. OCS. In addition, there are very few qualified U.S.-flag vessels available that can perform much of this necessary work. In addition, particularly as a result of hurricanes Katrina and Rita, there is a severe shortage of qualified U.S. citizens and permanent residents to work offshore. As a result, if a foreign worker was required to obtain an H-2B visa, work offshore would almost surely come to an immediate stop because it would become impossible to obtain enough H-2B visas. As discussed above, H-2B visas are only issued for intermittent or seasonal/peak work periods. OCS activities are continuous in nature and may not meet this criterion for the issuance of H2B visas to workers on OCS units. In addition, it would likely be difficult to justify an extension beyond that period, and in any event such visas may not be extended beyond three years. Furthermore, each year there are only 66,000 visas allocated under the H-2B nonimmigrant category. This cap is established by statute. The visa allocation is split into two separate allocations - the first allocation of 33,000 on October 1 and the second allocation of 33,000 on April 1. Unfortunately, due in part to the effects of the recent hurricanes, biannual allocation for these visas was reached almost as soon as they became available. OCS Notice of Requirements Arrival On September 29, 2006, Congress passed the Security and Accountability for Every Port Act of 2006 ("SAFE Port Act"). Section 109 includes an amendment directing the U.S. Coast Guard to finalize its proposed rulemaking on Notice of Arrival ("NOA") requirements for foreign flag vessels operating on the OCS within 180 days of enactment, consistent with requirements currently in place with regard to NOA requirements for vessels making calls at a U.S. port. The purpose of this provision is to provide for additional security relating to foreign vessels working on the OCS. There is a reporting gap under existing regulations related to advance notice of arrival reporting associated with OCS structures. This provision should close that gap. Fortunately, the initial proposal to this OCS NOA requirement was ultimately rejected by Congress. The initial proposal would have established a new regime called Maritime Security Identification Zones around all OCS artificial islands, installations, and structures. This was clearly unnecessary and overbroad particularly in light of the fact that the existing regime applicable to advance reporting related to U.S. port calls can be simply and quickly extended by finalizing a draft rule that was proposed in 1999 by the Coast Guard. Under the Coast Guard's current NOA requirements, all vessels, whether under the U.S. or a foreign flag, entering U.S. ports, must submit an NOA to the Coast Guard's National Vessel Movement Center. Vessels whose voyage time is 96 hours or more must submit their NOAs at least 96 hours prior to reaching their destination, while those whose voyage time is less must complete their submissions prior to departure and at least 24 hours before reaching their destination (updates are also required). Among other things, quality · reliability · guaranteed Wall-Mount Unit FCI Neptune Series commercial desalinators incorporate exclusive UROC technology providing total control and user-friendly system customization. Produces 1200 to 8300 GPD Four customizable configurations Multiple remote station capable with intuitive computer interface Designed to operate 24/7 316SS high and low pressure pumps Programmable Fresh Water Flush Digitally monitors water pressure, flow rates and production quality 80 sq ft of commercial pre-filtration Please visit us at the For t Lauderdale International Lauderdale Boat Show Booths 537& 538 Show Vertical Frame Unit Horizontal Frame Unit Modular Unit Now available with optional water lubricated, duplex stainless steel, radial axial pump. For more information on our complete line of watermakers, please call 714-850-0123 or visit www.fciwatermakers.com 38 · MarineNews · November 2006