Comment Submitted by Roberto Gomes

Dear Sir/Madam: In reference of the proposed rule docket number USCBP-2005-003, which will regulate the transmission of the passenger manifests for commercial aircraft arriving and departing from the US, I would like to present my contributions. In order to allow the involved US agencies to identify high-risk passengers and crewmembers and prevent them before departure for boarding any aircraft bound for or departing from the US, CBP has made a proposition with two alternatives as follows: 1. the submission of the complete manifests no later than 60 minutes before departure; or 2. the individual transmission of passenger data on real-time transactions. The alternative number 2 has more change of success since airlines can manage the boarding process more efficiently and deny boarding to the vetted passenger or crew member upon check-in avoiding to ?transfer? this to the gate area and allow passenger to have access to the sterile area. Also this procedure will allow airlines to maintain the passenger/baggage match accurately since they will accept only passengers/crew members cleared by CBP by the time that they are being checked in. Another aspect to be considered is the minimum connection time between carriers, which at the majority of the airports is 1 hour. I would like to point out that a passenger arriving to a connecting point via airline X to connect to airline Y depending on the agreement, has his/her baggage/boarding card issue by airline X, but APIS data must be inputted by airline Y which will be responsible for his/her transportation to the US. With this alternative, delays can be avoided and will not impact arrival in the US and subsequently Immigrations and Customs passenger processing. Finally is important to point out that many countries regulations have a deadline of one hour or up to 45 minutes prior to departure to accept passengers with confirmed reservations. Due to the above reasons, I would like to recommend that all efforts must be concentrated in the individual transmission of passenger data with real-time transactions and final manifest sent 20 minutes prior departure (push-back) for airlines with regular flights. Respectfully, Roberto Gomes