http://papersplease.org/wp/2008/12/18/dhs-extends-travel-permission-requirements-for-international-visitors-and-general-aviation/ Challenging ID Demands Fri, 12 Mar 2010 19:48:38 +0000 http://wordpress.org/?v=2.6.3 http://papersplease.org/wp/2008/12/18/dhs-extends-travel-permission-requirements-for-international-visitors-and-general-aviation/#comment-126130 Tova Wirsing Sun, 07 Mar 2010 13:43:14 +0000 http://www.papersplease.org/wp/?p=233#comment-126130 I can just reccomand everyone to read this posts , and enjoy them all this guy knows what he is writing about! I can just reccomand everyone to read this posts , and enjoy them all this guy knows what he is writing about!

]]> http://papersplease.org/wp/2008/12/18/dhs-extends-travel-permission-requirements-for-international-visitors-and-general-aviation/#comment-90839 Papers, Please! » Blog Archive » Exit permits, ESTA, APIS, and asylum seekers Tue, 10 Feb 2009 06:27:15 +0000 http://www.papersplease.org/wp/?p=233#comment-90839 [...] For what it’s worth, it’s unclear if an ESTA is actually required.  As we pointed out in our comments on the ESTA proposal, there are serious questions as to whether the DHS has jurisdiction, authority, or “boots on the gorund” at points of embarkation on foriegn countries to impose such a requirement, and about whether the DHS has complied with the procedural notice and comment rules applicable to such a rulemaking.  The DHS published a “notice” saying that ESTA approval would become mandatory as from January 12, 2009.  But that notice itself complied with none of the requirments for a binding rule, and failed to specify any enforcement mech.... [...] [...] For what it’s worth, it’s unclear if an ESTA is actually required.  As we pointed out in our comments on the ESTA proposal, there are serious questions as to whether the DHS has jurisdiction, authority, or “boots on the gorund” at points of embarkation on foriegn countries to impose such a requirement, and about whether the DHS has complied with the procedural notice and comment rules applicable to such a rulemaking.  The DHS published a “notice” saying that ESTA approval would become mandatory as from January 12, 2009.  But that notice itself complied with none of the requirments for a binding rule, and failed to specify any enforcement mech…. [...]

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