Not a lawyer, but when I am immigration is the area I plan to practice in. This is a terrible idea; even if the floating platform is conjured into a fully operation existence tomorrow, anyone who goes to work there will more likely be effectively barred from future entry to the US by the rather draconian criteria that currently govern the immigration system. This would be viewed as something akin to economic piracy and the list of legal things that could go wrong is growing exponentially the longer I think about it.

I know this is a pretty broad-brush criticism, but where I think the architects of this project are going wrong is in their mechanistic/formalist assessment of immigration and admiralty (maritime) law. You can look at things in the US code and say a particular legal approach should work, but in doing so you're assuming a purely neutral implementation and arbitration process. In reality, immigration is highly politicized for a variety of reasons. Most obviously, there's the general spirit of labor protectionism and xenophobia that reflects popular nationalistic and economic anxiety. Then there's the fact that immigration is one area where Congress exercises plenary power, and uses it to effectively exempt some immigration rules from judicial or executive review. On the administrative side, you have an executive that has repeatedly set records in enforcement (highs for deportation, lows for unauthorized entry) and has set out a fairly clear policy of prioritizing enforcement activities against violent criminals rather than undocumented economic migrants who are otherwise law-abiding; but the union that represents immigration enforcement officers is diametrically opposed to these goals, takes the position that 'the administration refuses to enforce the law', and its spokesperson has consistently aligned the union with the most hardline conservative stance imaginable on this issue. I don't know whether this is because the union leadership considers more aggressive enforcement to be economically beneficial to its membership or because the persons involved simply hold reactionary political views, but it's no exaggeration to say that there is open bureaucratic warfare between the uniformed and legal staff within ICE.

Under these circumstances, and bearing in mind that in immigration matters, the burden of proof rests with the non-citizen rather than the government (in contrast to criminal procedure), how long will a daily offshore ferry service on the doorstep of Silicon Valley be allowed to operate before being shut down as a 'suspected people smuggling operation' or similar? Aside from the obvious risk of maritime accidents when you have daily 'ferry' journeys going 12-24 miles into oceanic waters, visitors from an offshore labor platform are going to have about the least user-friendly experience it is possible to have when they come in contact with the coastal ICE agents. As in, being taken into custody and deported to their country, not their point, of origin. We're talking about an agency that has an occasional habit of deporting US citizens by accident, for example: http://www.lexisnexis.com/community/immigration-law/blogs/ou...

So, A+ for good intentions and drawing further attention to the economically self-defeating nature of current US policy, but F- for real world practicality.