Industry Joint Comments to the U.S. Customs and Border Protection on its Proposed Modifications to its Rulings Related to the Use of Jones Act Vessels in Offshore Oil and Natural Gas Activity

Industry Joint Comments to the U.S. Customs and Border Protection on its Proposed Modifications to its Rulings Related to the Use of Jones Act Vessels in Offshore Oil and Natural Gas Activity

Ladies and Gentlemen: The American Petroleum Institute (API), the Association of Diving Contractors International (ADCI), the International Association of Drilling Contractors (IADC), the Independent Petroleum Association of America (IPAA), the International Association of Geophysical Contractors (IAGC), the International Marine Contractors Association (IMCA), the Louisiana Mid-Continent Oil and Gas Association (LMOGA), the Offshore Operators Committee (OOC), the Petroleum Equipment & Services Association (PESA) and the U.S. Oil and Gas Association respectfully submit the following comments on the proposed modification and revocation of established ruling letters relating to Customs application of the Jones Act to the transportation of certain items on the Outer Continental Shelf (OCS).