Gunther Hoock

RE: Docket Number USCG-2007-28915; 33CFR101-105, TWIC – Reader Requirement; Proposed Rule We would like to comment on the proposed language in 104.263(d) for vessels and 105.253(d) for facilities, which read materially the same. We have a situation at one of our facilities where we are the exclusive land use lessee and have preferential but not exclusive berthing rights. Based on the criteria in the Proposed Rule, our vessels and facility will fall into Risk Group B. On a weekly basis, the berth also accommodates a fuel tanker that provides jet fuel to the island’s airport. When this tanker is berthed, it connects to moveable flexible hoses that, in turn, connect to an above ground valve outside our secure perimeter that pumps the fuel into an underground pipeline. While the tanker is at the berth, our facility creates a temporary mobile security perimeter around the tanker’s gangway landing which is manned on the facility side by our guard and on the vessel side by the ship’s guard. Since our facility has no other interaction with, responsibility for, or interest in the tanker and its operation, we request clarification that our facility will not be required to ramp up to the Risk Group A electronic reader and related requirements for this 3rd party vessel call at the public berth attached to our leased facility. Submitted by: Gunther Hoock, Director, Safety, Security & HazMat Horizon Lines, LLC, Irving, TX March 27, 2013